5. Other Issues

SDG&E presents data on the amount of time required to process initial and supplemental interconnection reviews in order to demonstrate that the adopted fees are insufficient to cover the costs of typical review of interconnection applications. PG&E does not present data but indicates that the fees are inadequate to cover its costs. SCE also does not supply data, but indicates that the fees are often inadequate to cover its costs. When we adopted the initial and supplemental review fees we recognized that they might require adjustment based on more experience with Rule 21. As described above, we require the utilities to track costs associated with § 2827 interconnections and interconnections that are not eligible for net energy metering. As a result of this tracking, the utilities will be in a position to present actual cost data to the Interconnection Working Group in order to develop a recommendation, if necessary, for revision of the initial and supplemental review fees.