6. Comments on Draft Decision
The draft decision of Administrative Law Judge Michelle Cooke in this matter was mailed to the parties in accordance with Section 311(g) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed by PG&E, SDG&E, SCE, CalSEIA, Adelman, ORA, and State Consumers, and reply comments were filed by PG&E, SDG&E, SCE, CalSEIA, Adelman, and State Consumers. Changes have been made throughout the decision in response to comments.
1. Rule 21, as approved in D.00-12-037, exempted net energy metered eligible customer-generators from payment of application review fees.
2. Adopted net energy metering tariffs do not require eligible customer-generators to pay standby charges like qualifying facilities or other generators.
3. Utilities have consistently treated net energy metered customers like retail customers without generation for purposes of the rate comparison described in § 2827(d).
4. Expansion of the net energy metering tariff to eligible customer-generators larger than 10 kW is temporary and expires December 31, 2002.
1. One of the objectives of the net energy metering program is to encourage installation of eligible renewable generating units.
2. Implementing § 2827(d) to exempt all eligible customer-generators from payment of application review fees, interconnection study costs, and distribution system modifications could result in a real (but undetermined) cost to ratepayers.
3. Eligible customer-generators should bear the costs of interconnection facilities, on either side of the meter, necessary to meet the safety and performance requirements of the National Electrical Code, the Institute of Electrical and Electronics Engineers, accredited testing laboratorie, and, where applicable, rules of the Public Utilities Commission regarding safety and reliability.
4. Generators eligible for net energy metering under Pub. Util. Code § 2827 are exempt from paying for costs associated with interconnection studies, distribution system modifications, or application review fees.
5. PG&E, SDG&E, and SCE should track the costs associated with all interconnections (application review costs (initial and supplemental), interconnection study costs, and distribution system modification costs) by project size, distinguishing between projects under 10 kW and those between 10 kW to 1 MW in order to determine whether significantly different costs are incurred based on project size. The data should distinguish between projects based on eligibility for net energy metering under Pub. Util. Code § 2827.
6. PG&E, SDG&E, and SCE should be allowed to establish a memorandum account to record the costs associated with interconnection of net energy metered customer-generators with projects between 10 kW and 1 MW in size.
7. This decision should be effective today in order to allow the tariffs to be updated expeditiously.
IT IS ORDERED that:
1. The service list shall be updated to reflect that Edward O'Neill is appearing as counsel for both California Solar Energy Industries Association and Kenneth A. Adelman and that RealEnergy has moved from Information Only status to Appearance status.
2. Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), and Southern California Edison Company (SCE) shall submit revised tariffs to exempt generators eligible for net energy metering under Pub. Util. Code § 2827 from any costs associated with interconnection studies, distribution system modifications, or application review fees. Eligible customer-generators shall be responsible for the costs of interconnection facilities, on either side of the meter, necessary to meet the safety and performance requirements of the National Electrical Code, the Institute of Electrical and Electronics Engineers, accredited testing laboratories, and, where applicable, rules of the Public Utilities Commission regarding safety and reliability.
3. PG&E, SDG&E, and SCE shall track the costs associated with all interconnections (application review costs (initial and supplemental), interconnection study costs, and distribution system modification costs) by project size, distinguishing between projects under 10 kilowatts (kW) and those between 10 kW to 1 megawatt in order to determine whether significantly different costs are incurred based on project size. The data shall also distinguish between projects based on eligibility for net energy metering under Pub. Util. Code § 2827.
4. PG&E, SDG&E, and SCE may file advice letters to establish a memorandum account to record the costs associated with interconnection of net energy metered customer-generators with projects between 10 kW and 1 MW in size.
5. PG&E, SDG&E, and SCE shall file a report on January 1, 2003 setting forth the data tracked pursuant to Ordering Paragraph 3.
This order is effective today.
Dated March 21, 2002, at San Francisco, California.
LORETTA M. LYNCH
President
HENRY M. DUQUE
CARL W. WOOD
GEOFFREY F. BROWN
MICHAEL R. PEEVEY
Commissioners
