20. Expedited Interconnection Procedures

This decision acknowledges that expedited interconnection is critical to the success of the § 399.20 FiT Program and implements the directives set forth in SB 32 pertaining to expedited interconnection by clarifying that parties should rely on the existing provisions of Tariff Rule 21 until the Commission finalizes its ongoing efforts to refine Rule 21 and expedited interconnection in R.11-09-011. In addition, we find that, until the Commission makes a final determination in R.11-09-011, utilities shall allow generators to choose which interconnection processes to use, either the process set forth in the existing Tariff Rule 21 or the FERC interconnection procedures under the Wholesale Distribution Access Tariff (referred to as "WDAT").87 We anticipate that generators will find Rule 21, as revised in R.11-09-011, sufficient to meet the statutory mandate of expedited interconnection and, at that point, we will no longer permit interconnection under the federal tariffs. On a broad level, we briefly summarize the issues pertaining to expedited interconnection below as more specific consideration of the issues will occur in R.11-09-011.

SB 32 added subsection (e) to § 399.20 to provide that an electric corporation shall provide expedited interconnection procedures for a facility that is connected on a distribution circuit and generates electricity in a manner to offset peak demand on the electric circuit. Notably, in D.07-07-027, the Commission established a need for expedited interconnection under AB 1969 "to prevent interconnection from becoming a barrier to completion, ..." and required the utilities to follow the interconnection procedures in Rule 21 or FERC interconnection procedures.88 Parties provided comments on this topic.

In March 2011 briefs, PG&E and SCE suggest that the Commission may not be able to address this issue because connections on the distribution level are FERC-jurisdictional. PG&E further suggests that an expedited procedure for only the § 399.20 FiT Program is not appropriate because interconnection to the grid must include a comprehensive review, and also states that it will make reasonable efforts to accommodate interconnection consistent with its legal obligations. SCE points to WDAT as a possible alternative process. We agree with PG&E that interconnection must be addressed on a comprehensive level and, therefore, anticipate addressing these issues in R.11-09-011.

Furthermore, to the extent generators decided to rely on the Tariff Rule 21, the existing provisions of Tariff Rule 21 will apply, rather than any potential revised version of Rule 21, until the Commission issues a decision on potential revisions to the Rule 21 Tariff in R.11-09-011 unless a different direction is provided for in either this proceeding or in R.11-09-011 by ruling of the Administrative Law Judge or Commission decision.

IREC, the Solar Alliance, and the Vote Solar Initiative find Rule 21, in its current format, insufficient but suggest other possible models. IREC also urges the Commission to pursue consistency among the many existing interconnection procedures. FuelCell Energy suggests current efforts underway before the CAISO regarding the Generator Interconnection Procedures and the electric utilities' efforts to reform qualifying facilities' interconnection procedures are sufficient to address the needs under the § 399.20 FiT Program. CALSEIA recommends that the Commission monitor the electric utilities' continued progress to reform the WDAT and suggests that these reforms may be sufficient for purposes of the § 399.20 FiT Program. The Solar Alliance and the Vote Solar Initiative support reliance on the WDAT as the most viable existing option. Sustainable Conservation points out that interconnection sometimes takes a year or longer and recommends reliance on Rule 21 as an accessible means of addressing interconnection under the Commission's jurisdiction.

As stated above, we acknowledge that expedited interconnection is critical to the success of the § 399.20 FiT Program. These issues are scheduled to be addressed in R.11-09-011. However, until the Commission makes a final determination in R.11-09-011 revisions to Tariff Rule 21 that may provide a more expedited interconnection process to participants in this Program, utilities shall allow generators to choose which interconnection processes to use, either the process set forth in the Rule 21 Tariff or the WDAT. We direct this choice since the utilities follow different internal processes regarding which interconnection procedure is allowed for different renewable energy programs. By allowing generators to choose the process, generators will be able to evaluate which interconnection procedure better addresses their specific needs.

87 The utilities use different names for their FERC-jurisdictional interconnection tariffs. SCE and SDG&E each use WDAT, while PG&E uses "Wholesale Distribution Tariff." This decision uses the term WDAT to refer to each utility's tariff.

88 D.07-07-027 at 40.

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