12. Governmental Efforts Regarding Distributed Generation
Although we determine that no environmental review is required of our adoption of policies surrounding distributed generation, we recognize that because of its nature, distributed generation has numerous impacts to local governments, in terms of siting and permitting responsibilities. In addition, we recognize that because electric customers in California are served by municipal and regulated utilities, consistency in interconnection requirements between regulated and local utilities was desirable. This section summarizes statewide efforts to assist local governments and municipal utilities in facilitating installation of distributed generation resources.
12.1 Local Government Outreach Regarding Interconnection Standards
The CEC held two meetings with municipal utilities on November 28, 2001 and April 10, 2002 regarding the interconnection standards adopted in D.00-11-001 and D.00-12-037. In addition, representatives of municipal utilities regularly participate in the Rule 21 Working Group, a collaborative effort designed to continuously refine and improve the interconnection standards. These efforts have also included the smaller Commission-jurisdictional utilities, in order to ensure consistency.
Riverside Public Utilities has already adopted interconnection standards in response to these efforts, which have been ratified by the Riverside City Council on June 4, 2002. The Sacramento Municipal Utilities District has indicated that it may adopt interconnection standards by the end of 2002 and the Los Angeles Department of Water and Power has also expressed interest in adopting the standards.
12.2 Identification of Permit Streamlining Opportunities
In R.98-12-015, we requested that the CEC "hold a workshop...to discuss whether local government agencies can use a streamlined CEQA process for the siting of certain types of distributed generation facilities." After a workshop and a public hearing, the CEC issued the report Distributed Generation: CEQA Review and Permit Streamlining (December 2000). The report recommended several CEC efforts to improve siting of distributed generation facilities, including:
1. Provision of technical assistance to local jurisdictions conducting CEQA review and land-use approval for peaker projects. CEC staff would provide training and technical assistance to city and county building department staffs to facilitate permitting and inspection of distributed generation technologies.
2. Development of the scope, definition, and criteria for categorical exemptions of certain distributed generation facilities. The report recommends that CEQA guidelines should be amended to provide categorical exemptions for certain types of distributed generation projects. CEC staff would work with local government planning departments to develop:
· Lists of distributed generation projects exempt from CEQA and land-use approval;
· Thresholds of significance in key environmental issues; and
· Standard mitigation measures for types of distributed generation projects that have the potential to cause significant impacts to air quality, noise, aesthetics and other environmental areas.
3. Providing assistance to the California Air Resources Board (CARB) in developing distributed generation emissions standards and certification program.
In 2002, the CEC undertook a separate initiative to define a strategic plan for distributed generation. CEC held a public workshop to gain input and then drafted its Strategic Plan for Distributed Generation (June 2002). Several of the goals of the Strategic Plan also will assist in improving local government siting efforts, including:
1. Assessment of the technical and economic potentials for distributed generation and the drafting of model ordinances for distributed generation facilities; and
2. Raising consumer and public awareness about distributed generation by creating and maintaining a central repository of distributed generation information. The CEC would:
· Develop a database of all distributed generation installations in the state; and
· Publish up-to-date information on distributed generation technologies, such as: environmental factors such as emissions and noise; efficiency and reliability; commercial availability; installation and operational costs; and control aspects.
These efforts will assist local jurisdictions in permitting decisions regarding distributed generation. As highlighted in the 2000 CEQA workshop report, local governments need information on distributed generation technologies, an inventory of current distributed generation installations, and identification of public health and environmental impacts, to accurately and efficiently assess projects that seek to locate in their communities.
Additionally, to enable expedited environmental review of proposed projects and to address cumulative impacts of increasing numbers of distributed generation sources, the CEQA Review and Permit Streamlining report recommends that public agencies undertake program or master Environmental Impact Reports (EIR). Project EIRs, prepared for individual projects, must include analysis of the potential cumulative impacts of the proposed activity. Rather than addressing cumulative impacts on a project-by-project basis, CEQA allows public agencies to address them in master EIR or program EIR, allowing future project EIRs to avoid conducting further cumulative impact analysis. This step could more efficiently and effectively allow local or regional public agencies to consider cumulative impacts from distributed generation projects and ensure that worthwhile mitigation measures were adopted on a program-wide basis.
We encourage the CEC to proceed with the education efforts it has identified. We realize that California's budget situation may impact the ability of state agencies to undertake new program activities such as these but we encourage the CEC and this Commission to leverage federal program funds (e.g. U.S. Department of Energy) to undertake these efforts.
12.3 Air Quality Standards Established for Distributed Generation
Senate Bill 1298, Chapter 741, Stats. 2000, required CARB to adopt uniform emission standards for distributed generation technologies, which have historically been exempt from air pollution control or air quality management district permit requirements. The statute also directed CARB to establish a certification program for distributed generation. CARB has also been developing guidance to local air districts and permitting authorities who may have oversight over distributed generation siting.
CARB approved a staff proposal for the distributed generation certification program (with certain modifications) and the district guidance document at its November 15, 2001 Board Hearing. These documents are available on CARB's website at http://www.arb.ca.gov/energy/dg/dg.htm. Adoption of these regulations will help to ensure that distributed generation in California is on the leading edge of emissions control technology and the cleanest in the country.
12.4 Evaluation of Efficiency, Emissions, and
Reliability of DER
Section 353.15 calls for the Commission, in consultation with the CARB and the CEC, to evaluate efficiency, emissions, and reliability of distributed generators over 10kW capacity that receives the rate treatment prescribed by SBX1 B. We intend to pursue this evaluation within this or a successor rulemaking.
