4. Forum for Post-Implementation Work

In its Supplemental Recommendation, the Energy Commission offers us a unique opportunity to ensure that Rule 21 best serves the California market in the future. The Energy Commission has offered, under the direction of the Siting Committee, to continue the working group process as a post-implementation phase. The Energy Commission would open a new proceeding to address issues and recommend changes to Rule 21 and the Interconnection Application and Agreement as parties gain more experience implementing the Rule and working with the application and agreement. The new proceeding would provide a forum for meetings of the technical and non-technical working groups. In comments, PG&E supported formation of an ongoing Rule 21 review group under the supervision of the Energy Commission. In PG&E's view, such a forum will provide an opportunity for ongoing evaluation of implementation issues under the new rule and potential revisiting of areas of concern. PG&E recommended that the Commission provide explicit endorsement of an ongoing Rule 21 tariff review group under the auspices of the Energy Commission in its final decision.

We agree that establishment of a post-implementation working group is a prudent and effective way to proceed and will work with the Energy Commission to accomplish this objective. We envision that this group will also monitor development of IEEE standards and how such standards should impact the Rule. The specifics of the Energy Commission proceeding will be developed under the direction of its Siting Committee, in consultation with this Commission.

The Energy Commission will also play an outreach role to entities not subject to Commission jurisdiction to increase the likelihood of statewide, standardized rules. The Energy Commission will work with the California Municipal Utilities Association (CMUA) to encourage municipalities, irrigation districts, and local governments to adopt Rule 21-type standards to encourage standardized interconnection rules across the entire state. CMUA, the municipal districts, and the irrigation districts have participated throughout this proceeding as these Rules have been developed in order to facilitate statewide standards. CMUA's agreement to assist the Energy Commission will facilitate information exchange between the Energy Commission and the publicly-owned utilities in the state and help make this statewide goal a reality.

The Energy Commission is also uniquely situated to become the central point of reference for participants in the distributed generation industry. Because of their expertise in this area, and their involvement in other programs that support distributed generation, we expect to rely on the Energy Commission to provide detailed information about distributed generation, through its website, by supporting the information needs of parties submitting and reviewing Interconnection Application requests, supplying information on permitting, and in other ways not yet defined.