Findings of Fact

1. The Energy Commission's recommended rules promote application of consistent interconnection standards across utility service territories and provide clear guidance to applicants regarding the standards that must be met for simplified interconnection.

2. An interconnection application must supply sufficient information to allow the utility to accurately evaluate the interconnection requirements for the facility but not be burdensome so as to serve as a barrier to entry.

3. All parties agreed that if their respective positions regarding indemnity are not adopted, no indemnity clause should be included in the interconnection agreement and it should be replaced with a limitation of liability clause.

4. This Commission last addressed proper insurance levels for interconnected generators in D.83-10-093.

5. The parties agree that the minimum liability insurance carried should be increased but should differ based on size and customer class.

6. The recommended testing and certification procedures rely heavily on those developed by Underwriter's Laboratories, the Institute of Electrical and Electronics Engineers, and the International Electrotechnical Commission.

7. Parties agree that the total cost of initial and supplemental review would not exceed $1,400.

8. The current record does not allow a conclusion about whether initial and supplemental review costs are already part of the utility's everyday operations or whether all of the costs are new costs.

9. Assuming the Commission finds that some of the initial and supplemental review costs are part of the utility's everyday operations, the initial and supplemental review fees should be adjusted accordingly.

10. PG&E did not demonstrate a compelling reason to modify standardized language for Rule 21 at this time.

11. The Energy Commission's data collection regulations require utilities to submit basic information about each interconnected generating facility, regardless of size.