To summarize, following is an initial list of the issues to be considered in this proceeding, and questions we ask parties to respond to as we prepare to scope this new Rulemaking.
1. General issues
The Commission, the CEC, the CARB, and the utilities are required to collect a significant amount of DG data in connection with administering incentive and net metering programs, and through legislatively-mandated data collection programs.
· How could these entities share data and streamline data collection?
· How could performance data collected from DG customers be verified?
· How could DG data be formatted to be made publicly available?
· Please identify all known DG data collection mandates and data sources.
· Parties should comment on the implementation of DG-related goals stipulated in the joint agency Energy Action Plan, as described above.
· How should the Commission coordinate its DG-related activities with those of the CPA, if appropriate?
2. Cost-Benefit Analysis for Customer and IOU Installations
· What is the proper definition of DG, including MW size ranges, for standardization across state agencies and programs?
· How might DG development affect the relative liabilities of ratepayers, utilities, DG owners and others?
· How are the avoided cost (and cost components) being developed in R.01-08-028 relevant to this inquiry? What changes are necessary for them to be applicable to the cost-benefit analysis of DG and net metered projects?
· Should a separate market structure (retail market or exchange) be created for the full range of DG technologies? Could this market be structured to maximize or aggregate the benefits at reasonable costs? How could consumer protections be established for any potential market structure?
· What are the positive and negative aspects of DG additions that need to be monetized?
· Which specific approaches to DG and net metering cost-benefit analyses should be adopted, and how should these analyses be employed by the Commission and the IOUs?
· Are standby charges and reserve requirements properly assessed and applied to DG projects?
· What are the emissions characteristics of present DG technologies, and in light of the pending ARB regulations, how should the Commission expect these characteristics to change over time?
· How should the Commission interpret the language of Pub.Util.Code 353.9, which requires that net costs of DG systems be recovered only within the DG owner's customer class? Should the Commission establish a separate customer class, or separate customer classes, to encompass DG installations, and contain net costs and benefits within each class?
3. DG as a Utility Procurement Resource
· We direct the IOUs to provide an update on the implementation plan to incorporate DG into grid-side system planning, as stipulated in Ordering Paragraph Two of D.03-02-068, to be submitted within two weeks of the issuance of this Order.
· Are there initial results from the DG Integration decision, D.03-02-068, which should be considered, and integrated with the resource planning and procurement process underway in R.01-10-024? What other dockets should this proceeding be coordinated with?
· Should the Commission consider any changes to the Net Metering program at this time?
· What is the potential for DG to mitigate the effects of blackouts, as some have contended in response to the August 14th, 2003 East Coast blackout?
· Generally, what role should DG play in the resource adequacy and reserve requirement equation of the IOUs?
· Are there tariffs or rates that could be crafted to provide better retail price transparency to DG? Could participation costs be reduced? Could the full range of DG participate?
· Can market rules and regulations be modified to allow DG to participate in current wholesale markets? Will they be consistent and stable? Can transaction and participation costs be reduced for DG? Could the full range of DG participate?
· How can utility distribution planning practices be modified to enable DG to provide distribution deferral and be compensated for it?
· Should distribution design be modified to be more accommodating to DG?
· What steps should the Commission take, if any, to influence the use of natural gas in DG systems?
4. Net Metering
· Is the current net metering capacity allowance of .5 percent of an electric service provider's aggregate peak demand sufficient to accommodate for increased net metering installations in all IOU service territories?
· Should the Commission consider reforms to the net metering program, such as development of a wholesale transaction tariff to allow actual sales from the DG owner to the IOU?
1. Outstanding Interconnection and Related Technical issues
· In consideration of the issues addressed above, as well as the views expressed in Appendix A, which Rule 21 issues should be considered in the course of this rulemaking? What should be the order of priority? Parties should bear in mind that the CEC continues to coordinate the Rule 21 Working Group, and many of these issues may be best vetted in that process, before being brought into this formal docket.
· Is FERC's Notice of Proposed Rulemaking for small generation compatible with California's policies and procedures for DG?
6. DG Issues for the Future
· How can the Commission and CEC integrate the results of ratepayer-funded R&D in DG technologies into the utilities' planning and procurement process?
· What role should DG policy play, if any, in stimulating development of hydrogen-based electricity generation? Should this issue be considered in conjunction with the utilities' Low Emission Vehicle Programs, potentially employing hydrogen as a power source for both mobile and stationary applications?
· Which advanced DG technologies, such as fuel cells, microgrids and storage systems, should be actively considered in this proceeding? What specific resource needs could be met by these technologies, at present or in the near future? What policy issues, if any, must be addressed to effectively deploy these strategies?
· Finally, what is the potential for aggregating DG loads at the transmission level? How should the Commission coordinate with the utilities, ISO and other relevant entities to explore this potential?