Decisions Under R.11-09-011

Under Rulemaking 11-09-011, the CPUC adopted three major decisions, in which ORA advocated for and which are outlined in detail below.

CPUC Decision on Rule 21 Reforms

In September 2012, the CPUC issued Decision (D.12-09-18) approving the first set of reforms to Rule 21 establishing a process to accommodate the interconnection of exporting generating facilities. If the exporting generating facility does not have an impact on the distribution system, it can interconnect after a fast track study is completed – this study is quicker than the previous process and accommodates the facility to come on line more quickly. Under this reform all requests made to the utilities to interconnect to their distribution systems would be designated to one of two major study tracks to be performed by the utilities:

  • The Fast Track: A streamlined interconnection review process for which Net Energy Metering, non-export facilities (not exporting energy to the distribution system), and some exporting facilities are eligible. To be eligible for the Fast Track, an applicant must meet a series of requirements.
  • The Detailed Study: A more lengthy interconnection review process should the applicant not meet the requirements set forth in the Fast Track process.

The ORA generally agreed with the work leading to this decision but advocated for primary focus on the cost certainty issue, introduced in initial comments here and discussed in detail further in this webpage.

CPUC Decision on Requiring “Smart” Inverters

On December 12, 2014, the CPUC issued Decision (D.14-04-003) requiring new inverters used by interconnecting generating facilities to have enhanced technical capabilities. The ORA supported that the design of these new inverter standards to allow interconnected generating facilities to offer system support functions to distribution or transmission system operators. ORA recommended that cyber-security be included separately but not within the scope of Rule 21 as the working group proposed.

CPUC Decision on Cost Certainty for Interconnection for New Technologies

On July 1, 2016, the CPUC issued Decision (D.16-06-052) to: (1) provide earlier and more reliable interconnection cost information (also known as Cost Certainty), for electric generation developers to ensure that the interconnection process is timely, non-discriminatory, cost-effective, and transparent, (2) set forth a streamlined process for analyzing requests for interconnection of electricity storage devices and (3) set forth guidelines for the revision of Rule 21 to incorporate the technical recommendations of the Smart Inverters Working Group (SIWG) for additional advanced inverter functions, otherwise known as Smart Inverters.

Cost Certainty

R.11-09-011 was initiated to address complaints by the Interconnection Applicants who were not getting early, reliable and cost certain interconnection cost information from the utilities. Through its advocacy addressing the issues raised by the Applicants, ORA was able to achieve higher level of Cost Certainty for the Applicants which may lead to keeping rates down for ratepayers through the reforms ordered in D.16-06-052. For more information on ORA’s advocacy work, click here for lobbying materials, here for comments, and here for reply comments on this issue.

CPUC Proceeding Docket

See the R.11-09-011 Proceeding docket.