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Solar Screen Test

Making room on the local grid for small-scale PV.

Fortnightly Magazine - May 2012

at least revisit its SGIP rule and conduct its own inquiry on how best to craft a new screen test.

New Jersey, for example, urges more transparency in the distribution-level interconnection process. It scoffs at industry claims that minimum load figures represent confidential customer data that FERC is bound to protect, or that ratepayers will be harmed financially by its release:

“There appears to be no legitimate reason to keep this data confidential,” writes New Jersey Attorney General Jeffrey Chiesa, representing his state commission. (Comments of NJ BPU, FERC Docket RM12-10, filed March 27, 2012.)

And it goes without saying that solar project developers support the proposed rule. Virinder Singh, director for regulatory and legislative affairs for enXco, a developer and service provider to wind, solar, and biogas generation facilities, complains that the distribution interconnection process—seen by some as a “black box”—remains opaque. He adds:

“It is difficult to obtain, let alone understand the rigorous technical justification for certain per-circuit limits…”

“This opacity was not a major market issue before demand for solar photovoltaics skyrocketed… Today it represents a major gap in the regulatory system that governs access to the grid.”

Surprising Opposition

The degree of industry opposition appears especially surprising, given that California, the national leader in solar energy, is now moving in the same general direction as advocated by SEIA, both at the transmission and distribution level.

Not long ago, for example, the FERC OK’d a new tariff proposed by the California Independent System Operator to modify its SGIP fast track process for transmission interconnections to increase the permitted generator size from 2 to 5 MW. (Dkt. ER11-1830, order issued Dec. 16, 2010, 133 FERC ¶61,223.)

A few months later, FERC approved a new wholesale distribution tariff for PG&E that eliminated the mandatory 2-MW cap from the utility’s SGIP fast-track process for small-scale distribution-level generation interconnections, by making the cap simply advisory. PG&E’s amended tariff retained the 15 percent screen test, but provided that a project failing the screen wouldn’t be rejected automatically, but would be eligible for a supplemental review based on actual minimum load data, if available. (Dkt. ER11-3004, order issued April 29, 2011, 135 FERC ¶61,094.)

And just six weeks ago, all three of California’s major investor-owned electric utilities signed on—along with the Sierra Club, SEIA, Interstate Renewable Energy Council, and other renewable energy advocates—to a settlement agreement by which the California PUC proposed new, liberalized fast-track procedures for distribution-level interconnections for small-scale generators and electric storage resources under a CPUC regulation known as Rule 21. The settlement would allow for fast-track interconnection for higher-capacity projects at specific distribution line voltages for each of the three IOUs:

So. Calif. Edison: A 3-MW cap for 12-, 16 or 33-kV interconnections.

San Diego Gas & Electric: A 1.5-MW cap for 12-kV interconnections.

PG&E: A 3-MW cap for 12-kV or larger voltages. (See, Motion for Approval of Settlement Agreement, CPUC Rulemaking 11-09-011, filed March 16, 2012.)

As the California PUC explained in comments it filed at FERC, the new CPUC Rule 21 retains the traditional FERC SGIP