FIT Coalition calls on renewable energy generators support; Submits comments to CAISO regarding proposal to eliminate SGIP

On Monday, June 21, the FIT Coalition submitted the following comments to CAISO:Download FIT Coalition CAISO Submission Here.

What is at stake and what you can do?

The California Independent System Operator (CAISO) is on the verge of undermining the Wholesale Distributed Generation (WDG) market segment, which is comprised of 20 megawatt (MW) and under proje cts that are interconnected to the distribution grid.

CAISO has proposed eliminating the Small Generator Interconnection Procedure (SGIP), which is the streamlined interconnection process for 20 MW and below energy projects that is mandated by the Federal Energy Regulatory Commission (FERC).

TheFITCoalitionurges all developers pursuing WDG projects in California to get involved tohelp ensure that CAISO does not eliminate SGIP. Pleaseemail[email protected]if theFITCoalitioncan call on your support to join our efforts.

On the surface, CAISO has initiated reform because the SGIP process has been taking longer than the 9-month timeframe that is intended to be its maximum duration. Rather than simply fixing the SGIP process, however, CAISO is proposing to eliminate SGIP by processing all projects through a process akin to the Large Generator Interconnection Procedure (LGIP), which would add a significant delay to the interconnection process for projects sized 20 MW and under.

The proposed process would take up to 2 years – and perhaps even longer. This would significantly undermine what is currently a MAJOR benefit of 20 MW and below renewables: a streamlined interconnection procedure. CAISO claims that it would maintain a so-called Fast Track process for 2 MW and under projects, but considering that the Fast Track process has virtually unattainable requirements, this is a useless concession even for the sliver of tiny wholesale projects that it is intended to help.

Additionally, theFITCoalitionis extremely concerned that the Investor-Owned Utilities (IOUs) would attempt to reflect anySGIP changes in their Wholesale Distribution Access Tariffs (WDATs), thereby creating HUGE impediments for WDG. While the WDATs are supposedly not being discussed in this CAISO proceeding, the IOUs historically adopt changes made in SGIP into their WDATs. As such, CAISO’s proposed elimination of SGIP would very likely lead to de facto reforms that make the WDATs equivalent to the LGIP (ie, all WDG projects would essentially be subject to LGIP, which would be a HUGE impediment to WDG).

CAISO needs to fix SGIP rather than eliminate it.TheFITCoalitionurges all developers pursuing WDG projects in California to get involved to help ensure that CAISO does not eliminate SGIP.Pleaseemail[email protected]if theFITCoalitioncan call on your support to join our efforts.

This CAISO proceeding is open to the public, and here is the calendar
of related events:

June 25: Working Group meeting #3
July 8: Working Group meeting #4
July 12: Draft Final Proposal posted to ISO website
July 20: Stakeholder meeting to discuss Draft Final Proposal
July 27: Written stakeholder comments due on Draft Final Proposal
Weeks of August 2 & 9:
Additional stakeholder engagement
Aug 13: Stakeholder Process Complete
Sep 9-10: Board of Governors meeting – approval of modified
SGIP requested
Sept 13: Draft tariff language posted
Sept 20: Written stakeholder comments on draft tariff language due
Sept 27: Stakeholder meeting to discuss draft tariff language
Oct 12: Tariff language filed at FERC
Dec 20: Anticipated FERC Order Issued

Additional details, including location and participation details, can be found at this CAISO weblink:http://www.caiso.com/27a2/27a2f34fa360.pdf

TheFITCoalitionhas submitted comments on this proceeding, and these can be found here. The link to download is at the top of this posting.

Again, theFITCoalitionhopes to have your support.

Pleaseemail[email protected]if theFITCoalitioncan call on you to join our efforts.