Improving cost certainty for distributed generation
The Clean Coalition has recommended a number of measures to the CPUC to enhance cost certainty for interconnection.
For years, the Clean Coalition has been driving improvements to the California Public Utilities Commission’s (CPUC) Rule 21, which regulates interconnection, operation, and metering requirements for distributed generation in California.
Building upon success streamlining interconnection studies, the Clean Coalition is now focused on improving cost certainty.
The interconnection process is marred by a lack of cost certainty under Rule 21, especially for wholesale distributed generation (that is, projects that connect on the utility-side-of-the-meter). These applicants must be prepared to incur a host of unknown and significant costs leading up to the project’s interconnection. Costs are neither pre-established nor standardized, and after a potentially costly study process, applicants are subject to contracts that leave them liable for expenses that may vary dramatically from estimates.
The Clean Coalition has recommended a number of measures to the CPUC to enhance cost certainty, including a push for contracts that include fixed prices or maximum cost commitments and the development of a “Per Unit Cost Guide” to improve cost transparency, consistency, and predictability throughout the interconnection process. The Cost Guide would contain both component costs and examples of a variety of project sizes, energy sources (generation and storage), and locations deemed relevant to interconnection applicants.
The Clean Coalition is also working with stakeholders on interconnection of energy storage installations, starting with clarification and simplification of rules for behind-the-meter (BTM) non-exporting facilities. Over the next few months, we expect to resolve issues regarding the treatment of loads associated with energy storage charging, the standards required to meet the definition of a “non-exporting” facility, and the measurement and control of exported energy to avoid grid impacts for all categories of energy storage.
Much work remains, but decisions on each of these cost certainty measures are expected by the end of December. Look for additional updates in future Clean Coalition newsletters.