Action alert: Provide feedback to the CPUC on Rule 21 Project Plan

Workshop on Rule 21 Program Evaluation — Draft Research Plan: 27 June 2019, 9am PT

  Provide feedback to the CPUC on Rule 21 Project Plan

Workshop on Rule 21 Program Evaluation — Draft Research Plan: 27 June 2019, 9am PT

This workshop provides an opportunity to give feedback to the California Public Utilities Commission (CPUC) on the Rule 21 Program project plan and research questions.

The CPUC is undertaking a comprehensive evaluation of utility administration of the Rule 21 tariff to provide data and insight into each utility’s administration of the tariff. Rule 21 describes the process a developer must follow to connect their distributed energy resource (DER) to the grid.

The objectives of this project are to:

  1. Characterize utility compliance with statutory requirements, CPUC-approved Rule 21 tariffs and timelines, and CPUC decisions through a structured process
  2. Benchmark utility interconnection business practices to understand the current state of Rule 21 implementation
  3. Identify areas for improvement and propose policy or programmatic changes resulting from this evaluation

This workshop will solicit stakeholder feedback for the following:

  1. Primary data collection questionnaire
  2. Interconnection Reporting website data and its format

CPUC staff ask that interested participants review the attached slides and the questionnaire prior to the workshop:

  1. Workshop slides
  2. Draft questionnaire for data collection

The CPUC staff will solicit feedback on the project plan and research questions at the workshop. Staff and the Navigant team will also answer questions regarding the project and process.

If you have any questions regarding the workshop, please send them to Reese Rogers,

Recommended talking points


  • WDG refers to distributed energy generation, often commercial-scale solar, that interconnects to the distribution grid and serves local loads while avoiding any use of the transmission grid. Rather than serving one customer, these systems can serve an entire community.
  • See the Clean Coalition’s WDG Interconnection Pilot for information on the issues with WDG interconnection and how they can be solved.

Talking points:

  • Let the CPUC know what specifically to evaluate in the WDG interconnection process, identifying specific areas of focus, especially where utilities are falling short. Note that “averaged” results will not be very helpful in identifying where the problems are — and you know best where you encounter problems.
  • Interconnecting a wholesale distributed generation (WDG) project to the grid in California can take years, and it can be arduous and expensive. That means many projects never get off the ground. Fixing the WDG interconnection process will result in significantly more clean local energy in the state.
  • Compared to the process for identically sized and similarly sited net energy metering (NEM) projects in California, interconnecting WDG projects costs significantly more, takes longer, and is far less predictable.
  • WDG projects should be allowed to interconnect at locations where the utilities’ ICA 2.0 and other published information indicate adequate available hosting capacity with no significant required grid upgrades and no transmission or other constraints.

Attend the meeting

Call in using the dial-in information below, or attend in person at the CPUC, Courtyard Room, 505 Van Ness Ave, San Francisco, CA 94102.

Thursday, June 27, 2019
9:00 am  |  Pacific Daylight Time (San Francisco, GMT-07:00)  |  3 hrs 30 mins

Meeting number: 712 173 128

Meeting password: !Energy1

Join by phone
Call-in: 1-866-830-4003
Passcode: 9869619


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