BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2590
                                                                  Page  1

          Date of Hearing:   May 7, 2012

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                   AB 2590 (Blumenfield) - As Amended:  May 1, 2012
           
          SUBJECT  :   Distributed generation: interconnection.

           SUMMARY :   Mandates investor owned electric utilities (IOUs) to 
          post any reports required by a revision to the California Public 
          Utilities Commission's Electric Rule 21 on its Internet Website 
          if that revision is adopted after January 1, 2012.  

           EXISTING LAW  :

          1)Prescribe both federal and state procedures and fees required 
            to connect a generation facility to the grid. The Federal 
            requirements are regulated by the Federal Energy Regulatory 
            Commission (FERC). The State requirements are regulated by the 
            California Public Utilities Commission (PUC). 

          2)Federal requirements apply to projects that interconnect to 
            the points in the grid that are owned and operated by 
            utilities or those points that are managed by the California 
            Independent System Operator (CAISO). CAISO manages the 
            transmission system. Those points that are controlled by the 
            utilities include anything not under CAISO control up to the 
            utility customer's electrical meter. These interconnection 
            procedures are known at the Generator Interconnection Process 
            (GIP) at CAISO and the Wholesale Distribution Access Tariff 
            (WDAT) at the utilities. These procedures are submitted to and 
            approved by FERC.

          3)State requirements apply to projects that interconnect on the 
            side of the electrical meter that is controlled by a customer 
            of a utility and designed to provide electricity that is 
            generally consumed on site by the customer (known as PUC Rule 
            21). The PUC has oversight of Rule 21.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :  According to the author, "alternative energy is the 
          path to meet California's future energy needs. We must do all 
          that we can to reduce barriers to producing clean, affordable 
          power close to where people live. Distributive energy producers 








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          need easy access to the information currently available in order 
          to make smart choices about their energy projects.

          One way to assist energy producers in designing good projects is 
          to provide easy access to this data by making sure that all 
          public reports required by Electric Rule 21 are posted online. 
          AB 2590 ensures that future reports relating to interconnection 
          are electronically available so that the public, distributive 
          energy producers and regulators can easily access this critical 
          information."

           1)Background  : Interconnection rules and processes are designed 
            to ensure that generation facilities connect to the 
            electricity grid in a manner that does create safety or 
            reliability problems for customers who rely on the electricity 
            from the grid.

            In light of successful deployment of customer-side renewable 
            energy projects, and lower costs of renewable technologies, 
            there is more opportunity to develop local generation that can 
            serve more than one customer at a time. This type of project 
            is commonly known as 'distributed generation.' The PUC has 
            implemented or is in the process of implementing programs to 
            encourage greater deployment of distributed generation (DG), 
            including the Reverse Auction Mechanism (RAM) and Feed in 
            Tariffs (FIT). The PUC has also approved photovoltaic DG 
            programs at both PG&E and SCE. These projects range in size 
            from 1 Megawatt (MW) to 20 MW. For the most part, they are 
            designed to interconnect through the WDAT procedure.

           2)The Rule 21 Settlement:  The PUC established a working group to 
            discuss reforming the interconnection process known as Rule 
            21. A settlement motion was filed on March 21 and is pending 
            before the PUC. The settling parties include the investor 
            owned utilities and Aloha Systems Incorporated; California 
            Farm Bureau Federation; Center For Energy Efficiency And 
            Renewable Technologies; the Clean Coalition; Interstate 
            Renewable Energy Council Inc.; Sierra Club, Solar Energy 
            Industries Association; SunEdison; Sunlight Partners; 
            Sustainable Conservation; and The Vote Solar Initiative.

            According to the settling parties, the settlement provides  
            significant revision of Rule 21 in a manner that maintains 
            distribution and transmission grid safety, reliability and 
            power quality while balancing the need for a more timely, 








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            efficient and transparent interconnection process without 
            delay.

            The Rule 21 Settlement specifies that there will be a publicly 
            available queue of projects and what information can be held 
            confidential and what cannot.

            Perhaps most important, the reforms were done with an eye 
            toward making conforming reforms to the WDAT process, which 
            will require the investor owned utilities to file a petition 
            before FERC to request approval for those changes.

           3)Transparency and open information:  The intent of AB 2590 is to 
            require the IOUs to post on their websites any reporting 
            requirements pursuant to changes in PUC Rule 21. This would 
            ensure the reports are easily accessible to the public, 
            distribution power generators and regulators. The bill also 
            defers to PUC authority relative to confidentiality rules 
            under Public Utilities Code Section 583.  

           4)Is this bill premature  :  This bill may not be needed as some 
            of the utilities are already posting Rule 21 updates on their 
            website. In particular, Southern California Edison is working 
            on an internet web-based conference with the PUC and 
            Governor's office on the Rule 21 Phase 1 settlement changes.  

            According to the PUC, there are three types of reports 
            currently required under the revised Electric Rule 21, all of 
            which will contain proprietary to a developer applying for 
            interconnection. The three reports are (1) a pre-application 
            report (a quick first look at a point of interconnection), a 
            system impact study report (stating the impacts of the 
            developer's proposed generating facility), and a facilities 
            study report (stating the interconnection facilities that will 
            have to be built to accommodate the generating facility).  
            These all contain information that a developer will consider 
            confidential and will likely not want posted to the IOU's 
            website.

            Moreover, the PUC notes that a staff proposal is currently 
            planned for the PUC's open interconnection rulemaking 
            (R.11-09-011) on broader reporting by the electric utilities 
            to identify overall compliance with the revised Rule 21 once 
            it has been formally adopted.  The proposed compliance reports 
            will draw only on non-confidential and that data will be 








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            required to be filed in the proceeding and posted publicly.
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           

           Opposition 
           
           
          Analysis Prepared by  :    DaVina Flemings / U. & C. / (916) 
          319-2083