2011 Interconnection Requests Must Meet March Deadline

New GIP Interconnection Rules Now Being Published

During 2010 all of the previous interconnection rules, procedures, fees, and timelines for completing these agreements have been massively changed for solar PV farms in California. Starting first in the spring was the CAISO collapse of separate interconnection rules for small (SGIP) and large (LGIP) solar facilities on the transmission line systems of the utilities into one inclusive “cluster” process. The serial and much simpler SGIP rules were basically abandoned because of utility concerns for being swamped with applications that had overlapping system reliability concerns being studied in isolation of one another. Indeed the CAISO transmission, SCE WDAT, and PG&E WDAT interconnection queues have exploded during 2010. Next late in the fall, the big two utilities(SCE and PG&E so far)  have moved toward the collapse of their WDAT distribution connection rules into a “cluster” process in fast unison.

On December 12th the FERC ruling basically blessed the CAISO proposal and set in motion the expected approval of similar WDAT reform GIP(Generator Interconnection Procedures) rules being proposed for approval by SCE and PG&E.

What this means is that the old serial study of individual projects at specific sites is now gone forever into a study process that puts your project into a system upgrade study process with all projects in the same region of the utility system. There are subtle exceptions such as a proposed Independent Study Process or a Fast Track Process that may be viable for smaller projects, but in general the rules are much more complicated and costly to navigate for a solar PV developer.  In particular I want to thank the FIT coalition and Jaclyn Marks of the CPUC for pushing the CAISO ruling to increase the size of a fast track project to 5MW.  However, the utilities in their distribution reform GIP processes are going back to the old 2MW limit.  More controversy is underway on this issue before final resolution, I predict.  For instance, the long awaited SB 32 FIT program with a 3MW limit will be outside any fast track possibility for projects above the 2MW limit, and these larger projects will be placed into a cluster applicaton.  Quite a mess it seems.

Make The Cluster #4 Interconnection Application Window

With some reading of the massive new rules it becomes apparent that your 2011 project trying to get an interconnection agreement in some finite time MUST be placed into the cluster #4 application group that closes by the end of March 2011. If you miss this window then you may wait until the late fall for another possible opening. Of course by then your possible connection site will already be over the capacity allocation limit for a reasonable interconnection charge and you will get a nice large system upgrade bill over a year later than the first group.

The time is now to work with partners to understand these new realities and to make this looming deadline for both transmission and distribution applications for 2011.