Tales from the frontlines of the solar and storage interconnection struggle in California

Getting connected to the utility grid is one of the biggest hurdles to the development of more distributed renewable energy resources. I would know since I’ve been working on interconnection policy and have also been managing interconnection applications for various clients for the last fifteen years in California.

In short: the interconnection process is still very expensive and still takes way too long for many projects if they don’t qualify for the expedited process available for net-metered projects.

I was the lead author on a report on behalf of my long-time client, the Green Power Institute (GPI), along with Sahm White, then with the Clean Coalition, that identified a number of streamlining and automation options for dramatically improving the interconnection process in California. This report was completed as part of the working group process in the longstanding interconnection proceeding (R.17-07-007) at the California Public Utilities Commission (CPUC), and is attached as an appendix to the working group’s final report (starting at page 90).

One of our recommendations during the working group process was to expand the use of template (standardized) single line diagrams (SLDs) for the interconnection process. SLDs are created by engineers as part of the interconnection process. They show the utility the electrical configuration of the proposed system and allow for the engineering and safety review by the utility. By allowing applicants to use template SLDs, both the cost of the application process and the time required for utility review can be reduced dramatically.

San Diego Gas & Electric has allowed use of this kind of template SLD for most of its interconnection applications for some time (as part of its DIIS interconnection platform) and we suggested during the working group process that this practice could be expanded and adopted by other utilities.

Unfortunately, our proposals languished at the CPUC as the decision on the working group report and its recommendations was delayed, and delayed, and delayed.

Microgrids and chance

Then the CPUC began a new microgrid-focused proceeding in September of 2019 (R.19-09-009) in response to new legislation, SB 1339, that required the CPUC to do what it can to help commercialize microgrids and remove barriers to deployment. In the first phase of that proceeding, the CPUC’s staff report recommended a template SLD process, applicable only to solar and battery storage, as one option for streamlining interconnection. This came after workshops in the new microgrid proceeding where almost every stakeholder discussed the very serious issues with interconnection that have plagued their projects.

Here’s where human interactions and chance played a role – or so it seems. It so happened that the staffperson leading the CPUC’s microgrid effort in the Energy Division at the CPUC was, in an earlier position, Commissioner Picker’s energy advisor and, in that role, attended a number of the working group meetings in the interconnection proceeding. I met with him a couple of times during that proceeding to discuss interconnection automation and streamlining options, and he was fairly involved since that proceeding was overseen by Commissioner Picker at that time (he has since left the Commission).

After the staff proposal in the microgrid proceeding was issued, most parties spoke in favor of adopting the template SLDs as a key step for streamlining interconnection for microgrids – specifically for behind the meter solar and energy storage.

I drafted comments for my client, GPI, that praised the inclusion of the template SLD proposal, but highlighted the need to also change the timelines in the Rule 21 interconnection tariff if the interconnection process was to be streamlined in practice. This is because utilities typically take the full amount of time they’re allowed by the tariff, and unless the time allowed is reduced commensurate to the reduction in review time made possible by template SLDs the actual interconnection time for new projects won’t be reduced.

The CPUC approved the staff proposal’s template SLD proposals, but these are applicable mostly only to small behind the meter solar and storage. Unfortunately, however, it didn’t heed our admonitions about also changing the Rule 21 timelines in approving the staff proposal for template SLDs. Or allowing larger projects to use template SLDs – which are the projects that need more help in expediting interconnection since smaller behind-the-meter projects already are generally processed very quickly.

Waiting game

So we are now in a waiting game to see whether we’re right or not about this being a half solution. The CPUC has a habit of letting stakeholder advice, based even on years of experience in the trenches, fall on deaf ears.

In sum, we now have a nice new tool available to a subset of interconnection applicants that will likely lead to substantial cost savings in preparing new interconnection applications – but it probably won’t lead to any reduction in processing time until the CPUC modifies the Rule 21 tariff accordingly. That process often takes years, with each reform cycle taking 5 to 7 years (I’ve been through two full cycles now as a policy lawyer and advocate).

Even without timeline changes to the tariff, developers will save money by using the template SLDs because engineers won’t have to create them from scratch. And over time it is likely that the size limits for using template SLDs will be increased – if enough pressure by developers and advocates is brought to bear.