Regulatory Action
To see all of the Clean Coalition's regulatory filings, click here.
While legislative initiatives often garner the most attention for clean energy policies, most of the critical activity happens in the regulatory bodies. Various regulatory agencies are responsible for implementing legislation and creating the detailed rules that govern the energy project development process, from incentives to engineering. These rules span a broad range of topics and are sufficiently complex that the overall system of related policy is constantly in flux.
To unleash the potential of Wholesale Distributed Generation (WDG), the Clean Coalition actively engages in the regulatory policy process. Through public proceedings, public comments, direct consultation, and coalition building, the Clean Coalition informs federal and California state agencies about the best practices for removing barriers to clean local energy and incentivizing WDG development. In many cases, the Clean Coalition coordinates a range of parties and organizes collective action to present a stronger, unified voice.
The Clean Coalition has established itself as a leader in the clean energy sector through successful regulatory work at the federal and California state level. Specifically, the Clean Coalition advocates for the following fundamental policy principles:
- WDG Procurement: The most effective way to promote clean economic development now is through procurement policies that open the WDG market to the broadest range of participants while also ensuring that ratepayer money is being invested wisely.
- CLEAN Programs: CLEAN Programs are proven to be the fastest and most cost-effective way to mitigate the barriers associated with WDG and reap all of the associated economic benefits.
- Long-term planning: Effectively managing the transition to renewable energy requires a comprehensive, long-term plan for the distribution grid that assumes high-penetration of WDG.
- Interconnection (aka Grid Access): An efficient and transparent interconnection process is a critical part of creating a supportive environment for WDG.
- Locational Benefits of WDG Projects: Connecting a WDG project to the distribution grid rather than the transmission grid is more efficient and creates substantial cost savings for the ratepayer; WDG project owners should be compensated for the full value associated with their project location.
To read all Clean Coalition Regulatory and Public Submissions that support the fundamental policy positions outlined above, please click here.
Federal Regulatory Action
Federal Energy Regulatory Commission (FERC)
The Clean Coalition’s regulatory affairs at the federal level primarily involve the Federal Energy Regulatory Commission (FERC). FERC is the U.S. federal agency with jurisdiction over interstate electricity sales and wholesale electric rates. FERC also has jurisdiction over the California Independent Systems Operator (CAISO), and thus has the final say on the adoption of the CAISO proposals. The Clean Coalition engages with Commissioners and senior staff at FERC when their analyses and rulings affect the deployment of clean local energy.
As a federal agency, FERC can create regulations that preempt or “trump” state laws. Therefore, the Clean Coalition monitors FERC’s rulings closely to eliminate the risk of federal preemption of state CLEAN Programs or similar initiatives. Additionally, the Clean Coalition ensures FERC standards for improved interconnection procedures are enforced and maintained.
Read all Clean Coalition Regulatory and Public Submissions for FERC here.
California Regulatory Action
The Clean Coalition closely monitors and engages with the regulatory agencies and utilities that are responsible for energy programs and policies, electric rates, and interconnection to the electric grid in the state of California.
California Public Utilities Commission (CPUC)
The CPUC is in charge of regulating the investor-owned electric and gas utilities in the state of California, including Pacific Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E). A short-list of the CPUC’s goals includes instituting service standards, overseeing interconnection to the distribution grid and authorizing utility rate changes, three areas that are of vital importance for establishing a statewide CLEAN Program. The Clean Coalition monitors several CPUC regulations and policies:
SB 32 is enacted legislation that calls for an expansion of California’s existing, albeit small, Assembly Bill (AB) 1969 CLEAN Program. Among other things, SB 32 expands the AB 1969 total program size from 500 megawatts (MW) to 750 MW of clean local energy and increases the eligible project size from 1.5 MW to 3 MW. The Clean Coalition supports the expansion of the program, and is working to ensure that pricing is set at a rate high enough to make projects viable for developers, and that all locational benefits of WDG are included in CLEAN Contracts prices. Additionally, the Clean Coalition is working to guarantee that the new program requires and enhances pre-identification of interconnection siting capacity, cost, and value. The Clean Coalition is also advocating for an Interim SB 32 Plan that will allow projects to take advantage of federal tax breaks that expire at the end of 2011.
Currently in California, Distributed Generation (DG) projects that want to interconnect to a portion of the distribution grid that falls under state jurisdiction are subject to the regulations found in a procedure known as Rule 21. While Rule 21 currently works well for projects that interconnect on the customer side of the meter to serve on-site load, the process is almost unworkable in its current state for projects that interconnect on the system side of the meter in order to sell power to the grid. Projects that want to interconnect to a portion of the distribution grid under FERC jurisdiction are subject to a Wholesale Distributed Access Tariff (WDAT). Each investor owned utility (IOU) has developed its own set of WDATs for projects that wish to interconnect within its territory. Since determination of jurisdiction can often be murky, having two very different sets of interconnection rules adds additional complications to the interconnection process. With the Distribution System Interconnection Settlement (DSIS) process, the CPUC aims to develop a single statewide standard for all generators that interconnect to the distribution grid, regardless of which jurisdiction they fall under.
The Clean Coalition is actively involved in the revision or replacement of Rule 21 and WDAT interconnection rules to improve efficient and predictable grid access for WDG. Specifically, the new rules should require the IOUs to make grid and queue data publicly available, pre-identify beneficial interconnection locations, and set standardized interconnection costs.
The RAM Program is a two-year procurement program that was adopted by the CPUC for the purpose of lowering transaction costs and promoting the development of projects on the larger end of the WDG market segment, which includes projects up to 20 MW in size.
The current RAM allows projects to be connected to the transmission grid, as opposed to the distribution grid, which will cause projects to lose several benefits of WDG that result from producing power close to the load. The Clean Coalition will monitor the results of the RAM auctions and work to improve the program.
Every two years, the CPUC holds an LTPP proceeding in order to review and approve the IOUs’ ten-year procurement plans based on forecasted demand. Among other goals, the LTPP proceedings ensure that utilities come into compliance with California’s Renewable Portfolio Standards (RPS).
The Clean Coalition closely monitors the LTPP proceeding to make sure it reflects a long-term plan for the major deployment of WDG projects while also guaranteeing that the capital expenditures made by the IOUs for distribution grid upgrades will be allocated to facilitate full deployment of WDG. The Clean Coalition encourages the IOUs to integrate renewable energy in a manner that is realistic and supported by best practices.
Read all Clean Coalition Regulatory and Public Submissions for the CPUC here.
California Independent System Operator (CAISO)
Among other responsibilities, the CAISO is responsible for maintaining reliability and access to the California transmission grid. The CAISO’s Generation Interconnection Procedure (GIP) is the process by which an energy generator of any size interconnects to the transmission grid.
The Clean Coalition is working to ensure that the CAISO interconnection process is actually streamlined in practice and that interconnection pre-application and outcome data is fully available for planning and evaluation of current practices. Also, the Clean Coalition is encouraging the CAISO to coordinate standards, timelines, and requirements with other CPUC procurement programs, such as RAM.
Read all Clean Coalition Regulatory and Public Submissions for the CAISO here.
California Energy Commission (CEC)
The CEC is responsible for energy policy and energy planning in the state of California. The Clean Coalition is working to ensure that CEC policies guarantee streamlined interconnection for renewable, localized generation. The Clean Coalition is also supporting the CEC as it takes action to meet Governor Brown’s goal to reach 12,000 MW of distributed generation by 2020.
Read all Clean Coalition Regulatory and Public Submissions for the CEC here.
Investor Owned Utilities (IOUs)
IOUs provide energy to ratepayers, yet they are run like private enterprises rather than as a function of government or a utility cooperative. There are three large IOUs in California: Pacific Gas & Electric (PG&E), Southern California Edison (SCE), and San Diego Gas & Electric (SDG&E).
Both PG&E and SCE revised their WDATs as a result of the CAISO’s GIP reform, and the Clean Coalition is advocating for additional WDAT reform for all three IOUs. The WDAT reform should promote greater transparency for interconnection procedures from IOUs and guarantee that streamlined interconnection processes are maintained and enhanced for WDG.
Read all Clean Coalition Public Submissions for PG&E here.
Read all Clean Coalition Public Submissions for SCE here.