Rule 21 Interconnection

Electric Rule 21 is a tariff that describes the interconnection, operating and metering requirements for generation facilities to be connected to a utility’s distribution system. The tariff provides customers wishing to install generating or storage facilities on their premises with access to the electric grid while protecting the safety and reliability of the distribution and transmission systems at the local and system levels.

Each investor-owned utility is responsible for administration of Rule 21 in its service territory and maintains its own version of the rule:

 PG&E Rule 21 Tariff Rule 21 Website
 SCE Rule 21 Tariff Rule 21 Website
 SDG&E  Rule 21 Tariff Rule 21 Website

  

 

 

Table of Contents: 

  • Interconnection Rulemaking (R.17-07-007)
  • Interconnection Discussion Forum
  • Dispute Resolution
  • Smart Inverters
  • Interconnection Data Reporting
  • D.16-06-052 Implementation
  • Rule 21 Applicability, Provisions, and History
  • Contact

Interconnection Rulemaking 17-07-007

On July 13, 2017, the Commission issued an Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21. Among the principal topics to be considered in the new rulemaking is the incorporation into Rule 21 of the utilities' Integration Capacity Analysis tools, currently under development in the Distribution Resources Plan proceeding, to inform interconnection siting decisions, streamline the Fast Track process for projects that are proposed below the integration capacity at a particular point on the system, and facilitate interconnection process automation.

Webpage: For information on proceeding scope, schedule, working groups, and history, please visit Energy Division's Interconnection Rulemaking 17-07-007 page. For materials and meeting notifications for Working Group Two, please visit the Gridworks Working Group Two website at http://www.gridworks.org/initiatives/rule-21-working-group-2.

Interconnection Discussion Forum

Energy Division is excited to announce the formation of an Interconnection Discussion Forum that will provide an informal venue for utilities, developers, and other stakeholders to explore a wide variety of issues related to interconnection practices and policies. The forum, established in Resolution ALJ-347 (approved October 12, 2017), is intended to meet the following objectives:

  • Foster proactive, constructive communication between utilities, developers, and other impacted stakeholders about issues related to implementation of Rule 21 and other interconnection rules
  • Resolve informally and/or prevent interconnection disputes
  • Share information and best practices across utilities and developers

Please refer to the Interconnection Discussion Forum Charter for more information about the scope and structure of the forum.  Presentations from previous forums are also available:

Schedule: The forum meets in person quarterly and may be convened more frequently as needed. For schedule information, please follow the directions below to join the distribution list.

Distribution List: Energy Division maintains a distribution list for those interested in attending forum meetings. To request to be added to the list, please contact Reese Rogers at Reese.Rogers@cpuc.ca.gov.

Dispute Resolution

Section K of Rule 21 describes existing procedures for resolution of interconnection disputes. For disputes regarding missed timelines, please contact the relevant utility’s Rule 21 ombudsman:

PG&E
Mike Mulvey
     rule21.ombudsman@pge.com   
916-203-6459  
SCE
Rod Vickers
   Rule21.Ombudsman@sce.com   
714-895-0211
SDG&E
Joeseph McCawley
    JMcCawley@semprautilities.com   
858-503-5302

 

For all other disputes, please use the procedures outlined in Section K of Rule 21. For CPUC assistance in reviewing or resolving a dispute, please contact Reese Rogers at Reese.Rogers@cpuc.ca.gov.

Coming Soon:  Expedited Interconnection Dispute Resolution Process 

On October 12, 2017, the Commission approved Resolution ALJ-347 establishing an Expedited Interconnection Dispute Resolution Process as authorized by Assembly Bill 2861 (Ting, 2016). The expedited dispute resolution process will issue binding determinations to electric distribution grid interconnection disputes based on the recommendations of a technical panel within 60 days of the Commission receiving the Application regarding a particular dispute. For a detailed description of the adopted process, please see Exhibit A of Resolution ALJ-347.

AB 2826 is intended to address the inadequacy of the existing interconnection dispute resolution process described in utility tariffs in Section K of Rule 21, which relies on protracted mediation and does not benefit from readily-leveraged technical expertise to review the engineering determinations and upgrade cost allocations that often lead to disputes.

For questions about the expedited process, please contact Reese Rogers at Reese.Rogers@cpuc.ca.gov.

Smart Inverters

The Smart Inverter Working Group meets on a regular basis to develop recommendations for advanced inverter functionality requirements. For more information on smart inverter deadlines and working group activities, please see Energy Division’s Smart Inverter Working Group page, or contact Justin Regnier, Senior Utilities Engineer -- Supervisor, at Justin.Regnier@cpuc.ca.gov.

Interconnection Data Reporting

Pursuant to Decision (D.) 14-04-003, the three California IOUs submit interconnection data reports to the CPUC Energy Division on a quarterly basis. Public versions of the reports are made available on our Utility Interconnection Data Reports page.

Decision 16-06-052 Implementation

Decision 16-06-052 (R.11-09-011), adopted by the Commission on June 23, 2016, institutes a 25% Cost Envelope for interconnection costs; grants Joint Motions pertaining to Cost Certainty and Non-Exporting, Behind-the-Meter Energy Storage; and requires Rule 21 revisions to incorporate the technical requirements for Phase 2 smart inverter communications and Phase 3 advanced inverter functions as recommended by the Smart Inverter Working Group.

For more information about the provisions of D.16-06-052, please visit the D.16-06-052 webpage.

General Information about Rule 21

Applicability 

Rule 21 governs CPUC-jurisdictional interconnections, which include the interconnection of all net energy metering (NEM) facilities, "Non-Export" facilities, and qualifying facilities intending to sell power at avoided cost to the host utility. Rule 21 does not apply to the interconnection of generating or storage facilities intending to participate in wholesale markets overseen by the Federal Energy Regulatory Commission (FERC). These facilities must typically apply for interconnection under the FERC-jurisdictional "Wholesale Distribution Access Tariff" (when connecting to the distribution system) or "CAISO Tariff" (when connecting to the transmission system).

Overview of Tariff Provisions 

Rule 21 contains provisions governing many aspects of interconnection, including:

  • Procedures and timeframes for reviewing applications
  • Fee schedules to process applications and perform impact studies
  • Pro forma application and agreement forms
  • Allocation of interconnection costs
  • Provisions specific to net energy metered facilities
  • Technical operating parameters
  • Certification and testing criteria
  • Technical requirements for inverters
  • Metering and monitoring requirements
  • Procedures for dispute resolution

Regulatory History 

The Commission's first iteration of Rule 21 was adopted in 1982.  As initially adopted, Rule 21 was designed to meet the needs of small, non-utility-owned generating facilities, namely qualifying facilities, which included renewable, non-renewable, and cogeneration plants as defined by the Public Utility Regulatory Policies Act.

The Commission revisited Rule 21 in 1999.  Working collaboratively with the California Energy Commission, the Commission undertook a redesign of Rule 21 to establish a more standardized and transparent engineering analysis for the interconnection of distributed generation, especially generation that offsets on-site load.  Rule 21 adopted an "Initial Review" screening process designed to permit the utility engineer to quickly identify, among other factors, whether a generating facility is configured to remain within certain technical limits, and thus unlikely to cause electrical disruptions on the grid. 


The modified Rule 21 successfully facilitated the interconnection of tens of thousands of net energy metered and non-exporting generation facilities between 1999 and 2011.  However, generators seeking to export a portion or all of their generation to the utility's distribution system lacked a straightforward means of interconnecting under Rule 21.  Gaps in the tariff also existed for the interconnection of new technologies, such as energy storage.

On September 22, 2011, the Commission opened Rulemaking (R.) 11-09-011 to "address the key policy and technical issues essential to timely, non-discriminatory, cost-effective and transparent interconnection." During the course of that proceeding, the Commission adopted three substantive decisions: Decision (D.) 12-09-018, D.14-12-035 and D.16-06-052. 

On September 20, 2012, the Commission issued D.12-09-018, which adopted a settlement agreement focused on the interconnection study process.  The settlement agreement required that each utility revise its Rule 21 to assign all interconnection requests to either the "Fast Track" - a screen-based, streamlined review process for net energy metering, non-export, and small exporting facilities - or the "Detailed Study" process for more complicated generating facilities.

On December 18, 2014, the Commission issued D.14-12-035, which adopted revisions to Rule 21 to require "smart" inverters for Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and San Diego Gas & Electric Company (SDG&E).  D.14-12-035 adopted the revisions recommended by the Smart Inverter Working Group in its January 2014 report "Recommendations for Updating the Technical Requirements for Inverters in Distributed Energy Resources." 

On June 23, 2016, the Commission issued D.16-06-052, which enhanced the Rule 21 Pre-Application Report, created a Unit Cost Guide, enhanced the behind-the-meter storage interconnection process, and established a pilot program to institute a cost certainty envelope for interconnections triggering a distribution upgrade.

Despite the significant progress made in R.11-09-011, additional improvements to Rule 21 are needed. On July 13, 2017, the Commission issued an Order Instituting Rulemaking to Consider Streamlining Interconnection of Distributed Energy Resources and Improvements to Rule 21. Among the principal topics to be considered in the new rulemaking (R.17-07-007) is the incorporation into Rule 21 of the utilities' Integration Capacity Analysis (ICA) tools, currently under development in the Distribution Resources Plan (DRP) proceeding (R.14-08-013).  The ICA tools use power flow analysis to determine the ability of a circuit to host distributed energy resources.  Incorporating the ICA tools into Rule 21 may better inform interconnection siting decisions and further streamline the Fast Track process for certain projects.

Contact Us

For utility-specific interconnection inquires, please contact the relevant utility using the contact information found on the utility's interconnection website.

For inquiries regarding interconnection disputes and the Interconnection Discussion Forum, please contact Reese Rogers, Regulatory Analyst, at Reese.Rogers@cpuc.ca.gov.

For inquires regarding smart inverters, please contact Justin Regnier, Senior Utilities Engineer -- Supervisor, at Justin.Regnier@cpuc.ca.gov

For all other interconnection-related inquiries, please contact Brian Korpics, Regulatory Analyst, at brian.korpics@cpuc.ca.gov.

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