Existing law requires the Public Utilities Commission to enforce rules governing the extension of service by electrical corporations, as specified.

This bill would require the commission, no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporations distribution interconnection queue and for the prioritization of customer service connections, including the prioritization of projects that are shovel-ready, in the final stage before commencing construction, as determined by the commission.

Under existing law, a violation of the Public Utilities Act or any order, decision, rule, direction, demand, or requirement of the commission is a crime.

Because the provisions of this bill would be a part of the act and because a violation of an order, decision, rule, direction, demand, or requirement of the commission implementing its requirements would therefore be a crime, the bill would impose a state-mandated local program by creating a new crime.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law requires the Public Utilities Commission to enforce rules governing the extension of service by electrical corporations, as specified.

This bill would require the commission commission, no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporations distribution interconnection queue and for the prioritization of customer service connections, including that the project is the prioritization of projects that are shovel-ready, as determined by the commission.

Under existing law, a violation of the Public Utilities Act or any order, decision, rule, direction, demand, or requirement of the commission is a crime.

Because the provisions of this bill would be a part of the act and because a violation of an order, decision, rule, direction, demand, or requirement of the commission implementing its requirements would therefore be a crime, the bill would impose a state-mandated local program by creating a new crime.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law requires the Public Utilities Commission to enforce rules governing the extension of service by electrical corporations, as specified.

This bill would require the commission to provide guidance to electrical corporations for the prioritization of interconnection projects, projects in each electrical corporations distribution interconnection queue and customer service connections, including that the project is shovel-ready, as determined by the commission.

Under existing law, a violation of the Public Utilities Act or any order, decision, rule, direction, demand, or requirement of the commission is a crime.

Because the provisions of this bill would be a part of the act and because a violation of an order, decision, rule, direction, demand, or requirement of the commission implementing its requirements would therefore be a crime, the bill would impose a state-mandated local program by creating a new crime.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law requires the Public Utilities Commission, by December 31, 2020, in an existing proceeding, to establish strategies and quantifiable metrics to maximize the use of feasible and cost-effective electric vehicle grid integration by January 1, 2030, as specified. Existing law requires electrical corporations to provide to the commission certain information relating to the electric vehicle integration strategies. Commission to enforce rules governing the extension of service by electrical corporations, as specified.

This bill would require each electrical corporation to develop an electric vehicle service energization timeline to ensure that customers with electric vehicle charging infrastructure are connected to the electrical grid within 125 business days. the commission to provide guidance to electrical corporations for the prioritization of interconnection projects, including that the project is shovel-ready, as determined by the commission.

Under existing law, a violation of the Public Utilities Act or any order, decision, rule, direction, demand, or requirement of the commission is a crime.

Because the provisions of this bill would be a part of the act and because a violation of an order or decision order, decision, rule, direction, demand, or requirement of the commission implementing its requirements would therefore be a crime, the bill would impose a state-mandated local program by creating a new crime.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law vests the Public Utilities Commission with regulatory authority over public utilities, including electrical corporations. Existing law requires the commission to annually report certain information to the Legislature, including a systemwide assessment of delays to interconnection or transmission approvals for eligible renewable energy resources or energy storage resources.

This bill would declare the Legislatures intent to enact subsequent legislation regarding the interconnection of electrical corporations.

SENATE COMMITTEE ON

Senator Anthony Portantino, Chair

2023 - 2024 Regular Session

AB 1293 (Irwin) - Interconnection: prioritization

Bill Summary:

This bill would require the California Public Utilities Commission (CPUC), no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporation’s distribution interconnection queue and for the prioritization of customer service connections.

Fiscal Impact:

• The CPUC estimates ongoing costs of about $652,000 annually (ratepayer funds) for rulemaking to develop guidelines for prioritization of projects in the interconnection queue and in the customer service connections, including the roles, responsibilities, timelines, and processes to follow for such prioritization.

Background:

Rules for connecting new buildings and resources to the electric distribution grid are generally governed by statute, CPUC rules, and tariffs for each electrical corporation. New service connections refer to extending electricity lines or distribution infrastructure to service new or expanded customer load, known as "energization." Electric Tariff Rules 15 and 16 set guidelines for design, cost allocation, and responsibilities between project applicants and utilities for electric distribution line extensions.

Connecting to the larger electrical system can take months or even years due to needed designs, cost assessments, and other issues. For new building developments, the need for electric service extensions may occur in phases over months or years, depending on the development size.

There is a growing backlog of utility energization projects due to increased demand for new connections and upgrades, driven by policies to deploy more electric vehicles, transition from natural gas to electricity in buildings, and increase the housing supply. These projects often require upgrades to the electric distribution system. Moreover, supply shortages and challenges resulting from the COVID-19 pandemic, including including shortages of electrical equipment like transformers, slowed or stalled projects to connect new customers and expand energy load. Delays have been particularly severe within the Pacific Gas & Electric (PG&E) service territory, where the backlog for energization projects has significantly increased. PG&E is attempting to better manage their project queue and has established a monthly Technical Committee work group to address technical and field issues, provide updates on improvement actions, and collect feedback from stakeholders. Nevertheless, the backlog remains a growing frustration for project developers, customers, local governments, and others awaiting energization.

To address energization timing, the CPUC issued Resolution E-5247 in December 2022 in response to a proposal from the electric IOUs. This resolution establishes an interim 125-business day average service energization timeline for projects under the EV Infrastructure Rules, excluding specific cases. The resolution directs the electric IOUs to collect one year of EV Infrastructure Rule implementation data to inform a proposal for a permanent service energization timeline.

Additionally, Load and Generation Integration Capacity Analysis (ICA) Maps provide data to help contractors and developers identify project sites with available capacity to interconnect new distributed energy resources. Each of the three largest electric IOUs host a public data portal with these maps.

Proposed Law:

This bill would require the CPUC, no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporation’s distribution interconnection queue and for the prioritization of customer service connections, including the prioritization of projects that are in the final stage before commencing construction, as determined by the CPUC.

Related Legislation:

AB 50 (Wood, 2023) would propose policies to help address challenges related to connecting new customers or need to upgrade capacity for customers of electric IOUs.

AB 643 (Berman, 2023) would have allowed the CPUC to impose fines for electrical corporations that routinely violate established interconnection timelines, and consider negligent exceedance of the timeline as a violation of CPUC rules subject to a maximum $100,000 penalty per offense. The bill was held in the Assembly Committee on Appropriations.

AB 1482 (Gabriel, 2023) would have established an average service energization time for electric vehicle charging infrastructure of 125 business days for electric publicly owned utilities (POUs), and would require POUs to annually report certain information to the CEC regarding the service energization time for electric vehicle charging infrastructure projects. It would additionally require the CPUC and the CEC, in consultation with electric IOUs and POUs, to jointly host an annual public workshop to review and evaluate the information submitted and to revise, if needed, the average service energization time for EV charging infrastructure. The bill was held in the Assembly Committee on Appropriations.

SB 83 (Wiener, 2023) would have required the CPUC to establish time periods for electric IOUs to connect energization projects to the electrical distribution system. Additionally, would have required electric IOUs to compensate development projects for failing to meet the deadline. The bill was held in this committee.

SB 410 (Becker, 2023) would require the CPUC to maximum and average time periods for energization projects and requires the CPUC to authorize a mechanism to allow electric IOUs to recover costs from energization projects between general rate case proceedings.

AB 1026 (Wood, Chapter 446, Statutes of 2019) required an electrical or gas corporation to apply only construction and design specifications, standards, terms, and conditions that are applicable to a new extension of service project for the 18 months following the date the application for a new extension of service project is approved. It also authorized an electrical or gas corporation to adopt modifications, as specified, of the construction and design specifications, standards, terms, and conditions of a new extension of service project.

-- END --

SENATE COMMITTEE ON ENERGY, UTILITIES AND COMMUNICATIONS

Senator Steven Bradford, Chair

2023 - 2024 Regular

Bill No: AB 1293 Hearing Date: 7/3/2023

SUBJECT: Interconnection: prioritization

DIGEST: This bill requires the California Public Utilities Commission (CPUC), no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporation’s distribution interconnection queue and for the prioritization of customer service connections.

ANALYSIS:

Existing law:

1. Establishes and vests the CPUC with regulatory authority over public utilities, including electrical corporations. (Article XII of the California Constitution)
2. Authorizes the CPUC to establish an expedited distribution grid interconnection dispute resolution process, with the goal of resolving disputes over interconnection applications within the jurisdiction of the CPUC in no more than 60 days from the time the dispute is formally brought to the CPUC. (Public Utilities Code §769.5)
3. Requires an electrical corporation to permit any new or existing customer who applies for an extension of service from that electrical corporation to install an electric extension in accordance with the regulations of the CPUC and any applicable specifications of that electrical corporation. (Public Utilities Code §783)
4. Establishes guidelines for the design, cost allocation, and responsibilities of a project applicant and a utility for electric distribution line extensions necessary to furnish permanent electric service. (Electric Rule 15)
5. Establishes guidelines for the design, cost allocation, and responsibilities of a project applicant and a utility for the extension of electric service from an investor-owned utility (IOU) distribution line. (Electric Rule 16)
6. The CPUC has issued and revised Electric Tariff Rule 21 establishing operational and metering requirements for a generation or storage facility to be interconnected to an electrical corporation’s distribution grid. (Electric Rule 21)

This bill requires the CPUC, no later than January 1, 2025, to provide guidance to electrical corporations for the prioritization of projects in each electrical corporation’s distribution interconnection queue and for the prioritization of customer service connections, including the prioritization of projects that are shovel-ready, as determined by the CPUC.

Background

Connecting to the electric distribution grid. Rules governing the ability of new buildings and generation and storage resources to connect to the electric distribution grid are generally determined by statute, CPUC rules, and tariffs, (i.e., document that specify rates, charges, rules, and conditions under which an electrical corporation will provide services to the public) for each of the electrical corporations. These service connections include:

Interconnections, which generally refers to the interaction of physical connection of an energy generation or storage device to the electric distribution system that is either in front of the meter or behind-the-meter. Interconnection is a defined term in utility tariff rules that generally describes an electric utility’s physical connection to an external source of power.

Electric Tariff Rule 21 is a tariff that describes the interconnection, operating and metering requirements for generation facilities to be connected to an electrical utility’s distribution system. The tariff provides customers who would like 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 electrical corporation is responsible for administration of the rule in its service territory and maintains its own version of the tariff.

New service connections refers to extending an electricity line or expanding distribution infrastructure to service new or expanded customer load, known as “energization.”  

Electric Tariff Rule 15 (Distribution Line Extensions) relates to distribution line extensions. Specifically, new distribution facilities that are a continuation of, or branch from, the nearest available existing permanent distribution line (including any facility rearrangements and relocations necessary to accommodate the extension) to the point of connection of the last service. Rule 15 generally pertains to electric distribution grid equipment used by multiple customers, for example, a transformer serving multiple homes.

Electric Tariff Rule 16 (Service Line Extensions) relates to service line extensions. The overhead and underground primary or secondary facilities (including but not limited to utility-owned service facilities and applicant owned service facilities) extending from the point of connection at the distribution line to the service delivery point. Rule 16 generally pertains to network equipment used by just one customer.

Electric Tariff Rules 15 and 16 establish the guidelines for design, cost allocation, and responsibilities of a project applicant and a utility for electric distribution line extensions. The ability to connect to the larger electrical system can take months (if not, years, in some cases) as the process can entail the need for designs, assessments on costs allocations associated with improvements on the electric distribution system to allow for the connection, and other issues. In the case of new building developments, depending on the size of the development, the need for electric service extensions may be needed in phases over months, or years.

Growing backlog of utility energization projects. The demands for new service connections and/or upgrades to existing distribution lines have been increasing, especially as California advances policies to deploy more electric vehicles, shift natural gas usages to electricity in buildings, and increase housing supply, including affordable housing. These projects all rely on access to the electric utility grid and, often require upgrades to the electric distribution system. Additionally, growing use of distributed energy resources behind and in front of the meter require connecting to the electric distribution grid. Moreover, the COVID-19 pandemic has created supply shortages and challenges affecting many sectors of the economy, including supply shortages for electrical equipment needed to connect new customers or expand energy load, such as transformers. Delays and challenges have been especially acute within the Pacific Gas & Electric (PG&E) service territory as the backlog for energization and interconnection projects has grown substantially and delays have increased. The utility has acknowledged the growing backlog of identified capacity work that has delayed – sometimes by years – the in-service dates for new business customers. PG&E has shared that it is attempting to better manage their queue for projects. The utility recently formed a monthly Technical Committee work group with representatives from their labor partners, California Building Industry Association, and regional building association staff and members to work on all technical and field issues. These monthly meetings are used to provide updates on the actions underway to improve the new service connection process, the impacts of those actions and next steps. Additionally, these meetings are used to collaborate and collect feedback on the improvement efforts and to address emerging areas of concern or interest. Nonetheless, the backlog is a growing frustration for the project developers, customers, local governments, and others waiting to have their projects energized.

CPUC adopts resolution to address energization timing. In response to a proposal from the electric IOUs, the CPUC issued Resolution E-5247 in December 2022, which establishes an interim 125-business day average service energization timeline for projects taking service under the EV Infrastructure Rules. This timeline excludes projects that must go through Rule 15 for distribution upgrades, projects above two megawatts, and projects that require upgrades to a substation. The resolution directs the IOUs to collect one year of Electric Vehicle (EV) Infrastructure Rule implementation data to inform an updated proposal for a permanent service energization timeline.

Comments

Need for this bill? As the state adopts policies that require reductions in greenhouse gas emissions, including requirements to shift fossil fuels applications to electrification of transportation and other uses, there is a growing demand to connect to the electric distribution grid. As noted above, PG&E has a growing backlog of projects that need energization, and other utilities may face similar backlogs with growing demand. This bill requires the CPUC to provide guidance regarding the prioritization of projects awaiting to connect to the electrical grid. Such guidance could be useful, but should be tempered by the flexibility needed to address growing demands and fairness of the various project applications queues.

Amendments needed. The author and committee may wish to amend this bill to remove the language stating “shovel ready” and replace with “in the final stage prior to construction,” as determined by the CPUC.

Prior/Related Legislation

AB 50 (Wood, 2023) proposes policies to help address challenges related to connecting new customers or need to upgrade capacity for customers of electric IOUs. The bill is pending before this committee.

AB 643 (Berman, 2023) would have allowed the CPUC to impose fines for electrical corporations that routinely violate established interconnection timelines, and consider negligent exceedance of the timeline as a violation of CPUC rules subject to a maximum $100,000 penalty per offense. The bill was held in the Assembly Committee on Appropriations on May 18, 2023.

AB 1482 (Gabriel, 2023) would have established an average service energization time for electric vehicle charging infrastructure of 125 business days for electric publicly owned utilities (POUs), and would require POUs to annually report certain information to the CEC regarding the service energization time for electric vehicle charging infrastructure projects. It would additionally require the CPUC and the CEC, in consultation with electric IOUs and POUs, to jointly host an annual public workshop to review and evaluate the information submitted and to revise, if needed, the average service energization time for EV charging infrastructure. The bill was held in the Assembly Committee on Appropriations.

SB 83 (Wiener, 2023) would have required the CPUC to establish time periods for electric IOUs to connect energization projects to the electrical distribution system. Additionally, would have required electric IOUs to compensate development projects for failing to meet the deadline. The bill was held in the Senate Committee on Appropriations.

SB 410 (Becker, 2023) requires the CPUC to maximum and average time periods for energization projects and requires the CPUC to authorize a mechanism to allow electric IOUs to recover costs from energization projects between general rate case proceedings. The bill is pending in the Assembly Committee on Utilities and Energy.

AB 1026 (Wood, Chapter 446, Statutes of 2019) required an electrical or gas corporation to apply only construction and design specifications, standards, terms, and conditions that are applicable to a new extension of service project for the 18 months following the date the application for a new extension of service project is approved. Authorizes an electrical or gas corporation to adopt modifications, as specified, of the construction and design specifications, standards, terms, and conditions of a new extension of service project. The bill is pending in this committee.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: Yes

SUPPORT:

Clean Power Campaign

OPPOSITION:

None received

ARGUMENTS IN SUPPORT: According to the author:

California will not be able to meet its clean energy and climate change goals if developers cannot get interconnected to the grid fast enough. AB 1293 would help solve interconnection delays by prioritizing shovel ready projects.

-- END --

Date of Hearing: May 17, 2023

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Chris Holden, Chair

ABPCA Bill Id:AB 1293

Author:(Irwin) – As Amended Ver:May 1, 2023

Urgency: No State Mandated Local Program: Yes Reimbursable: No

SUMMARY:

This bill requires the California Public Utilities Commission (CPUC) provide guidance to electrical corporations for the prioritization of projects in each electrical corporation’s distribution interconnection queue and customer service connections, including that the project is “shovel-ready,” as determined by the CPUC.

FISCAL EFFECT:

The CPUC contends existing processes governing how each utility prioritizes projects in its interconnection queue already moves shovel-ready projects ahead of over projects that are not ready for construction. Therefore, CPUC anticipates no costs as a result of this bill.

COMMENTS:

1. Background. Broadly speaking, interconnection refers to establish a physical connection between an electricity generation source and an electrical utility’s distribution grid.

Interconnections to utilities under the jurisdiction of the CPUC are governed by the CPUC’s Electric Rule 21, which the CPUC describes as:

a tariff that describes the interconnection, operating and metering requirements for certain generating and storage facilities seeking to connect to the electric 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.

Rule 21 applies to large generation sources, as well as generally smaller distributed generation facilities, such as rooftop solar systems. The CPUC notes that 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).

The author asserts it takes utilities too long to interconnect projects and “California will not be able to meet its clean energy and climate change goals if developers cannot get interconnected to the grid fast enough.”

1. Related Legislation. AB 50 (Wood) requires CPUC to determine the criteria for timely energization for electric customers. AB 50 is pending is this committee.

AB 643 (Berman) directs the CPUC to commence consideration of adopting mechanisms for distributed renewable generation interconnections to enforce timelines, reduce administrative burden and provide transparency and certainty to customer. AB 643 is pending in this committee.

AB 1482 (Gabriel) would establish an average service energization time for electric vehicle charging infrastructure of 125 business days for publicly-owned utilities (POUs), and would require POUs to annually report certain information to the CEC regarding the service energization time for electric vehicle charging infrastructure projects. The bill is pending before this committee.

Analysis Prepared by: Jay Dickenson / APPR. / (916) 319-2081

Date of Hearing: April 26, 2023

ASSEMBLY COMMITTEE ON UTILITIES AND ENERGY

Eduardo Garcia, Chair

ABPCA Bill Id:AB 1293 (

Author:Irwin) – As Amended Ver:April 17, 2023

SUBJECT: Interconnection: prioritization

Requires the California Public Utilities Commission (CPUC) to provide guidance to investor-owned utilities (IOUs) for the prioritization of interconnection projects, including that the project is shovel-ready, as determined by the CPUC.

EXISTING LAW:

1. Authorizes the CPUC to establish an expedited distribution grid interconnection dispute resolution process with the goal of resolving disputes over interconnection applications within the jurisdiction of the CPUC in no more than 60 days from the time the dispute is formally brought to the CPUC. (Public Utilities Code § 769.5)
2. Requires an IOU to permit any new or existing customer who applies for an extension of service from that IOU to install a gas or electric extension in accordance with the regulations of the commission and any applicable specifications of that electrical or gas corporation. (Public Utilities Code § 783)
3. Limits the application of state and local building standards to those in effect on the date an application for a building permit is submitted to a local building department. (Health & Safety Code § 18938.5)
   
4. Requires that a local building permit remain valid for 12 months after it is issued, if the work on the site is commenced within 12 months; allows a permittee to apply for extensions. (Health & Safety Code § 18938.6)
5. Establishes guidelines for the design, cost allocation, and responsibilities of a project applicant and a utility for electric distribution line extensions necessary to furnish permanent electric service. (Electric Rule 15)
6. Establishes guidelines for the design, cost allocation, and responsibilities of a project applicant and a utility for the extension of electric service from an IOU distribution line. (Electric Rule 16)

FISCAL EFFECT: Unknown. This bill is keyed fiscal and will be referred to the Committee on Appropriations for its review.

BACKGROUND:

IOUs and Interconnection – California’s IOUs build, own, and manage most of the transmission and distribution that serves their customers. Consequently, the IOUs play an integral role in interconnecting new generation and battery resources, which are generally owned by merchant developers. These interconnection projects are split into two queues: the distribution interconnection queues, which are operated by the individual IOUs, or the transmission interconnection queue, which is operated by the California Independent System Operator (CAISO) but also involves the utilities. Which of the two queues a project enters is determined by the desired interconnection voltage level of the project. Projects exceeding a specific voltage threshold, set by whichever IOU covers the territory that the project is sited in, are routed into the transmission queue and shepherded through the process by CAISO.^[1]

Figure 1- The Parallel Interconnection Queues for Transmission and Distribution-level Projects.^[2]

Connecting to the Transmission Grid – The interconnection process is largely guided by an agreement between the utility, the merchant developer, and CAISO after the completion of interconnection studies conducted by CAISO. The timeline for interconnection is based on the study results and is reflected within the interconnection agreement as the expected in-service date. After a resource has completed the study phases of the interconnection process, contracts must be signed, the resource must be modeled in the CAISO’s market systems, and metering and telemetry equipment will need to be installed before participation in the wholesale power market is allowed.^[3] The in-service date of a project can be affected by a wide variety of factors including permitting, engineering, procurement, and construction of generation and transmission.

National Efforts to Address Transmission Interconnection Delays – PJM, a regional transmission organization (RTO) which covers the Mid-Atlantic United States, recently received approval from the Federal Energy Regulatory Commission (FERC) for a plan to accelerate energization of new generation resources to the transmission grid by modifying the RTO’s interconnection queue.^[4] The PJM interconnection queue will move to a “first-ready, first-served” review process that groups proposals and assigns upgrade costs in clusters. While PJM clears out its pending backlog of interconnection requests, the grid operator won’t review new interconnection requests until early 2026. The plan includes a transition phase that will prioritize half of the pending projects, introduces a “fast-lane” process for projects to help clear the existing backlog, and will impose new requirements, such as “readiness deposits,” that aim to remove more speculative projects from the queue.

Connecting to the Distribution Grid – Rules governing the ability of new buildings, electricity generation, and storage resources to connect to the electric distribution grid are generally determined by statute, CPUC rules, and tariffs^[5] for each of the IOUs. These service connections include:

• Interconnections, which generally refer to the interaction of physical connection of an energy generation or storage device to the electric distribution system that is either in front of the meter or behind-the-meter. Interconnection is a defined term in utility tariff rules that generally describe an electric utility’s physical connection to an external source of power. The interconnection process of generation resources is largely structured by Electric Tariff Rule 21.^[6]
• New service connections, also known as “energization”, involve extending an electricity line or expanding distribution infrastructure to service new or expanded customer load. Energizations are subject to provisions specified in Electric Tariff Rule 15 and Electric Tariff Rule 16.

Talking Tariffs – Electric Tariff Rule 21 describes the interconnection, operating, and metering requirements for generation facilities to be connected to an electrical utility’s distribution system. The tariff provides customers who would like to install generating or storage facilities on their premises with access to the electric grid while protecting the safety and reliability of the electric grid at the local and system levels. Each IOU is responsible for administration of the rule in its service territory and maintains its own version of the tariff.^[7]

Electric Tariff Rule 15 relates to distribution line extensions. Specifically, new distribution facilities that are a continuation of, or branch from, the nearest available existing permanent distribution line (including any facility rearrangements and relocations necessary to accommodate the extension) to the point of connection of the last service. Rule 15 generally pertains to electric distribution grid equipment used by multiple customers, for example, a transformer serving multiple homes.

Electric Tariff Rule 16 relates to service line extensions. The overhead and underground primary or secondary facilities (including but not limited to utility-owned service facilities and applicant owned service facilities) extending from the point of connection at the distribution line to the service delivery point. Rule 16 generally pertains to network equipment used by just one customer.

Electric Tariff Rules 15 and 16 establish the guidelines for design, cost allocation, and responsibilities of a project applicant and a utility for electric distribution line extensions. The ability to connect to the larger electrical system can take months (or years, in some cases) as the process can require designs and assessments on cost allocations associated with improvements on the electric distribution system to allow for the connection, among other issues. In the case of new building developments, electric service extensions may be required in phases over the span of months or years, depending on the size of the development.

Timelines for Electric Lines – The demands for new service connections and/or upgrades to existing distribution lines have been increasing, especially as California advances policies to deploy more infrastructure to charge electric vehicles, shift from natural gas to electricity in buildings, and increase the housing supply.^[8] These projects all rely on access to the electrical grid and often require upgrades to the distribution system. Additionally, the COVID-19 pandemic has created supply shortages and challenges affecting many sectors of the economy, including limiting access to electrical equipment needed to connect new customers or expand energy load, such as transformers.^[9]

The challenges have been especially acute within the Pacific Gas & Electric (PG&E) service territory as the backlog for energization projects has grown substantially and delays have increased.^[10],[11] The utility company has acknowledged the growing backlog of identified capacity work that has delayed, sometimes by years, the in-service dates for new business customers. PG&E has taken steps to attempt to better manage their project queue. The utility recently formed a technical committee, led by representatives from labor groups and regional building association members, to work on technical issues in the interconnection process, evaluate the impact of recent process changes, and determine next steps. Nonetheless, the backlog is a growing frustration for the utility, project developers, customers, and others waiting to have their projects energized.

Efforts to Address Energization Delays – In response to a proposal from the IOUs, the CPUC issued Resolution E-5247 in December 2022, which establishes an interim 125-business day average timeline for the energization of projects under the EV Infrastructure Rules. This timeline excludes projects that must go through Rule 15 for distribution upgrades, projects above two megawatts, and projects that require upgrades to a substation, and applies only to EV infrastructure projects entering the queue. The CPUC cites lack of data as the rationale for setting an interim timeline requirement and directs the IOUs to collect one year of EV Infrastructure Rule implementation data to inform an updated proposal for a permanent service energization timeline.^[12]

COMMENTS:

1. Author’s Statement. “California will not be able to meet its clean energy and climate change goals if developers cannot get interconnected to the grid fast enough. AB 1293 would help solve interconnection delays by prioritizing shovel ready projects.”
2. Scratching the Surface. Energizations are generally a routine and core electric utility function. Unfortunately, the growing backlog of projects has led to frustrated customers, including affordable housing developers, local governments, and other customers which has sparked the desire for legislation. However, as the process to energize projects entails many factors and stakeholders, it can be challenging to pinpoint the causes for delay, or develop universal solutions when problems are very project specific. The proposed change in prioritization put forward by this bill does not attempt to resolve the underlying structural problems contributing to the pervasive delays in interconnection. However, in requiring the CPUC to provide guidance to the IOUs for prioritizing interconnection and energization projects, this bill may invite a larger discussion of existing problems and potential solutions with these delays.
3. Winners and Losers. Any prioritization of certain types of projects in a queue will likely lead to delays to other projects, as dollars and workers shift from one project type to another. The implementation of CPUC Resolution E-5247, as mentioned above to add a 125 business day project timeline to EV charger energizations, may shift the project queue to favor certain EV energization projects over other projects. Placing timeline requirements on a specific type of project, as this bill seeks to do in an unspecified manner, will likely divert resources from and lead to delays on other project types.

In the PJM case, where the priority was to clear out the substantial backlog of transmission interconnection requests in the queue, PJM indicated that it would cease review of new interconnection requests until early 2026. The “readiness deposits” required under the PJM queue reforms essentially raise the ante for projects to enter the queue. The implicit trade-off in that change is that more of the projects entering the queue will be closer to fully funded, and therefore more likely to proceed to completion, but the change may bias queue entry toward more readily funded types of projects or those backed by large corporations. The “shovel-ready” specification included in this bill may have a similar effect by giving preference to projects that meet a certain funding threshold or have already met certain permitting requirements. This may cause a surge in project completion but risks biasing the process toward projects which were most expedient to complete. The CPUC in providing guidance to the IOUs on prioritization, as well as defining what constitutes as “shovel-ready,” will need to be mindful of these potential pitfalls.

1. A Tale of Two Queues. The bill requires the CPUC to direct the IOUs to provide “prioritization of interconnection projects”. However, this language is broad enough to refer to both the distribution interconnection queues, which are operated by the individual IOUs, and the transmission interconnection queue, operated by CAISO. The author has expressed her desire to have the bill specific to distribution interconnection, but also inclusive of customer energization projects. As such, the author and committee may wish to consider amendments to specify that the bill applies to the IOU distribution interconnection queue and customer energization projects.
2. Related Legislation.

AB 50 (Wood) would require public utilities to furnish and maintain timely service, , require the CPUC to determine the criteria for timely service for electric customers that meets specified requirements, and, until the CPUC determines those criteria, would require each large electrical corporation to make a good faith effort to deliver electric service within 90 days of issuing a written commitment to serve for customers seeking a new connection or 30 days for upgrades to an existing connection. Status: set for hearing in this committee on April 26, 2023.

AB 1482 (Gabriel) would establish an average service energization time for electric vehicle charging infrastructure of 125 business days for publicly-owned utilities (POUs), and would require POUs to annually report certain information to the CEC regarding the service energization time for electric vehicle charging infrastructure projects. It would additionally require the CPUC and the CEC, in consultation with IOUs and POUs, to jointly host an annual public workshop to review and evaluate the information submitted and to revise, if needed, the average service energization time for EV charging infrastructure. Status: set for hearing in this committee on April 26, 2023.

SB 319 (McGuire) would require the CEC, CPUC, and CAISO to jointly develop and recommend an expedited permitting roadmap that describes timeframes and milestones for a coordinated, comprehensive, and efficient permitting process for electrical transmission infrastructure. Status: pending hearing in the Senate Committee on Energy, Utilities and Communications.

SB 83 (Wiener) requires electrical corporations to interconnect development projects to the electrical distribution system within eight weeks for projects defined as interconnection ready. Additionally, this bill requires electrical corporations to compensate development projects for failing to meet the deadline. Status: pending hearing in the Senate Committee on Energy, Utilities and Communications.

SB 410 (Becker) requires the CPUC to establish a working group to improve the ability of the electric IOUs to be informed of needed distribution capacity and requires the CPUC to establish time periods for interconnection projects and provides for cost recovery processes from ratepayers for these projects. Status: pending hearing in the Senate Committee on Appropriations, after passage in the Senate Committee on Energy, Utilities, and Communications on a 17-0-1 vote.

1. Prior Legislation.

AB 1026 (Wood) requires an electrical or gas corporation to apply only those construction and design specifications, standards, terms, and conditions that are applicable to a new extension of service project for the 18 months following the date the application for a new extension of service project is approved. Authorizes an electrical or gas corporation to adopt modifications, as specified, of the construction and design specifications, standards, terms, and conditions of a new extension of service project. Status: Chapter 446, Statutes of 2019.

AB 2861 (Ting) authorizes the CPUC to establish an expedited distribution grid interconnection dispute resolution process with the goal of resolving disputes over interconnection applications within the jurisdiction of the CPUC in no more than 60 days. Status: Chapter 672, Statutes of 2016.

SB 48 (Vuich) established rules governing the extension of service by gas and electrical corporations to new residential, commercial, agricultural, and industrial customers. Status: Chapter 1229, Statutes of 1983.

REGISTERED SUPPORT / OPPOSITION:

Support

None on file.

Opposition

None on file.

Analysis Prepared by: Samuel Mahanes / U. & E. / (916) 319-2083

1. California ISO; “​Getting started - exploring interconnection to the grid”; http://www.caiso.com/participate/Pages/ResourceInterconnectionGuide/default.aspx ↑

2. California ISO; “​Getting started - exploring interconnection to the grid”; http://www.caiso.com/participate/Pages/ResourceInterconnectionGuide/default.aspx ↑

3. California ISO; “​Getting started - exploring interconnection to the grid”; http://www.caiso.com/participate/Pages/ResourceInterconnectionGuide/default.aspx ↑

4. Utility Dive; “FERC approves PJM’s ‘first-ready, first-served’ interconnection reform plan, steps to clear backlog”; December 2022; https://www.utilitydive.com/news/ferc-pjm-interconnection-reform-plan-queue/637717/ ↑

5. Documents that specify rates, charges, rules, and conditions under which an IOU will provide service. ↑

6. CPUC; “Rule 21 Interconnection”; https://www.cpuc.ca.gov/rule21/ ↑

7. CPUC; “Rule 21 Interconnection”; https://www.cpuc.ca.gov/rule21/ ↑

8. California Energy Markets; “Interconnection Delays Disrupting Housing Markets, Causing 'Chaos'”; March 2023; https://www.newsdata.com/california_energy_markets/regional_roundup/interconnection-delays-disrupting-housing-markets-causing-chaos/article_a577776a-c4fc-11ed-9e15-5ffc130cbd98.html ↑

9. Bakersfield Californian; “Power connection work delays local development projects”; November 2022; https://www.bakersfield.com/news/power-connection-work-delays-local-development-projects/article_8bc9ed88-6d0f-11ed-b3ee-973f5213928a.html ↑

10. Fresno Bee; “California homes face PG&E delays for power connections. Frustrated leaders seek options”; October 2022; https://www.fresnobee.com/news/local/article267995517.html ↑

11. San Francisco Chronicle; “Big holdup for new Northern California housing? PG&E”; March 2023; https://www.sfchronicle.com/politics/article/california-housing-projects-pge-17828169.php ↑

12. ↑