1. Confidential Draft
2012 PG&E Wholesale Distribution Tariff (WDT) Generator Interconnection Procedures (GIP) Changes
Electric Generation Interconnection
William Chung – Principal

2. Definitions FERC Interconnections CPUC Interconnections
Applies to all voltage levels of interconnection if the generator is selling energy exported to the utility grid
Except generators under CPUC jurisdiction listed in the CPUC Section below
Interconnection is completed pursuant to the following:
Transmission voltage (60 kV and above): CAISO Tariff
Distribution voltage (below 60 kV): PG&E Wholesale Distribution Tariff (WDT)
Rates for any load or standby power are governed by CPUC jurisdictional PG&E tariffs even for FERC jurisdictional interconnection projects (i.e. Standby Tariff)
CPUC Interconnections
Applies to interconnection if the generator is one of the following:
Self Generation (all voltage levels):
Onsite generation that serves on-site or over the fence load only
Net-Energy Metering (NEM)
Exporting generation (distribution voltage only):
New Qualifying Facilities (QFs) selling all their exports to the grid to their serving utility under a PURPA PPA (i.e. Standard Offer, AB1613, SB32)
New Transmission interconnected QFs will interconnect under the CAISO process
Grandfathered QFs selling under PURPA PPAs may continue under Rule 21 interconnections at either Distribution or Transmission
Interconnection is completed pursuant to Electric Rule 21
Rates for any load or standby power is governed by CPUC jurisdictional PG&E tariffs

3. WDT Update
PG&E filed on December 3rd an amendment to PG&E’s Wholesale Distribution Tariff (WDT). Please see link below for the transmittal and filing.
Title: Amendment to WD Tariff: Generator Interconnection Procedures
File Date: 12/3/2012 Docket : ER
Electronic Link:
Amended WDT Effective Date pending FERC approval: 12/4/2012
Amended WDT Link:
Amended Rule 21 Effective Date: 9/20/2012
Amended Rule 21 Link:
These changes were made to conform WDT with the amended Rule 21 for Queue generators (Queue generators are exporting generators and Rule 21 non-NEM generators) following these guiding principles:
Fair and Consistent Queue management
PG&E’s public Queue contains both WDT and non-NEM Rule 21 interconnection requests and the amended WDT results in an identical procedure to process interconnection requests
Eliminate policy driven differences between the WDT and Rule 21 except for limited cases such as:
WDT Fast Track Process is at actual costs vs. Rule 21 which has some fixed fees
Allow for easy transition between WDT and Rule 21
Rule 21 is limited to eligible Generating Facilities that enter into PURPA PPAs and as a result, Rule 21 Interconnection Requests should be allowed to transition to WDT if PURPA PPA not obtained
Allow Rule 21 Interconnection Requests that fail Screens Q & R (a.k.a. Electrical Independence Test) to use the WDT Cluster Study Process and transition back to Rule 21 post study

4. WDT Changes – Part 1
The following pages outline the various changes made in PG&E’s WDT Amendment:
General Changes:
Improved clarity on applicability of the WDT
Matched application processing fee (previously only study deposits)
Eliminated 3 out of 6 security posting mechanisms
Clarified when interest is paid on customer funds for studies/reviews
Added language in SGIA to state the Network Upgrades shall be refunded pursuant to the CAISO tariff
Conformed Queue process (did not match Queue posting requirement language)
Did not add Pre-Application Report and process (The Pre-Application Report is available to all customers)
Expanded the Annual Deliverability Assessment to allow Rule 21 generators to participate
Allows Rule 21 generators that fail the Electrical Independence Test to utilize the WDT Cluster Study Process and opt for a Rule 21 GIA post study
Allows Rule 21 generators that fail to maintain eligibility to interconnect under Rule 21 to enter the WDT procedures

5. WDT Changes – Part 2 Fast Track Changes:
Fast Track Review Process Alignment
Matched the 20BD timeline for Supplemental Review (from 10BD)
Matched the process for Initial Review and Supplemental Review Results Meetings
Added the non-binding cost estimate milestone and timelines
Eliminated the optional facilities study
Matched the IA process and timelines
Independent Study Process Changes:
Matched study deposit structure for projects less than 5MW
$10k for SIS and $15k for FAS (previously $50k + $1k/MW up to $250k)
Matched 1st posting deadline of 60CD (previously 30CD)
Matched the IA process and timelines (can tender IA after Results Meetings if held)
Cluster Study Process Changes:
Rule 21 projects may apply for Cluster but opt out of WDT after study
Study deposit structure remained the same (Currently no Cluster Study Process under Rule 21)

6. Remaining Differences
General:
Rule 21 has a Pre-Application Process. All customers can elect the Rule 21 Pre-Application Process and submit an interconnection request under Rule 21 or WDT.
Rule 21 has detailed Queue Posting requirements. PG&E will post the same information for WDT projects.
Fast Track:
Rule 21 Fast Track is limited to 3MW. WDT has discretionary limits and exceeding these limits will likely result in Fast Track screen failures.
Rule 21 Fast Track is open to all interconnection requests 3MW or less. WDT is limited to certified generators (however Rule 21 has a screen for certified generators).
Rule 21 Fast Track includes detailed Supplemental Review process and screens information in the tariff language. As business practice, PG&E will apply the same process and screens for WDT projects as well (100% min load is an example).

7. Appendix
The following slides provide more information on the various changes made to the WDT
PG&E is updating the following to address these changes found at
PG&E’s online application under WDT
WDT process overviews
WDT FAQs
For questions on the WDT changes and how to submit an interconnection request, please contact
Similarly for Rule 21, please contact

8. Overview of Study Paths
Fast Track Process
Screening process to allow for a quick path for proposed generators that do not require detailed study
Up to 3MW for Rule 21 (or limit export)
Up to 5MW for WDT and limited to certified generators
Independent Study Process
Serial study process for proposed generators that are not in a location common to other interconnection requests under study
Cluster Study Process
Group study process for proposed generators that are in a location common to other interconnection requests under study

9. Overview of Study Paths
Eligibility
Studies
Timelines
Process Costs
Deliverability Option
Fast Track
Rule 21: less than 3MW (or limit export)
WDT: Certified, Advisory limit of 2MW on 12kV and 3MW on 21kV
Initial Review (IR) & Supplemental Review (SR)
IR – 10 BD
SR – 20 BD
$800 Application Fee include IR, $2500 SR fee
Rule 21: Nonrefundable fee
WDT: Actual cost post study
Energy Only
Independent Study Process
Must pass EIT
Rule 21: no size limit but, given current programs, rare to exceed 20MW
WDT: no size limit
System Impact Study (SIS) & Facilities Study (FAS)
SIS – 60 BD
FAS – 60 BD
For 5MW or less: SIS - $10K deposit and FAS - $15K deposit
All else: $50K + $1K/MW up to $250K
Rule 21: Energy Only
WDT: Energy Only or Full Capacity
Cluster Study Process
Rule 21: Go to WDT
Phase I Study & Phase II Study
Phase I – 134 CD
Phase II – 196 CD
$50K + $1K/MW up to $250K
Rule 21: Go to FERC process

10. Fast Track Review Process and Changes
Characteristic
Rule 21
WDT
Changes to WDT
Size Limit
3MW (or limit export)
5MW (2MW on 12kV, 3MW on 21kV, 5MW on higher voltages
No change
Eligibility
Any technology
Certified technology
Studies or Reviews
Initial Review (IR) & Supplemental Review (SR)
Eliminated the Optional Facilities Study
Initial Fee or Deposit (actual cost)
$800 App Fee covers IR, $2500 SR Fee
SET FEE
$800 App Fee toward IR, SR Deposit (amount not specified in tariff)
ACTUAL COSTS
Add $800 IR deposit and change practice to collect $2500 for SR
IR Timeline
15 BD
No Change
SR Timeline
20 BD
Change from 10 BD to 20 BD
IR Screens
13 Screens
10 Screens
SR Screens
3 Screens plus failed screens. 100% min load screen vs. 15% peak load (proxy for 50% min load)
failed screens
No Change to Tariff but will change practice to evaluate 100% min load

11. Additional Changes to Fast Track
Results Meetings
Changed Options Meeting to Optional Initial Review Results Meeting
Added Optional Supplemental Review Results Meeting
Non-Binding Cost Estimate
Added a 15 BD non-binding cost estimate process for projects that pass Initial Review or Supplemental Review but require Interconnection Facilities or minor Distribution Upgrades
Contract
Changed process similar to ISP except the 90CD deadline is triggered by issuance of the draft GIA
Maintained SGIA (Rule 21 has a Fast Track IA but very similar to SGIA)

12. Independent Study Process and Changes
Characteristic
Rule 21
WDT
Changes to WDT
Size Limit
None (Rare over 20MW)
None
No change
Eligibility
Any technology
Pass EIT
Studies or Reviews
System Impact Study (SIS) & Facilities Study (FAS)
Deposit (actual cost)
For 5MW or less: $10K for SIS and $15K for FAS
All else, $50K + $1K/MW up to $250K
Added the 5MW or less difference
SIS Timeline
60 BD
No Change
1st Posting
60 CD after SIS
Change from 30 CD to 60 CD
FAS Timeline
2nd Posting
120 CD after FAS
IA timeline
Tender 30 CD after study or Results Meeting
Execute by 90 CD after study
Change to allow tendering of IA after results meeting

13. Cluster Study Process and Changes
Characteristic
Rule 21
WDT
Changes to WDT
Size Limit
Not Applicable
None
No change
Eligibility
Any technology
Studies or Reviews
Phase I and Phase II
Deposit (actual cost)
$50K + $1K/MW up to $250K
Phase I Timeline
134 CD start June 1
No Change
1st Posting
90 CD after Phase I
196 CD start Jan 15
2nd Posting
180 CD after FAS
IA timeline
Tender 30 CD after study or Results Meeting
Execute by 90 CD after study
Change to allow tendering of IA after results meeting