On November 21, 2024, Pacific Gas & Electric Company (PG&E) filed an application at the California Public Utilities Commission (CPUC or Commission) seeking approval of a new Electric Rule No. 30 (Electric Rule 30) to address the interconnection of non-residential customers requesting retail electric service at transmission-level voltages between 50 kilovolts (kV) and 230 kV

Seth Hilton
Seth Hilton, a partner in Stoel Rives’ Energy Development group, focuses his practice on energy regulation and litigation, representing clients before a variety of energy regulatory agencies in California, including the California Public Utilities Commission and California Energy Commission, as well as in stakeholder proceedings at the California Independent System Operator. His clients include developers of thermal and renewable generation, energy storage developers, transmission developers, energy service providers, and investor-owned and publicly-owned utilities. Seth also represents energy clients in state and federal court and has significant experience in a wide variety of complex commercial litigation.
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CAISO Interconnection Process Enhancements Proposal Faces Protest at FERC
CAISO’s Interconnection Process Enhancements proposal faces protests from independent power producers, clean energy organizations, and renewable energy developers at FERC. Challengers claim that CAISO’s scoring criteria provide undue influence to load-serving entities (LSEs) and may violate principles of open access.
CAISO’s proposal addresses the backlog in its interconnection queue by prioritizing projects in zones with…
CAISO Releases Addendum to Interconnection Process Enhancements Final Proposal Ahead of Board of Governors Meeting
On Thursday, May 9, 2024, the California Independent System Operator (CAISO) issued an addendum to its Interconnection Process Enhancements (IPE) Track 2 Final Proposal, and issued a revised version of that addendum on May 17. Track 2 focuses on modifications to the interconnection and queue management processes to address the substantial interconnection request volumes in…
Stakeholders Express Concern That CAISO’s Interconnection Scoring Criteria May Prioritize Load-Serving Entity Selection
Background
The California Independent System Operator’s (CAISO) recently issued Interconnection Process Enhancements (IPE) final proposal[1] provides heightened requirements to complete an interconnection request and relies on scoring criteria to determine which projects advance to the interconnection study process. Due to the proposed 150% cap on specific interconnection zones, not all interconnection requests in each…
CAISO Releases Interconnection Process Enhancements Final Proposal
Summary
On March 29, 2024, the California Independent System Operator (CAISO) released the Track 2 final proposal for its Interconnection Process Enhancements (IPE) initiative. The proposed changes in the IPE proposal aim to address the “unprecedented and unsustainable interconnection request volumes” in the CAISO. CAISO proposes to adopt a zonal approach that prioritizes project interconnection in areas with existing or planned transmission capacity, to cap the number of projects permitted to proceed into the study process at 150% of the available and planned transmission capacity in specific zones, and adopt scoring criteria for eligibility and prioritization in the interconnection study process. Continue Reading CAISO Releases Interconnection Process Enhancements Final Proposal
California Public Utilities Commission Implements New Prevailing Wage Requirements for Large NEM Projects Seeking to Interconnect After December 31, 2023
On November 16, the California Public Utilities Commission (Commission) voted to adopt a decision resolving the remaining issues in the Net Energy Metering (NEM) proceeding. The decision, issued on November 22 as D.23-11-068, applies the net billing tariff concept adopted in D.22-12-56 to virtual net metering customers (VNEM) and aggregated NEM customers (NEMA), which…

Effective Immediately, California Energy Commission Jurisdiction Expands to Include Non-Thermal Projects Greater Than 50 MW
On June 30, 2022, California Governor Gavin Newsom signed Assembly Bill 205 (“AB 205”), which, among various other things, expands the siting jurisdiction of the California Energy Commission (“CEC”) to include non-thermal generating facilities, such as solar and wind projects, with a capacity of 50 megawatts (MW) or more. The CEC’s siting jurisdiction was previously…
The California Public Utilities Commission Issues Proposed Decision on New Resource Adequacy Framework
On May 20, 2022, the California Public Utilities Commission (CPUC or Commission) issued a proposed decision (PD) that would, among other things, adopt Southern California Edison’s (SCE) 24-hour-slice proposal as the new resource adequacy (RA) framework applicable to load-serving entities (LSEs) under the CPUC’s jurisdiction. Generally, the proposal would require each LSE to show that it has enough capacity to meet its specific gross-load profile, including a planning-reserve margin, or PRM, for all 24 hours for the “worst day” of each month. The “worst day” would be defined as the day of the month that has the highest coincident-peak-load forecast. This new RA framework would likely be implemented in 2025, with 2024 serving as a “test year” for the new framework.
The Commission initially began examining potential changes to its RA framework due to significant and ongoing changes in California’s generation-resource mix, with the increasing reliance on variable resources such as solar and wind, and use-limited resources, such as energy storage and demand response, as well as the retirement of older natural gas generation. The Commission solicited proposals for a new RA framework starting in 2020, and in 2021 it tentatively adopted Pacific Gas and Electric’s (PG&E) slice-of-day proposal in decision 21-07-014. The Commission ordered a series of workshops to further develop the proposal, culminating in a workshop report submitted March 1, 2022. During the workshops, two alternate proposals were developed: SCE’s 24-hour-slice proposal, and a two-slice proposal developed by Gridwell Consulting. The parties generally favored one of the two alternate proposals, rather than the PG&E slice-of-day proposal. The selection of SCE’s 24-hour-slice proposal will set the direction for further development of the new RA framework.
Continue Reading The California Public Utilities Commission Issues Proposed Decision on New Resource Adequacy Framework
California Energy Commission Discusses Draft Report on Offshore Wind
On May 18, 2022, the California Energy Commission met to discuss its draft report to evaluate and quantify the maximum feasible capacity of offshore wind to achieve reliability, ratepayer, employment, and decarbonization benefits and establish megawatt offshore wind planning goals for 2030 and 2045. The report is the first of three interim work products that California AB 525 directs CEC to prepare. By the end of this year, the CEC must complete and submit a preliminary assessment of economic benefits as they relate to seaport investments and workforce development needs, and complete and submit a permitting roadmap. The ultimate requirement of AB 525 is to require, by June 30, 2023, the CEC, in coordination with federal, state, and local agencies and a wide variety of stakeholders, to develop a strategic plan for offshore wind energy developments installed off the California coast in federal waters and submit it to the California Natural Resources Agency and the Legislature.Continue Reading California Energy Commission Discusses Draft Report on Offshore Wind
California Makes Progress Towards Ensuring Electric Reliability for Summer 2022
On January 11, 2022, the California Energy Commission (CEC) issued an update to its Summer 2022 Stack Analysis. Previously, on September 8, 2021, the CEC issued a revised Summer 2022 Stack Analysis that showed potential energy shortfalls ranging from 200 MW to 4,350 MW during the months of July through September 2022, in the evening…