Jim: Here's the DG stuff from the Hertzberg letter ***************************************************************************= 8  Key Barriers to the Development of Distributed Generation and Proposals to= =20 Remove the Barriers  Barrier:  Excessive and Unnecessary Utility Stand-by Charges  Solution The executive orders issued by the Governor on February 14th took a step in= =20 the right direction, but don=01,t go nearly far enough.
Utility stand-by= =20 charges have always been designed by the utilities to protect their monopol= y=20 position, extract monopoly prices from customers, or both.
They must be=20 eliminated for all distributed generation applications.
There is no reason= =20 to limit the elimination of these charges to generation facilities that are= =20 less than 1MW.
These limits will only lengthen unnecessarily the time it= =20 takes for California to close the significant gap between supply and demand= =20 and reduce the risk of black outs this summer.=20  The provisions of SB27X eliminating stand-by charges were stripped from the= =20 bill.
This will likely thwart any attempts to encourage the near-term=20 development of distributed generation and reduce the severe supply-demand= =20 imbalance in California.
The language eliminating stand-by charges should be re-inserted into SB27X= =20 and modified to remove all caps on plant size.=20 =20 Barrier: Excessive delays and costs related to interconnecting facilities= =20 with investor-owned and municipal utilities  Solution:  =20 The Governor=01,s executive order regarding interconnection is a step in th= e=20 right direction=01*D-D-26-01 requires utilities to complete interconnection= =20 studies within 7 days.
California should ensure that this requirement=20 applies to all generation facilities, including distributed generation.
In= =20 addition, the financial conflicts the utilities face when interconnecting= =20 generation facilities are simply too powerful to overcome through executive= =20 orders or other regulations.
=20  To the greatest extent possible, California should shift control over=20 interconnection away from the utility and place that control with the=20 California ISO.
This could be accomplished through amendments to SB 27X.
Barrier:  Permitting and Air Quality Issues Developers of distributed (i.e., =01&on-site=018) generation that is 50 MWs=  or=20 greater must receive certification from the California Energy Commission an= d=20 therefore face all of the impediments to development that large-scale=20 generation faces.
=20  Solution:=20 California should ensure that the executive orders (D-22-01 thru D-26-01)= =20 issued by the Governor to expedite plant siting and maximize plant output= =20 apply equally to smaller scale, =01&distributed generation=018 facilities.
= In=20 addition, distributed generation that is less than 50 MWs continues to face= =20 local opposition.
The State should ensure that local, parochial interests= =20 cannot block otherwise beneficial distributed generation projects.
=20  These objectives could be accomplished through amendments to SB27X.

DG Impediments
Jim: Here's the DG stuff from the Hertzberg letter ***************************************************************************= <NUMBER> Key Barriers to the Development of Distributed Generation and Proposals to= =<NUMBER> Remove the Barriers Barrier: Excessive and Unnecessary Utility Stand-by Charges Solution The executive orders issued by the Governor on February 00th took a step in= =<NUMBER> the right direction, but don=<NUMBER>,t go nearly far enough.
Utility stand-by= =<NUMBER> charges have always been designed by the utilities to protect their monopol= y=<NUMBER> position, extract monopoly prices from customers, or both.
They must be=<NUMBER> eliminated for all distributed generation applications.
There is no reason= =<NUMBER> to limit the elimination of these charges to generation facilities that are= =<NUMBER> less than 0MW.
These limits will only lengthen unnecessarily the time it= =<NUMBER> takes for California to close the significant gap between supply and demand= =<NUMBER> and reduce the risk of black outs this summer.=<NUMBER> The provisions of SB00X eliminating stand-by charges were stripped from the= =<NUMBER> bill.
This will likely thwart any attempts to encourage the near-term=<NUMBER> development of distributed generation and reduce the severe supply-demand= =<NUMBER> imbalance in California.
The language eliminating stand-by charges should be re-inserted into SB00X= =<NUMBER> and modified to remove all caps on plant size.=<NUMBER> =<NUMBER> Barrier: Excessive delays and costs related to interconnecting facilities= =<NUMBER> with investor-owned and municipal utilities Solution: =<NUMBER> The Governor=<NUMBER>,s executive order regarding interconnection is a step in th= e=<NUMBER> right direction=<NUMBER>*D-D-<NUMBER>-<NUMBER> requires utilities to complete interconnection= =<NUMBER> studies within <NUMBER> days.
California should ensure that this requirement=<NUMBER> applies to all generation facilities, including distributed generation.
In= =<NUMBER> addition, the financial conflicts the utilities face when interconnecting= =<NUMBER> generation facilities are simply too powerful to overcome through executive= =<NUMBER> orders or other regulations.
=<NUMBER> To the greatest extent possible, California should shift control over=<NUMBER> interconnection away from the utility and place that control with the=<NUMBER> California ISO.
This could be accomplished through amendments to SB 00X.
Barrier: Permitting and Air Quality Issues Developers of distributed (i.e., =<NUMBER>&on-site=<NUMBER>) generation that is <NUMBER> MWs= or=<NUMBER> greater must receive certification from the California Energy Commission an= d=<NUMBER> therefore face all of the impediments to development that large-scale=<NUMBER> generation faces.
=<NUMBER> Solution:=<NUMBER> California should ensure that the executive orders (D-<NUMBER>-<NUMBER> thru D-<NUMBER>-<NUMBER>)= =<NUMBER> issued by the Governor to expedite plant siting and maximize plant output= =<NUMBER> apply equally to smaller scale, =<NUMBER>&distributed generation=<NUMBER> facilities.
= In=<NUMBER> addition, distributed generation that is less than <NUMBER> MWs continues to face= =<NUMBER> local opposition.
The State should ensure that local, parochial interests= =<NUMBER> cannot block otherwise beneficial distributed generation projects.
=<NUMBER> These objectives could be accomplished through amendments to SB00X.
barriers development distributed reduce severe ensure executive orders expedite hertzberg letter number california energy commission 0mw limits stand charges inserted jim dg stuff plant size