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Qualifying Facilities Conversion

A Qualifying Facility (QF) is a generating facility which meets the requirements for QF status under the Public Utility Regulatory Policies Act of 1978 (PURPA) and the Federal Energy Regulatory Commission (FERC) Regulations (18 C.F.R. Part 292), and meets certification and registration requirements for QF status.

In 1983, the California Public Utilities Commission (CPUC) encouraged QF development by establishing a “standard offer” power purchase contracts that utilities were required to accept from QFs. Today, about 200 legacy QF projects, representing about 4,500 megawatts of generating capacity (enough to serve 4 million homes) are currently on-line within SCE’s service territory.

The standard offer contracts of these legacy QFs are starting to reach the end of their terms, and as such, new power purchase agreements are replacing the original contracts for the projects that want to remain operating. The terms of the “standard offer” contracts that legacy QFs entered into contain provisions that provided for interconnection to SCE’s electric system. With the expiration of these contracts, the need to replace the terms of the interconnection services with a current interconnection agreement is evident.

In today’s market structure, new power purchase agreements do not contain terms for interconnection service as such service is typically provided under interconnection tariffs that did not exist when the original QF contracts were executed. Thus, SCE has the obligation to provide the owners of existing legacy QF contracts a mechanism to replace the original terms of interconnection with new interconnection agreements under the appropriate jurisdiction. The process of obtaining the new interconnection agreement for legacy QFs is known as a “QF conversion”, or simply a “conversion”.

If you are a QF owner that would like to renew your interconnection agreement, SCE's Grid Interconnection and Contract Development (GICD) team can help you manage the interconnection process. We recommend initiating the required steps for conversion approximately 12 months before you would expect to terminate your existing QF PPA.

Following the submittal of the application package, SCE’s assigned project manager will coordinate the review of the information provided with the application; an assigned engineer will perform a validation of the technical data as well. Once the application package is deemed complete and valid, SCE will perform a substantial change test.

Substantial Change Determination. SCE will perform a substantial change test using the information and the technical data provided by the QF customer, along with any data for the QF held by SCE, to make a determination on whether substantial changes to the QF were made or will be made. It is the customer’s responsibility to provide the data requested by SCE to enable SCE to make such determination. At any point during the review, SCE reserves the right to request additional information, schedule meetings to exchange or discuss facts about the facility, or perform any other reviews or activities (which may include a site visit to the facility) to allow SCE reach a determination on whether substantial changes to the QF were made or will be made. Failure by the QF customer to provide information for SCE to complete the substantial change test may significantly delay SCE’s substantial change determination and SCE may stop working on the conversion request until the requested information is provided.

In addition, SCE will make a determination whether a facilities assessment of the existing interconnection facilities associated with the QF is needed to determine any upgrades necessary to allow for the safe and reliable operation of the QF while meeting the requirements of SCE’s Interconnection Handbook.

In performing these reviews, SCE will use reasonable engineering judgment to arrive at any pertinent determination on substantial change or current compliance of the QF’s interconnection facilities with the current Interconnection Handbook (see link above).

Determination of the Conversion Capacity. Following the determination that there are no substantial changes to the QF, SCE will perform an evaluation of the capacity eligible for QF conversion. The determination of the conversion capacity requires the evaluation of two numbers: (1) the total operating capacity (otherwise referred to as “rated capacity”) of the converting QF, and (2) the net export capacity from the QF that can be injected into SCE’s electric system.

When the QF operating capacity is greater than its net export capacity, the QF customer must demonstrate that the facility has the controls and protection scheme needed to ensure that the amount of energy injected into SCE’s electric system does not exceed the approved net export capacity.

Interconnection Agreement. Following the determination of the approved conversion capacity for the QF, at the request of the QF customer, SCE will provide a draft interconnection agreement (GIA). Once SCE provides a draft GIA, SCE and the customer will begin negotiations to complete the GIA under the guidelines provided in the applicable interconnection tariff for executing an interconnection agreement.

Distribution Service. QF projects connecting to SCE’s distribution system (either through the WDAT or the Rule 21), are required to obtain “Distribution Service” with SCE. “Distribution Service” allows the customer to be able to use SCE’s distribution system to “transport” their energy from the point of interconnection with SCE’s electric system to the CAISO system (where most power sales are expected to be delivered and settled in accordance with the CAISO market rules).

Expose as Block
No

DISCLAIMER: The guidelines in this section are provided with the intent to help SCE’s customers understand SCE’s Interconnection Procedures. However, in the case of discrepancies with SCE’s rules, such tariffs and regulations will prevail.