Texas PUC Staff Seek Guidance on Increasing or Eliminating MW Cap in Defining Distributed Generation

Staff of the Public Utility Commission of Texas have sought guidance from the Commission whether the current 10 MW cap used to define distributed generation should be increased or eliminated from the rules governing distributed generation.

Staff's request came in a rulemaking addressing various distributed generation issues, including ownership of distributed renewable generation (DRG) by an entity other than the retail customer (Project 42532).

Staff noted that the current distributed generation (DG) rule applies only to a generation facility of 10 MW or less.

Some stakeholders have argued for elimination of the cap or a 20 MW cap, stating that the Federal Energy Regulatory Commission (FERC) guidelines for small generators allow for up to 20 MW for DG. While no stakeholders specifically opposed the elimination of this 10 MW cap, some urged caution and advised further study.

Additionally, Staff sought Commission guidance on whether the word "on-site" with regard to DG should be retained in the DG rule, and, if so, how should it be defined?

The current DG rule applies to "on-site distributed generation" and the term is defined as follows: "On-site distributed generation (or distributed generation) -- An electrical generating facility located at a customer's point of delivery (point of common coupling) of ten megawatts or less and connected at a distribution voltage less than 60 kilovolts (kV) which may be connected in parallel operation to the utility system." Some commenters stated that "on-site" should be eliminated from the rule, while others commented that it should be retained and defined in the rule.

Staff presented the following options to the Commission regarding these two issues:

(1) decide the issues in the instant rulemaking project;

(2) direct Staff to gather more information regarding the issues in a new project; or

(3) not address the issues at this time, with the option to address the issues in a new project in the future.