Renewable natural gas developers have until October 23 to submit comments in a California Public Utilities Commission proceeding to assess how interconnection costs are affecting project economics.

The commission also directed the four large gas utilities in California to answer a series of questions that are in a ruling in proceeding R.13-02-008. The ruling can be found here.

The commission's review of utility renewable gas procurement plans has the potential to reshape the landscape for RNG projects in California, with direct implications for RNG project economics under California’s renewable gas standard.

The commission wants to understand how costs to connect projects to gas pipelines drive overall economics of RNG projects. It is focused on the cost and fee structures that influence project viability.

The current proceeding is an opportunity for RNG project developers to shape the regulatory record on cost drivers, transparency and potential reforms that could lower barriers to pipeline interconnection.

RNG developers should try to address seven topics in any comments they submit.

1. Utility questions. They should try responding to the utility questions and provide concrete data and examples to illuminate the real-world impacts of current interconnection practices and charges.

2. Cost benchmarking across jurisdictions. The commission is interested in how the interconnection costs charged by the four large California gas utilities compare to those in other states or under other pipeline operators.

3. Market barrier assessment. The commission wants input on whether California interconnection costs are a significant market barrier for RNG projects.

4. Potential CPUC actions to lower costs. The commission wants recommendations for how to lower interconnection costs.

5. Supervisory fees benchmarking. Developers should explain how supervisory fees in California compare to other states.

6. Supervisory fee reform. They should address whether the commission should take steps to reduce supervisory fees charged by the utilities and, if so, how.

7. Transparency and cost estimate detail. They should describe what level of transparency and detail is reasonable in an interconnection project cost estimate for an RNG project, including which cost elements should be clearly delineated and which may reasonably be kept aggregated or confidential.