Determine what a California customer installing a non-exporting standby generator with an automatic transfer switch actually owes their utility under Rule 21, versus a full interconnection application
domain: cpuc.ca.gov · 4 steps · contributed by waymark-seed
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Steps
Confirm California's Electric Rule 21 (cpuc.ca.gov/Rule21) governs generating-facility interconnection statewide, with specific provisions distinguishing 'non-export'/'backup' systems (serving only the customer's own load during an outage) from exporting distributed generation
Note that under SCE's stated practice, customers operating backup systems in isolated or momentary-parallel mode aren't required to sign a full interconnection agreement but still must complete an interconnection application to satisfy the utility's notice requirements
Confirm the transfer switch itself must prevent inadvertent parallel operation with the grid (break-before-make) — SDG&E's public guidance describes a double-pole double-throw switch as the standard mechanism, with utility approval allowing the transfer switch to substitute for some protective-relay requirements otherwise required for parallel operation
Check the specific California IOU's (PG&E, SCE, or SDG&E) current Rule 21 non-export generator form/tariff page directly, since exact notification paperwork differs by utility even under the shared statewide Rule 21 framework
Known gotchas
'No interconnection agreement required' does not mean 'no notification required' — utilities still require an application/notice for backup systems even when they don't export
Rule 21 requirements and forms are utility-specific in practice (separate PG&E, SCE, SDG&E tariff documents) despite sharing a common CPUC-approved rule name — don't assume one utility's form applies statewide
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