Washington Commission Approves PSE Interconnection Tariff

The Washington Utility and Transportation Commission (Washington Commission) approved a new interconnection tariff for Puget Sound Energy (PSE). PSE’s new tariff is only available to state jurisdictional qualifying facilities (QFs) interconnecting and selling power to PSE under the Public Utility Regulatory Policies Act (PURPA), and provides a third, lower cost option for interconnection service. 

While interconnection service options under the Federal Energy Regulatory Commission’s pro forma interconnection procedures are simplified into the binary options of Network Resource Interconnection Service (NRIS) or Energy Resource Interconnection Service (ERIS), PSE’s proposed new tariff offers a practical and feasible third option. With this option, if PSE has adequate available transmission capacity for a given QF’s interconnection, then PSE will allow that QF to choose limited curtailments as an alternative to paying for “full network service upgrades.” PSE allows the QF to choose which type of network service upgrades it wishes. This new option for interconnection customers will be Schedule 153, which will also allow a QF to agree to a limited curtailment of their power delivery to the system during a System Emergency or a reliability condition in return for not having to pay for full network service upgrades in order to keep the QF’s interconnection costs manageable.

The docket was opened in October 2021 and saw involvement from both the Northwest & Intermountain Power Producers Coalition (NIPPC) and the Renewable Energy Coalition (REC). The parties filed joint comments recognizing that PSE’s proposal for an optional, lower quality network interconnection service as a constructive and creative proposal that may likely resolve many interconnection related disputes. The parties, however, challenged PSE’s tariff on the grounds that it could require interconnecting QFs to still have to pay for certain network upgrades that provide energy and capacity benefits to the entire system, rather than just the interconnecting customer. The Washington Commission Staff concluded that this tariff does not address the issue of cost responsibility for network upgrades and that it would be most appropriate to address interconnection cost reimbursement through an individual complaint filed by a QF. The Commission Staff stated that this would allow the Commission to consider the specific facts of a particular case. Ultimately, NIPPC and REC supported the Staff recommendation, and the Commission, at the December 23 Open Meeting, decided to take no action, which meant the tariff took effect on January 1, 2022, by operation of law.

Sanger Law, PC represented NIPPC and REC in this proceeding.

NIPPC represents electricity market participants in the Pacific Northwest, including independent power producers, electricity service suppliers, and transmission companies. NIPPC is committed to facilitating cost-effective electricity sales, offering consumers choices in their energy supply, and advancing fair, competitive power markets.

REC advocates for reasonable PURPA and interconnection policies on behalf of renewable QFs located in in Oregon, Idaho, Montana, Utah, Washington, and Wyoming.


These materials are intended to as informational and are not to be considered legal advice or legal opinion, nor do they create a lawyer-client relationship. Information included about previous case results does not assure a similar future result.