Presentation to the Massachusetts DG Collaborative Gene Shlatz

1. Comparison of State and Federal Standard Distributed Generation Interconnection Agreements Presentation to the Massachusetts DG Collaborative Gene Shlatz November12, 2002

2. Presentation Overview • Summarize Interconnection Standards for States Where Enacted or Proposed • Includes FERC and NARUC Model Agreement • Compare These Standards to Those Proposed by Mass. Utilities • Identify Potential “Best Practices”

3. Standards and Procedures Reviewed • DG Classification • Thresholds • Expedited Application & Review • Radial & Network Systems • Cost Responsibility • Dispute Resolution • Interconnection Requirements

4. Interconnection Standards Reviewed • Texas PUCT – Distributed Generation Interconnection Manual (May 2002) {Co-Funded by DOE Office of Energy Efficiency & Renewable Energy} • New York PSC – Standardized Interconnection Requirements, Application Process . . . For New DG 300kVA and Less (November 2000) • California PUCTRulemaking, Rule 21 Model Tariff Language (Decision Issued December 2000) • FERC ANOPR – Standardization of Small Generator Interconnection Agreements and Procedures (August 2002) • NARUC – Model Distributed Generation Interconnection Procedures and Agreement (July 2002) • Specific Ratings and Thresholds Not Provided in Model Agreement • IEEE P1547 – Draft Standard for Interconnecting Distributed Resources with Electric Power Systems (Draft 10, Issued August 2002)

5. DG Classification • Massachusetts:5 Levels • Up to 10kW, 10kW to 60kW, 60kW to 300kW, 300kW to 1 MW, 1MW and Greater • Texas PUCT:2 Levels • Up to 300kW, 300kW to 10MW • No Provision for DG > 10MW • New York PSC:1 Level • Up to 300kW • Standard Agreement Does Not Address DG >300kW or Networks • California PUCT:2 Levels • Small: Up to 11kVA Large: Above 11kVA • FERC ANOPR:2 Levels • Small: Up to 2MW Large: 2MW to 20MW

6. Application Fees • Application Fees

7. Thresholds and Timeframes for Expedited Processing of Applications • Radial Systems

8. Thresholds and Timeframes for Expedited Processing of Applications • Network Systems

9. Cost Responsibility • Application Fees – Some States Require Fees; Others do Not Indicate if Fees Apply (See Prior Slides) • Study Fees – Most States Impose Fees for DG’s That do Not Meet Fast Track or Expedited Review Criteria • Texas Waives Fees if Certain Criteria Are Met • Several States Waive Fee Where Net Metering Applies • California Has 3-Level Fee Structure: Initial; Supplemental & Detailed. • Initial and Supplemental Review Fees (Calif.) Are Capped ($800 & $600) • Upgrades/Credits – Not Addressed in Most States • California: Cost Allocation Issues Will be Addressed in Next Phase; Total Cost Borne by Applicant should be Reduced by Distribution Cost Allocation • Texas; Utility Must Assess DG Benefits to System if Upgrades Required • FERC ; Transmission Rates Includes Credit for Reflect Network Upgrades • Operation & Maintenance – Not Addressed in Most States • California Places Obligation for Future O&M on DG Customer

10. Dispute Resolution

11. Interconnection Requirements