Consumers Energy Talking Points – Homework 6

1. Consumers Energy Talking Points – Homework 6 Theresa Martinez, Director, Distribution Agreements & Attachments June 20, 2019

2. Key Points Pre-Application Report Study Scope and Costs Material Modification Defined DER Output 1

3. Disclaimer Consumers Energy’s review of the MN DIP does not mean: • We have necessarily reviewed other referenced documents, or that we do or do not agree with those referenced documents. • Our comments on the assigned sections do not necessarily address those cross-references, which we will address at a later time. The fact that we comment or do not comment on particular provisions does not mean we will not have further input on those sections at a later time.  We have used best efforts to incorporate as much feedback as possible, but it is difficult to do as only partial/ individual sections of the MN DIP are reviewed. 2

4. Pre-Application Report Information concerning the utility system operating characteristics and location of system components. • Per MPSC Rule 20(1) • 2-hour technical consultation upon request • No cost to the Applicant Information needed from the Applicant • Location (coordinates or address of project) • Total project capacity (MW) • Type of generation Information provided by Consumers Energy • Information concerning the utility system operating characteristics and location of system components pertinent to the Applicant-submitted location and project capacity 3

5. Pre-Application Report Responses Examples of responses: Does not appear to be in Consumers Energy Electric territory Primary system voltage is 14.4/24.9 grounded wye from Substation A Approximately 2.2 miles from the substation Three-phase primary in the area Will require some primary system modifications Note: impacts to the system could vary greatly. These impacts will have to be studied to determine the feasibility of this interconnection to the LVD system. A new dedicated 46 kV line (approximately 2.2 miles or longer) and 46 kV substation upgrades would be required to connect X MW of generation at this location at a significant interconnection cost. An application and study would be required to determine feasibility of the interconnection. There is a 46 kV line adjacent to the coordinates given. Direct connection of X MW would be marginally feasible and would require application and study to confirm. Alternatively , a new dedicated 46 kV line, potentially Y miles or longer and 46 kV substation upgrades would be required to connect X MW of generation at this location at a significant interconnection cost, but would also require an application and study to confirm feasibility. 4

6. Study Scope System Impact and Facilities Study • The purpose of the studies • Within the Rules • The details on what to study to achieve that purpose • Utility discretion System Impact Study • Similar to the MPSC Engineering Review • Initial feasibility study, identification of distribution system upgrades, interconnection facilities and cost estimates Facilities Study • Similar to the MPSC Distribution System Study • In-depth confirmation of the feasibility study, distribution system upgrades, interconnection facilities and cost estimates 5

7. Study - Consumer Energy Reports Example study outline: Circuit Analysis • Steady State Voltage Analysis • Power Flow • Reactive Power Considerations • Short Circuit Duty Unbalanced System Conditions Technical Requirements • Isolating Transformer • Isolation Device • Interconnecting Lines • Substation • 46kV High Voltage Distribution System • Interconnection Protection Relaying • Direct Transfer Trip • Automatic Reclosing and Single-Phase Conditions • Prevention of Islanding • Telemetry and Disturbance Monitoring • Parallel Operation • Communication Circuits • Metering Connection Costs 6

8. Costs Consumers Energy Recommendation: • Pre-application Report, Processing, Screens and Study Costs • Review at intervals to determine non-refundable cost based on average actual completion costs • Pre-application report, processing and screens costs determination • Methodology approved by MPSC • Calculated costs updated and posted in Requirements or on public site • Review Costs • Methodology approved by MPSC • Calculated costs included in the review agreements • Distribution system upgrades – • Applicant responsible for estimated costs prior to construction • Estimates calculated based on best practices • May include contingency • Reconciliation with actual costs post construction • If actual costs are greater than estimated costs – Attacher pays Utility the remainder; if actual costs are less than estimated costs – Utility pays Attacher the remainder 7

9. Material Modification Material Modification: • Existing connected generation • Generator owner must apply through the interconnection process prior to making a material modification • Applications in-process • Any material modification will cause the application to be resubmitted and include the modification • Applicant must submit an updated application packet detailing the change along with payment so it can be reviewed by the Utility. • If the change is deemed to be material a new reference number will be created and the application will be processed as new. • If the change is deemed not to be material, the project will resume in its present stage. 8

10. Material Modification Defined Non-exhaustive list of material modification by Applicant: • Any change in total project size (increase or decrease) • Change in major equipment* • Change in interconnection point* • Change in protective equipment • Change in high-voltage collector system lengths/impedances • Change in the number or size of inverters *Any changes in major equipment or interconnection point will result in the project being reviewed for Material Change on a case-by-case basis. 9

11. DER Output There is a need for well defined standards • IEEE or U.L. Utility would need to monitor the output • One suggestion – Utility control 10

12. Thank you