Presentation for Plenary Meeting #2 Wednesday June 13 th Current timeline issues

1. Presentation for Plenary Meeting #2 Wednesday June 13thCurrent timeline issues Mike Brigandi - NStar Cindy Janke - WMECo

2. Morning Presentation • Outline • Root Causes of Current Application Timelines – these were not captured in the KEMA report • Strategy for Deeper Dive/Streamlining internal process

3. Root Cause Overview • General Inquiries • Speculative applications • Multiple applications slated for same POI • Increasing complexity • Maturing applications • Customer delays in providing info • Stale applications • External factors • Program vs Process Activity • Unrealistic Timeframes/Expectations

4. Root causes of Current Timelines Applicant Inquiries for Interconnection without an Application • We receive Large # of customer RFI’s W/O App • Google Earth or Bing Liveview image marked up with their proposed location • We typically provide: Circuit voltage, Number of Phases • These inquiries can nonetheless take significant time to process. • The interconnection process requires an application with a one line diagram and a plot plan.

5. Root causes of Current Timelines “Speculative Applications" • About 20% of the applications received considered “speculative " • Minimal/No due diligence in preparing application • No inverter / generator specs. • "Plot plan" consists of a Hand Marked Google Earth image with a box drawn to show the PV array. • One Line diagram incomplete, may not agree with either the plot plan or the application. • No protection system drawings • In these cases, it is clear that the applicant has expended minimal effort and commitment searching for easy-to-interconnect sites and sends minimal information. • Sent back to the applicant for more complete information

6. Root causes of Current Timelines Multiple Applications in a Single Area • Several developers want to come online in a single region. • All applicants submitted full applications and paid application fees. • Applicants are queued • Each applicant’s interconnection study is interdependent and must await completion of the prior application in the queue • May take over three months, for example, to study 4th applicant in queue • Studying multiple n-1 contingencies further exacerbates this issue • Bottom Line here is in some cases job clock CAN NOT start with completed application acknowledgement because it may have to sit static in the queue for some time as prior studies are completed

7. Root causes of Current Timelines Engineering Complexities • DG interconnections over 1MW requires a recloser at PCC to disconnect DG during N-1 • Minimal DG recloser design requires • radio test to determine SCADA connectivity • Coordination of several engineering groups; C&P, Communication, SCADA, System Eng, Field End, Field Communication • Engineering solution may require additional construction at our station • Direct Transfer Trip scheme may be required • Synchronous Generators • Areas where no radio signal can be acquired • Adverse conditions during N-0 system configuration • Require Fiber infrastructure at site which may be complicated if region has none • Huge amount of coordination between both Utility and Customer, and internal groups at Utility

8. Root causes of Current Timelines • Maturing Pipeline of Applications • Large applications are just now starting to go through construction and interconnection phase of process • Significant amount of coordination required due to wide range of functions involved – this is done by the same group that processes applications • It’s a dynamic process…new issues typically encountered weekly

9. Root causes of Current Timelines Customer Info Required • DG process often is held up while information is required from the Customer • Complete set of stamped C&P drawings • Copy of settings and protection study • Lack of understanding leads to incomplete applications and slow turnaround of updated information • Often the Customer’s engineer is not able to provide the information needed in an expeditious manner, resulting in the overall project complete date being inevitably moved out.

10. Root causes of Current Timelines • Skill-set of Customer Engineers • Very few capable firms • Often Utility engineers are asked many fundamental questions • Working closely with the consultants takes up a significant amount of time • More meetings • More emails • More phone calls • Often customer consultants simply lack Utility and Power Engineering experience

11. Root causes of Current Timelines Projects “Dead on the Vine” • DG Customers often ask where the best places to interconnect • Currently no such information is directly available • This info would be very difficult to build and maintain. • Would take a significant effort and allocation of vital resources to create such a database • Would quickly become out of date because Utility system is constantly changing • Comprehensive system studies for each customer will remain as the only option for guaranteeing safe and reliable system for our customers. • Customers solution – submit many simultaneous applications intending to act on most lucrative • Result – many projects clogging up the DG pipeline with unknown or obsolete statuses. • Only rarely are irrelevant projects withdrawn proactively

12. Root causes of Current Timelines • External Factors • Permitting • Telephone company pole sets • Tree trimming • Applications 1 MW and above require further ISO-NE study, review and approval. • Applications 1 to 5 MW also requires additional document filed and approved by Reliability Committee (This can take up to 2 Months) • Applications > 5 MW require at least a level 2 I.3.9 application • Additional approvals • May take an additional 3 to 6 months for review and approval • Can not be filed until Interconnection Study Completed

13. Process vs. Program Activity • The staff involved in the processing of applications is generally the same staff that addresses all other aspects of the utility’s DG “program”. • Beyond processing of applications, the staff is involved in providing external and internal reports, conducting outreach sessions, updating website, assisting with billing resolution issues, and providing internal DG process training to name a few.

14. Strategy for a Deeper Dive • New work management processes are being put in place (e.g. NSTAR Passport, National Grid STORMS, etc.) • Can capture all aspects of the DG lifecycle cradle-to-grave • ‘Custom Info’ function will stop the clock any time there is a customer action item that needs to be addressed • Will assign accountability to all DG process members within Utility • Metric will be analyzed to determine strengths and weaknesses of all parts of the DG life cycle • Shortcomings of new process • May not alleviate any time constraint issues. The new process may shave off a few days by directly assigning people accountability but will not empower engineering to engineer any faster or solve any of the queuing and other issues that currently exist.

15. Strategy for a Deeper Dive • Review existing process to find areas of improvement • Should there be a fourth track for large IPPs? • How do we get a complete application? • How do we clean up the speculative applications? • What are basic technical requirements? • Is there another place or resource to answer questions? • How do we better coordinate with state agencies? • Can we set up some kind of certification for installers?

16. Strategy for a Deeper Dive • Need to address fundamental lack of experienced technical personnel on both sides (utility and customer) for volume of applications • Could work together to train outside contractors • Could approach technical colleges (i.e. Northeastern, MIT, WPI, etc.) to suggest an interconnection specialty in their power engineering programs • Additional research needed to address large intermittent generators on distribution feeders and other issues

17. FAQs from Customers • What is the interconnection process? • How do I apply/submit my application? • How long will it take? (What is current timeline for study? screening? construction?) • What is next step in the process? • Will projects gets kicked out for "real" projects? What is the timeframe to kick people out? • What is the cost and feasibility of the proposed site? • What do I need to do to limit my costs? • What will be consequences of proposing different generator/ inverter? Will my application start from the beginning? How long to restudy a different inverter?

18. FAQs from Customers • What voltage and how many phases are in this location • How large a system can we install? • How many other active DG are in the area? • How many other DG not completed have applied in the area? • How much will any upgrades cost? • What size is the Transformer and/or service? • What size is the conductor in the area? • Where is the nearest substation? • Can we install metering in the transformer? • Is this location on a spot or secondary area network? • How far is the nearest radial circuit from this location and how much will it cost to get it there?

19. FAQs from Customers – Net Metering • How do I fill out a Schedule Z? • Why does the Host Customer fill out/sign the form? • Why does the customer have to sign it? (developer/installer has signed for customer) • I'm the developer and want to control the Schedule Z, why can't I fill out the form? • I'm allocating, why do I have to give you the account info for the customers I'm allocating to? • Why did the NM rate change?   • Why don't you give me 90 cents per kwhr like in Europe? • Why can't I submit more than 2 Schedule Z's per year? • Can I transfer my credit balance? • Can I get a check for my credit balance? • Why do I need a production meter? • Why do I need to report my production to the utility? • What will be my Net Metering? • How come my first bill isn't right?

20. FAQs from Utilities • What are you looking to do? • What is the access to the site? • What inverter will you be using? Is this UL listed? • Please provide an updated one-line diagram with relay settings. • Please provide a clearer site diagram. • Please provide the requested information on the checklist. • What is the status of your project and how you would like to proceed. • What is your account number? Your name on the account does not match the application. • What is the AC side of the system? • What is your timeframes/construction schedule?