Kansas Interconnection Implementation Workshop The FERC Process:

1. Kansas Interconnection Implementation Workshop The FERC Process: What it means for Kansas and other states Wichita, Kansas Oct. 1, 2003 Christopher CookInterstate Renewable Energy CouncilInterconnection and Net Metering SpecialistE3 Energy Services, LLCwww.E3Energy.com

2. Procedural History at the Federal Energy Regulatory Commission (FERC) • FERC ANOPR B Large and Small generators • Issued in October 2001 • Negotiations until Jan. 2002 • Parties filed consensus documents (including differences) Jan 11, 2002 • NOPR issued April 24,2002

3. FERC Generator Interconnection Rulemaking - Procedure • Original ANOPR suggested FERC wanted expedited procedures for small generation B set bar at 20MW • Parties achieved little consensus on small generator interconnection standards • Second ANOPR issued for small generators August 2002

4. FERC Generator Interconnection Rulemaking - Workgroups • Working groups started in September • Many meetings with utilities; small generator coalition; NARUC • Input from best technical sources in the country • Meetings went on till parties were sick of each other • Consensus document filed with FERC in Dec.

5. Small Generator ANOPR • Super Expedited (<2MW) very detailed guidelines • 2 Technical components • Protection on the generator • Impact on the Grid at the point of interconnection • Also includes fees; timing; procedure; standard form contract; application

6. Small Generator ANOPR (cont.) • Generator protection • Meets or exceeds all applicable IEEE, UL, and NEC requirements • UL Listed Generator System = plug and play • FERC registry of certified equipment

7. Small Generator ANOPR (cont.) • Grid impact • <15% of peak load • Limited fault current contribution • Limits on imbalances • 10 steps total

8. Small Generator ANOPR (cont.) • Secondary screens • Issue: should grid modifications be included or should the small generator have to accept the grid conditions as found • Cut-out • Small Gen proposal: $300 time and materials

9. Small Generator ANOPR B Non- technical • Fees (nc) • Free for <20kW • Graduated up to 2 MW • Max $700 • Anticipates average of three hours work and/or minor equipment change

10. Small Generator ANOPR B Non- technical • Timing • Most interconnections approved in 30 days • Disputes • Technical Master

11. FERC ANOPR B Technical Difficulties • Distribution networks • Found in large urban areas B where DG most valuable • Sensitive protection devices • Utilities would suggest no interconnected generators • Very small and those with no export should be fine

12. FERC Issued NOPR • Published in Federal Register Aug. 19, 2003 • Comments due Oct. 3, 2003 • Details are difficult to discern • Redundant and conflicting procedural guides • Fundamental misunderstanding of consensus documents • Bad parts for both sides B some items could be dangerous

13. FERC Interconnection Processes High or low voltage (69kV)? Low Generator Application >20MW? No Yes < 2MW High No Large Gen Full Application Process: Feasibility Impact Facilities Studies Yes < 10MW? Super Expedited Application Process Expedited Application Process Quick version of studies Interconnection Agreement

14. FERC NOPR Technical • Small Gen defined as those less than 20 MW (Orig. FERC position opposed by many) • Super Ex IP • 2MW and under low voltage (radial) only • 5% of peak load; spot network 5% or 50kW; 10% fault current; can’t exceed 85% short circuit ratings; 10MW total in stability limited areas; 3wire & 4wire configurations; 20kVA secondary limit; 20% imbalance on center taps

15. FERC NOPR Technical • Expedited (<10MW) • Same as Super Ex except 15% of peak load, • 90% of short circuit max • Seems to apply to failed Super Ex. as well • If passes screens but utility is nonetheless concerned, can send to feasibility study. If study finds no impact, utility pays for study.

16. Non-expedited small generator review • Feasibility Study (high level look --benefits generator before spending $ on Impact Study) • Impact Study BT&D (this costly study waived in most cases for small generators) • Facilities study (equipment) • These are expedited versions of the same for large generators

17. FERC NOPR Procedures • Single queue • TP must work with Affected Systems • Dispute Resolution B no FERC technical master • Costs - not defined but generator must pay • Insurance - same as Large Gens.

18. FERC NOPR Procedures (cont.) • Does not apply to incremental additions • Unlike PJM procedures

19. FERC ANOPR -Jurisdiction • Would apply to all FERC regulated generators • FERC defines as generator interconnecting to dual use low voltage facility (has some wholesale generation already on it) • Safe Harbor utilities would have to follow rule to preserve safe harbor

20. FERC NOPR gaps/contradictions • No transmission checks on 2-10MW on low voltage • No small low voltage procedures for area networks • Incentive to find impact • Different criteria used in titles

21. Commentary:Interconnection Policy • All interconnection rules to date focus on integrating DG without change to the grid • There is at present NO discussion in the regulatory arena about changing the grid to be more accommodating to DG • DG unlikely to attain lofty goals without a more deliberate debate on interconnection

22. That's all Folks...