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Interconnection Best Practices

Interconnection Best Practices. MA Interconnection Working Group Plenary #4 July 12, 2012. What does IREC do?. Expand customer access to distributed energy resources 501(c)(3) – no lobbying !! Funding – U.S. Department of Energy, Energy Foundation & Others Interconnection Efforts

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Interconnection Best Practices

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  1. Interconnection Best Practices MA Interconnection Working Group Plenary #4 July 12, 2012

  2. What does IREC do? • Expand customer access to distributed energy resources • 501(c)(3) – no lobbying!! • Funding – U.S. Department of Energy, Energy Foundation & Others • Interconnection Efforts • Currently active: CA, HI, MA, NJ, WA & FERC • Prior work: AK, FL, IA, IL, ME, NC, NM, TX, UT, VA, VT, WV • Developed model rules for interconnection (adopted in ME) • Co-author of annual Freeing the Grid publication • Reports for Solar America Board for Codes and Standards: • Comparison of Four Leading Small Generator Interconnection Standards • Utility External Disconnect Switch Report • Updated Recommendations for Federal Energy Regulatory Commission Small Generator Interconnection Procedures

  3. Reasons for Interconnection Procedure Reform • Higher volumes of interconnection requests • Higher penetrations of distributed generation • New distributed generation programs

  4. SEPA’s 2011 Utility Solar Rankings Report • In 2011, utilities interconnected over 62,500 PV systems • To put this in perspective, about 350 non-solar power plants (> 1 MW) were expected across the entire U.S. in 2011 • Conservative forecasts indicate that this number will grow to more than 150,000 interconnections in 2015

  5. Annual Installed PV Capacity by Sector

  6. Problems with CA Rule 21 • Designed for net metered and non-export systems (primarily serve onsite load) • Exporting generators fail fast track screens • Supplemental review is not transparent • Study process is poorly defined • No deadlines for utility or developers • Inadequate access to information about potential points of interconnection

  7. Overview • Meeting interconnection Timeframes • Pre-Application Feasibility • Initial Review/Supplemental Review • Distribution Group Study Process • Q&A

  8. Meeting Interconnection Timeframes • PROBLEM: Projects that don’t move forward, but don’t drop out, hold up projects further back in line. • Particularly problematic when project sizes, interconnection application volumes and penetration levels increase • Increases interdependencies between projects • Inability to move forward on later-queued projects until earlier-queued project studies are completed • Utilities in California estimated as long as 7 year wait to clear backlog • Extending deadlines does not address problem of clearing backlog • Additional utility staffing may address some issues related to processing high volume, but doesn’t allow tandem study of interrelated projects

  9. Meeting Interconnection Timeframes SOLUTIONS: 1) Use technical screens to avoid study of projects with no or low impacts; 2) Place timelines on developers and utilities throughout the process; 3) Require deposits and security postings earlier in the process; 4) Develop group study processes to jointly study projects with interdependencies; and 5) Pre-screen distribution circuits

  10. Meeting Interconnection Timeframes • APPROACH: • CA and HI: Aim to reduce number of applications by providing more information to developers in advance – discussion will follow • CA and HI: Created more detailed initial screening process – discussion will follow • CA and HI: Added more defined supplemental review process (a little more time to review, focusing on reasons for screen failure) – discussion will follow • CA: Each step in interconnection process is time bound – party has specific timeframe to complete step (attempted to incorporate realistic timeframes) • CA: Opportunity for developers to request a single, time-bound extension

  11. Meeting Interconnection Timeframes • APPROACH (continued): • CA: If developer does not request an extension or does not complete step on time, application is deemed withdrawn • CA: Required deposits and security postings earlier in the process • CA: Developing group study approach to jointly study projects with interdependencies – discussion will follow • HI: Pre-screening distribution circuits to identify penetration levels that can be accommodated without costly upgrades (Sacramento Municipal Utility District used this approach for its feed-in tariff)

  12. Pre-Application Feasibility • PROBLEM: Many speculative applications filed by developers who are trying to identify feasible, low cost places to interconnect projects. • Occurring in states with wholesale and community renewables programs, where developers have a choice of site selection • Speculative applications clog the interconnection process and slow down the review of projects further back in the queue • Developers may file several applications for same projects or portions of projects on nearby parcels looking to see how much capacity can be developed before upgrades are needed • Creates interdependence between projects, which undermines utility’s ability to study requests in tandem (must study serially or in group)

  13. Pre-Application Feasibility SOLUTIONS: 1) Reduce the number of speculative applications by providing developers more information prior to the filing of a formal application; and 2) Impose application requirements

  14. Pre-Application Feasibility • APPROACH: • CA and HI: Developed mapping tools that provide general information (see next slide for Hawaii example) • CA: Proposed pre-application report to provide predefined information not contained on maps • CA and HI: Imposed application requirements (e.g. building permits, site control, or payment in lieu of site control)

  15. Pre-Application Feasibility Penetration levels on Oahu

  16. Pre-Application Feasibility • PROPOSED CA RULE 21 Pre-APPLICATION REPORT: • Report, not a meeting (no back-and-forth discussion) • Only pre-existing information (see pp. 24-25 of tariff, pp. 94-95 of PDF) • $300 fee for a report • Provides more up to date information than mapping tools (reduces pressure on utilities to keep maps fully up to date) • Provides more granular data (reduces the level of detailed information that needs to be provided on the maps) • Information provided may change prior to application being submitted • Confidentiality issues can be addressed by NDA (data provided in reports is typically provided in interconnection studies or when screen results are provided anyway)

  17. Initial Review/Supplemental Review • PROBLEM: Initial technical review screens are necessarily conservative, but not every project that fails these screens requires a full study. • Initial review screens are intended to identify projects with very low probability of impacts to safety and reliability • Projects that fail these screens may need additional review to determine potential impacts – but full study is not necessarily required

  18. Initial Review/Supplemental Review SOLUTIONS: 1) Bring initial review screens up to date; and 2) Provide a more robust supplemental review process to allow projects that only needed limited review to avoid full study process

  19. Initial Review/Supplemental Review • APPROACH: • HI: Increased 10% peak load initial review screen to 15% of peak, but added California screen for line configuration that allows utility to address temporary overvoltage concerns above 10% peak load penetration for three-phase, four-wire configurations to ensure generators with this transformer interface are appropriately grounded) • HI: Added supplemental review process to allow projects that contribute to penetration level less than 50% of minimum load, or that fail line configuration screen, to pass on supplemental review without full study. Currently being reevaluation to possibly increase to 100% of minimum load. • HI: Kauai: Projects less than 80-90% of minimum load allowed to pass on supplemental review.

  20. Initial Review/Supplemental Review • APPROACH: • CA: Added several new initial review screens and adopted a detailed supplemental review process • CA: 3 Supplemental review screens • 1) Penetration Screen (100% minimum load measured when generator is expected to be online) • 2) Power Quality and Voltage Tests • 3) Safety and Reliability Tests • NJ: Understand utilities typically screen projects up to 100% of minimum load using supplemental review

  21. Distribution Group Study Process • PROBLEM: As volume of interconnection applications and penetration level of distributed energy resources increase, projects are increasingly interrelated in a way that makes tandem study or serial study of projects impractical • Serial study process allows no mechanism to share costs for upgrades that may be required to accommodate multiple proposed generators

  22. Distribution Group Study Process • SOLUTION: Create a distribution group study process that allows utility to study interrelated projects together in a group and allocate costs of study and required upgrades across group members. • May lower overall cost of studying multiple generators

  23. Distribution Group Study Process • APPROACH: • Determine approach to determine who gets studied in a group • Determine when a study window closes and a group study moves forward • Develop mechanism to allocate costs across members of the group • Address reallocation of costs in case of dropouts • Address potential need for restudy

  24. Questions? www.irecusa.org Erica Schroeder eschroeder@kfwlaw.com

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