Draft Comments of a

The Pennsylvania Environmental Council ,, Before

I .._ The Pennsylvania Public Utility Commission

Regarding

. h - h I

Proposed Rulemaking Re Interconnection S'tandards A for Customer-generators pursuant to Section 5 of the .

Alternative Energy Portfolio Standards Act . ,, - 4

- II.

P.S Section 1648.5 .I

. r, i I. '1- I I b

April 25,2006 "' I

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The Pennsylvania bvimmmentetl Council (FEC) reviewed the Public Utility h n m k i u n (PUC) propod ruladchg on A l W t i v e Portfolio Stadads; Inknmmection Standards for Custmner-~emhrs published in the February 25,2006 issue, of the Pennsylvania 3ulleain. PEC applauds the effbrt and stakeholder process devoted to the devdopment of the proposed rules ad recognizeg that they will remove many of the Wtid barrim to interconnection but there are several ways to improve them further to encourage the development of clean renewable dhixibuted electric genemiion across the Commonwealth as intended by Act 213.

PEC apprsciates that ~ m r ~ g dbhibuted gemation presents many cumems includjng safbty and reliddity for existing utilities and tbat the d e s should be designed to mure a safe d reliable mviromnmt for all employees yet provide as much ease and simplicity for ~ e r - ~ e r a t o m as possible in oPda to encourage the development of clan distributed generation.

Other states including C o l d , New Jersey, Nevada and Cdifomia have adopted -on s t m k d s that provide lessons and examples for Pemsyhania. Natural1 J,

the New Jersey stan* should be d d d as a model because of its common bardm with PA and its stsltus as a m m k of the PJM grid with EDCs and EGCs that W d l e that border. In addition, numy of the New Jersey standards were designed, though e a ~ e and simplicity, to tomurage dktfi'buted renewable generation rather than simply d o w it. ObviousIy, it is to the b&t of those EDCs operating in both NJ md PA to adopt similar if not identical intercom& s t d a d s as New Jersey.

G e n d Comments:

PEC r ecummd that EIX: approvals for interconnection applications have timelines similar to those adopted in New Jersey. Far example, a h o r h h e h e for a Level 1 review of a solar system interconnection applicqtion malrea sense. Such areview WI typldly be compld in 1 hour or less. A one-week review period is reasonable and enoouq& A f i v e w d review period to review md approve the q p l i d i m fix interconnection isnot

PEC applauds the PUC for c o n v ~ the Inkrmnuection Working Group and recammends reconvening the Group to provide further input md ~ e n ~ o m to that will maximize ease and simplicity of the htercumectim s t d a d s and attend to those circumstances that we unique to PA including those facing the @cultural sector.

As stated above, the PA ixltacormection standads should minm the New Jersey &mdads as much as pomiIe in order to stfeamline the process for dl parties involved.

S d c Comments:

PEC provida sevaal comments listed bdow that address specific issuest that can clarify and simplify the proposed rules and further ~ ~ g e the iwdldiort dean renewable capacity md help meet the gods of Act 213.

1. Lhdhg L e d 2 review to hverter based equipment: PEC reammends Level 2 review of non-inverter based equipment wder certain ckumtances. Automatically requiring LRveZ 3 review fix non-inverter based system can pose a signifiant barrier to entry for many system including farm-based methane digesters, or low-impact hydro, techuologies that Act 2 13 is specifically designed to support Restricting Level 2 review to only inverter based systems is umemwq and should be deleted h m the proped rule.

2. Appropriate Mt for exposure of distribution protective d e v i a to fault currents. PEC recummads that the PUC adopt a less ratdctive limit than the proposed Wt of 85%. PEC cites that the limits adapted rmder FJ3RC 2006 (87.5%) and MADRI. (90%) interconnection rules are less restuictive d more comistent witb the intent of Act 213.

PEC expresstes concern that the limit of 85% for fault curreah tshblished in the proposed rule, in combhation with existing system h h s h c h m and opedng pmdiceg do= not create. a de fmto M e r , d d t in a s i t d o n where a sijpif id portion of distri'bution circuits are not eligible for new distributed gemmtiofl.

3, Certificate of Completion. PEC recommends that applicants for intermmedon simply submit signed copies of all required building an8 electrical code impedm as part of their h a l domnentatim package rather thm requiring all applicants to submit a propod d f i a t e of completion. The proposed d c a t e cmta d e r potential b e e r and delay.

4. Timdha for EDC reviews. PEC m o m m d s that PA adopt the Level 1,2, wad 3 timelines adopted by New Jersey. The New Jersey timelines will provide a m m M i n e d and rapid qpmvd grows than the PA proposed standards and those recommended by the MADN process. It is also worth noting that the FERC 2006 timelines are more expedient thctn the PA propod standards.

PEC q p r b the PUC folr adopting the reporting requirements regding interconnection req- and processing times. PEC concurs that emergency ~~WMLS should allow for more flexible timelines, but it is understood these &auld Iw e rd i na t y and emergency situations.

5. S w e d m g of new capacity. PEC recommends that the level of review applied to new intermmeetion qpli wtim be baaed on the propod new incremental capacity. The aggregate result of &sting distrr'buted g a d o n crrpacity (whether wt the same customer site or others) on a circuit is addressed by each Level of the s m m i n g criteria.

6. k W cap in addition to 7'0 W for network applications. PEC questions the need for st 50 kW cap in addition to the 5% maximum load limit should be applied to spot and area network applications. This requirement wodd result in a 50 k W cap being more restrictive in some cases and PEC herdore ssaommmds a percentage only h i t .

7. Cost responsibility for a single paint of interconnection. h the event an EDC requests a single point of iatemmdon in order to reduce costs, then the costs wsmiated with the single point of intemmection should be paid by the EX. If the standard requires the Customer-generator to assume this cost, it would be a potential unnecessary barrier to distributed generation.