Kansas Interconnection Implementation Workshop
The FERC Process: What it means for Kansas and other states
Wichita, Kansas Oct. 1, 2003Christopher Cook
Interstate Renewable Energy CouncilInterconnection and Net Metering Specialist
E3 Energy Services, LLCwww.E3Energy.com
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
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
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
countryMeetings went on till parties were sick of each
otherConsensus document filed with FERC in Dec.
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
Small Generator ANOPR (cont.)
Generator protectionMeets or exceeds all applicable IEEE, UL, and
NEC requirementsUL Listed Generator System = plug and playFERC registry of certified equipment
Small Generator ANOPR (cont.)
Grid impact<15% of peak loadLimited fault current contributionLimits on imbalances10 steps total
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
Small Generator ANOPR B Non- technical
Fees (nc)Free for <20kWGraduated up to 2 MWMax $700Anticipates average of three hours work and/or
minor equipment change
Small Generator ANOPR BNon- technical
TimingMost interconnections approved in 30 days
DisputesTechnical Master
FERC ANOPR B Technical Difficulties
Distribution networksFound in large urban areas B where DG most
valuableSensitive protection devicesUtilities would suggest no interconnected
generatorsVery small and those with no export should be fine
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 documentsBad parts for both sides B some items could be dangerous
FERC Interconnection Processes
Generator Application
>20MW?
Large Gen
Full
Application
Process:
Feasibility
Impact
Facilities
Studies
Interconnection Agreement
High or low voltage
(69kV)?
Quick
version of
studies
Super
Expedited
Application
Process
< 10MW?
Yes
High Ye
s
Low < 2MWN
oExpedited
Application
Process
No
FERC NOPR Technical
Small Gen defined as those less than 20 MW (Orig. FERC position opposed by many)
Super Ex IP2MW and under low voltage (radial) only5% 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
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.
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
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.
FERC NOPR Procedures (cont.)
Does not apply to incremental additions Unlike PJM procedures
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
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
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
That's all Folks...