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Interconnection Issues at Higher Penetrations Sky C. Stanfield 1

Interconnection Issues at Higher Penetrations

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Current interconnection processes are no longer keeping pace with the rapid expansion of renewable energy markets in key regions of the country. These inadequacies are resulting in multi-year delays before solar and other renewable energy projects are interconnected, which is significantly slowing solar market expansion. IREC has participated in the development and updating of interconnection procedures in over two dozen states and at the Federal Energy Regulatory Commission. Sky discussed the latest approaches that are being deployed in interconnection processes to keep pace with solar market growth.

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Page 1: Interconnection Issues at Higher Penetrations

Interconnection Issues at Higher Penetrations

Sky C. Stanfield

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Page 2: Interconnection Issues at Higher Penetrations

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Installed Grid-Connected Solar Capacity (MW)

0  

500  

1,000  

1,500  

2,000  

2,500  

3,000  

3,500  

Capa

city  (M

W-­‐dc)  

U)lity  

Non-­‐Residen)al  

Residen)al  

1800  MW  

3340  MW  

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Number of Annual Grid-Connected Installations

65,000  

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

U)lity  

Non-­‐Residen)al  

Residen)al  

95,000  

Page 4: Interconnection Issues at Higher Penetrations

Most Interconnection Procedures Were Designed for a Different Era

•  FERC adopted SGIP in 2005, subsequently many states adopted procedures modeled on SGIP or the original California Rule 21 –  In 2005 the US installed 79 MW of grid connected

PV –  In 2012 the US installed 3,300 MW of grid

connected PV •  Until last year, few states had updated their

procedures to reflect this changing reality 4

Page 5: Interconnection Issues at Higher Penetrations

Key Reasons for Updating Interconnection Procedures

•  High volume of interconnection applications •  Increased penetration on distribution circuits •  Backlogged study queues •  Unclear review requirements •  Lack of transparency regarding system

conditions •  Better procedures = lower costs for solar

customers and utilities/rate payers 5

Page 6: Interconnection Issues at Higher Penetrations

Interconnection Rules Are Changing

•  Both state and federally regulated procedures in California have been updated

•  Hawaii, Massachusetts, Ohio and others have recently adopted or are considering changes

•  FERC is currently considering significant updates to SGIP

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A Few Principles for Efficient Interconnection

•  Filter projects before applications are filed •  Enable developers to select low-cost sites •  Apply the appropriate amount of study to

each project •  Ensure timelines are clear and complied

with •  Allow opportunities for cost sharing

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Page 8: Interconnection Issues at Higher Penetrations

New and Noteworthy Approaches to Interconnection

•  Pre-Application Reports and other tools •  Fast Track size limits •  Improved Supplemental Review •  Differentiated Study Processes •  Group/Cluster Studies •  Up Next: Integrated Distribution Planning?

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Pre-Application Report

•  Report on system conditions at a particular point of interconnection

•  Reduces number of speculative projects •  Help developers strategically locate projects •  Maximizes utilization of existing infrastructure •  Can help manage expectations •  Minimizes study queues, conserves utility

staff time

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Page 10: Interconnection Issues at Higher Penetrations

Fast Track Size Limits •  Most common Fast Track limit is 2 MW •  May result in studies being required where

not needed to protect safety and reliability •  Goal should be to filter projects that are

unlikely to pass the Fast Track screens •  Size is a key factor, but location on the circuit

is also a key determining factor •  Couple of options on the table at FERC

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Fast Track Eligibility Proposals

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Line Capacity Fast Track Eligibility-regardless of location

Fast Track Eligibility- on > 600 amp line and < 2.5 miles from substation

< 4kV < 1MW < 2 MW 5kV – 14 kV < 2MW < 3 MW

15 kV – 30 kV < 3MW < 4 MW 31 kV – 60 kV < 4MW < 5 MW

Line Voltage Fast Track Eligibility Regardless of Location

Fast Track Eligibility on a Mainline* and <2.5 Miles**

from Substation < 5 kilovolt (kV) < 500 kW < 500 kW

≥ 5 kV and < 15 kV < 2 MW < 3 MW ≥ 15 kV and < 30 kV < 3 MW < 4 MW ≥ 30 kV and 69 kV < 4 MW < 5 MW

* For purposes of this table, a mainline will typically constitute lines with wire sizes of 4/0 AWG, 336.5 kcmil, 397.5 kcmil, 477 kcmil and 795 kcmil ** Electrical Line Miles *** An Interconnection Customer can determine this information in advanced by requesting a pre-application report pursuant to section 1.2.

Page 12: Interconnection Issues at Higher Penetrations

Defined Supplemental Review •  Retains the 10 existing initial review screens

– if any are failed options are: 1.  Approve anyway with “minor modifications” 2.  Offer to perform supplemental review, or 3.  Get agreement to study

•  Three supplemental review screens: 1.  100% of minimum load, daytime for PV; 2.  Power quality and voltage, and 3.  Safety and reliability

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Differentiated Study Processes

•  Pre-Application (± 10 days) •  Fast Track (± 30 days) •  Supplemental Review (± 60 days) •  Independent Study (± 6 months) •  Distribution Group Study (± one year) •  Transmission Cluster Study (± two years)

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Page 14: Interconnection Issues at Higher Penetrations

Group/Cluster Studies

•  Can be necessary to avoid serial-study queue clogging

•  Have advantages in cost sharing for study fees as well as upgrades

•  Longer study time per-project, but overall shorter wait time to be studied

•  Still in the experiment stage in California

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Integrated Distribution Planning

•  Proactive instead of Reactive •  Advanced determination of hosting capacity •  Can shorten project specific study time •  Could even result in upgrades not done on a

project-by-project basis •  For more see 3iForum talks on IDP

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Questions?

Sky Stanfield Keyes, Fox & Wiedman LLP

(510) 314-8204 [email protected]

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What is FERC Doing with SGIP?

•  Issued a NOPR in January 2013 post SEIA petition

•  Workshops were held, Comments filed in June •  Considering a rule similar to Rule 21 •  Why does it matter?

–  Model for state procedures –  Could help facilitate greater penetration of DG at lower

cost to developers •  Watch for decision later this year or early next

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THANKS to our generous sponsors for the 2013 3iForum and 3iAwards