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.

1. Interconnection Issues at
Higher Penetrations
Sky C. Stanfield
1

2. Installed Grid-Connected Solar Capacity (MW)
3,500
3,000
3340
MW
Capacity
(MW-­‐dc)
2,500
2,000
1,500
1800
MW
U)lity
Non-­‐Residen)al
Residen)al
1,000
500
0
2

3. Number of Annual Grid-Connected Installations
100,000
90,000
95,000
80,000
70,000
60,000
50,000
40,000
65,000
U)lity
Non-­‐Residen)al
Residen)al
30,000
20,000
10,000
0
3

4. 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

5. 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

6. 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
6

7. 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
7

8. 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?
8

9. 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
9

10. 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
10

11. Fast Track Eligibility Proposals
Line Capacity
Fast Track Eligibilityregardless of location
Fast Track Eligibility- on >
600 amp line and < 2.5
miles from substation
< 4kV
5kV – 14 kV
15 kV – 30 kV
31 kV – 60 kV
< 1MW
< 2MW
< 3MW
< 4MW
< 2 MW
< 3 MW
< 4 MW
< 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)
≥ 5 kV and < 15 kV
≥ 15 kV and < 30 kV
≥ 30 kV and 69 kV
< 500 kW
< 2 MW
< 3 MW
< 4 MW
< 500 kW
< 3 MW
< 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.
11

12. 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
12

13. 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)
13

14. 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
14

15. 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
15

16. Questions?
Sky Stanfield
Keyes, Fox & Wiedman LLP
(510) 314-8204
sstanfield@kfwlaw.com
16

17. 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
17

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