Summary of Proposal for Proactive Review ApproachBackground and Basis for Recommendations: As a result of dynamic market trendsand technological advances, the HECO Companies are responding to increasing levels ofdistributed generation (DG) on their distribution systems. To contend with the pace ofDG requests, a new proactive and holistic approach to interconnections and distributionsystem planning is needed for Hawai’i utilities to safely and reliably address highpenetrations of DG resources.Currently, the HECO Companies’ Interconnection Tariff Rule 14H uses the proxies “15%of peak load” and “50% of minimum load” (recently increased to 75% of minimumdaytime load for certain systems as part of NEM Express) to screen InterconnectionApplications for potential impacts to safety, reliability and power quality. Such proxiesmay unintentionally create the appearance of artificial caps on interconnection and mayimpact customer expectations about the ability to install DG systems, like solarphotovoltaic (PV). The 2008 Energy Agreement between the HECO Companies andState of Hawai’i representatives recognized the need to move beyond proxies inproviding that “for those circuits where interconnection requests (particularly for PV)approach the 15% limit, the utility will perform . . . analysis to determine whether thelimit can be increased.” Id. at 28.Interconnection reviews traditionally proceed in response to interconnection applicationsbeing submitted for specific proposed projects. At the same time, the utilities alsotraditionally conduct transmission and distribution system planning reviews to provide amore comprehensive view of system changes. Such distribution planning, however,traditionally views DG as “negative load” rather than generation resources to beconsidered in planning and equipment upgrade decisions. This approach contributes tothe reactive nature of DG interconnection and is becoming increasingly unfeasible asHawai’i reaches higher levels of DG penetration.Since 2009, the HECO Companies have been continuing to take steps towards facilitatinginterconnection reviews through improved monitoring and modeling and implementingvarious proactive planning measures discussed herein, collectively referred to as theProactive Review Approach, or Proactive Approach.The RSWG PV Subgroup supports and recommends this Proactive Approach to thelarger RSWG and the PUC as the next evolutionary step in renewable DGinterconnection, and towards the clean energy grid of the future. (See attachedconceptual figure.) The PV Subgroup recognizes that the Proactive Approach mayrequire time to implement within the utility processes and consideration of additionalproposals including: modifications of program and interconnection tariffs, selectivedeployment of monitoring equipment, staff training, public outreach, and determinationsof reasonable cost recovery by the utility.
The PV Subgroup recommends that the PUC consider such approvals as may benecessary and prudent to enable reliable adoption of distributed resources and successfulimplementation of the Proactive Approach.Purpose: The Proactive Approach aims to coordinate and mutually enhance the utilities’functions of (1) interconnection and (2) transmission and distribution planning in order toanticipate and plan for the interconnection of higher penetration levels of DG and accountfor their aggregated impacts on the system. Specifically, the utility will employ enhancedtools for modeling distributed PV to inform both system and distribution level planningand operations. Enhancement areas include: assessing potential system and regionallevel impacts due to high penetrations; evaluating impacts to dispatch and generation,reserve planning, and response to ramping events; informing and streamlining thedistribution level interconnection process; and helping to identify circuit penetrationcapabilities, potential issues, and necessary upgrades.The overall goal is to create a more transparent and efficient process for interconnectinghigher levels of DG while maintaining safety, reliability, and power quality across thetransmission and distribution infrastructure. This will benefit all parties involved,including customers, developers, utilities, as well as the broader public.The Proactive Approach will enable numerous advancements, including: • More accurate understanding of the currently feasible penetration capability of the distribution system, including any engineering safety margins, based on actual measured (or observed) feeder conditions instead of proxy figures; • Greater and more reliable facilitation of renewable DG interconnection and attendant progress towards the state’s clean energy goals; • Better informed and engaged customers and developers with the ability to check online the updated, current feeder availability (kWs or MWs of available capacity remaining) to interconnect DG; • More transparent and accessible interconnection process, where customers and developers will be able to understand the opportunities for interconnection, or anticipate the need for additional review such as an interconnection requirements study (IRS), before submitting an Interconnection Application; • Streamlined interconnection, where the utility “gets ahead of” potential circuit and system issues that may arise resulting from high penetrations at a more comprehensive level rather than the traditional, piecemeal approach; • More systematic interconnection review, where the utility conducts forward- looking analysis based on field-monitored data, including data gathered from customers and industry, to inform the interconnection review process, assess and
narrow potential issues, and develop any mitigation options and solutions, as required; • More cost-effective interconnections, where enhanced modeling and monitoring capabilities supported by customer and industry data provide a more efficient and consistent method to evaluate high feeder penetrations and aggregated system impacts and devise cost-effective options that can address systemic issues and broad benefits for many projects; • Increased visibility into the location and impacts of DG on the utilities’ systems, which carries a number of benefits, including, for example, more targeted solutions and intelligences in applying solutions such as load shedding.Proactive Approach Review Process:1. Coordination with 14H Process: The Proactive Approach will supplement, and not supplant, the HECO Companies’ 14H interconnection review process. The Proactive Approach will provide insight into the penetration capabilities of the distribution system, solutions and strategies to facilitate higher penetration capabilities, and outstanding issues for further project-specific review. This will inform the project- specific interconnection review process under 14H, which may continue to proceed on a parallel course. The Proactive Approach is not a “group or cluster study” or project-specific study, where the utility requires specific details in response to proposed projects. Rather, the Proactive Approach will work alongside the 14H interconnection process to facilitate and inform the interconnection process through proactive monitoring and tracking of high penetration and system reliability issues in order to better highlight potential issues and alleviate delays and burdens.2. Enhanced Modeling: The Proactive Approach uses enhanced utility models currently being developed and validated to account for DG, particularly PV, on the distribution system. These models utilize field-monitored information incorporating the solar resource and PV generation at key “nodal” locations to refine and validate assessment of impacts. To support the modeling efforts, the utilities are installing monitoring devices, gathering SCADA data on PV production from large projects, and requesting available monitoring from customers and developers. Information will provide greater visibility to distributed PV generation characteristics and enable more accurate analysis under the Proactive Approach.3. Interconnection Queue: As part of the Proactive Approach, the utility shall, in consultation with stakeholders, work to establish and utilize a single interconnection queue for all projects seeking interconnection to the distribution system. The interconnection queue will help establish an annual “Base Case” for consideration in the proactive analysis to understand potential distribution upgrades that may be needed.
4. Base Case: During a designated period each year generally correlating with the timeframe for annual distribution planning (see “Timing of Annual Review,” infra), utility will establish a Base Case of anticipated DG development for each cluster of distribution feeders on their grids. A cluster is a group of electrically related distribution feeders in a particular geographic area. The Base Case will consider projects from all programs under which projects are seeking interconnection affecting the distribution system (i.e., those projects already in the interconnection queue, including any transmission-level projects that may impact the DG interconnection capabilities in the region). This recognizes that the proposed projects in the interconnection queue may not all be ultimately installed, but nonetheless provides a useful starting point for gauging interconnection demand. The Base Case establishes a planning baseline and does not constitute a detailed project study. The Base Case may also include an anticipated number of distribution projects that may enter the queue during the planning period, which under annual distribution planning looks ahead about a year. The anticipated increase in installed capacity may be based on the utility’s Integrated Resource Plan or other forecasts of the expected growth in distribution-interconnected projects in a particular year’s distribution planning period. The Base Case may also include any anticipated demand response programs, energy efficiency installations, changes in load profiles or other issues that may affect the loading of a particular cluster or line (e.g., entry of electric vehicle loads).5. Application of the Base Case to Feeder Clusters: The utility shall analyze the penetration capabilities for each feeder cluster, using the Base Case along with the models utilities are developing to account for PV generation on their distribution systems. Among other information, the utility shall conduct simulations to help assess the penetration level of DG, particularly PV, that the cluster can accommodate without upgrades, specific issues for that cluster that require further review under the project-specific interconnection process, and upgrade option(s) appropriate for the cluster to enable higher penetrations. Additionally, the utility shall analyze the effect of the base case on safety, reliability, and power quality of the grid, and curtailment to the existing and proposed renewable projects.6. Penetration Capabilities: The utility will establish the existing capability of each feeder cluster to absorb additional PV without upgrades. The penetration capability for PV will be stated as a percentage of the highest (or “peak”) minimum daytime load. This recognizes that existing PV generation decreases the net minimum daytime load, and that the highest minimum daytime load most closely equates to the actual gross minimum load without the effects of the existing PV. The penetration capability for other generation technologies will be stated as a percentage of minimum load during the period that the generation is available. The penetration capability for feeder clusters may include an engineering safety factor.
Distinct from the current proxy levels in interconnection procedures (e.g., 15% of peak load and 50% of minimum load), the penetration capability will establish, based on actual analysis, the feeder availability. The feeder availability is the maximum kW or MW value of DG, particularly PV, that can be interconnected to a feeder with the existing equipment on that feeder, including protection and control equipment. In order for this system of measuring penetration capabilities in terms of percentages of minimum load to work, the utilities must establish and maintain the ability to measure minimum loads on their distribution systems. The HECO Companies have largely, but not completely, installed such capability. To this end, the utility shall continue to install the necessary equipment to measure load profiles on feeders with priority focus on existing high penetration feeders and moving to feeders with DG at or above a threshold of 10% of peak feeder load.7. Informing of Upgrades: Where application of the Base Case results in an amount of generation that exceeds the penetration capability of a feeder cluster without upgrades, the Proactive Approach may be used to help evaluate options to upgrade the distribution infrastructure in order to accommodate the Base Case amount of growth of projected DG. Note: IRS studies may still be necessary for project specific needs, as determined by the utility. If upgrades are needed, the utility shall determine the best way to implement such upgrades and allocate the costs, as allowed by law and tariff. In any event, the utility should inform the customers and developers in the Interconnection Queue for the Base Case of its determination of any necessary upgrades and provide appropriate opportunities to proceed with interconnections through the interconnection process. [There are a number of open issues yet to be resolved in this proposal. These issues include clarification of how costs will be allocated to the new generators that seek interconnection and the tariff changes that may be required to implement the approach.]8. Online Information: The utility shall provide appropriate online information where customers and developers can input addresses and view their interconnection status, feeder penetration range and known upgrades using online utility DG tracking tools such as the location value maps (LVM). The goal is to provide customers and developers with a publicly accessible and transparent system of understanding present and potential penetration capabilities and minimize misinterpretation of any perceived or arbitrary feeder caps.9. Narrowing of Issues: In addition to the penetration capabilities and upgrades above, the Proactive Approach will help identify any issues requiring further review in the project-specific interconnection process under Rule 14H. This will facilitate the Rule 14H process by narrowing the scope of interconnection review to an already previewed set of issues. This preview under the Proactive Approach may inform each stage of the Rule 14H interconnection process, including Initial Technical Review, Supplemental Review, and the Interconnection Requirements Study.
10. Timing of Annual Review: The Proactive Approach review process will occur in a consistent timeframe each year, targeted around May through July, which dovetails with the HECO Companies’ process for transmission and distribution planning reviews conducted during 1st quarter of each year (January through April) and the PV industry’s end-of-year tax deadlines. The HECO Companies shall work to make the timeframe for the Proactive Approach review consistent across all the utilities. The completion of this process by June conforms with the timeframes for renewable development, under which the viability of projects must be known sufficiently far in advance of the tax deadlines at the end of the year.11. Timing of Rollout: The Proactive Approach will take time to implement and put into practice, realizing that it is in everyone’s best interests to achieve this goal under an expeditious timeframe. The HECO Companies are already moving ahead with conducting cluster studies in key areas of current or anticipated high penetration and DG growth, using the new cluster-based methodology, additional field data, and enhanced planning models. Since the Proactive Approach process is designed to work in parallel with the Rule 14H interconnection process, as the feeder cluster evaluations are completed for each of the islands, the information shall be made available to support the Rule 14H process. Solutions such as improved penetration capabilities or upgrade options shall be applied on an ongoing basis as they are identified. The following outlines the basic timeframe for establishing and implementing the framework for the Proactive Approach: a. HECO: i. 2013 1st Q proactive review for 3-4 clusters in O’ahu complete, inclusive of feeder monitoring device installations ii. 2013 3rd Q, completion for all clusters (estimated 15-20) by summer 2013 with ongoing installation of monitoring devices at priority locations. b. MECO: i. 2013 1st Q proactive review for 1-2 high demand feeders on Maui complete, inclusive of feeder monitoring device installations ii. 2014 2nd Q completion for all clusters on Maui (estimated 8-10) with ongoing installations of monitoring devices at priority locations iii. 2013 4th Q begin Molokai and Lanai modeling efforts to initiate cluster evaluations with completion of islands by 2015 1st Q. c. HELCO: i. 2013 1st Q proactive review for 1-2 high demand feeders on Hawai’i complete. Inclusive of feeder monitoring device installations
ii. 2015 2nd Q completion of all clusters (estimated 10-15) with ongoing installations of monitoring devices at priority locationsd. 2015 3rd Q, all islands on Proactive Approach track and annual review cycle.