Interconnection Issues at
Higher Penetrations
Sky C. Stanfield

1
Installed Grid-Connected Solar Capacity (MW)
3,500	
  
3,000	
  

3340	
  MW	
  

Capacity	
  (MW-­‐dc)	
  

2,500	
  
2,0...
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...
Most Interconnection Procedures
Were Designed for a Different Era
•  FERC adopted SGIP in 2005, subsequently
many states a...
Key Reasons for Updating
Interconnection Procedures
• 
• 
• 
• 
• 

High volume of interconnection applications
Increased ...
Interconnection Rules
Are Changing
•  Both state and federally regulated
procedures in California have been
updated
•  Haw...
A Few Principles for Efficient
Interconnection
•  Filter projects before applications are filed
•  Enable developers to se...
New and Noteworthy
Approaches to Interconnection
• 
• 
• 
• 
• 
• 

Pre-Application Reports and other tools
Fast Track siz...
Pre-Application Report
•  Report on system conditions at a particular
point of interconnection
•  Reduces number of specul...
Fast Track Size Limits
•  Most common Fast Track limit is 2 MW
•  May result in studies being required where
not needed to...
Fast Track Eligibility Proposals
Line Capacity

Fast Track Eligibilityregardless of location

Fast Track Eligibility- on >...
Defined Supplemental Review
•  Retains the 10 existing initial review screens
– if any are failed options are:
1.  Approve...
Differentiated Study Processes
• 
• 
• 
• 
• 
• 

Pre-Application (± 10 days)
Fast Track (± 30 days)
Supplemental Review (...
Group/Cluster Studies
•  Can be necessary to avoid serial-study queue
clogging
•  Have advantages in cost sharing for stud...
Integrated Distribution Planning
• 
• 
• 
• 

Proactive instead of Reactive
Advanced determination of hosting capacity
Can...
Questions?
Sky Stanfield
Keyes, Fox & Wiedman LLP
(510) 314-8204
sstanfield@kfwlaw.com

16
What is FERC Doing with SGIP?
•  Issued a NOPR in January 2013 post SEIA
petition
•  Workshops were held, Comments filed i...
THANKS to our generous sponsors for the
2013 3iForum and 3iAwards
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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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Interconnection Issues at Higher Penetrations

  1. 1. Interconnection Issues at Higher Penetrations Sky C. Stanfield 1
  2. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 16. Questions? Sky Stanfield Keyes, Fox & Wiedman LLP (510) 314-8204 sstanfield@kfwlaw.com 16
  17. 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. 18. THANKS to our generous sponsors for the 2013 3iForum and 3iAwards

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