The document proposes a Proactive Review Approach for reviewing and approving distributed generation interconnection requests in Hawaii. This approach aims to coordinate interconnection and distribution planning to anticipate higher levels of distributed generation. Key aspects include using enhanced modeling informed by monitoring data, establishing an interconnection queue, setting an annual baseline of anticipated projects, and identifying any necessary upgrades to facilitate higher penetrations of distributed generation while maintaining reliability. The goal is to create a more transparent and efficient process for interconnecting renewable energy.

1. Summary of Proposal for Proactive Review Approach
Background and Basis for Recommendations: As a result of dynamic market trends
and technological advances, the HECO Companies are responding to increasing levels of
distributed generation (DG) on their distribution systems. To contend with the pace of
DG requests, a new proactive and holistic approach to interconnections and distribution
system planning is needed for Hawai’i utilities to safely and reliably address high
penetrations 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 minimum
daytime load for certain systems as part of NEM Express) to screen Interconnection
Applications for potential impacts to safety, reliability and power quality. Such proxies
may unintentionally create the appearance of artificial caps on interconnection and may
impact customer expectations about the ability to install DG systems, like solar
photovoltaic (PV). The 2008 Energy Agreement between the HECO Companies and
State of Hawai’i representatives recognized the need to move beyond proxies in
providing that “for those circuits where interconnection requests (particularly for PV)
approach the 15% limit, the utility will perform . . . analysis to determine whether the
limit can be increased.” Id. at 28.
Interconnection reviews traditionally proceed in response to interconnection applications
being submitted for specific proposed projects. At the same time, the utilities also
traditionally conduct transmission and distribution system planning reviews to provide a
more comprehensive view of system changes. Such distribution planning, however,
traditionally views DG as “negative load” rather than generation resources to be
considered in planning and equipment upgrade decisions. This approach contributes to
the reactive nature of DG interconnection and is becoming increasingly unfeasible as
Hawai’i reaches higher levels of DG penetration.
Since 2009, the HECO Companies have been continuing to take steps towards facilitating
interconnection reviews through improved monitoring and modeling and implementing
various proactive planning measures discussed herein, collectively referred to as the
Proactive Review Approach, or Proactive Approach.
The RSWG PV Subgroup supports and recommends this Proactive Approach to the
larger RSWG and the PUC as the next evolutionary step in renewable DG
interconnection, and towards the clean energy grid of the future. (See attached
conceptual figure.) The PV Subgroup recognizes that the Proactive Approach may
require time to implement within the utility processes and consideration of additional
proposals including: modifications of program and interconnection tariffs, selective
deployment of monitoring equipment, staff training, public outreach, and determinations
of reasonable cost recovery by the utility.

2. The PV Subgroup recommends that the PUC consider such approvals as may be
necessary and prudent to enable reliable adoption of distributed resources and successful
implementation 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 to
anticipate and plan for the interconnection of higher penetration levels of DG and account
for their aggregated impacts on the system. Specifically, the utility will employ enhanced
tools for modeling distributed PV to inform both system and distribution level planning
and operations. Enhancement areas include: assessing potential system and regional
level impacts due to high penetrations; evaluating impacts to dispatch and generation,
reserve planning, and response to ramping events; informing and streamlining the
distribution level interconnection process; and helping to identify circuit penetration
capabilities, potential issues, and necessary upgrades.
The overall goal is to create a more transparent and efficient process for interconnecting
higher levels of DG while maintaining safety, reliability, and power quality across the
transmission 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

3. 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. 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.

5. 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.

6. 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

7. ii. 2015 2nd Q completion of all clusters (estimated 10-15) with
ongoing installations of monitoring devices at priority locations
d. 2015 3rd Q, all islands on Proactive Approach track and annual review
cycle.