Transcript NJ BPU Interconnection Workshop Trenton, New Jersey Sept

Kansas Interconnection
Implementation Workshop
The FERC Process:
What it means for Kansas and other states
Wichita, Kansas Oct. 1, 2003
Christopher Cook
Interstate Renewable Energy Council
Interconnection and Net Metering Specialist
E3 Energy Services, LLC
www.E3Energy.com
Procedural History at the Federal Energy
Regulatory Commission (FERC)
 FERC ANOPR B Large and Small generators
 Issued in October 2001
 Negotiations until Jan. 2002
 Parties filed consensus documents (including
differences) Jan 11, 2002
 NOPR issued April 24,2002
FERC Generator Interconnection
Rulemaking - Procedure
 Original ANOPR suggested FERC wanted
expedited procedures for small generation B
set bar at 20MW
 Parties achieved little consensus on small
generator interconnection standards
 Second ANOPR issued for small generators
August 2002
FERC Generator Interconnection
Rulemaking - Workgroups
 Working groups started in September
 Many meetings with utilities; small generator
coalition; NARUC
 Input from best technical sources in the country
 Meetings went on till parties were sick of each
other
 Consensus document filed with FERC in Dec.
Small Generator ANOPR
 Super Expedited (<2MW) very detailed
guidelines
 2 Technical components
 Protection on the generator
 Impact on the Grid at the point of
interconnection
 Also includes fees; timing; procedure; standard
form contract; application
Small Generator ANOPR (cont.)
 Generator protection
 Meets or exceeds all applicable IEEE, UL, and
NEC requirements
 UL Listed Generator System = plug and play
 FERC registry of certified equipment
Small Generator ANOPR (cont.)
 Grid impact
 <15% of peak load
 Limited fault current contribution
 Limits on imbalances
 10 steps total
Small Generator ANOPR (cont.)
Secondary screens
 Issue: should grid modifications be included or
should the small generator have to accept the
grid conditions as found
 Cut-out
 Small Gen proposal: $300 time and materials
Small Generator ANOPR B
Non- technical
 Fees (nc)
 Free for <20kW
 Graduated up to 2 MW
 Max $700
 Anticipates average of three hours work and/or
minor equipment change
Small Generator ANOPR B
Non- technical
 Timing
 Most interconnections approved in 30 days
 Disputes
 Technical Master
FERC ANOPR B Technical Difficulties
 Distribution networks
 Found in large urban areas B where DG most
valuable
 Sensitive protection devices
 Utilities would suggest no interconnected
generators
 Very small and those with no export should be fine
FERC Issued NOPR
 Published in Federal Register Aug. 19, 2003
 Comments due Oct. 3, 2003
 Details are difficult to discern
Redundant and conflicting procedural guides
 Fundamental misunderstanding of consensus
documents
Bad parts for both sides B some items could be
dangerous
FERC Interconnection Processes
Generator
Application
>20MW?
High
or low voltage
(69kV)?
Low
No
Yes
High
Large Gen
No
< 10MW?
Full
Application
Process:
Feasibility
Quick
Impact
version of
Facilities
studies
Studies
Interconnection
Agreement
Expedited
Application
Process
< 2MW
Yes
Super
Expedited
Application
Process
FERC NOPR Technical
 Small Gen defined as those less than 20
MW (Orig. FERC position opposed by many)
 Super Ex IP
 2MW and under low voltage (radial) only
 5% of peak load; spot network 5% or 50kW; 10%
fault current; can’t exceed 85% short circuit
ratings; 10MW total in stability limited areas;
3wire & 4wire configurations; 20kVA secondary
limit; 20% imbalance on center taps
FERC NOPR Technical
 Expedited (<10MW)
 Same as Super Ex except 15% of peak load,
 90% of short circuit max
 Seems to apply to failed Super Ex. as well
 If passes screens but utility is nonetheless
concerned, can send to feasibility study. If
study finds no impact, utility pays for study.
Non-expedited small generator review
 Feasibility Study (high level look --benefits
generator before spending $ on Impact Study)
 Impact Study BT&D (this costly study waived
in most cases for small generators)
 Facilities study (equipment)
 These are expedited versions of the same
for large generators
FERC NOPR Procedures
 Single queue
 TP must work with Affected Systems
 Dispute Resolution B no FERC technical
master
 Costs - not defined but generator must pay
 Insurance - same as Large Gens.
FERC NOPR Procedures (cont.)
 Does not apply to incremental additions
 Unlike PJM procedures
FERC ANOPR -Jurisdiction
 Would apply to all FERC regulated generators
 FERC defines as generator interconnecting to
dual use low voltage facility (has some
wholesale generation already on it)
 Safe Harbor utilities would have to follow rule
to preserve safe harbor
FERC NOPR gaps/contradictions
 No transmission checks on 2-10MW on low
voltage
 No small low voltage procedures for area
networks
 Incentive to find impact
 Different criteria used in titles
Commentary:
Interconnection Policy
 All interconnection rules to date focus on
integrating DG without change to the grid
 There is at present NO discussion in the
regulatory arena about changing the grid to
be more accommodating to DG
 DG unlikely to attain lofty goals without a
more deliberate debate on interconnection
That's all Folks...