Kansas Interconnection Implementation Workshop

The FERC Process: What it means for Kansas and other states

Wichita, Kansas Oct. 1, 2003Christopher Cook

Interstate Renewable Energy CouncilInterconnection and Net Metering Specialist

E3 Energy Services, LLCwww.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

countryMeetings went on till parties were sick of each

otherConsensus 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 protectionMeets or exceeds all applicable IEEE, UL, and

NEC requirementsUL Listed Generator System = plug and playFERC registry of certified equipment

Small Generator ANOPR (cont.)

Grid impact<15% of peak loadLimited fault current contributionLimits on imbalances10 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 <20kWGraduated up to 2 MWMax $700Anticipates average of three hours work and/or

minor equipment change

Small Generator ANOPR BNon- technical

TimingMost interconnections approved in 30 days

DisputesTechnical Master

FERC ANOPR B Technical Difficulties

Distribution networksFound in large urban areas B where DG most

valuableSensitive protection devicesUtilities would suggest no interconnected

generatorsVery 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 documentsBad parts for both sides B some items could be dangerous

FERC Interconnection Processes

Generator Application

>20MW?

Large Gen

Full

Application

Process:

Feasibility

Impact

Facilities

Studies

Interconnection Agreement

High or low voltage

(69kV)?

Quick

version of

studies

Super

Expedited

Application

Process

< 10MW?

Yes

High Ye

s

Low < 2MWN

oExpedited

Application

Process

No

FERC NOPR Technical

Small Gen defined as those less than 20 MW (Orig. FERC position opposed by many)

Super Ex IP2MW and under low voltage (radial) only5% 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...