Presentation on theme: "Kansas Interconnection Implementation Workshop The FERC Process: What it means for Kansas and other states Wichita, Kansas Oct. 1, 2003 Christopher Cook."— Presentation transcript:
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? 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 Yes Low < 2MW No Expedited Application Process No
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