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Kansas Interconnection Implementation Workshop The FERC Process: What it means for Kansas and other states Wichita, Kansas Oct. 1, 2003 Christopher Cook.

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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:

1 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

2 Procedural History at the Federal Energy Regulatory Commission (FERC)  FERC ANOPR B Large and Small generators  Issued in October 2001  Negotiations until Jan  Parties filed consensus documents (including differences) Jan 11, 2002  NOPR issued April 24,2002

3 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

4 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.

5 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

6 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

7 Small Generator ANOPR (cont.)  Grid impact  <15% of peak load  Limited fault current contribution  Limits on imbalances  10 steps total

8 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

9 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

10 Small Generator ANOPR B Non- technical  Timing  Most interconnections approved in 30 days  Disputes  Technical Master

11 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

12 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

13 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

14 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

15 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.

16 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

17 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.

18 FERC NOPR Procedures (cont.)  Does not apply to incremental additions  Unlike PJM procedures

19 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

20 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

21 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

22 That's all Folks...


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