1. Goals for 2003 Kansas Interconnection Standards Development Larry Holloway Chief of Energy Operations Kansas Corporation Commission

2. Kansas Interconnection Standard Development History Legislation Staff Analysis Order Process

3. Kansas Interconnection Standard Development Legislation HB 2018 Section 32 –Passed by 2003 Legislature K.S.A. 66-101a and amendments thereto –Defines Commission jurisdiction K.S.A. 66-104 and amendments thereto –Definition of a jurisdictional public utility K.S.A. 66-1,184 –Parallel Generation Act

4. Kansas Interconnection Standard Development Section 32 HB 2018 On or before September 1, 2003, the state corporation commission shall establish standard provisions, including applicable fees, for agreements providing for interconnection between the facilities of an electric public utility, as defined by K.S.A. 66-101a, and amendments thereto, and a generator which generates electricity from renewable resources or technologies, as defined by section 2, and amendments thereto.

5. Kansas Interconnection Standard Development K.S.A. 66-101a and amendments thereto K.S.A. 66-101 –Commission jurisdiction over electric public utilities as defined in 66-101a K.S.A. 66-101a –"Electric public utility" means any public utility, as defined in K.S.A. 66-104, and amendments thereto, which generates or sells electricity.

6. Kansas Interconnection Standard Development K.S.A. 66-104 and amendments thereto An electric public utility is all companies that produce, transmit or deliver power except for private use. Exceptions –Deregulated rural electric distribution cooperatives (safety, wholesale and transmission still regulated). –Municipal electric utility operations more than 3 miles outside the city limits. –Independent generators built after January 1, 2001 have the option of being a public utility.

7. Kansas Interconnection Standard Development K.S.A. 66- 66-1,184 Parallel Generation Act: – … every public utility which provides retail electric services in this state shall enter into a contract for parallel generation service with any person who is a customer of such utility, upon request of such customer, … – …utility means an electric public utility, as defined by K.S.A. 66-101a, and amendments thereto, any cooperative, as defined by K.S.A. 17-4603, and amendments thereto, or a nonstock member-owned electric cooperative corporation incorporated in this state, or a municipally owned or operated electric utility. …

8. Kansas Interconnection Standard Development Staff Analysis Kansas Requirements Federal Requirements Models –NARUC –NRECA Suggested procedural process

9. Kansas Interconnection Standard Development Kansas Requirements KCC required to establish interconnection standards for each jurisdictional utility by September 1, 2003. –Standards to include all generation – not just renewable. KCC working with jurisdictional and non jurisdictional electric utilities to adopt statewide interconnection standards. –Jurisdictional Kansas electric utilities serve 70% of the customers but only 40% of the area.

10. Kansas Interconnection Standard Development Federal Requirements (Transmission Interconnections) Order 2003 (FERC Docket No. RM02-01) –Final order July 24, 2003. –Generation exceeds 20 MW. Proposed Rules for Small Generators (FERC Docket No. RM02-12) –Generation 20 MW or less Staff recommended FERC Rules for non- FERC jurisdictional utilities. FERC website: www.ferc.gov

11. Kansas Interconnection Standard Development Models National Rural Electric Cooperative Association (NRECA) –Distributed Generation toolkit. –http://www.nreca.org/nreca/Policy/Re gulatory/DGToolKit/index.htmlhttp://www.nreca.org/nreca/Policy/Re gulatory/DGToolKit/index.html National Association of Regulatory Utility Commissioners (NARUC) –Distributed Generation Interconnection Model –http://www.naruc.org/Programs/dgia/d giaip.pdfhttp://www.naruc.org/Programs/dgia/d giaip.pdf

12. Kansas Interconnection Standard Development Process Recommended by Staff 3 Phases –First phase will address and develop general standards. Requirements for applications, contracts, etc. –Second phase, if necessary to address and implement detailed standards. Generic application form, process, contracts, schematics. –Third phase to implement final standards. Note: This is a fluid process subject to change.

13. Kansas Interconnection Standard Development Suggested Phase 1 and 2 Process Staff issues a list of recommendations and issues Commission issues a list of questions Participants respond to questions (November 17, 2003) Staff prepares summary of responses and provides recommendations. Commission issues a list of issues for technical conference Participant provide written response Commission conducts technical conference Participants and staff submit final recommendations Commission issues order

14. Kansas Interconnection Standard Development Commission Orders KCC Docket No. 04-GIME-080-GIE Active Dockets at www.kcc.state.ks.us www.kcc.state.ks.us July 23, 2003 Order –Jurisdictional utilities required to file individual interconnection standards by September 1, 2003. –All interested parties to respond to list of recommendations and questions by September 30, 2003. Order 2, August 28, 2003 –September 1 filing deadline extended to October 1, 2003 –September 30 comment deadline extended to November 17, 2003

15. Kansas Interconnection Standard Development Requirements for Initial Interconnection Standard Filings Review process flow chart Standards application form Specified maximum generator size for expedited procedure Small generator interconnection technical requirements including specifications, standard contract and application fee Description of approval process, including technical requirements, standard contract and fees, for large generator interconnections Time required for both small and large generator interconnection applications

16. Kansas Interconnection Standard Development Questions and Recommendations Expedited process for certain generators –Size, type, fees, studies, equipment, metering? Time for review NARUC, NRECA, or other models –Application process –Standard application forms –Standard contracts –Verification testing Need for insurance, dispute process, pre-certification FERC standards Isolated generation

17. Kansas Interconnection Standard Development Process Jurisdiction utilities Non-jurisdiction utilities Other interested parties –Formal participation Intervention in the docket Legal representation likely required –Contact Mike Peters at (785) 271-3181 –Informal participation Respond to certain issues Participate in technical conference

18. Kansas Interconnection Standard Development Informal Participation Request Participation –Explain viewpoint on specific issues –Request participation in specific technical conference –Send comments and requests to: –Susan Duffy, Executive Director KCC –1500 Arrowhead Road –Topeka, KS 66604 »Refer to Docket No. 04-GIME-080-GIE –Questions? contact Larry Holloway (785) 271-3222