PROPOSED RULEMAKING
PENNSYLVANIA PUBLIC UTILITY COMMISSION
[52 PA. CODE CH. 75]
[L-00050175]
Alternative Energy Portfolio Standards; Interconnection Standards for Customer-Generators
[36 Pa.B. 942] The Pennsylvania Public Utility Commission, on November 10, 2005, adopted a proposed rulemaking order which promotes onsite generation by customer-generators using renewable resources and eliminates barriers which may have previously existed regarding interconnection.
Executive Summary
Under section 5 of the Alternative Energy Portfolio Standards Act (73 P. S. § 1648.5), the Pennsylvania Public Utility Commission is required to develop regulations governing interconnection standards within this Commonwealth through a stakeholder process. This is the initial, formal proposed rulemaking resulting from the stakeholder process. The proposed regulations govern the process by which a customer-generator, as defined by the Alternative Energy Portfolio Standards Act, may interconnect onsite generation equipment to an electric utility's distribution lines. The proposed regulations set forth specific levels of review and review criteria depending on the rated generation capacity of the generation equipment. The proposed regulations also provide for a dispute resolution process to manage disputes which may arise during the interconnection process.
Regulatory Review
Under section 5(a) of the Regulatory Review Act (71 P. S. § 745.5(a)), on February 9, 2006, the Commission submitted a copy of this proposed rulemaking and a copy of a Regulatory Analysis Form to the Independent Regulatory Review Commission (IRRC) and to the Chairpersons of the House and Senate Committees. A copy of this material is available to the public upon request.
Under section 5(g) of the Regulatory Review Act, IRRC may convey any comments, recommendations or objections to the proposed rulemaking within 30 days of the close of the public comment period. The comments, recommendations or objections must specify the regulatory review criteria which have not been met. The Regulatory Review Act specifies detailed procedures for review, prior to final publication of the rulemaking, by the Commission, the General Assembly and the Governor of comments, recommendations or objections raised.
Public Meeting held
November 10, 2005Commissioners Present: Wendell F. Holland, Chairperson; James H. Cawley, Vice Chairperson; Bill Shane; Kim Pizzingrilli; Terrance J. Fitzpatrick
Proposed Rulemaking Re Interconnection Standards for Customer-generators pursuant to Section 5 of the Alternative Energy Portfolio Standards Act,
73 P. S. § 1648.5; L-00050175
Implementation of the Alternative Energy Portfolio Standards Act of 2004: Interconnection Standards; M-00051865
Proposed Rulemaking Order By the Commission:
The Alternative Energy Portfolio Standards Act of 2004, 73 P. S. §§ 1648.1--1648.8 (the Act), includes directives that the Commission develop regulations setting forth interconnection standards for customer-generators. In accordance with section 5 of the Act, 73 P. S. § 1648.5, the Commission formally commences its rulemaking process to establish regulations governing interconnection for customer-generators. The Commission seeks comments from all interested parties on these proposed regulations, which are found at Annex A to this Order. Additionally, the Commission will close the Net Metering sub-group as that subgroup has reached its goal by way of this proposed rulemaking Order and the companion rulemaking Order proposing regulations which set forth net metering standards.
Background1
Section 5 of the Act provides as follows:
The commission shall develop technical and net metering interconnection rules for customer-generators intending to operate renewable onsite generators in parallel with the electric utility grid, consistent with rules developed in other states within the service region of the regional transmission organization that manages the transmission system in any part of this Commonwealth. The commission shall convene a stakeholder process to develop Statewide technical and net metering rules for customer-generators. The commission shall develop these rules within nine months of the effective date of this act.73 P. S. § 1648.5.
On March 3, 2005, the Commission convened an Alternative Energy Portfolio Standards Working Group (AEPS WG). The AEPS WG was established to provide a forum for considering the technical standards, business rules and regulatory framework necessary for the Act's implementation. The Net Metering sub-group was formed out of the AEPS WG and was specifically tasked with developing proposed regulations governing net metering and interconnection standards.
The Net Metering sub-group has met on several occasions since March 3 to discuss and develop a set of proposed regulations in two parts. First, the Net Metering sub-group focused on net metering. Second, the Net Metering sub-group focused on interconnection standards, which is the subject of this proposed rulemaking proceeding.
Participants in the Net Metering sub-group have included representatives from Commission Staff, the Department of Environmental Protection (DEP), the Energy Association of Pennsylvania (EAPA) and several of its member companies, the Pennsylvania Farm Bureau, the Office of Consumer Advocate (OCA), the Office of Small Business Advocate (OSBA), Citizens for Pennsylvania's Future (Penn Future), the Small Generator Coalition (SGC) with the Solar Energy Industries Association and several similar entities.
At the initial meeting, participants were requested to discuss various issues which any rulemaking involving interconnection standards would need to address. As the Net Metering sub-group moved forward with the interconnection standards stakeholder process, the Commission determined that the Mid-Atlantic Distributed Resource Initiative (MADRI) was also moving forward with a stakeholder process to develop model interconnection standards for small generators in the PJM Interconnection L.L.C. (PJM) footprint. MADRI is comprised of the public utility commissions of Pennsylvania, Delaware, the District of Columbia, New Jersey and Maryland, along with the United States Department of Energy and PJM. Similar to the Pennsylvania process, stakeholders from the utility industry, consumer organizations, distributed generation interest groups and vendors along with the MADRI members were invited to participate in developing model interconnection standards.
On May 15, 2005, the Commission notified the Net Metering sub-group that it would hold the Pennsylvania interconnection standards process in abeyance, pending the development of a uniform model by the MADRI stakeholder process. Participants in Pennsylvania's Net Metering sub-group were strongly encouraged to participate in the MADRI interconnection process. Participants were advised that the Commission Staff would use the MADRI model as the basis for the Staff proposal which would lead to this Order proposing the interconnection standards rulemaking.
Following several meetings held in June, July and August of 2005, the MADRI stakeholder group advised Commission Staff that a draft model addressing interconnection standards was in sufficient form to merit consideration in the Pennsylvania process. Commission Staff received the MADRI model on or about August 19, 2005. On August 29, 2005, Staff issued its initial proposal (initial Staff proposal) to the Pennsylvania Net Metering sub-group and requested comments on or before September 19, 2005. The initial Staff proposal was based upon the MADRI model interconnection standards. In the notice for comments, Staff identified those areas where the initial Staff proposal modified the MADRI model and invited comments specifically directed to those modifications as well as any other areas participants wished to address.
Following the receipt of comments to the initial Staff proposal, Commission Staff developed the recommendation now before us. This Staff proposal was developed based upon the MADRI model interconnection standards as of August 19, 2005, the initial Staff proposal which modified that model, and comments submitted through the Net Metering sub-group process. The foregoing is consistent with the Act's mandate that these regulations be developed through a stakeholder process.
Discussion
The Act provides a great deal of flexibility to the Commission regarding net metering and interconnection, providing only that the regulations are to be developed through a stakeholder process and, to the extent possible, regulations promulgated here should be ''consistent with rules defined in other states'' within the transmission zones of regional transmission organizations serving Pennsylvania. As we have noted previously, the proposal now before us has been developed using the MADRI stakeholder process as well as the Pennsylvania specific Net Metering sub-group. Certainly, the MADRI process developed its model with a view to rules and circumstances existing in states within the PJM footprint. During the consideration of the MADRI model and its own modifications, Commission Staff has also continued to monitor other states and their efforts with regard to interconnection.
The proposed interconnection standards are consistent with the rules now in place in other jurisdictions within the transmission zones of regional transmission organizations serving Pennsylvania. In addition, the proposed regulations have been drafted with a view towards promoting onsite generation by customer-generators using renewable resources, consistent with the over-arching goal of the Act. Accordingly, the proposed regulations strive to eliminate barriers which may have previously existed with regard to interconnection while ensuring that interconnection by customer-generators will not pose unnecessary risks to the electric distribution systems in the Commonwealth nor unduly burden other customers on a particular electric distribution company's (EDC) system.
As noted in the companion net metering rulemaking, the Commission is proposing to add Chapter 75 to its regulations. Chapter 75 will contain many of the regulations needed to implement the Act. Proposed Subchapter A of Chapter 75 contains a set of definitions for terms that will be used throughout Chapter 75. Proposed Subchapter B contains the net metering regulations. In this Order, we propose to add Subchapter C, found in Annex A to this Order, to Chapter 75.
A. Scope
This section endeavors to set forth the scope of the interconnection standards adopted under the Act. In the initial Staff proposal, the Scope of the regulations was described as applying to residential and small commercial customers. In the net metering rulemaking, several participants commented that use of the phrase ''residential and small commercial customers'' had the potential of excluding some agricultural customers who otherwise would be considered ''customer-generators'' under the Act.
Specific comments were not received on the proposed scope in this rulemaking. However, we have modified the initial Staff proposal to be consistent with the scope provided in the net metering rulemaking. As we stated there, paraphrasing the Act is the best method of setting forth the scope of the regulations. The Act expressly provides that the net metering and interconnection regulations are to be developed for ''customer-generators.'' That term is defined in the Act and has specific capacity limits in place. Accordingly, the proposed scope of the regulations provides that they apply to EDCs which have customer-generators who intend to pursue net metering and interconnection opportunities in accordance with the Act.
B. Interconnection definitions
Several new definitions are set forth in Subchapter C that were not in the initial Staff proposal. Definitions for ''Adverse System Impact,'' ''Area Network,'' ''Interconnection Facilities,'' and ''Queue Position'' have been developed, among others. Several participants proposed ministerial edits to definitions which provided greater clarity and they have been adopted in this proposed rulemaking. For example, one of the participants suggested modification of the definition of ''Small Generator Facility'' to delete material that was not properly within a definition. In addition, we will eliminate several definitions from the Staff proposal since they have been included in proposed Subchapter A in the net metering rulemaking and need not be repeated here. We also point out that the definition of ''Adverse System Impact'' has been modified to provide that such an impact occurs when a negative effect compromises the safety and reliability of the electric distribution system. We have deleted the word ''may'' from the definition.
One of the comments suggested that the definition of ''Certification of Completion'' include the possibility of using forms used by local inspection authorities to signify completion of any required local inspections. We have modified that definition consistent with that comment. We have also eliminated the definition of PJM Interconnection L.L.C. and used the more encompassing ''Regional Transmission Organization'' or ''RTO.'' That term is defined in proposed Subchapter A contained in the Net Metering rulemaking.
One issue has been raised by the EAPA. The EAPA recommends the addition of a definition for ''Affected System.'' The EAPA suggests that there will be situations where interconnection of a customer-generator may have an impact on a neighboring EDC, particularly for higher capacity installations. Accordingly, the EAPA recommends adding ''Affected System'' to the definitions and providing a mechanism for system study and accounting/cost allocation in these situations. The Commission requests comments specifically addressing this issue as presented by the EAPA in its comments to the initial Staff proposal.2 Comments in support of the EAPA position should also address the language to be used for the definition and its implementation in the review levels.
C. General Interconnection Provisions
This section describes the procedures for small generators with a nameplate capacity of up to two megawatts who wish to interconnect to an EDC's electric distribution system. The procedures divide the process into four distinct review screens, Levels 1, 2, 3, and 4, depending on the size and nature of the interconnection equipment involved. It should be noted that the initial Staff proposal provided for a Level 3A, but no level 4. Several comments suggested changing the Level 3A review to Level 4 for the sake of clarity. We have adopted that comment.
Level 1 projects are those which: a) have a nameplate capacity of 10 kW or less; and, b) are inverter based using customer interconnection equipment that is certified.
Level 2 projects are those which: a) have a nameplate capacity rating which is 2 MW or less; b) are inverter based; c) have received certification of the customer's interconnection equipment or review of the generator facility under Level 1 was not approved.
Level 3 projects are those which: a) have a nameplate capacity of 2 MW or less; b) do not qualify for either Level 1 or Level 2 review procedures or have been reviewed under Level 1 or Level 2 process but have not been approved for interconnection.
Interconnection customers who do not qualify for Level 1 or Level 2 review and do not export power to the grid may request to be evaluated under Level 4, which is an expedited review process.
West Penn Power raised the concern that the timelines for application review may need to be extended in emergencies when EDC employees that ordinarily review applications are temporarily assigned to emergency functions. Initially, it appears that these concerns can be addressed on a case-by-case basis through a waiver or some other method rather than providing specific regulatory treatment. However, the Commission specifically requests comments on this issue.
The Level 2 review process is limited to inverter based equipment. Penn Future and the SGC suggested that this restriction should be removed. The SGC noted that the limitation for inverter based equipment in a Level 2 review is not present in the Federal Energy Regulatory Commission's (FERC) proposed uniform interconnection standards (FERC Order 2006). Conversely, Staff has received comments that other types of equipment could present technical problems which a Level 2 review is not designed to address. The Commission requests comments on this issue. Please provide specific details in support of any comments filed.
The Staff proposal provides that an interconnection request for an increase in capacity is to be evaluated on the basis of the total nameplate capacity. Penn Future and the SGC suggested that the evaluation should be based on the new incremental addition only. To ensure system reliability and to remain within the mandate of the Act, Staff believes that the review must be based on the total nameplate capacity of the interconnection facility. Any comments on this issue should specifically address the concern that any interconnection review must evaluate the total capacity which may flow onto an EDC's electric distribution system at a given point.
The EDC is required to maintain records for three years on interconnection requests received, time required to approve or disapprove, and justification for the action taken. Penn Future and SGC support this requirement and suggest that this record keeping be expanded into a report requirement. Penn Future also suggests that additional data should be collected on the total number of interconnection customer requests, the timeliness of processing, issues raised and their resolution. On the basis of these comments, we have expanded upon the reporting requirements that were originally presented in the initial Staff proposal. The report will be expanded to include: the total number of interconnection customer requests; the number of requests denied or moved to another review level; and, the number of requests that were not processed within established timelines. We believe that this provides adequate information for the Commission to monitor the process without imposing undue reporting burdens on the EDCs.
An EDC may propose to interconnect more than one small generator facility at a single point of interconnection to minimize cost. The OSBA commented that the regulation does not explicitly state that the EDC is to bear the cost of the single point interconnection. The Commission seeks comments on this issue.
The lack of a requirement for a readily accessible external AC disconnect switch was the subject of much discussion and comment. Many participants argued that the external switch was unnecessary if certified inverter equipment was used. They suggested that the running of cable and other equipment would make the external switch too costly with little or no additional benefit. The EDCs strongly advocated the need for a readily accessible disconnect switch for worker safety and system reliability. A compromise position was presented that proposed the use of a lock box to house a key that would allow the EDC to gain access to the interconnection equipment whether it was inside the structure or elsewhere on the property.
We believe the customer should be given the choice of installing an accessible external disconnect switch or a lockbox to hold a key to provide entry to the interconnection facility. The customer will allow the EDC to place a placard in a location of the EDC's choosing that gives instructions on how to gain access to the isolation device. We have modified the initial Staff proposal and specifically request comments on this issue.
For interconnection of a proposed small generator facility to the load side of spot network protectors, the proposed small generator facility must utilize an inverter-based equipment package, the interconnection equipment must be certified and the aggregated other generation on that spot network may not exceed 5% of the spot network's maximum load. The EAPA commented that a 50 kW cap in addition to the 5% requirement is necessary for system reliability and safety. The Commission requests additional comments on this issue. Comments should provide detailed technical information regarding why a specific kilowatt cap is necessary in addition to the percentage of load cap.
The review periods for customer generator applications follow the MADRI recommendations. Certain parties suggested that the review periods were too long. The projects at issue will normally have a 10 to 20 year useful life. On that basis, we believe that a review period of 25-35 days as opposed to 10-15 days will not significantly impact the feasibility of the project or create a barrier to entry. At the same time, the longer review periods will permit EDCs to review the applications without undue haste or require significant personnel additions. Any comments on these timelines should specifically explain why shorter time frames will provide substantial benefits to the applicant while not imposing substantial hardships on the EDCs.
The OCA suggested that under the Level 1 review we clarify that the EDC has 10 days to determine that the application is complete in addition to the 15 days that the EDC has to determine that the equipment can be interconnected safely and reliably. This is the correct interpretation. The EDC has a total of up to 25 days to determine that the application is complete and that the equipment can be interconnected safely.
The Staff proposal provides that distribution protective devices are not to be exposed to fault currents exceeding 85% of the short circuit interrupting capability. The SGC suggested that 85% was too low and wanted the level raised to at least 90%. Comments provided by an EDC suggested 82% was more appropriate. The EAPA argued that 80% is the appropriate limit. Commission Staff suggests that a 90% cap offers too little margin for error and an 80% cap is too conservative based on the EDC's own analysis. Therefore, the proposed regulation adopts an 85% fault current limit. We request specific comments on this issue. Again, please provide technical detail in support of the comments.
Section 75.39 describes the types of generator facilities that may be considered under a Level 3 review. This class permits applications not approved under Levels 2 and 4, to be submitted as new interconnection requests for consideration under Level 3 review. The generation facilities are described as facilities with a nameplate capacity of less than 2 MW that are not certified and are non-inverter based.
The EDC has 10 business days to complete its initial review of a Level 3 request, and if necessary, shall advise the applicant in writing of any additional information needed to satisfy the review. If the EDC requests additional information from the applicant, 10 business days shall be allowed for response. The request shall be deemed complete when the requested information is received and reviewed by the EDC. The interconnection customer may request additional time to respond to the EDC's request for additional information.
The Level 3 review process includes a Scoping Meeting, Interconnection Feasibility Study, an Interconnection Impact Study, an Interconnection Facilities Study and a Witness Test. The EDC and applicant may agree to waive some of the steps in appropriate circumstances. A non-binding good faith estimated cost of the required studies is to be developed by the EDC and shall be the responsibility of the applicant.
If, as a result of the studies conducted, the EDC determines that the application should be granted, a Standard Small Generator Interconnection Agreement shall be provided to the applicant from the EDC. Upon receipt of the agreement, the applicant shall have 30 days, or another mutually agreeable timeframe, to sign and return the agreement to the EDC. Conversely, if upon the result of the studies conducted, the EDC determines that the interconnection request should be denied, the EDC shall provide a written explanation to the applicant.
A small generator facility that does not qualify for a Level 1 or Level 2 review may request to be evaluated under Level 4 procedures. Evaluation under Level 4 may also pertain to interconnection requests where there is no desire for export capability to the EDC's distribution system. A Level 4 review may also be used for requests for interconnection on the load side of an area network for facilities with a nameplate capacity up to 10 kW, utilizing certified inverter-based equipment, with customer-generator installed reverse power relays and where the aggregated other generation on the area network does not exceed 5% of that network's maximum load.
The SGC suggested eliminating the Level 4 review and addressing those applications under Level 2 reviews for non-exporting generators. The EAPA asserted in its comments that absent a 50 kW limitation, as incorporated into the FERC Order 2006 standards in addition to the 5% limitation, a portion of the system could fall out of balance and cause failures in network protectors, especially under light load conditions. The EAPA also commented that Level 4 reviews should be permissive rather than mandatory as provided in the Staff proposal. The EAPA commented that the permissive use of a Level 4 review was agreed to by the majority of the MADRI working group to allow the EDC the flexibility to permit an expedited interconnection review for an area network while preserving its ability to perform more detailed reviews when necessary. The EAPA believes the proposed regulations are inconsistent with EDCs' current practices in the design of area networks to meet reliability standards. The EAPA stated that such an approach would negatively impact the ability of EDCs to meet the Commission's reliability benchmarks and should, therefore, result in revision of the benchmarks.
We request additional comments on the EAPA issues presented previously to clarify the technical aspects of incorporating the 50 kW limitation as well as permissive versus mandatory use of Level 4 reviews in specific instances. As noted before, specific technical support for a stated position is crucial to the Commission's determination in these areas.
D. Dispute Resolution
In this section, we outline the process the parties will use to resolve any disputes arising from the interconnection process. The proposed regulations direct aggrieved parties to the Commission's complaint procedures, but emphasize that informal alternative dispute resolution is preferred for the sake of expediency. The regulations propose that disputes related to the technical details of interconnection be referred to a Commission designated technical master. Any costs associated with dispute resolution will ultimately be determined by the Commission.
E. Insurance and Indemnification
The proposed regulations do not address indemnification or liability insurance. Commission Staff suggests that the appropriate vehicle for indemnification, and insurance requirements, if any, would be the interconnection agreement form. Some participants have suggested following the MADRI model with regard to insurance. MADRI's standard interconnection agreement does not require customer generators to provide general liability insurance, but does recommend that every customer generator protect itself with insurance due to the risk of incurring damages. It should be noted that proposed § 75.13(k) in the proposed net metering regulations provides that insurance may not be required by an EDC. We invite comments on the issue of requiring customer generators to provide general liability insurance as a prerequisite for interconnection. Comments on this issue should discuss whether the issue of insurance and indemnification is different, depending on the nature of the interconnection equipment involved.
F. Forms and Fees
At several points in the proposed regulations, reference is made to the use of forms, agreements and fees as approved by the Commission. As we move further into the rulemaking process, the Commission will initiate a proceeding to establish uniform form agreements and fees for interconnection and net metering purposes. That process is expected to take the form of one or more tentative orders, followed by comments and a final order resulting in uniform forms and fees. The proposed regulations do require that standard forms be posted on the EDC websites.
Conclusion
The Commission welcomes the filing of comments by all interested parties on all aspects of these regulations. As we have previously noted, the Commission is particularly interested in comments regarding the following issues: definition of ''affected system'' and its impact on the applicable review level; the extension of timelines in emergency circumstances; whether Level 2 reviews should be restricted to inverter based equipment; whether review of an increase in capacity should be limited to the incremental addition or involve the total rated capacity of the generation equipment for which interconnection is sought; who bears the cost of a single point of interconnection for several customer-generators when recommended by the EDC; the external disconnect switch/lock box option; elimination of a set kilowatt limitation for spot networks in favor of a percentage limit only; the timelines for application review by the EDCs; the stated 85% limitation for fault currents; elimination of the 50 kW limitation for area network applications in favor of a percentage only cap; the mandated use of Level 4 reviews in certain circumstances; and, the issue of insurance requirements for customer-generators. Please bear in mind that specific, technical information has been requested to support positions taken on most of these issues.
To the extent that a participant believes any section of these proposed regulations needs modification, alternative language should be proposed together with the rationale for the modification. This is particularly important in the area of definitions. A comment period of 60 days has been provided.
Accordingly, under section 501 of the Public Utility Code, 66 Pa.C.S. §§ 501; section 5 of the Alternative Energy Portfolio Supply Act of 2004, 73 P. S. § 1648.5; sections 201 and 202 of the act of July 31, 1968, P. L. 769 No. 240, 45 P. S. §§ 1201 and 1202, and the regulations promulgated thereunder at 1 Pa. Code §§ 7.1, 7.2, and 7.5; section 204(b) of the Commonwealth Attorneys Act, 71 P. S. 732.204(b); section 745.5 of the Regulatory Review Act, 71 P. S. § 745.5; and section 612 of The Administrative Code of 1929, 71 P. S. § 232, and the regulations promulgated thereunder at 4 Pa. Code §§ 7.231--7.234, we are considering adopting the proposed regulations set forth in Annex A; Therefore,
It Is Ordered That:
1. The proposed rulemaking will consider the regulations set forth in Annex A.
2. The Secretary shall submit this order and Annex A to the Office of Attorney General for review as to form and legality and to the Governor's Budget Office for review of fiscal impact.
3. The Secretary shall submit this order and Annex A for review and comments to IRRC and the Legislative Standing Committees.
4. The Secretary shall certify this order and Annex A and deposit them with the Legislative Reference Bureau to be published in the Pennsylvania Bulletin.
5. An original and 15 copies of any written comments referencing the docket number of the proposed regulations be submitted within 60 days of publication in the Pennsylvania Bulletin to the Pennsylvania Public Utility Commission, Attn.: Secretary, P. O. Box 3265, Harrisburg, PA 17105-3265.
6. A copy of this order and Annex A shall be served on the DEP, all jurisdictional electric distribution companies, all licensed electric generation suppliers, the Office of Trial Staff, the Office of Consumer Advocate, the Office of Small Business Advocate and all other participants in the Alternative Energy Portfolio Supply Working Group at M-00051865.
7. The contact persons for this proposed rulemaking are Greg Shawley, Bureau of Conservation, Economics and Energy Planning, (717) 787-5369 (technical); and H. Kirk House, Office of Special Assistants, (717) 772-8495 (legal).
JAMES J. MCNULTY,
SecretaryFiscal Note: 57-245. No fiscal impact; (8) recommends adoption.
Annex A
TITLE 52. PUBLIC UTILITIES
PART I. PUBLIC UTILITY COMMISSION
Subpart C. FIXED SERVICE UTILITIES
CHAPTER 75. ALTERNATIVE ENERGY PORTFOLIO STANDARDS
Subchapter C. INTERCONNECTION STANDARDS GENERAL
75.21. Scope. 75.22. Definitions. INTERCONNECTION PROVISIONS
75.31. Applicability. 75.32. Interconnection requests. 75.33. Fees and forms. 75.34. Review procedures. 75.35. Technical standards. 75.36. Additional general requirements. 75.37. Level 1 interconnection review. 75.38. Level 2 interconnection review. 75.39. Level 3 interconnection review. 75.40. Level 4 interconnection review. DISPUTE RESOLUTION
75.51. Disputes.
GENERAL § 75.21. Scope.
This subchapter sets forth the interconnection standards that apply to EDCs which have customer-generators intending to pursue net metering opportunities in accordance with the act.
§ 75.22. Definitions.
The following words and terms, when used in this subchapter, have the following meanings unless the context clearly indicates otherwise:
Adverse system impact--A negative effect, due to technical or operational limits on conductors or equipment being exceeded, that compromises the safety and reliability of the electric distribution system.
Applicant--A person who has submitted an interconnection request to interconnect a small generator facility to an EDC's electric distribution system, also referred to as the interconnection customer.
Area network--
(i) A type of electric distribution system served by multiple transformers interconnected in an electrical network circuit, which is generally used in large metropolitan areas that are densely populated.
(ii) The term has the same meaning as the term ''distribution secondary grid network'' as stated in IEEE Standard 1547 Section 4.1.4 (published July 2003), as amended and supplemented.
Certificate of completion--A certificate in a form approved by the Commission containing information about the interconnection equipment to be used, its installation and local inspections. Completion of local inspections may be designated on inspection forms used by local inspecting authorities.
Certified--A designation that the interconnection equipment to be used by a customer-generator complies with the following standards, as applicable:
(i) IEEE Standard 1547, Standard for Interconnecting Distributed Resources with Electric Power Systems, as amended and supplemented.
(ii) UL Standard 1741, ''Inverters, Converters and Controllers for use in Independent Power Systems'' (January 2001), as amended and supplemented.
Distribution upgrade--A required addition or modification to the EDC's electric distribution system at or beyond the point of interconnection. Distribution upgrades do not include interconnection facilities.
Electric distribution system--
(i) The facilities and equipment used to transmit electricity to ultimate usage points such as homes and industries from interchanges with higher voltage transmission networks that transport bulk power over longer distances. The voltage levels at which electric distribution systems operate differ among areas but generally carry less than 69 kilovolts of electricity.
(ii) Electric distribution system has the same meaning as the term Area EPS, as defined in 3.1.6.1 of IEEE Standard 1547.
Electric nameplate capacity--The net maximum or net instantaneous peak electric output capability measured in volt-amps of a small generator facility as designated by the manufacturer.
Fault current--The electrical current that flows through a circuit during an electrical fault condition. A fault condition occurs when one or more electrical conductors contact ground or each other. Types of faults include phase to ground, double-phase to ground, three-phase to ground, phase-to-phase, and three-phase. Often, a fault current is several times larger in magnitude than the current that normally flows through a circuit.
IEEE standard 1547--The most current official published version of the Institute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 1547 (2003) ''Standard for Interconnecting Distributed Resources with Electric Power Systems'' at the time the interconnection request is submitted.
IEEE standard 1547.1--The most current official published version of IEEE Standard 1547.1 (2005) ''Conformance Test Procedures for Equipment Interconnecting Distributed Resources with Electric Power Systems'' at the time the interconnection request is submitted.
Interconnection agreement--An agreement between an interconnection customer and an EDC, which governs the connection of the small generator facility to the electric distribution system, as well as the ongoing operation of the small generator facility after it is connected to the system consistent with the requirements of this subchapter.
Interconnection customer--An entity, including an EDC, that proposes to interconnect a small generator facility to an electric distribution system.
Interconnection equipment--A group of components or integrated system connecting an electric generator with an electric distribution system that includes all interface equipment including switchgear, protective devices, inverters or other interface devices. Interconnection equipment may be installed as part of an integrated equipment package that includes a generator or other electric source.
Interconnection facilities--Facilities and equipment required by the EDC to interconnect the small generator facility and the interconnection customer's interconnection equipment. Collectively, interconnection facilities include all facilities and equipment between the small generator facility and the point of common coupling, including any modification, additions or distribution upgrades that are necessary to physically and electrically interconnect the small generator facility to the EDC's electric distribution system. Interconnection facilities are sole use facilities and do not include distribution upgrades.
Interconnection facilities study--A study conducted by the EDC or a third party consultant for the interconnection customer to determine a list of facilities (including EDC's interconnection facilities and required distribution upgrades to the electric distribution system as identified in the interconnection system impact study), the cost of those facilities, and the time required to interconnect the small generator facility with the EDC's electric distribution system.
Interconnection facilities study agreement--An agreement in a form approved by the Commission which details the terms and conditions under which an EDC will conduct an interconnection facilities study.
Interconnection feasibility study--A preliminary evaluation of the system impact and cost of interconnecting the small generator facility to the EDC's electric distribution system.
Interconnection feasibility study agreement--An agreement in a form approved by the Commission which details the terms and conditions under which an EDC will conduct an interconnection feasibility study.
Interconnection request--An interconnection customer's request, in a form approved by the Commission, requesting the interconnection of a new small generator facility, or to increase the capacity or operating characteristics of an existing small generator facility that is interconnected with the EDC's electric distribution system.
Interconnection study--Any of the following studies:
(i) The Interconnection Feasibility Study.
(ii) The Interconnection System Impact Study.
(iii) The Interconnection Facilities Study.
Interconnection system impact study--An engineering study that evaluates the impact of the proposed interconnection on the safety and reliability of an EDC's electric distribution system. The study must identify and detail the system impacts that would result if the small generator facility were interconnected without project modifications or system modifications, focusing on the adverse system impacts identified in the interconnection feasibility study, or to study potential impacts.
Interconnection system impact study agreement--An agreement in a form approved by the Commission which details the terms and conditions under which an EDC will conduct an interconnection system impact study.
Line section--That portion of an EDC's distribution system connected to an interconnection customer, bounded by automatic sectionalizing devices or the end of the distribution line.
Minor equipment modification--Changes to the proposed small generator facility that do not have a material impact on safety or reliability of the electric distribution system.
NRTL--Nationally recognized testing laboratory--A qualified private organization that meets the requirements of the Occupational Safety and Health Administration's (OSHA) regulations. NRTLs perform independent safety testing and product certification. Each NRTL must meet the requirements as set forth by OSHA in the NRTL program.
Parallel operation-parallel--The state of operation which occurs when a small generator facility is connected electrically to the electric distribution system and the potential exists for electricity to flow from the small generator facility to the electric distribution system.
Point of common coupling--The point where the customer's interconnection equipment connects to the electric distribution system at which harmonic limits or other operational characteristics (IEEE Standard 1547 requirements) are applied.
Point of interconnection--The point where the interconnection equipment connects to the EDC's electric distribution system.
Queue position--The order of a valid interconnection request, relative to all other pending valid interconnection requests, that is established based upon the date and time of receipt of the valid interconnection request by the EDC. An interconnection request may not be deemed invalid by virtue of its being finally evaluated under different procedures than those under which it was originally considered. For example, an interconnection request originally submitted as a Level 1 interconnection request but eventually evaluated under Level 2 procedures is still a valid interconnection request and is to be assigned a queue position based on the date of its original submission as a Level 1 interconnection request.
Scoping meeting--A meeting between representatives of the interconnection customer and EDC conducted for the purpose of discussing alternative interconnection options, exchanging information including any electric distribution system data and earlier study evaluations that would be reasonably expected to impact interconnection options, analyzing information, and determining the potential feasible points of interconnection.
Small generator facility--The equipment used by an interconnection customer to generate, or store electricity that operates in parallel with the electric distribution system. A small generator facility typically includes an electric generator, prime mover, and the interconnection equipment required to safely interconnect with the electric distribution system.
Spot network--The term has the same meaning as the term ''spot network'' under IEEE Standard 1547 Section 4.1.4, (published July 2003), as amended and supplemented. As of August, 2005, IEEE Standard 1547 defined ''Spot Network'' as ''a type of electric distribution system that uses two or more inter-tied transformers to supply an electrical network circuit.'' A spot network is generally used to supply power to a single customer or a small group of customers.
Standard small generator interconnection agreement (SGIA)--A form of interconnection agreement approved by the Commission which is applicable to a Level 2, Level 3 or Level 4 interconnection request pertaining to a small generating facility.
UL Standard 1741--Means Underwriters Laboratories' standard titled ''Inverters Converters, and Controllers for Use in Independent Power Systems.''
Witness test--The EDC's interconnection installation evaluation required by IEEE Standard 1547 Section 5.3 and the EDC's witnessing of the commissioning test required by IEEE Standard 1547 Section 5.4. For interconnection equipment that has not been certified, the witness test shall also include the witnessing by the EDC of the on-site design tests as required by IEEE Standard 1547 Section 5.1 and witnessing by the EDC of production tests required by IEEE Standard 1547 Section 5.2. All tests witnessed by the EDC are to be performed in accordance with IEEE Standard 1547.1
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1 In our Implementation Order entered March 25, 2005, at this docket, we stated that we would use the Advanced Notice of Proposed Rulemaking proceeding at L-00040168 (Order entered November 19, 2004) as a means to initiate this interconnection rulemaking process. However, with the enactment of the Energy Policy Act of 2005, we have decided to hold the November 19, 2004 Order in abeyance and issue a new docket number for this proceeding, specific to the interconnection standards rulemaking under the Act.
2 The EAPA comments to the initial Staff proposal may be found at this Commission's website at www.puc.state.pa.us in the electricity/issues/Alternative Energy Portfolio Standards tabs.
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