A more efficient interconnection process for small renewable generators is something we have been working hard to achieve, tediously, state by state. So yesterday’s proposed modifications by the Federal Energy Regulatory Commission (FERC) to its Small Generator Interconnection Procedures is an exciting win. If finalized, it speeds up the approval process, while maintaining safety and reliability. It lays the groundwork for facilitating a national model. And most importantly, it benefits utilities and energy consumers, keeping costs down while removing barriers to the safe, reliable expansion of the solar market.
What does it all mean? Here are some specifics.
The proposed rule changes contain two significant modifications to the expedited review process that will enable a greater number of small renewable generators to interconnect more quickly, without the need for a lengthy study process.
First, FERC proposes to modify the size limit for the current Fast Track process, by adopting an approach pioneered by IREC. Instead of utilizing a single threshold across the entire system, IREC proposed adopting a size limit that would vary depending on several factors. The approach was developed after we heard from utilities across the country regarding the relevant factors that determine what sized generator can safely interconnect at different points on the system, without the need for detailed study. Instead of limiting access to Fast Track to generators sized below 2 MWs, there is now potential for generators up to 5 MWs to interconnect using this expedited process.
Second, in response to the growing volume of interconnection applications and the number of circuits that are starting to see high penetrations of renewables, FERC proposes to modify the Supplemental Review process to incorporate a 100 percent of minimum load screen along with two additional technical screens that evaluate generators’ impact on safety, reliability and power quality. Under the proposed rule, if a generator fails any of the initial Fast Track review screens, including the contested 15 percent of peak load screen, it can choose to be reviewed under the Supplemental Review screens rather than proceeding to full study.
IREC worked first in both California and Hawaii on the development of this improved process and we strongly believe it will help maintain the efficiency of the interconnection process nationally if ultimately adopted by FERC.
Beyond these changes, the proposed rule also adopts an innovative Pre-Application Report that will enable generators to access greater information about existing system conditions prior to submitting a formal application. This process could potentially reduce the overall volume of interconnection requests and help make more efficient use of the existing distribution system. IREC assisted with the development of this process in California’s Rule 21 and supports its adoption by FERC. Finally, FERC proposes allowing generators the opportunity to comment on any upgrades that are determined by the utility to be necessary for interconnection of their system.
IREC helped to develop these proposed changes through active engagement with a wide range of stakeholders in California, Hawaii and Massachusetts. We believe the modifications reflect best practices on interconnection and will provide an important model for state procedures across the country. IREC will continue to engage at FERC in the coming months to help ensure this proposed rule becomes final.
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