Over the past decade, the Interstate Renewable Energy Council (IREC) has worked with dozens of states across the country to facilitate and support the adoption of fundamental regulatory policy reforms that maintain the safety and reliability of the electric grid, while also allowing for fair, affordable and efficient consumer access to renewable energy. Central to our efforts is a concerted focus on interconnection standards – the technical protocols that govern the processes by which renewable energy projects connect with the electricity grid.
As with all standards, interconnection processes are constantly evolving and changing, particularly as demand for renewable energy grows, penetration increases, and as technologies and protocols evolve. While no simple task to update these complex standards, the merits of staying ahead of the curve are substantial, as more and more states run into challenges stemming from outdated interconnection standards.
Over the past few years, the Midwest has received a lot of IREC’s attention, as three emerging renewable energy markets in particular are seeking to stay ahead of the curve and tackle interconnection reform. IREC is pleased to see the direction this region is heading as the first of three states, Illinois, moves toward final adoption of a substantial overhaul (and improvement) of their interconnection standards. Heading in to 2016, Iowa and Minnesota are poised to follow suit, setting the stage for a renewable energy policy trifecta in the Midwest.
IREC’s efforts in Illinois started in 2014, when we supported the Environmental Law and Policy Center (ELPC) and the Citizens Utility Board (CUB) in their petition to the Illinois Commerce Commission to consider proactive updates to the state interconnection standards to ensure they reflected the most up-to-date national best practices. While the Illinois interconnection standards reflected best practices when they were initially adopted in 2008, considerable advancements in both the renewable energy market as well as in the techniques and processes used to evaluate the impacts of these systems on the grid warranted an update.
In its 2013 landmark decision, the Federal Energy Regulatory Commission (FERC) revised its Small Generator Interconnection Standards (SGIP), which serve as a model for state standards, after finding that it was necessary in order to ensure they “remain just and reasonable and not unduly discriminatory.” IREC also updated its model interconnection procedures earlier in 2014 to reflect emerging best practices. Since the Illinois procedures were based on these two models, it was time to take a fresh look at them.
After a lengthy series of workshops and multiple rounds of comments, in November 2015 the Illinois Commission voted unanimously to publish a First Notice in the state register that includes adoption of the most important best practices that have emerged from the updates to the IREC and FERC models. The changes include adoption of pre-application reports, increased size limits for the expedited review processes, and an enhanced supplemental review process that will allow more projects to access expedited review even as renewable energy penetration increases. If adopted, the new Illinois rules will make it easier for the state’s utilities to process interconnection applications for small and mid-sized distributed generation systems, resulting in cost savings for ratepayers and reduced delays (and frustrations) for developers, consumers, and utilities alike.
The Illinois Commission decision is important for the Midwest, and the rest of the country, because Illinois is the first state to take proactive efforts to update interconnection standards before the utilities began experiencing significant queue backlogs and before substantial numbers of projects began to fail the initial expedited review screens. Rather than waiting until a boiling point was reached, Illinois took to heart the experiences of high penetration states such as Hawaii, California, and Massachusetts and decided to move ahead with well tested interconnection reforms that will help the state’s renewable energy market thrive for many years to come.
As we look beyond the borders of Illinois, we are starting to see positive signs that other states in the Midwest may also be moving toward improved interconnection standards. In Iowa, the state’s largest utilities have recently affirmatively supported adoption of many of the FERC SGIP innovations (the same ones that are poised for adoption in Illinois). With wide ranging stakeholder support, we are hopeful that the Iowa Utilities Board will continue the favorable Midwest trend and adopt national best practices in coming months. Minnesota has unfortunately already begun to experience some of the heartburn associated with inadequate interconnection standards as the utilities begin to process a significant number of applications for the state’s community solar gardens. The rough road that these projects have gone through has brought interconnection to the state’s attention and some commissioners have acknowledged that it is time to take a closer look at the standards in that state.
As IREC looks ahead to 2016, we look forward to continuing our efforts to work with local partners in the Midwest (and many other states) to guide and inform the adoption of best practice interconnection standards that match, or even exceed, national best practices. To the extent Illinois is a bellwether state for the region, we are hopeful that more states will take similar positive steps to enable renewable energy market growth without the growing pains.