Meeting #1: Summary - Raab Associates



Meeting #1 Summary

The Massachusetts Distributed Generation Interconnection Collaborative

Monday, November 4, 2002

NStar Conference Room

The Prudential Building

Boston, MA

40 People attended the meeting, which began at 9:30 and ended at 3:45. See attached attendance list.

I. Documents Distributed

Prior to the meeting

- Joint Utilities Proposed Interconnection Standards

- Proposed Groundrules

- (via website) Interconnection standards from other regulatory agencies and standards-setting bodies.

i. California Rule 21

ii. Texas

iii. New York

iv. NARUC

v. FERC ANOPR Attachments A and B

vi. IEEE P1547

At the meeting

- Slide handouts from the utilities’ presentation on their joint proposed interconnection standards.

Introduction

Dr. Jonathan Raab opened the meeting, providing an overview of the process and the schedule. He introduced the facilitation team, and noted that MTC has provided resources for a technical consultant to work with the facilitators and collaborative members. Stan Blazewicz and Eugene Shlatz of Navigant Consulting Inc. will serve in this role.

Procedural Issues

First, the Group discussed the Collaborative’s membership and the Ground Rules. It approved both the membership and the Ground Rules, but noted that Ground Rule 3, which states that alternates may sit at the inner table only in the absence of the lead representative, needs clarification. The Group agreed that while each member would continue to have only one seat at the inner table, members could determine whether to put the alternate or lead at the table as the member deems appropriate.

Group members also made comments about the need to manage the consensus process in a way that allows time for representatives to consult with their constituencies and reflect on potential points of agreement between meetings, and about whether issues outside of the scope of the interconnection focus would be addressed. Dr. Raab noted that, given the time constraint and charge to the group, the focus would be primarily on the issues listed in the DTE order. However, if consensus developed on other issues, it may be possible to note those agreements in the report to DTE. He also pointed out that the members need to be clear on a case-by-case basis about when they need to take certain issues back to their organizations before final sign-off.

Presentation on the Joint Utilities’ Proposed Interconnection Standards by Tim Roughan and John Bzura of National Grid

The utility cluster group reviewed a proposal for interconnection standards by National Grid, Northeast Utilities, NStar, and Unitil/FG&E. Click here to view the presentation.

Group feedback on the utilities’ presentation, and issues in need of further consideration

The group had a free-ranging discussion in which members voiced their initial reactions to the utilities’ document, as well as their opinions as to which issues the Collaborative should flag for further discussion. Most comments related to the structure and length of the interconnection process, the system of classifying distributed generation (DG) units by size for the purpose of assessing their impact on grid reliability and safety, how to address the need for utilities to study those impacts when a DG interconnection is proposed, and intertwining the Massachusetts DG interconnection regime with that in place in other parts of the country and at the Federal level.

Process Issues

Many of the group’s comments surrounded how to streamline the costs and time required for a generator to win approval to interconnect.

The comments by one or more Group members in this field follows. They are not meant to depict a consensus recommendation of the Group.

• There is a need for each utility to assign staff to deal with small generators, as well as large generators, as their needs may differ. This would help shorten the time to interconnect while maintaining the appropriate controls on network reliability and safety. Also, have a central repository (website and/or a manual) for DG customers that contains all relevant technical and process-related information. This might be separate from web sites available to the general public. Can the utilities’ interconnection processes be streamlined such that bringing DG online is similar to a new-customer connect?

• Is 45 days too much time for Cat I/II interconnections?

• The DG provider needs to notify the utility if the DG provider intends to disconnect. Such a requirement is not in the utility documents.

• DG owners and operators should not have any requirements imposed by the utilities regarding when they can take their facilities off line.

• The interconnection standards process must be accompanied by a speedy and low-cost dispute resolution process, especially given that an expensive ADR process would be a significant barrier to market entry for small DG.

Classification

The group was largely in agreement that small generators are likely to have negligible grid impact and that some sort of expedited track for approval of certain units is advisable. The group differed on how to classify larger generators, and some members offered thoughts on alternative or supplemental classification criteria not necessarily tied to size.

The comments by one or more Group members in this field follows. They are not meant to depict a consensus recommendation of the Group.

• The 10kw super-expedited track in the utilities document is a welcome element and needs to be preserved in the Collaborative’s final document.

• In the categorization of size, there was concern about the larger categories where interconnection was not automatic. When the utilities indicate that a generating facility (GF) can qualify for interconnection pending further study, it would be helpful if DG providers knew more about the scope, timeline, and costs associated with further study.

• The utilities’ requirements indicate that a GF may be interconnected where the GF does not exceed 5% of load – who determines what the load is?

• The utilities’ generator classification scheme (and the interconnection processes associated with each of the tiers) is a function of planning that focuses on worst-case scenarios. Such planning may be appropriate for safety or reliability, but it is not useful for classifying machines. Outlying cases should be treated separately and not used as a basis for rules.

• Does a 20 KW DG on a 1 MW load have the same grid impact as it would if attached to a 100 KW load? The size of the generator relative to the load it serves is a driver of grid impacts, and this could be a part of a screen.

• Systems that displace load are cheaper to study than those that are trying to sell back into the grid. Thus, distinguishing between exporters and non-exporters could be a logical element of a DG classification system.

• Category 3, 4 and 5 generators may use inverters, not only induction or synchronous generators as outlined in the proposal. Devices falling in these categories should be planned for in the classification system.

• Strive to create functional/performance-based criteria and not just descriptive/prescriptive criteria.

Studies – structure and who should pay for them

The group was also was in broad agreement that studies will be necessary to assess the impacts of certain DG units. Group members had differing opinions as to whether the DG providers and interconnecting customers should be required to pay for the studies, or if the utilities and ratepayers should bear the cost. Several members also wanted more information about the nature, cost, and scope of such studies. Finally, the group wondered if a learning process could be instituted that would use past experience to expedite future interconnections.

The comments by one or more Group members in this field follows. They are not meant to depict a consensus recommendation of the Group.

• Improve the definition of the scope of the studies and ensure their appropriateness.

• Knowing how long the study will take and potential associated costs will help DG providers with their planning.

• Perhaps have the utilities could furnish a menu showing the costs of study for different facilities.

• Recognition of past performance of interconnected cogeneration plants of all sizes is missing from the utilities’ document. This body of experience could help inform the development of an automatic approval mechanism (like pre-certification).

• Can the utilities build learning into their process such that each new interconnection is not a de novo process? If there were an institutionalized learning process, past experiences could expedite interconnections in like situations.

• The issue of cross-subsidization arose repeatedly. The utilities noted their goal not to have ratepayers or their own organizations subsidize generators who would use their capacity to sell the energy for profit. Others noted that DG helps reduce or defer transmission and distribution (T&D) investment, line loss charges, and other network, security, and environmentally-related benefits and these should be considered a counterbalance to the cross-subsidization of studies by other rate payers.

• The burden should be on the utility to show that there is a problem/impact and a cost. There should be a rebuttable presumption of no-impact.

• Requirements of customers regarding safety, etc. should be clarified.

• The threshold level of expedited approval proposed by the utilities seems low at 10kw; the threshold for presumption of an expedited process in the FERC ANOPR is for facilities below 2 MW. Can the Collaborative create some better “rebuttable presumption” options?

Other state and federal guidance

Several group members indicated that the Collaborative’s deliberations should be informed by rulemaking in other regulatory arenas.

• The ANOPR proceedings should be tracked. Note that the ANOPR documents contain tests different from the joint utilities’ proposal regarding the identification of DG connections that may require impact studies.

• Massachusetts should use information from similar efforts in other jurisdictions, where it is useful, to avoid “reinventing the wheel.” Also, awareness of other states’ plans will help create a unified system for utilities and DG providers.

• Utilities with subsidiaries in other jurisdictions tend to prefer a single set of policies that they can apply across all their subsidiaries.

• Keep in mind that IEEE 1547 is a work in progress. The current goal for that process is to have consensus on broader, guiding principles in the next six to nine months. Several sub-documents describing how to apply the principles will be developed on a later timetable.

Other

One commenter observed that getting successful DG interconnection online may be a function of the fact that under current rules the utilities have no incentive to provide interconnection. Perhaps we should consider performance-based criteria which would provide a basis for financial incentives for utilities for faster and more effective interconnection performance

Action items to prepare for the next meeting

Before breaking, the group discussed how it should structure the next meeting. The DG cluster indicated that it would like to present its response to the utilities’ proposal during the next meeting. They indicated that their remarks would take into account the FERC ANOPR proceedings.

The group also determined that the utilities could provide feedback or clarification to the group on several points raised during the discussion. These will include, but are not necessarily limited to:

a. Schedules for different studies that will allow the group to see easily how long the interconnection process would take.

b. A proposal for study cost ranges or information about historic costs

c. An indication as to the time frames and costs required to interconnect a positive load.

d. What the utilities have in mind for an alternative dispute resolution (ADR) process, if anything. It was noted that the DTE had specifically asked for a recommendation on this topic, and that the facilitators could assist the group in developing it.

Finally, the group directed the technical consultants to develop a comparison of all the standards in place in different jurisdictions, including California, New York, Texas, NARUC, and the FERC ANOPR. Navigant will also seek reports filed by the utilities with DTE on the extent of DG connections within each utility.

The discussion of these items will occupy the bulk of the morning at the next meeting, which will start at 9 a.m. to allow for more discussion time. In the afternoon, the Group will break up into two groups, one addressing process issues and the other addressing technical issues. The technical group will look at the issue of classification and protection standards. The process group will address issues of timing, the ADR process, and the issue of who pays for studies and requirements. The discussion of the timing issues will be deferred to Meeting #3 or later, pending the development of a classification proposal by the technical group.

The meeting adjourned at 3:45 p.m.

To Do

• Check on space for caucus rooms at all meeting sites – Raab Associates

• Check on space for Nov. 20 meeting – Raab Associates, NU, Roger Freeman

• Provide Group with DG cluster’s memo (by Monday) – DG Cluster, Raab Associates (for dissemination to the Group)

• Provide further proposals on timing, study costs, and ADR process—Utility Cluster

• Provide comparison table of other regulatory regimes’ existing or proposed interconnection standards-- Navigant

• Provide summary, from reports to DTE, of DG penetration by utility--DTE/ Navigant

• Meeting Summary – Raab Associates

• Look into vegetarian lunch option – Raab Associates

• Agenda for next meeting—Raab Associates

|Attendance Sheet |

|Organization |Name |11/4 |

|DG PROVIDERS |

|Aegis Energy Services |Spiro Vardakas |X |

|SEBANE |Steve Cowell |X |

|SEBANE (alternate) |Ed Kern |X |

|E-Cubed |Peter Chamberlain |X |

|E-Cubed (alternate) |Ruben Brown |X |

|Ingersoll-Rand |Jim Watts |X |

|Ingersoll-Rand (alternate) |Bob Mack | |

|NAESCO |Don Gilligan | |

|Northeast CHP Initiative |Sean Casten |X |

|NECA |Larry Plitch |X |

|NECA (alternate) |Tobey Winters |X |

|Hill & Barlow (for Real Energy et al) |Roger Freeman |X |

|UTC |Herb Healy |X |

|UTC (alternate) |Heather Hunt | |

|KeySpan |Patricia Crowe |X |

|GOVERNMENT/QUASI GOVERNMENT |

|DOER |Dwayne Breger | |

|DOER (alternate) |Gerry Bingham |X |

|DOER (alternate) |David Rand |X |

|MTC |Sam Nutter |X |

|MTC (alternate) |Judy Silvia |X |

|MTC (alternate) |Raphael Herz |X |

|Attorney General's office |Joseph Rogers | |

|Attorney General’s office |Judith Laster | |

|Attorney General’s office |Patricia Kelley | |

|Cape Light Compact |Margaret Downey |X |

|DEM | | |

|DTE |Paul Afonso |X |

|CONSUMERS |

|AIM |Angie O'Connor |X |

|for Solutia and MeadWestVac Co. |Andy Newman |X |

|for Wyeth |Lisa Barton |X |

|for Wyeth (alternate) |Susan Richter |X |

|UTILITIES |

|Unitil/FG&E |John Bonazoli |X |

|Unitil/FG&E (alternate) |Justin Eisfeller | |

|ISO-NE |Henry Yoshimura |X |

|ISO-NE (Alternate) |Carolyn O'Connor |X |

|NSTAR |Larry Gelbien |X |

|NSTAR (Alternate) |Dave Dishaw |X |

|NSTAR (Alternate) |Dan Butterfield |X |

|WMECO/NU |Doug Clarke |X |

|WMECO/NU (alternate) |Rich Towsley |X |

|NGRID |Tim Roughan |X |

|NGRID (alternate) |John Bzura |X |

|PUBLIC INTEREST GROUPS |

|UCS et al |Deborah Donovan |X |

|UCS et al (alternate) |Frank Gorke | |

|UCS et al (alternate) |Seth Kaplan | |

|Mass Energy Consumers Alliance |Larry Chretien | |

|Mass Energy Consumers Alliance |Leslie Grossman |X |

|COLLABORATIVE TEAM |

|Raab Associates |Jonathan Raab |X |

|Raab Associates |Joel Fetter |X |

|Raab Associates |Colin Rule |X |

|Facilitation Consultant |Suzanne Orenstien |X |

|Navigant Consulting |Stan Blazewicz |X |

|Navigant Consulting |Eugene Shlatz |X |

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