Interconnection and Net Metering Service in Ohio

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Interconnection and Net Metering Service in Ohio Partnership between National Association of Regulatory Utility Commissioners and The National Commission for Energy State Regulation of Ukraine June 20, 2014 Anne Goodge, PUCO Staff (anne.goodge@puc.state.oh.us)

What are Interconnection Rules? Interconnection Rules generally consist of: 1. The administrative procedures and technical standards used to evaluate potential impacts associated with interconnecting a generation resource to the electric power system. 2. Standard contractual agreements stipulating operational and cost responsibilities between the electric utility and the generation resource owner.

Consist of three steps: Interconnection Procedures 1. Customer submits interconnection application 2. Utility assigns queue position and executes technical review 3. Joint signing of Interconnection Agreement* * An Interconnection Agreement is a legal contract between the electric utility and customer establishing all terms and conditions associated with operating distributed generation (DG) in parallel with the utility s electric power system.

Why have Interconnection Rules? Balancing two objectives: 1. Provide a transparent and efficient means to interconnect generation resources to the electric power system. 2. Maintain the safety, reliability and power quality of the electric power system.

Interconnection Jurisdiction Transmission-Level Interconnections: Governed by federal policy and overseen by the Federal Energy Regulatory Commission (FERC). Generally apply to largescale merchant generation resources. Distribution-level Interconnections: Governed by state policy and administered by state Public Utility Commissions. Generally apply to Distributed Generation (DG) behind-the-meter, residential and commercial facilities that are Net Energy Metered (NEM).

Federal interconnection policy is adopted and administered by Regional Transmission Organizations (RTOs). Where none exist, FERC directly oversees Transmission-Level Interconnections. Image source: https://http://www.opuc.texas.gov/ercot.html

States with Distribution-Level Interconnection Policies Image source: http://www.dsireusa.org/documents/summarymaps/interconnection_map.pdf

June 2003: Technical Standards for Small Generators Institute for Electrical and Electronics Engineers (IEEE) 1547 Standard for Interconnecting Distributed Resources with the Electric Power System. Provides requirements relevant to performance, operation, testing, safety, and maintenance of Distributed Generation smaller than 10 MW interconnecting to electric power systems.

July 2003: Federal Rules for Large Generators FERC Large Generator Interconnection Procedures (LGIP) and Large Generator Interconnection Agreement (LGIA) First federal policy to address the interconnection of Large Merchant Generators greater than 20 MW in capacity. Established a standard three-study procedure for Large Generator interconnection that applies to all transmission-level interconnections in the country.

May 2005: Federal Rules for Small Generators FERC Small Generator Interconnection Procedures (SGIP) and Small Generator Interconnection Agreement (SGIA). Applicable to transmission level interconnections. Developed 3 review levels, scaling DG size with technical review scope. Adopted a Fast Track review process for systems smaller than 2 MW, utilizing technical screens.

August 2005 Energy Policy Act: (EPAct) Section 1254 of EPAct required state regulatory commissions and certain non-regulated utilities to consider adopting interconnection procedures based on IEEE 1547 Standards and current best practices.

Transmission-Level Interconnection within the PJM RTO Generation resources are not centrally planned by PJM. Any proposed generation project may request transmission system interconnection. All costs associated with installing system reinforcements and/or attachment facilities to accommodate a proposed generation system are the responsibility of the interconnection applicant. Project economic viability determines successful interconnection. PJM has a cost-sharing methodology for allocating expenses among generators that benefit from the same system upgrades. Image source: https://edata.pjm.com/econtour/#

FERC Small Generator Interconnection Procedures FERC s SGIP* are designed to: Serve as a useful model for state-level interconnection standards. Include provisions for three levels of interconnection (mostly at the transmission level): The 10-kilowatt (kw) Inverter Process The Fast Track Process (based on individual system and generator characteristics up to a limit of 5 MW) The Default Study Process (all other systems 20 MW) *Small Generators Interconnection Procedures http://www.ferc.gov/industries/electric/indus-act/gi/small-gen.asp

Interconnection Policy in Ohio Ohio s Interconnection Rules* are designed to: 1. Standardize technical requirements across the state. 2. Streamline development of DG pursuant to Ohio renewable energy policy objectives. 3. Maintain the reliability, safety, and power quality of electric service in the state. *Applicable to distribution-level interconnections

Ohio Interconnection Policy Language Ohio Revised Code: ORC: 4928.02 (K) (statute) http://codes.ohio.gov/orc/4928.02 Ohio Administrative Code: 4901:1-22 (rule*) http://codes.ohio.gov/oac/4901%3a1-22 * On December 4, 2013 the PUCO adopted amended rules for electric interconnection services and standards in Chapter 4901:1-22 in accordance with the State of Ohio s 5-year rule review procedures (Commission Finding and Order, Case no. 12-2051-EL-ORD).

Ohio Interconnection Rule Review Public Utilities Commission of Ohio (PUCO) staff evaluates the rules contained in Chapter 4901:1-22, O.A.C following July 17, 2012 notice of Rulemaking. o Include stakeholders in the development of the rule. o Consider the continued need for the rules, the nature of any complaints or comments received concerning the rules, and any change in the subject matter area affected by the rules. o Evaluate the impact of the rule on businesses. o Follow due process of law. Recommends whether to amend/rescind/continue the rules.

Ohio s interconnection rules adopt the principal features of the FERC SGIP 1. Require adherence to the IEEE 1547 and UL 1741 technical standards. 2. Similar customized, multi-level approach matching degree of technical review with project characteristics. 3. Establish standard and simplified applications and interconnection agreements. 4. Expenses for application processing, technical studies, and system or facility upgrades are the responsibility of the applicant, not the utility (or its ratepayers).

Ohio s Interconnection Review Levels Review Level Eligibility Application / Contract Review Pre-Application 1 2 2 Supplemental 3 Line Voltage any project» IEEE 1547 and UL 1741 compliance certified» inverter-based systems 25 kw» IEEE 1547 and UL 1741 compliance certified» systems that are ineligible for/failed to pass Level 1 Review» system types not exceeding the limits identified below Expedited Review Regardless of Location Expedited Review on line capacity 600 amp and distance < 2.5 feeder miles from substation 5kV 500 kw < 2 MW 5kV & 15 kv 2MW < 3 MW 15 kv & 30 kv 3MW < 4 MW 30 kv & 69 kv 4MW < 5 MW» systems reviewed under Level 2 and failed to meet the criteria but could possibly be interconnected consistent with safety, reliability, and power quality standards after minor modifications/further study» not IEEE 1547 and UL 1741 compliance certified» all system types 20MW that are ineligible for/failed to pass Level 1 and Level 2 Review applicant's informal request / discussion of information specified in 4901:1-22-04 (B)(1) applicant's formal written request / Pre-Application Report Short Form Application / Standard Interconnection Agreement Standard Application / Standard Interconnection Agreement applicant's written agreement within 15 days of EDU's offer to perform Supplemental Review / Standard Interconnection Agreement Standard Application or applicant s agreement to continue evaluating the application that fails the Supplemental Review criteria / Standard Interconnection Agreement Pre-Application Review Simplified Review Expedited Review Expedited Review including customized studies based on technical screens Standard Review including customized studies

Application Processing and Queuing Interconnection Requests are Interdependent Applications are processed in the order they are received. The utility assigns the application a queue position in relation to other interconnection requests on the same or nearby distribution system sections. The queue position is used to determine the cost responsibility of any necessary facility upgrades in relation to other interconnection requests on the same or nearby distribution system sections.

Interconnection Agreements allow customers to: 1. Operate onsite generation in parallel with the electric utility s distribution system. 2. Sign a net metering contract with utility. 3. Become a certified Ohio Renewable Energy Resource Generating Facility. 4. Generate and sell Renewable Energy Credits.

Ohio Net Metering Policy Customers who generate power on-site from renewable sources may offset what they purchase from the utility. Receive a monetary credit on their bill for electricity that flows back into utility system (for generation only, not full retail rate or kwh credit); and annual refund for any net excess generation. System must be sized to customer requirements for electricity. Must first sign an agreement with the utility for interconnection service. No overall state or system capacity limit. Annual utility net metering reporting requirements.

Qualified Net Metering Sources in Ohio s Statute Solar Wind Biomass Landfill gas Hydropower Microturbine Fuel Cell Hospital net metering policy allows any type of generation source and size, and credits are based on market value of electricity at time of generation.

Net Metering. www.dsireusa.org / July 2013 43 states, + Washington DC & 4 territories,have adopted a net metering policy. Note: Numbers indicate individual system capacity limit in kilowatts. Some limits vary by customer type, technology and/or application. Other limits might also apply. This map generally does not address statutory changes until administrative rules have been adopted to implement such changes.

Net Metering Benefits Allows intermittent sources (solar, wind) to apply credits for excess power generated during high production months to lower producing months. Reduces need for transmission and may alleviate congestion. Has encouraged development of small-scale renewable facilities.

Ohio Net Metering Policy Language Ohio Revised Code: ORC: 4928.01, 4928.67 (statute) http://codes.ohio.gov/orc Ohio Administrative Code: 4901:1-10 (rules*) http://codes.ohio.gov/oac * On May 28, 2014 the Public Utilities Commission of Ohio adopted amended rules for electric service and safety standards in Chapter 4901:1-10 in accordance with the State of Ohio s 5-year rule review procedures (Commission Finding and Order, Case no. 12-2050-EL-ORD).