Solar Industry FERC Filing on Small Generator Interconnection Procedure
SEIA has filed a petition with the Federal Energy Regulatory Commission (FERC) requesting significant improvements to federal interconnection rules for solar wholesale distributed generation. Solar wholesale generation interconnection is under FERC's jurisdiction because it involves a wholesale power sales transaction, typically to a utility. If FERC adopts SEIA's proposed interconnection solutions, the amount of solar wholesale DG capacity eligible for fast track interconnection would roughly double. It also would help make interconnection faster and less costly for many solar projects.
The key improvement SEIA seeks is a change in the rules governing "fast track" interconnection of solar generation 20 megawatts (MW) or less without the imposition of costly and lengthy studies. Under current FERC rules, fast track interconnection with no requirement for studies is permitted for projects 2 MW or less if the aggregate distributed generation interconnected on a utility circuit does not seek 15 percent of circuit peak load. This is known as the "15 percent rule or screen."
For many years, solar developers have believed that the 15 percent screen for fast track interconnection was much more restrictive than necessary to maintain distribution system safety and reliability. This view was recently confirmed by an expert report on the 15 percent screen authored by the National Renewable Energy Laboratory, the Sandia Laboratory and the Electric Power Research Institute. The Laboratory/EPRI report suggests an alternative fast track screen, 100 percent of minimum daytime load that can be used when the 15 percent screen is triggered.
Based on the expert report, SEIA has proposed the adoption of the 100 percent of minimum daytime load screen and the elimination of the 2 MW capacity threshold. SEIA has also proposed that utilities be required to provide minimum and peak load data to solar developers on circuits with significant distributed generation penetration. For solar projects 20 MW or less that are unable to meet fast track screens, SEIA recommends the adoption of an option for expedited, independent, third-party expert technical review of proposed study and upgrade requirements.
In the petition, SEIA made clear to FERC that it appreciates that all "retail" interconnections of solar generation directly to consumers are subject to state, not federal, jurisdiction and that SEIA respects these jurisdictional boundaries. However, SEIA believes that if FERC improves its own rules, they could serve as a model for states that would like to improve solar market access.
With the petition now filed at FERC, SEIA's efforts are shifting to encouraging FERC to act swiftly and working with other stakeholders. We are hopeful that the Commission will take up this important issue.