On November 29, 2011, the Hawaii Public Utilities Commission issued an order that significantly improves Hawaii’s interconnection procedures, known as Rule 14H. For almost two years, IREC has worked collaboratively with parties in Hawaii to reform Hawaii’s existing Rule 14H and move Hawaii’s interconnection process toward best practices. The PUC’s November 29 order approves stipulated revisions to Rule 14H that parties submitted to the Commission in October. The Commission’s order adopts the stipulated revisions but defers determination on two issues related to supervisory control provisions and frequency regulation for a later order.
IREC played a central role in drafting revisions to Rule 14H, including updating the technical review screens, introducing a supplemental review process, and improving the interconnection study process. With the Commission’s approval of these features, Hawaii dramatically improves its interconnection standards. In the 2011 edition of Freeing the Grid, which went to print before the Commission approved these changes, Hawaii received an “F” for its interconnection policies. After the Commission’s order, Hawaii’s will now earn a “B” for interconnection.
The key reasons for Hawaii’s dramatic grade improvement are discussed briefly below.
Hawaii’s score for “Technical Screens” in FTG jumps from “-2” to “1” point
One of the most significant shortcomings of Rule 14H was the fact that it did not feature objective technical screens for evaluating fast track interconnections. Revised Rule 14H includes nine technical screens that are based closely on California’s Rule 21 interconnection process, with an improvement to the “penetration” screen that constitutes a new best practice. Although Rule 14H employs the standard “penetration” screen that allows a generator to interconnect on a more expedited basis so long as aggregate generating capacity is equal to or less than 15% of the line section peak load, a supplemental review process that has been incorporated into Rule 14H will allow a generator to avoid more intensive study if the “aggregate capacity per Line Section is below 50% of the Line Section minimum kW load during the period when the proposed generation is available (including noon on Sunday for solar photovoltaic systems).” This approach is far less restrictive than FERC’s pro forma SGIP and results in awarding a bonus point.
Revised Rule 14H Timelines improve upon the SGIP to earn “1” point
Previously, Rule 14H had few definite timeframes for completion of the interconnection process. Revised Rule 14H has clear timelines for when an application must be deemed complete, examined through initial review, processed through supplemental review, or moved on to a more intensive interconnection requirements study (IRS). Under the revised rules, an IRS must be completed within 150 calendar days of the time a customer agrees to proceed with the IRS and pays for the study. The maximum time under Rule 14H to complete the IRS is significantly shorter than the maximum time that may be required under the SGIP, which is calculated in business days.
Revised Rule 14H features several breakpoints
Although revised Rule 14H does not feature distinct levels of review like SGIP—demarcated by generator size—the Rule 14H technical screens make two distinctions based on generator size that reduce the scrutiny of the initial review process for smaller generators. For inverter-based generators 10 kW or less, Rule 14H will allow these generators to skip screens 7-9 and proceed directly to simplified interconnection. For inverter-based generators less than 250 kW that meet both IEEE 1547 and UL 1741 standards, revised Rule 14H will allow these generators to skip screen 8, which addresses short circuit contribution ratios.