Massachusetts might not get as much sun as California but, judging by interconnection queues, the Bay Staters’ interest in solar seems just as high. According to a KEMA report prepared for the Massachusetts Department of Energy Resources (DOER) and the Massachusetts Clean Energy Center in 2011, the total volume of interconnection applications grew four-fold for National Grid and NSTAR between 2004 and 2010. Additionally, for those same utilities, the number of kilowatts reviewed through the Commonwealth’s two more complex interconnection paths (Expedited and Standard) increased seven-fold between 2004 and 2010.
The KEMA report was undertaken to provide a snapshot of the status of distributed generation (DG) interconnection activities in Massachusetts and to deliver a summary of the recent experience of DG developers. In September 2012, largely in response to the KEMA report, the Massachusetts DG Working Group submitted detailed recommendations specifying changes to the Commonwealth’s interconnection procedures. I recently looked at these two documents to see how a few of the DG working group recommendations have built off the findings in the KEMA report.
In high-penetration solar areas, it can be challenging for developers to know where DG can be most readily accommodated on the utility grid. As a result, the KEMA report recommended the implementation of a pre-application consultation option between utilities and developers.The DG Working Group therefore recommended the adoption of a required pre-application report for applicants over 500 kW to the Expedited and Standard tracks, to help applicants prioritize among potential locations and DG configurations, and to reduce the number of speculative applications that tend to congest the queue. There would be no additional fee for this report, as it would be figured into the new application fees.
Timelines are important to keeping projects moving along the queue and ensuring cost efficiencies. The original KEMA report found that, while they are laudable targets, the timelines set out by Massachusetts interconnection procedures are aspirational in nature and frequently go unmet. In keeping with these findings, the DG Working Group recommends the adoption of a “multi-faceted utility timeline assurance and enforcement strategy that provides all parties with confidence that the utilities will be able and incented to deploy all necessary resources” to meet those timelines. It also recommends a utility-run tracking system to monitor both utility and customer timelines, from the application submittal through the application process and interconnection, with transparency for each customer, and enhanced monthly reporting to DOER on timelines.
The KEMA report notes that batching DG applications (studying them in groups, rather than in succession) can add efficiency where volumes are high enough to allow batching by feeder, DG type or application track. It can also help distribute the significant costs of distribution system upgrades among multiple DG facilities that will benefit from the upgrades. The working group recommended that a group study process be considered for feeders with multiple applications, where system upgrades would be extensive, though it left the development of the details of that process for the coming year. Regarding how shared costs would be allocated, the working group suggested that DG developers in batched applications should share common segments pro rata by megawatt, while unique segments should be covered by the specific DG developer.
These were just some of the improvements that Massachusetts may have in store, pending the adoption of these recommendations by the Massachusetts Department of Public Utilities (DPU). IREC participated in the DG Working Group and the group’s proposed changes incorporated several suggestions encouraged by IREC, including the provision for a pre-application report and an increased Expedited Track penetration screen (from 7.5 percent of peak load to 15 percent).
In addition to the proposed changes, the working group agreed to address more complex issues going forward, including two critical issues from IREC’s perspective. The first is the development of an effective group study process targeted at multiple projects on a single circuit, as discussed above, which is an emerging challenge in Massachusetts and elsewhere. The second is increasing transparency of and explicitly justifying technical standards, including when a direct transfer trip (DTT) is required, and how to determine if a particular feeder’s capacity is exhausted. This second issue is expected to be addressed through a technical standards committee, which should have its first meeting in January 2013.
The DPU held a technical conference to discuss the working group’s recommendations on October 24, 2012, which IREC attended. IREC anticipates that the DPU will request public comments on these recommendations sometime in the coming weeks. In particular, IREC expects that the DPU and Massachusetts stakeholders will be interested in resolving the one outstanding issue from the working group process—the appropriate minimum-load-based penetration screen for the updated Supplemental Review process proposed by the group. IREC agrees that this is a critical issue and looks forward to participating in the DPU-led process going forward.