IREC Regulatory Team Newsletter – April 2023
The first issue of the new Quarterly Newsletter from IREC’s Regulatory team.
Dear IREC supporter,
I’m thrilled to introduce the first issue of the new Quarterly Newsletter from IREC’s Regulatory team. Throughout the year, our team is constantly hard at work to improve the regulatory landscape for the deployment of clean energy in the U.S. Often this work is behind the scenes, so it is our hope that this newsletter gives you a window into some of the important work we’re involved in between press-worthy milestones. Each newsletter will highlight some notable regulatory developments from the past quarter, as well as explore some of the state-level activities we’re involved in.
– Radina Valova, IREC Vice President – Regulatory Program
Clean Energy Progress Report
Oregon Draft Interconnection Rule Revisions Include Several Changes Proposed by IREC
Oregon stakeholders have been hard at work updating the state’s interconnection procedures over the past year. On March 10, 2023, Oregon Public Utility Commission Staff released their first draft interconnection rule revisions, including a number of consensus-based solutions. Oregon Staff’s proposed rules incorporate many of IREC’s suggestions, including a new export controls section to enable energy storage projects and a new supplemental review process to allow projects to interconnect without a full study. Oregon Staff also proposed to modernize interconnection screens that evaluate the penetration of DERs on a circuit, grounding, and inadvertent export. IREC thanks the proceeding participants and Oregon Staff for working together to chart a path for the streamlined interconnection of new projects in Oregon. In the coming months, Oregon Staff will bring the proposal to the Commission for approval.
IREC Helps Advance the Use of Smart Inverters in Minnesota’s Interconnection Policies
IEEE 1547™-2018 is a technical standard that establishes how distributed energy resources (DERs)—like solar and energy storage—can connect to the grid. In particular, it establishes interconnection requirements for smart inverters, which have advanced “grid support” functions that can help the grid accommodate higher levels of renewable energy.
Minnesota was the first state to incorporate the IEEE 1547™-2018 standard into its technical requirements in January 2020, by publishing the state’s first Technical Interconnection and Interoperability Requirements (TIIR). Since then, many requirements that rely on inverters certified to IEEE 1547™-2018 have been on hold because certified inverters have not been available (see this IREC blog post detailing the response for this delay and our original research on when compliant products will be available).
A technical subgroup was formed in late 2022 to revise portions of the TIIR in preparation for full implementation. IREC helped revise the TIIR, and the revisions were approved by the MN Public Utilities Commission on March 2, 2023, with an implementation date still to be determined based on certified inverter availability.
Once implemented (likely later this year), smart inverters will have the functionality to help alleviate voltage issues and potentially increase circuit hosting capacity or reduce the need for voltage-related distribution upgrades for new inverter-based DERs seeking to interconnect.
New Mexico Public Regulations Commission Upholds Updated Interconnection Procedures
In November 2022, New Mexico overhauled its interconnection rules, incorporating national best practices for the review of renewable and energy storage projects. The changes improved process efficiency and provided clarity on how to evaluate the interconnection impacts of DERs that limit the amount of power they send back to the grid (aka non- and limited-export projects).
In response to the rule changes, Public Service Company of New Mexico, El Paso Electric Company, and Southwestern Public Service Company filed separate motions for rehearing, citing safety and reliability concerns, compliance issues, and/or inconsistent language. In January 2023, the New Mexico Public Regulations Commission denied the utilities’ motions for rehearing, but did agree to remove inconsistent language in one of the rule appendices. IREC supports the Commission’s finding in the Order that, “This Rule serves as forward looking and a considerable improvement to a Rule last revised 14 years ago that has been made obsolete with time, evolving technologies, and greatly increased demand for [DERs] by New Mexico consumers.”
IREC in the States
Ongoing Efforts to Improve Accuracy of Hosting Capacity Analysis Data
Hosting Capacity Analyses are key grid transparency tools that provide a snapshot in time of the conditions on the grid that impact its ability to “host” additional DERs at specific locations on the grid—without the need for costly grid upgrades or lengthy interconnection studies. During the summer of 2022, while conducting an analysis of California’s hosting capacity data (known as the integration capacity analysis or ICA in California), IREC discovered what appeared to be significant changes in Southern California Edison’s (SCE) data that showed a drastically reduced amount of available hosting capacity on their system. The timing of this discovery was critical because updates to the state’s interconnection procedures (known as Rule 21) that would require utilities to begin utilizing the ICA data in the screening of interconnection applications were supposed to go into effect in August.
Following discussions with IREC and the California Public Utilities Commission, SCE conducted an analysis and determined that errors had been made during recent updates to the ICA. In response, SCE proposed a plan to remedy the issue and re-process the data. SCE has been providing regular updates on its progress and, as of February, approximately 38% of its feeders (i.e., circuits on its distribution grid) had been updated. SCE expects to have updated ICA data for all of its feeders by June 2023. This experience has further highlighted how essential it is that hosting capacity analyses be subject to robust data validation, and for all stakeholders to work effectively together in identifying and resolving issues.
Implementation of Limited Generation Profiles to Improve Hosting Capacity Availability
In September 2020, the California Public Utilities Commission ordered the adoption of a process that would allow interconnection applicants to propose DER projects that utilize a “limited generation profile” that aligns with the hosting capacity constraints throughout the year at their point of interconnection. The use of limited generation profiles will allow projects to avoid the need for distribution system upgrades, while also better utilizing available hosting capacity. After some delay, the details of how the limited generation profiles will be implemented are now being worked out through a series of workshops and advice letters. Some of the issues that are being addressed include:
- what technologies will be utilized to limit export according to the pre-determined schedule,
- the granularity of the schedule (e.g., a single export value for each month, a 24-hour profile for each month, or some other variation),
- and how changes to the load on the distribution system after interconnection may impact the feeders after limited generation profile projects are interconnected.
IREC has been working closely with the Commission, the California Public Advocates Office, and other parties to help implement this innovative approach to interconnection, which has the potential to facilitate greater utilization of existing distribution system assets while also providing additional clean energy during the periods of greatest need.
Addressing Direct Transfer Trip Requirements
In response to a recent Order for Comment on Interconnection by the State Corporation Commission, solar industry stakeholders highlighted significant concerns related to community-scale project feasibility due to an expensive grid protection requirement known as Direct Transfer Trip (DTT). Some utilities require DTT for larger projects to address the potential for DERs to continue sending power to the grid during an event where the grid shuts down, which can impact safety and power quality. However, project developers are questioning the need for DTT given the capability of certified inverters to detect and respond to grid events. The IREC team is leveraging its internal engineering expertise to collaborate with impacted stakeholders and utilities to discuss and evaluate alternative mitigation solutions with a goal of finding a compromise that is less financially prohibitive while maintaining system reliability.
Each month, we’ll demystify energy policy with IREC’s Regulatory Vice President, Radina Valova, who will guide you through solutions and exciting developments in the energy transition. Each episode tackles a thorny energy policy challenge in 25-minute bite-sized interviews with leading experts. If you’re new to how we regulate the energy system, we’ll demystify it for you. If you’re a seasoned practitioner, we’ll hopefully leave you with renewed optimism to keep doing the work to improve our energy system.
Sky Stanfield, a Partner at Shute, Mihaly, & Weinberger, LLP who represents IREC in interconnection proceedings across the U.S, recently sat down with the Local Energy Rules Podcast to discuss how proactive grid planning and good interconnection policy can capitalize on existing distribution infrastructure for the most cost-effective clean energy transition.
New Mexico’s updated interconnection rules—adopted by the New Mexico Public Regulation Commission on November 30, 2022—represent a major win for New Mexico communities, clean energy developers, and the environment. The updates reflect a number of cutting-edge best practices developed under the BATRIES project to reduce barriers to energy storage and solar-plus-storage interconnection.
Building A Technically Reliable Interconnection Evolution for Storage (BATRIES) Project
The BATRIES project is a multi-year effort to reduce barriers to energy storage and solar-plus-storage interconnection, funded by the U.S. Department of Energy’s Solar Energy Technologies Office and led by IREC, in partnership with the Electric Power Research Institute, utilities New Hampshire Electric Cooperative and PacifiCorp, the California Solar and Storage Association, the Solar Energy Industries Association, and law firm Shute, Mihaly, & Weinberger, LLP. Published in March 2022, the Toolkit and Guidance for the Interconnection of Energy Storage and Solar-Plus-Storage is the culmination of the project team’s research and analysis to develop solutions to eight interconnection barriers. Since the publication of the Toolkit, IREC and its project partners have been conducting virtual workshops and trainings to provide stakeholders with a better understanding of both the challenges and solutions identified in the report.
Interconnection Innovation e-Xchange from the U.S. Department of Energy
The Department of Energy’s Interconnection Innovation e-Xchange (i2x) convenes interconnection stakeholders to enhance peer learning, identify interconnection barriers, and develop innovative solutions. i2X also provides technical assistance to stakeholders to address challenges. The first i2x working group meetings will begin in April, focused on the important topics of cost allocation and queue management. The schedules for upcoming working groups are available at the link above.