On September 14, the Massachusetts Distributed Generation Working Group published its final report on recommendations for moving the Commonwealth’s interconnection procedures forward. IREC has been participating throughout the four-month working group process, advising the working group on national best practices and encouraging them to integrate these practices into Massachusetts’ model interconnection tariff.
The report incorporated several suggestions encouraged by IREC, including a pre-application report and an increased penetration screen (from 7.5% of peak load to 15%). In addition, 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, which is an emerging challenge in Massachusetts and elsewhere. The second is increasing the transparency and explicitly justifying technical standards, including when a direct transfer trip is required and how to determine if a particular feeder’s capacity is exhausted.
Finally, the group spent significant time debating appropriate changes to the supplemental review process. While parties agreed with IREC’s suggestion that a more transparent supplemental review process could be beneficial, and could serve to keep certain projects from unnecessary study, parties disagreed on whether the new screen should be based on 67% of minimum load or 100% of minimum load.
The report’s recommendations are intended to improve the clarity and efficiency of the interconnection process, and include:
1) 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;
2) A more clear-cut and definitive process for utilities to withdraw project applications when applicants miss deadlines to provide information or other documents, thus freeing up feeders for other applicants and potentially reducing utility workload;
3) Additional time within the Standard Track for “Complex” applications that will require more analysis and hence more time than a typical Standard Track project;
4) Utility-run tracking system to monitor both utility and customer timelines, from the application submittal through the application process and construction/interconnection, with transparency for each customer, and enhanced monthly reporting to DOER on timelines;
5) A uniform utility-published Technical Standards Manual that is periodically updated and into which non-utility parties have a formal process for providing input;
6) Revisions to the technical screens and Supplemental Review time budget to potentially allow more projects to qualify for both the Simplified and Expedited tracks; and
7) 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).