Improving Risk-Based Review to Enable Developers to “Fly” Through Interconnection Hurdles

Making safe, reliable interconnection of renewable energy easier is the goal. Increasing the number of interconnections, through improved application efficiency and cost-effectiveness, while maintaining safety and electrical system reliability, that’s the challenge.

Just last week, Massachusetts adopted revised interconnection procedures that should pave the way for more renewable energy projects to come on line there.  Last month, the Federal Energy Regulatory Commission (FERC) proposed procedural modifications that lay the national groundwork for facilitating a more efficient interconnection process for small renewable generators. These and other groundbreaking successes in California and Hawaii are all wins both for utilities and energy consumers.

But I’m not sure most people, even many who are involved and interested in our clean energy future, have an understanding of how and why these state by state, and now proposed federal changes are important.

Airport security may be the best analogy. Ever since the 9/11 terrorist attacks, the process of boarding a plane has become increasingly cumbersome for travelers.  It seems the lines keep getting longer and the screening process more complex.  This is just how the interconnection process may seem to developers and utilities, particularly in states with increasingly high concentrations of distributed solar.

In response to the rising demands of frequent travelers and airlines, the government has begun to explore ways of sorting out high-risk passengers, by offering pre-screening programs and allowing certain passengers deemed as low risk to pass through the lines more quickly.  Likewise, some states with high-penetrations of distributed solar have begun to adopt interconnection procedures that sort generators into more refined study processes, depending upon the level of risk they pose to the system.  They have also sought to increase access to information in order to reduce the overall number of projects waiting in the queue.  These advances are significant because they offer benefits for developers and utilities.

One way that states are improving the queuing process for interconnection applicants is to provide increased information to help developers determine the most efficient locations to interconnect, and to understand the likely duration and magnitude of costs associated with particular locations.  There are portions of the distribution system that may have limited capacity or other technical constraints; providing this information upfront can help developers avoid those circumstances, or to at least plan accordingly.

This is the equivalent of providing travelers warnings that they need to arrive at the airport two hours early if they are flying during peak travel times or that they need to check their bags if they want to fly with liquids in containers larger than three ounces.

In addition to enhancing the availability of information regarding system conditions, states are beginning to create a greater number of study tracks to better align the risks that a system poses to the amount of study that it receives.  In most states, there are generally only two study paths.  Either a project will qualify for a “fast track” process that can be completed in about a month, or it will be put into a full study process that can take many months, and in some cases, well over a year.  An intermediate level known as supplemental review has often existed in state procedures but is frequently ill defined and thus not always applied in a consistently useful manner.

California, Hawaii and Massachusetts have recently enhanced their supplemental review processes to enable a greater number of projects to proceed quickly to interconnection without requiring full study.   As more and more circuits experience high penetrations of distributed generation, the number of projects that are able to pass the traditional fast track screens has decreased.  While higher penetrations of renewables on a distribution circuit can sometimes pose additional safety, reliability or power quality concerns, they do not always indicate that every project needs a full study to interconnect without problems.

Thus, in these states, qualified projects that fail one or more of the fast track screens will now be reviewed under an enriched supplemental review process.  If the project falls under a new higher penetration threshold, and satisfies the safety, reliability or power quality tests, it can interconnect without needing to go to full study.  This process enables use of a less conservative penetration threshold because the utility is provided with slightly more time to review the project, and the threshold is also articulated in a manner that makes it more relevant for solar systems that only operate during daylight hours.

Increasing the number of projects that can avoid full study is also beneficial to other projects in the interconnection queue.  Since most states study projects one at a time, reducing the overall number of studies required means that the time spent waiting in the queue is reduced.  Coming back to the airport security analogy, this means that the more travelers that apply for and participate in the pre-screening programs that are now offered in some airports, the shorter the wait times might be for everyone else.

Waiting in line and undergoing unnecessary scrutiny is painful whether it occurs in an airport or an interconnection queue.  In both cases, improved information upfront along with better sorting based upon risk profiles may improve the experience for everyone involved.

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