Interstate Renewable Energy Council 2019 Model Interconnection Procedures
The report, Interstate Renewable Energy Council (IREC) 2019 Model Interconnection Procedures, identifies several best practices for interconnection procedures.
Interstate Renewable Energy Council 2019 Model Interconnection Procedures (IREC 2019)
The objective of this summary document is to provide state regulators an insight into the main report and highlight the key points relevant to them.
IREC has been instrumental in assisting several state utility commissions in rules that focus on distributed energy resource (DER) interconnection procedures. With time, IREC has updated the procedure by identifying several best practices. The latest update was published in 2019 and focuses on several aspects of the procedure such as pre-application report, interconnection review process for the four levels, and supplemental review process.
The scope of this report is applicable to all state jurisdictional interconnection of generating facilities. The first chapter provides an overview of the full report describing the optional pre-application report, the interconnection review process set for the four paths (Level 1 through 4), and the applicable standards that customers should comply with.
A pre-application report, although optional, reduces the number of interconnection requests that utilities must serve by providing the basic system conditions to the customer attempting to connect to the distribution system, thus reducing the number of unapproved requests and making the utilities more efficient. Additionally, states can also provide a hosting capacity map to further reduce the number of requests filed (California Rule 21). A pre-application report does not obligate the utilities to analyze the effect of adding a new interconnection; it only includes the best available pre-existing data. This report provides details on the information to be incorporated into the pre-application report.
The pathway of interconnection is determined based on the generating capacity and classified into one of four levels. Every level of review contains the description of all the steps involved in the interconnection process including:for peer reviewers
- Application process
- Screens applicable for each level
- Processing time
- Steps taken during screen failure
- Agreement with customer
- Operation of the interconnected system.
Some screens and interconnection steps may be subjected to modifications depending on the type of interconnection, intent, and level. An application fee depends on the level of interconnection review and is state specific. In case of screen failures pertaining to expensive upgrades, the utilities may classify such circuits as "full" or "closed."
This process could even be optimized by using a pre-application report and hosting capacity maps. If the results of the review process are satisfactory, interconnection agreement copy is sent to the customer. The system can start operation after a successful inspection by the utility.
Supplemental Review Process
Supplemental review described in this report is distinct from the one provided by The Federal Energy Regulatory Commission (FERC) Small Generator Interconnection Procedures (SGIP) in that the SGIP does not provide customers any details regarding the timeline or additional evaluation required. This report contains a separate section on the supplemental review process that describes the screens and the timeline utilities are required to adhere to.
A clear supplemental review aids in enabling better interconnections at higher DER penetration levels by eliminating unnecessary reviews and the associated costs. The screens include the aggregate load on the line section, compliance with the standards that deals with voltage fluctuations and harmonics, and the location of the proposed interconnection. Requests that pass the supplemental screens follow the standard procedure in the next steps. Further, in case the interconnection request needs to undergo the Level 4 evaluation (lengthy and costly), the customer can participate in an Applicant Options meeting to determine suitable modifications that can permit a safe and reliable connection.
Level Four Review
The Level 4 interconnection review path is different from the others because it entails an impact study and a facilities study to analyze the effect of the interconnection on the circuit and determine if any upgrades are necessary. The impact study or facilities study requirement is decided at the initial review after presenting the details of the proposed point of interconnection.
An impact study checks if the generating facility devices are compliant with the IEEE 1547 standard. An impact study may result in substantial modification to the system. In that case, the estimated cost of a facilities study is provided.
A facilities study will provide better clarity about the costs involved in system upgrades. The utility can then provide the interconnection agreement, which includes significant commitment from the customer to pay for the upgrades. The remaining steps are similar to the standard procedure.
General Provisions and Requirements
This report concludes with a section on general provisions and requirements. It describes a simplified online application procedure that a state can enforce to streamline the interconnection procedure. Escalation of disputes may involve state commission in a formal or informal capacity to reach resolution. Utilities are also required to provide some information to the commissions about their generating facilities by March 1 of every year for further analysis. The last section of the report also lists the responsibilities of an applicant, the additional cost of supplemental or Level 4 review, insurance requirements, periodic tests/inspections, etc.
In addition to this report, IREC also provides a supplemental free document for states that are looking to improve or update their interconnection procedure. This document consists of relevant examples of state rules regarding the key components of interconnection. In addition to the topics discussed in the Interstate Renewable Energy Council 2019 Model Interconnection Procedures report, state regulators can gain insight into consolidating the impact studies, cost determination for upgrades, and inclusion of energy storage.