MA Utility Response Utility position in FERC ANOPR

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MA Utility Response Utility position in FERC ANOPR consensus document 11/12/02 1

MA Utility Response Utility position in FERC ANOPR consensus document 11/12/02 1

Proposal Overview Standardized Process and Requirements n Ensure safety and reliability w Follows national

Proposal Overview Standardized Process and Requirements n Ensure safety and reliability w Follows national standards w Equipment must be certified or undergoes design review n For small generation < [IP: 10]; [SG: 20] MW Differentiating By: n n n One of [IP: four] [SG: three] generator size thresholds Potential “impact” of generator on Electric Power System (EPS) Type of EPS at Point Of Common Coupling (PCC) 2

Process Overview Generator Application Scope of process shrinks considerably when expedited Defines [IP: simplified

Process Overview Generator Application Scope of process shrinks considerably when expedited Defines [IP: simplified study process] [SG: screens] for certified equipment >[IP: 10][SG: 20]MW? Yes >2 MW? Yes Historic Application Process No Expedited Application Process Meets [IP: Screenin g criteria] SG: Screens] ? No Yes [SG: Super] Expedited Application Process Interconnect Agreement 3

Size Threshold Categories Less than 10 k. W n n Accepts utility proposal Inverter

Size Threshold Categories Less than 10 k. W n n Accepts utility proposal Inverter based [IP: Short form][SG: three page] application/agreement [IP: Minimal or] no review/payments necessary Less than 2 MW eligible for super-expedited process n n n Certified equipment Possible De minimis grid impact No connection to transmission lines 2 -[IP: 10] [SG: 20] MW eligible for expedited process n Check for distribution impact and transmission impact 4

10 k. W To 2 MW Units certified by UL or other NRTL against

10 k. W To 2 MW Units certified by UL or other NRTL against UL 1741 (representing IEEE Std 1547 Draft 10) 2 simplified study screening criteria to look at during Feasibility and/or Impact Study n [SG: Primary screen] [IP: ing criteria – conservative][SG: Utility origin] w [SG: 100] [IP: 80 -99] % of units that pass are OK n [SG: Secondary screen][IP: ing criteria – more liberal][SG: less conservative] w [ SG: 80 -99] [IP: 50 -80] % of units are OK Creates [SG: presumption [IP: high likelihood] of acceptance 5

Screening Criteria – Primary Aggregate DG capacity limited to a low percentage of the

Screening Criteria – Primary Aggregate DG capacity limited to a low percentage of the peak load of a distribution circuit (different limits for radial vs spot network vs secondary grid network) DG contribution to circuit fault current is limited DG not allowed to cause grid protective devices to exceed [IP: 85][SG: 90]% of their short circuit interrupting capability In aggregate, DG cannot be > 10 MW where transient stability limits posted Interconnection configuration-specific limits on singlephase generator hookup and capacity to avoid imbalance, overload, and possible neutral/grounding problems 6

10 k. W-2 MW Costs Application fee Additional surcharge for interconnection review n Limited

10 k. W-2 MW Costs Application fee Additional surcharge for interconnection review n Limited to reasonable amounts based on size No other costs for interconnection under [SG: Super] Expedited procedures n [IP: Unless Utility can detail rationale] 7

Dispute Resolution Elements n n n Technical Master Hotline ADR for non-technical disputes [IP:

Dispute Resolution Elements n n n Technical Master Hotline ADR for non-technical disputes [IP: Dispute resolution is binding on both parties. IPs will cover their costs, however only if found in error will IPs bear Applicant’s cost] [SG: IP must initiate if SG Applicant clears secondary screen] Gen Applicant has burden if both screens failed 8

Distribution Impact Study Purpose n n [IP: Identify Impacts to distribution system from generator][SG:

Distribution Impact Study Purpose n n [IP: Identify Impacts to distribution system from generator][SG: Identify generator design elements that protect distribution system] [IP: Does not assess impact of system on generator][SG: Assess impact of generator on distribution [IP: Design review will always be needed] [SG: No design review needed if n n Certified Generator meets criteria similar to 0 -2 MW secondary screens ( without secondary network items)] Includes n n Distribution load flow study Equipment interrupt rating analysis Protection coordination study System operation impact analysis 9

[SG: Screens – Primary][IP: primary screening criteria] <5% of annual peak load on radial

[SG: Screens – Primary][IP: primary screening criteria] <5% of annual peak load on radial circuits <5% of peak load (or 50 k. W max) on spot networks (inverters only) [SG: Secondary grid distribution networks n n induction generator or inverter not exceeding 50% of facility minimum load] [IP: No connection to secondary networks except spot networks] <10% contribution to circuit max fault current Not cause grid protective devices to exceed [SG: 90][IP: 85]% of their short circuit interrupting capability In aggregate, cannot be >10 MW where transient stability limits posted Phase imbalance limits if single-phase and connected to center tap neutral of a 240 V service <20 k. VA if single-phase and on a shared secondary Single-phase connection requirements <10% of peak load of line if single phase and section configuration is 10 three-phase, 4 -wire or a mix

[SG: Screens – Secondary][IP: Secondary screening criteria] Radial circuits: <15% of line section [IP:

[SG: Screens – Secondary][IP: Secondary screening criteria] Radial circuits: <15% of line section [IP: annual peak load][ SG: design] capacity Spot networks: <5% of peak load on spot networks Secondary grid networks n n On any network, use [SG: reverse power protection except][IP: proper systems to prevent operation of network protectors in all cases] [SG: if generator < 50% of min facility load or 500 k. W][ IP: Allows 10% of minimum load or 50 k. Ws] [SG: Basically same][IP: Raises] limits of short circuit interrupting impact as primary screen 11

Spot Network System EPS Network Trf Customer 12

Spot Network System EPS Network Trf Customer 12

Secondary Network System Network Transformer EPS includes secondary bus Customer Customer 13

Secondary Network System Network Transformer EPS includes secondary bus Customer Customer 13