Current through Register Vol. 48, No. 12, March 22, 2024
An EDC shall use the Level 4 study review procedures for an
interconnection request that meets the criteria in Section
466.80(d).
a) The applicant submits an interconnection
request using the appropriate form, along with the Level 4 application fee (see
Appendix C).
b) Within 10 business days
after receipt of an interconnection request, the EDC shall notify the applicant
whether the request is complete. When the interconnection request is not complete,
the EDC shall provide the applicant with a written list detailing the information
required to complete the interconnection request. The applicant has 10 business days
to provide the required information or the interconnection request is considered
withdrawn. The parties may agree to extend the time for receipt of the additional
information. The interconnection request is deemed complete when the applicant has
provided the required information or when the parties have agreed that the applicant
may provide additional information later and the interconnection request is ready to
be studied.
c) After an interconnection
request is deemed complete, the EDC shall assign a queue position to it based upon
the date the interconnection request is determined to be complete. When assigning a
queue position, an EDC may consider whether there are any other interconnection
projects on the same distribution circuit. If there are other interconnection
projects on the same distribution circuit, the EDC may consider them together. If an
EDC assigns a queue position based on the existence of interconnection projects on
the same distribution circuit, the EDC shall notify the applicant of that fact when
it assigns the queue position. The queue position of an interconnection request is
used to determine the cost responsibility for the facilities necessary to
accommodate the interconnection. The EDC shall notify the applicant as to its
position in the queue. If the interconnection request is subsequently amended due to
a material modification, queue position is determined under Section 466.125 Material
Modifications.
d) After the
interconnection request has been assigned to the queue, the following procedures
shall be followed in performing a Level 4 study review:
1) By mutual agreement of the parties, the scoping
meeting, interconnection feasibility study, interconnection impact study, or
interconnection facilities study provided for in a Level 4 review and discussed in
this Section may be waived or combined. The applicant may unilaterally combine the
interconnection feasibility study and the interconnection system impact study.
Notwithstanding the waiver of any studies, any such waiver does not preclude further
analysis and study by the EDC. The applicant retains the obligation to pay all
resultant costs of required upgrades.
2)
If agreed to by the parties, a scoping meeting on a mutually agreed upon date and
time shall be held, after the EDC has notified the applicant that the Level 4
interconnection request is deemed complete, or the applicant has requested that its
interconnection request proceed under Level 4 review after failing the requirements
of a Level 2 or Level 3 review. The meeting's purpose is to review the
interconnection request, existing studies relevant to the interconnection request,
and the results of the Level 2 or Level 3 screening criteria.
3) When the parties agree that an interconnection
feasibility study shall be performed, the EDC shall provide to the applicant, no
later than 10 business days after the receipt of a complete interconnection request
or, if held, the scoping meeting, an interconnection feasibility study agreement
(see Appendix E), including an outline of the scope of the study and a non-binding
estimate of the cost to perform the study. If the applicant does not sign and return
the study agreement within 15 business days, the application shall be deemed
withdrawn.
4) When the parties agree
that an interconnection feasibility study is not required, the EDC shall provide to
the applicant, no later than 10 business days after the receipt of a complete
interconnection request or, if held, the scoping meeting, an interconnection system
impact study agreement (see Appendix F), including an outline of the scope of the
study and a non-binding estimate of the cost to perform the study. If the applicant
does not sign and return the study agreement within 15 business days, the
application shall be deemed withdrawn.
5) If the parties agree that neither an
interconnection feasibility study nor a system impact study is required, the EDC
shall provide to the applicant, no later than 10 business days after receipt of a
complete interconnection request or, if held, the scoping meeting, an
interconnection facilities study agreement (see Appendix G) including an outline of
the scope of the study and an estimate of the cost to perform the study. If the
applicant does not sign and return the study agreement within 15 business days, the
application shall be deemed withdrawn.
6) Contingent upgrades that are identified during
the evaluation of the interconnection request shall be documented in the applicable
study reports and the interconnection agreement. For each contingent upgrade, when
available, the EDC shall provide non-binding estimated interconnection facilities
and distribution upgrades costs (if any) and estimated construction schedule upon
request of the applicant.
e)
The following guidelines shall govern all required interconnection studies:
1) Unless waived by an applicant, an
interconnection feasibility study shall include any necessary analyses for
identifying a potential adverse system impact to the EDC's electric distribution
system that would result from the interconnection at the applicant's proposed point
of interconnection from among the following:
A)
Initial identification of any circuit breaker short circuit capability limits
exceeded because of the interconnection.
B) Initial identification of any thermal overload
or voltage limit violations resulting from the interconnection.
C) Initial review of grounding requirements,
including review per IEEE C62.92.6 for inverter-based DER when additional grounding
equipment is considered, and system protection.
D) Description and non-binding estimated cost and,
if available, construction schedule of facilities required to interconnect the DER
facility to the EDC's electric distribution system in a safe and reliable manner,
including identification of potential increased expenses due to location,
distribution system assets, or other relevant factors. Cost estimates provided in
each instance must be itemized in line item format and must break down costs by
equipment, labor, and other cost categories. The cost estimates must also provide
the component parts for direct, indirect, and other identified cost
categories.
E) If an applicant requests
that the interconnection feasibility study evaluate multiple potential points of
interconnection, additional evaluations may be required. Additional evaluations
shall be paid for by the applicant.
F)
An interconnection system impact study is not required when the interconnection
feasibility study concludes that there is no adverse system impact, or when the
study identifies an adverse system impact, but the EDC is able to identify a remedy
without the need for an interconnection system impact study.
G) A study results meeting will be held within 10
business days after study completion if requested by the applicant. The study
results meeting will be attended by technical representatives of the EDC and the
applicant. The study results meeting shall not relieve the applicant from its
obligations, nor does it toll the clock for the applicant, to take the actions
required by the rules at that point in the Level 4 review.
H) Each party may require that the standard form
of interconnection feasibility study agreement approved by the Commission be used.
If both parties agree, however, an alternative form can be used.
2) An interconnection system impact
study evaluates the impact of the proposed interconnection on both the safety and
reliability of the EDC's electric distribution system. The study identifies and
details the system impacts that interconnecting the DER facility to the distribution
system has if there are no system modifications. It focuses on the potential or
actual adverse system impacts identified in the interconnection feasibility study,
including those that were identified in the scoping meeting. The study shall
consider all other DER facilities that, on the date the interconnection system
impact study is commenced, are directly interconnected with the EDC's system, have a
pending higher queue position to interconnect to the electric distribution system,
or have signed an interconnection agreement.
A) A
distribution interconnection system impact study shall be performed when a potential
distribution system adverse system impact is identified in the interconnection
feasibility study. The EDC shall send the applicant an interconnection system impact
study agreement within 10 business days after transmittal of the interconnection
feasibility study report. The agreement shall include an outline of the scope of the
study and a non-binding estimate of the cost to perform the study. The system impact
study shall take into account the proposed DER facility's design and operating
characteristics and study the project according to how the project is proposed to be
operated. The applicant must provide adequate design assurance in accordance with
Section 466.75, through demonstration of devices tested to national standards, or
approved by the EDC. The export capacity shall be used except when assessing fault
current contribution, in which case the nameplate rating is appropriate (unless
assurance, approved by the EDC, has been provided showing fault currents are not
directly related to nameplate rating and are controlled by some means). The impact
study shall include any pertinent elements, assumptions, and thresholds identified
in the Impact Study Template in Appendix F.
B) The final interconnection system impact study
shall provide the following:
i) The underlying
assumptions of the study;
ii) A summary
of the analyses;
iii) The results of the
analyses, including detailed information on any impacts identified, the drivers and
reasons for those impacts, including load, voltage, thermal and other limitations,
as well as the boundaries of the impacts, to the extent possible;
iv) A list of any potential impediments to
providing the requested interconnection service and information regarding technical
thresholds that drive modifications;
v)
Required distribution upgrades;
vi) A
non-binding estimate of cost and time to construct any required distribution
upgrades. Those cost estimates shall provide the component parts for direct,
indirect, and other identified cost categories. Cost estimates must be itemized and
must break down costs by equipment, labor, overhead and other cost categories;
and
vii) If the cost estimate exceeds
150% of the estimated cost set forth in the feasibility study, a written
itemization, by equipment, labor, overhead and other cost categories, of the
component parts that increased in cost and a detailed explanation for the cost
increase.
C) A study results
meeting will be held within 10 business days after study completion if requested by
the applicant. The study results meeting shall not relieve the applicant from its
obligations, nor does it toll the clock for the applicant, to take the actions
required by the Rules at that point in the Level 4 review.
D) The parties may use an interconnection impact
study agreement as approved by the Commission. If both parties agree, however, an
alternative form can be used.
3) Unless waived by the applicant, the
interconnection facilities study shall be conducted as follows:
A) The interconnection facilities study agreement,
which includes an outline of the scope of the study and a non-binding estimate of
the cost to perform the study, shall be transmitted to the applicant within the
later of 10 business days after completion of the interconnection system impact
study or 5 business days after the study results meeting, if performed, or within 10
business days after the applicant notifies the EDC pursuant to Section
466.90(b)(4)(C),
Section
466.100(c)(3),
or Section
466.110(b)(3).
B) The interconnection facilities study shall
estimate the cost of the equipment, engineering, procurement and construction work,
including overheads, needed to implement the conclusions of the interconnection
feasibility study and the interconnection system impact study.
i) Non-binding cost estimates must be itemized and
must break down costs by equipment, labor, overhead, and other cost categories.
These cost estimates must also provide the component parts for direct, indirect, and
other identified cost categories; and
ii) If the cost estimate exceeds the lesser of
150% of the estimated cost set forth in the feasibility study or 125% of the
estimated cost set forth in the system impact study, a written itemization, by
equipment, labor, overhead and other cost categories, of the component parts that
increased in cost and a detailed explanation for the cost increase.
C) The interconnection facilities study
shall identify:
i) The electrical switching
configuration of the equipment, including transformer, switchgear, meters and other
station equipment;
ii) The nature and
estimated cost of all the EDC's interconnection facilities and distribution upgrades
necessary to accomplish the interconnection; and
iii) An estimate for the time required to complete
the construction and installation of the facilities.
D) The EDC may agree to permit an applicant to
separately arrange for a qualified third party to design and construct the required
interconnection facilities. In such a case:
i) The
applicant shall utilize EDC-approved engineering and construction contractors for
the design and construction of the interconnection facilities, which shall be built
in accordance with the EDC's specifications;
ii) Such facilities shall be limited to
interconnection facilities serving only the applicant's DER facility;
iii) The applicant shall not include work on
existing energized EDC electric distribution facilities, or in energized EDC
substations;
iv) The applicant must
comply with security and confidentiality requirements before the EDC provides all
relevant information and required specifications to the applicant to permit the
applicant to obtain an independent design and cost estimate for the facilities;
and
v) The EDC shall maintain the right
to inspect, test, or witness test all facilities designed and constructed under the
provisions of this subsection and shall be allowed to recover the associate costs it
incurs from the applicant.
E)
A study results meeting will be held within 10 business days after study completion
unless parties mutually agree to waive the meeting. The study results meeting shall
not relieve the applicant from its obligations, nor does it toll the clock for the
applicant, to take the actions required by the rules at point in the Level 4
review.
F) Upon completion of the
interconnection facilities study, and after the applicant agrees to pay for the
interconnection facilities and distribution upgrades identified in the
interconnection facilities study, the EDC shall provide a standard DER
interconnection agreement (see Appendix D) for the applicant to sign the day the EDC
makes its determination.
G) In the event
that distribution upgrades due to the impact of the interconnection request are
identified in the impact study that shall be added only in the event that
higher-queued customers not yet interconnected eventually complete and interconnect
their generation facilities, the applicant may elect to interconnect without paying
for such upgrades at the time of the interconnection, provided that it agrees to pay
for such upgrades at the time the higher-queued customer is ready to interconnect.
If the applicant does not pay for such upgrades at that time, the EDC shall require
the applicant to immediately disconnect its distribution generation facility to
accommodate the higher-queued customer.
H) Notwithstanding anything to the contrary,
nothing prohibits two or more joint applicants directly adjacent in the
interconnection queue on a feeder or substation from jointly informing the EDC of a
request for a group study or estimate. That notice shall be provided on a form
approved by the Commission that, at minimum, authorizes a group study with costs for
upgrades and the facilities study to be shared as determined by the joint applicants
and waives confidentiality protections only to the extent necessary to generate and
circulate that group study. For the purposes of this subsection, a "group study" is
an impact study or facilities study created and issued under subsection (e)(2) or
(e)(3) (as applicable) that studies the least-cost upgrades to interconnect all of
the joint applicants' facilities.
I) The parties shall use an interconnection
facilities study agreement approved by the Commission. If both parties agree,
however, an alternative form can be used.
4) All studies analyzing or projecting load flow
or system impact shall take into account the impact of storage, operating profile
(including voluntary operational restrictions), impact and timing of load flow, or
other parameters provided by the applicant that would impact timing or volume of
load flow. Any parameters shall be reflected in Attachment 2 to the interconnection
agreement. When performing feasibility studies, system impact studies, and facility
studies for a DER facility, operating characteristics (including maximum export and
import capacity) as identified in the application by the applicant shall be
utilized, except that fault current contribution shall be evaluated based on
aggregate AC nameplate rating. The utility's technical review shall determine
whether the proposed facility, operating per the characteristics identified in the
application and with any necessary controls, can be safely and reliably
interconnected to the utility's distribution system.
f) When an EDC determines because of the studies
conducted under a Level 4 review that it is appropriate to interconnect the DER
facility, the EDC shall provide the applicant with a standard DER interconnection
agreement. If the interconnection request is denied, the EDC shall provide the
applicant with a written explanation as to its reasons for denying interconnection.
If denied, the interconnection request does not retain its position in the
queue.
g) Within 30 business days after
receipt of the standard DER interconnection agreement, the applicant shall provide
all necessary information required of the applicant by the agreement, and the EDC
shall develop all other information required of the EDC by the agreement. After
completing the agreement with the additional information, the applicant shall sign
and return the agreement to the EDC. If the applicant does not sign and return the
agreement within 30 business days after its completion, the interconnection request
shall be deemed withdrawn, unless the applicant requests in writing to have the
deadline extended by no more than 15 business days. The EDC shall not deny an
initial request for extension. If the applicant does not sign the agreement after
the 15-business-day extension, the interconnection request shall be deemed
withdrawn. The EDC shall return a fully executed DER interconnection agreement
within 10 business days of receipt of the signed agreement from the applicant. If
withdrawn, the interconnection request does not retain its position in the queue.
When construction is required, the interconnection of the DER facility shall proceed
according to milestones agreed to by the parties in the standard DER interconnection
agreement.
h) The DER facility is not
permitted to operate until:
1) The requirements of
the interconnection agreement are satisfied;
2) The DER facility is approved by electric code
officials with jurisdiction over the interconnection;
3) The applicant provides a certificate of
completion (see Appendix B) to the EDC. Completion of local inspections may be
designated on inspection forms used by local inspecting authorities; and
4) The witness test is successfully completed if
required by the EDC or if the witness test is waived according to Article 2.1.1 of
Appendix D.