Interconnection
Section 1251 of the EPAct of 2005, PURPA 111(d) Standard (15) Interconnection states the following:
Each electric utility shall make available, upon request, interconnection service to any electric consumer that the electric utility serves. For purposes of this paragraph, the term "interconnection service" means service to an electric consumer under which an on-site generating facility on the consumer's premises shall be connected to the local distribution facilities. Interconnection services shall be offered based upon the standards developed by the Institute of Electrical and Electronics Engineers: IEEE Standard 1547 for Interconnecting Distributed Resources with Electric Power Systems, as they may be amended from time to time. In addition, agreements and procedures shall be established whereby the services are offered shall promote current best practices of interconnection for distributed generation, including but not limited to practices stipulated in model codes adopted by associations of state regulatory agencies. All such agreements and procedures shall be just and reasonable, and not unduly discriminatory or preferential.
In order for SEIEC to make a specific determination as to whether this standard is appropriate to implement, SEIEC reviewed the stated purpose for this new standard as follows:
(1) Conservation of energy supplied by electric utilities
(2) Optimal efficiency of electric utility facilities and resources
(3) Equitable rates for electric consumers
One area of benefit for utilities that can be achieved by distributive generation resources includes the ability to potentially avoid transmission and distribution upgrades in the future thereby improving asset utilization. One area of potential concern, due to the relative unreliability of distributive generation facilities as compared to utility generation facilities, is the less efficient operation and utilization of utility generation facilities and resources. The level of concern regarding this issue depends upon the capacity and type of distributive generation technologies installed and connected to SEIEC's system. If designed appropriately, interconnection standards can achieve the first two PURPA stated purposes above while not negatively impacting the third purpose.
SEIEC is a proponent of renewable energy resources and conservation of energy. In fact, SEIEC has had distributive generation interconnections with sizable coal-bed methane distributive generation facilities in the past and achieved successful and safe working relationships with those projects. Those sizable projects ceased when the technology became available to process the methane gas and sell into primary natural gas pipeline facilities.
There are a number of opportunities that must be evaluated when considering the interconnection of distributive generation facilities. The primary area of concern with this type of interconnection is the safety of utility personnel due to reverse power flow and distributive generation facility personnel while working with or around these interconnections. Other areas of reliability concerns include frequency and phase synchronization, short circuit current levels, voltage stability and regulation.
Another primary area of concern with distributive generation interconnection is stranded costs (reasonable expenses recovered through electric rates that SEIEC charges to pay for the cost to construct and deliver power in a safe, reliable manner) that must be recovered by SEIEC. SEIEC invested in the facilities required to deliver energy to an account and recovers that facility investment over a period of years in the form of charges in the electric rates. When a distributed generation facility is installed and is delivering energy to said account, SEIEC may not have the ability to recover the required investment. In the case of an individual residence with minimal generation facilities, this stranded cost investment may be very small or insignificant but in the case of larger distributed generation projects that serve larger commercial facilities; this stranded cost recovery may be very significant.
Recommendation:
As stated in the PURPA Standard, this Interconnection recommendation pertains to a member-owned generating facility that is interconnected with SEIEC's distribution system that permits parallel operation of the facilities. This standard or recommendation does not pertain to a member-owned generating facility that is used only as backup supply to SEIEC energy supply and is only operated thru an approved transfer switch or other appropriate isolation method that completely isolates the generation facility from SEIEC facilities and does not permit parallel operation of the facilities.
In order to address the safety, power quality and reliability concerns, SEIEC has developed a list of specifications that distributive generation projects must comply with. The Institute of Electrical and Electronics Engineers, Inc. (IEEE) developed the IEEE Standard 1547 titled "Standard for Interconnecting Distributed Resources with Electric Power Systems" that specifies safety and technical standards with the interconnection of distributed resources. All distributed resources that desire an interconnection with SEIEC shall comply with the IEEE Standard 1547, which includes all future updates and amendments to this standard. In addition, all distributed resources that desire an interconnection with SEIEC shall comply with the National Electric Code (NEC), the National Electric Safety Code (NESC), the American National Standards Institute (ANSI), and any other future, applicable standard that governs such installation including that of federal, state and local authorities. In addition, any distributive generation facility with a nameplate rating of 50 KW or more for residential applications and 200 KW or more for all other applications shall comply with all previously stated specifications and with Southern Illinois Power Cooperative's (SIPC) Facilities Connection Requirements.
The distributed generation facility must include a disconnect device between SEIEC's facilities and those facilities owned by the generation facility. The disconnect device shall meet all requirements of the IEEE Standard 1547, National Electric Code, National Safety Code, Underwriters Laboratories and must provide a visible opening between SEIEC facilities and the generation facilities. The disconnect device shall be readily accessible and be lockable by SEIEC employees. This is to provide SEIEC employees and facilities with an appropriate isolation device to help prevent what is known as "back feed" that can occur during normal utility outages.
When SEIEC receives a request for a qualified distributed generating facility with a nameplate rating of less than 50 kW for residential applications and a nameplate rating of less than 200 kW for all other applications, SEIEC will:
1. Provide the applicant with an application (See Appendix F - SEIEC Application for Operation of Customer-Owned Generation) that shall be completed by the applicant.
2. After receipt of the application, SEIEC will determine if a system impact study is required. If the system impact study is required, SEIEC will provide the applicant with the cost to perform the study and applicant will make the decision to pay for the study and proceed or to abandon the project.
3. In the event the system impact study indicates that the generation capacity must be limited, SEIEC will work with the applicant to determine the capacity limit of the generation on a case by case basis.
4. SEIEC will determine the costs of the required system upgrades or additional work that must be performed in order to accommodate the interconnection with the facility. SEIEC will also perform feasibility studies to determine the amount, if any, of stranded costs (reasonable expenses recovered through electric rates that SEIEC charges to pay for the cost to construct and deliver power in a safe, reliable manner) that must be recovered by SEIEC. SEIEC may recover the stranded cost thru an upfront contribution or an increased facility charge.
5. If the applicant agrees to pay for the required system upgrades, additional work required and the stranded cost recovery amount, the applicant will be provided with the interconnection agreement (See Appendix G - SEIEC Agreement For Interconnection and Parallel Operation of Distributed Generation) which states the requirements of the applicant for installation.
6. Once the interconnection agreement is executed by both parties and the applicant has paid for all required amounts, SEIEC will proceed with its responsibilities as shown in the agreement.
SEIEC retains the right to review the amount of distributed generation connected to the member's system and may limit the total amount, if necessary.
When SEIEC receives a request for a qualified distributed generating facility with a nameplate rating of 50 kW or more for residential applications and a nameplate rating of 200 kW or more for all other applications, SEIEC and SIPC will:
1. Provide the applicant with an application (See Appendix F - SEIEC Application for Operation of Customer-Owned Generation) that shall be completed by the applicant.
2. After receipt of the application, SEIEC and SIPC will determine if a system impact study is required. If the system impact study is required, SEIEC will provide the applicant with the cost to perform the study and applicant will make the decision to pay for the study and proceed or to abandon the project.
3. In the event the system impact study indicates that the generation capacity must be limited, SEIEC and SIPC will work with the applicant to determine the capacity limit of the generation on a case by case basis.
4. SEIEC and SIPC will determine the costs of the required system upgrades or additional work that must be performed in order to accommodate the interconnection with the facility. SEIEC will also perform feasibility studies to determine the amount, if any, of stranded costs (reasonable expenses recovered through electric rates that SEIEC charges to pay for the cost to construct and deliver power in a safe, reliable manner) that must be recovered by SEIEC. SEIEC may recover the stranded cost thru an upfront contribution or an increased facility charge.
5. If the applicant agrees to pay for the required system upgrades, additional work required and the stranded cost recovery amount, the applicant will be provided with the interconnection agreement which states the requirements of the applicant for installation.
6. Once the interconnection agreement is executed by all three parties and the applicant has paid for all required amounts, SEIEC and SIPC will proceed with their respective responsibilities for installation.
SEIEC and SIPC retain the right to review the amount of distributed generation connected to the member's system and may limit the total amount, if necessary.