At the start of any journey, it’s important to have a clear understanding of the road ahead. A detailed map and a good set of directions show us the distance we plan to travel and the landmarks we’ll see along the way.
Even after we’ve hit the road, GPS technology and social media platforms keep us, and people we’re meeting, apprised of our progress in real time. And traffic reports help us spot bottlenecks in advance, so we can avoid logjams and find the best alternative routes.
Without a doubt, information about the road ahead helps us travel more efficiently and ensures a smoother ride toward our final destination.
The same is true for interconnection. Greater knowledge and visibility into our electricity system at the start of the process -- and the use of tracking and information-sharing tools once the process is underway -- help the queue move efficiently and ensure a smoother journey for renewable energy and other distributed energy resources connecting to the grid.
Just as we reach for mapping technologies when we’re on the road, there are many proven and emerging tools that applicants, utilities and regulators can use to improve transparency and access to grid data in the interconnection process.
The first of these tools -- highlighted by both IREC and FERC -- is a little-known gem called a pre-application report. As the name suggests, these reports, which are usually generated by a utility for a modest fee paid by the customer, allow a prospective interconnection applicant to request specific, readily available information about potential grid locations before submitting a formal interconnection application.
Obtaining this information at the beginning of the project development process makes it easier to identify more optimal locations on the grid for a project and to avoid problematic locations where significant grid upgrades or lengthy study may be required. The reports also benefit utilities because they curtail the volume of “fishing” applications, which force utilities to review projects that are unlikely to be built and create obstructive queue backlogs. For example, California has had a very positive experience with Rule 21’s robust pre-application report, which the Public Utilities Commission recently approved. These “enhancements” provide developers with even more sophisticated technical information.
Distribution system maps
Another tool for improving access to grid data: detailed maps of utility distribution systems. Similar to time-saving pre-application reports, system maps can help interconnection customers identity upfront the more optimal (and less optimal) grid locations. By increasing visibility into the characteristics and feasibility of individual circuits, these maps save both customers and utilities time and money. Bandwidth-strapped utility engineers can avoid the time-intensive review of “fishing” applications and time-consuming communications with customers.
Another benefit of the maps is that they are more likely to result in strategically located projects throughout the utilities’ systems. Just as the automatic traffic detection features on our smartphones help us reroute to avoid potential gridlock, distribution system maps can help customers make more informed choices about where they choose to locate on the grid, avoiding areas where a project might be problematic or too costly to accommodate.
Several states are already leading the way on this front. California has required its utilities to enhance their existing online interconnection maps with additional information showing available capacity as part of their distribution resources plans. As a result, customers in Pacific Gas & Electric’s service territory can scout for potential interconnection points with the click of a mouse on this interactive website map.
Similar maps exist for California’s other big investor-owned utilities, Southern California Edison (see figure below) and San Diego Gas & Electric. Hawaiian Electric Company is similarly using online maps to provide customers with information on the penetration levels that have been reached on distribution circuits.
FIGURE 1: Southern California Edison’s Distributed Energy Resource Interconnection Map
Interconnection data collection and sharing
Even with improved access to grid data and distribution system maps, the interconnection process can be opaque. Applicants are often left in the dark after they submit their initial paperwork to utilities -- they have no way to check their projects’ progress in the queue, and they have little understanding of how long it will take for utilities to complete their review.
The lack of transparency can be frustrating for utilities and regulators too, because they can’t identify or address where the bottlenecks may be happening. In North Carolina, for example, high volumes of interconnection requests recently resulted in backlogged study queues and prevented renewable energy projects from being developed in a timely manner. Utilities, unfortunately, did not have objective details regarding which projects were stuck or where the impasse seemed to be, and the state is continuing to struggle with this burden.
Another low-cost and increasingly important strategy to improve system transparency: utilities and regulators can collect and share data about the interconnection process itself.
To keep tabs on applicants’ projects and help everyone understand what’s happening in the queue, states can require utilities to track when timeline milestones are met on a project-by-project basis. Doing so can allow regulators and utilities to see if applicants are meeting their deadlines and if utilities are completing their studies on time -- and it can potentially reveal whether they are subject to any penalties or incentives related to timeline compliance.
One of the best ways to keep track of projects seeking to interconnect is to require utilities to post a single publicly available queue, and to update it on at least a monthly basis. Sharing the queue with the public is valuable because it gives all parties greater insight into the interconnection process.
In the most useful cases, applicants can tell how many projects are ahead of them in line, as well as where those projects are sited, and consider how that might impact their decisions regarding their own projects. Utilities and state regulators can also look to the queue to identify and address any bottlenecks or other problems in the process. For example, in Minnesota, Xcel provides a public queue of communitysolargardens applications, and IREC has encouraged its expansion to encompass all interconnection applications, as well as additional relevant data points.
Interconnection reporting to an appropriate state agency is another key strategy for data transparency and information sharing, and it can be especially helpful during regulatory proceedings to inform any changes that may need to be made. In Massachusetts, utilities provide monthly reports to the state Department of Energy Resources on the status of all interconnection applications. The agency uses the data in these reports to generate information -- posted online and updated every other month -- identifying the type and quantity of distributed generation projects within the interconnection process.
Some states are beginning to consider more ambitious tools to streamline interconnection and better integrate information sharing within the process. For example, as part of its ambitious Reforming the Energy Vision initiative, New York has emphasized its plans to develop an online portal for interconnection, allowing customers to submit online applications with automated management and screening. This concept has generated interest in other states as well. In the meantime, more modest steps, such as those discussed above, can yield major benefits, especially in states whose distributed energy markets are just emerging.
In addition to understanding how the interconnection process is running, and where a project is in the queue, having some certainty about the costs of interconnection is critical. Right now, most customers move through the process without knowing how much they will ultimately have to pay to bring their projects on-line. When the final costs are low, this uncertainty doesn’t matter too much. But when the bills are high, there can be major repercussions.
Erica McConnell is special counsel and Cathy Malina is an environmental law fellow with Shute, Mihaly and Weinberger LLP, attorneys for the Interstate Renewable Energy Council.
IREC’s Regulatory Program Director, Sara Baldwin Auck, will be a panelist on an interconnection session at the NARUC Winter Committee Meeting on Feb. 12 in Washington, D.C. The session is titled "Reimagining State Interconnection Rules for Distributed Generation Plug-and-Play Procedures."