(inaudible)
(item:1:54233, Welcome - David Smeltzer, Director of Rules & Projects) Hear ye, hear ye. Thus openeth the Staff Workshop in
Project 54233, Interconnectional Requirements for Distributed
Energy Resources. We have some topics that are posted
uh for discussion. And I think that we uh I think if
we're going to try and keep this pretty loose. As long
as we're all being sort of civil and taking our turns.
We think this discussion will be better if there's
some back and forth opportunity. To ask questions or
even ask each other questions. So that we can make sure
we're, you know, running down all the rabbit trails.
And so I think uh (item:2:54233, David Smeltzer - Director of Rules & Projects) my name is David Smeltzer. Hi, I'm the
Director of Rules and Projects. Uh a couple of
other Members of Staff up here. They may be asking
questions. (item:2:54233, Mariah Benson - Market Analysis) Mariah Benson, Market Analysis.
Yeah, (item:2:54233, John Poole & Sherryhan Ghanem - Engineering) I'm John Poole, Engineering. Sherryhan Ghanem, Engineering.
Very good. And so um sort of the, (item:3:54233, Order of Business - David Smeltzer) the order of business.
We'll open up one of the discussion uh topics. And then
anyone that has an opinion or wants to ask questions.
Go ahead and just come down to the front. Take one
of the seats. Um, uh I'll sort of gesture in your direction
when it's, when it's your turn to go. And if you will
say your, your name and who you represent. Um, just
for our record keeping purposes. Um, so we can reach
back out with questions if we need to. And then at
the end of anyone that has sort of, I guess opening
comments on a question, that they would like to address.
Uh Staff may ask questions in real time or you know
at the end after everyone's spoken. If anyone has questions
that they want to ask other people. Um I'll just do
my best to acknowledge, as people raise their hands
or wave uh in real time. Um so that we can just
make it pretty functional. I mean, the last thing is
uh we have some Staff proposals that are listed here.
And I think that we have a request from Infrastructure.
That if you have other proposals try and give us uh
flush out. Why yours are good and why ours are bad?
And so, to the extent that we can get a full consideration
of the different thresholds and stuff. That would be
helpful to us. And then if we still have time, we will
uh under the third topic. If there are additional topics
that you guys want to pose for discussion. For future
workshops or whatever, we will um sort of record those.
Uh and we can have discussion on that if it makes sense.
So, uh I think that's right.
So does anyone, so we. Our first, uh Mariah do you want
to introduce the first topic? Sure. Um, (item:4:54233, Mariah Benson gives overview of Proposal One) the First Proposal
Staff put forward is for the Interconnection Standards.
What is currently 25.211. Uh we are proposing splitting
the standards into 2 different rules. The first rule
would be 25.211 existing. And it would continue to
apply for small DERs and we're proposing small be
anything under 50 kilowatts. The second we'd propose
is a new rule to apply for Big DERs. Which
would be anything over 50 kilowatts. Um and we're looking
for comments on again the 50 kilowatt threshold. And
if it should be two rules? One rule? What were the
rules should be taken up on? Anything related to the
proposal is what we're seeking comments on.
We are gonna have a very short uh consensus reached
on this.
(inaudible)
Yeah. And so just to clarify, anybody who has an alternative
proposal, supports the proposal. Thinks it's a horrible
proposal. Now is the time to come up and air your thoughts.
(item:4.1:54233, Eric Goff with Texas Solar Power Association) Eric Goff on behalf of the Texas Solar Power
Association. Um we support uh bifurcating the rule.
Um we suggested a higher threshold than 50 kW in our
comments, but aren't opposed to 50 kW. We, we think
it should be um considered to be higher though. Because
the, the issues at hand um, don't really arise if you
get a larger threshold. So, while 50 kW isn't objectionable.
We, we think that uh you know you could, you could
go higher than that. Um, and then we also suggested
specifics for um what that uh proposal would be.
So to try, to uh reduce burdens as much as possible
on the homeowner or the DER installer that's been trying
to install that. We got in specifics in our comments
there. I don't know that we need to do that right now.
Um but if you want me to, we can. (item:4.1:54233, Eric Goff's follow-up on wattage question from Mariah Benson) Just to clarify,
what would you recommend it be, if not 50 kilowatts?
I think we said, um a megawatt in our comments. Um
but um you know the, the higher, the better. I think
it's appropriate. Um there are some things that, you
know. It's, it's not black and white, it's a gradient.
But to the extent that there are, it's a simple process
for option A. The higher you feel comfortable going
the better. Because you'll be able to have a lot more
customers and the installers to follow a simpler process.
Good afternoon.
Good afternoon. I don't think that was on, was it?
I think it was, but you can switch. All right. (item:4.1:54233, Martha Henson with Oncor) Good afternoon, Martha
Henson with Oncor. I'm actually gonna agree with Eric,
maybe for once. Um
so in our comments that we filed in Project 54233 back
in January. Oncor had also suggested two different
rules for DERs. Although our cut point was based on
DER behavior. Um so we do like the Staff proposal
of having two separate rules. And although we know
that Staff here is asking for a cut point based on
size, not behavior. We're also very supportive of that.
So Oncor's recommendation though is actually also a
1 megawatt division point. So we think 1 megawatt
makes more sense. To be the dividing point between the
two rules. Such that the 1 megawatt and smaller
DERs would go into the existing 211. Which we know
needs to be updated. And then the greater than 1
megawatt DERs, would belong in the new substantive
rule. That perhaps the discussion draft in 54233, could
serve as a starting point for. One thing that would
be important though, in the rule for the smaller ones.
We think that, that rule should allow for the interconnecting
utility. To be able to separately address DERs, that
pose some sort of unique complexity. That might necessitate
a more detailed rule than, a more detailed review than
that rule provision. Would, would most likely provide
for the vast majority of 1 megawatt or smaller
DERs. So that's just one additional suggestion for
the, I guess Interconnection Standard, B.
Thank you.
So do our recent additions, do you guys have uh separate
comments or responsive comments? Had a question and
then a responsive comment, so.
And I have, uh a responsive comment to the initial
question. And maybe responding back to the others, as
well. Okay. Yeah. So if you have to the initial question.
Why don't you go take a shot at it? Okay. Uh (item:4.2:54233, Stephanie Kroger with Hunt Energy Network) Stephanie
Kroger with Hunt Energy Network. Um I think also like
the others, we support bifurcating the rule. Um and
I think we suggested that in the comments that we filed
originally too. We are, I don't know that we have a
strong preference for whether it's uh 50 kW or 1
megawatt. I do see, you know, some simplicity in having
the same cut point in both rules. Uh but the other
issue that I think needs to be addressed is. Um where
the, the facility is located and whether it's front
of the meter, stand alone, participating as DGR or
ADESR or whether it's behind the meter. Um and
part of that I mean. The language that is currently
in the draft rule. Suggests that it only applies behind
the meter. So I think we just need to be intentional
about. Are we trying to apply this to both or are we
trying to be specific? About not just a size but also
you know, is it a stand alone resource? I think it
clearly works for standalone resources.
The behind the meter creates perhaps another level
of, of um challenges. With the interconnection or issues
not challenges but different issues.
I, I don't know if others in the audience have questions
about that. I know that something on Staff side. We
have struggled with. Because at least we've heard about
uh front of the meter and behind the meter, that are
relatively the same size. But then when we talk about
treating them differently, and to a certain extent what
that really means. Could you just flush out a little
bit? Like front of the meter, behind the meter? Why we
need two different standards for them? (item:4.2:54233, Stephanie Kroger's follow-up on front/behind the meter question from Mariah Benson) What, and it
may not be, that there has to be two. But, but the
rule needs to be clear. If it's applying to both or
if it's applying just to one. So, so front of the meter,
DGR/DESR are standalone resources. They go
through the ERCOT Commissioning Process. They're providing
energy ancillary services into the market. Um and,
and in our mind, the really the only difference between
those resources and transmission level resources is
the voltage. They're going through what's effectively
a very similar process and qualification. Um with behind
the meter, I think you just have a greater variation
of um of types of resources, you know. You may have
resources that are SODGs for example. Um or,
or are interconnecting but not really injecting. Um
and it may be that the same interconnection process
can work for that. Uh but it just needs to be recognized
that they are um different types of resources. And,
and um many of those tend towards, tend towards the
smaller, smaller resources as well. I guess from, from
HEN's perspective. What we want to make sure is that
we have a very clear, non discriminatory standardized
process. For those resources that are going through
the ERCOT process, and trying to participate in the
market.
(item:4.2:54233, Ramya Ramaswamy with Commission Staff asks clarifying question to Stephanie Kroger) Um Ramya Ramaswamy for Staff. Um so um, just to clarify. So you're
saying this is whether it's 1 megawatt, 50 kilowatts
it doesn't matter. You just want it to be very clear
on whether it's front of the meter or behind the meter?
I'm just trying to. (item:4.2:54233, Stephanie Kroger's follow-up comments) Yes, I don't think we have a strong
opinion on the 50 kW versus 1 megawatt. Although
again, I think there is some simplicity in using the
same for both. Um but I, I don't know that we have
a strong opinion on that. But we do want to be clear.
When it's front of the meter and when it's behind the meter.
So on this just so that while, while we're on that
topic. Is there anyone else, that wants to talk about
on the meter, front of the meter, behind the meter issues
in response to what Stephanie was just discussing?
If so, if so come on forward.
Is that what? Sir, is that what you came up to talk
about or no? No. Okay.
(item:4.2:54233, Mickey Moon with CenterPoint) Yeah, Mickey Moon with CenterPoint. Um I agree with Stephanie.
From a TDU perspective. Uh one of the differences between
a behind a meter and in front of the meter. Is in
behind the meter situation, uh the generator will be
able to piggyback on the facilities. That we install
for the Load, the Load metered customer. Whereas a standalone
generator, in front of the meter generator. There's
no Load customer facilities to be piggyback on. So
the facility, the way you interconnect will be different
as a TDU with those type of facilities. And I know
cost is not uh subject in this rulemaking. But you're
going to have different cost issues. Between the behind
the meter generator and the front of the meter generator.
(cough)
Are you joining us for this topic? Yes. Before you
moved on Craig Bennett. Hopefully, you can hear me without
the microphone. But I'll try to make sure I bring it
in. Just for the broadcast. Yeah, absolutely. Um (item:4.2:54233, Craig Bennett with CPS Energy comments on both subjects under Proposal One) Craig
Bennett, I'm representing CPS Energy for purposes
of this workshop today. Um we wanted to first off say
that we support, um Oncor's position. About if we're going
to have that break in terms of the standards. That it's
more appropriate to have it closer to 1 megawatt
or have use that as the standard. But we also think
it's important to as Oncor mentioned. Talk about the
function, that the function is more important than the
size. And so in general, we support Oncor's comments
on, on both of those matters. Um also, you know, in
terms of when we talk about in front of the meter or
behind the meter. It gets kind of tricky. And this
is going to be a topic you'll hear from us frequently
today, as an MOU. Is that once you start getting behind
the meter with an MOU and front of the meter. You know
the authority that the Commission has. Gets very interesting
and different than it does with IOUs. And so that's
something you to be cognizant of. And so, when you start
talking about a distinction of front of the meter, behind
the meter. That's going to be something, as with a lot
of things today. You're going to have to keep in mind
the different jurisdiction that the Commission has
over an MOU. Than it does over other sorts of utilities.
Very good. Other people on the big or behind the front
of meter topic. Okay. Christine, I think you're next. I just
had a question about the um. So we're also supportive
of the concept of having a bifurcated role of resources
above and below a certain um size, are treated somewhat
differently. On the 50 kilowatt break point, our question
was just that. Were you trying to pick that, because
you thought it tracked more with where the break point
is for a small commercial customer under your other
rules? Not really, it just seemed like a common number
coalesced around in comments filed. And we wanted to
break it from 1 megawatt in the operational requirements.
Just to create conversation and see if they should
be broken. Or if again, for simplicity reasons they
should be 1 megawatt. It was just to throw out something
different. And then, we tend to probably agree with um Oncor's
point of view, as well. As I think they're expressed
maybe a one Megawatt, might make sense for these purposes.
That tends to track well with what you're doing in
your ADR pilot project. Where the individual DERs
within an ADR. Are kind of sized underneath that 1
megawatt threshold, so.
All right. So let's do a, a quick classroom activity
here. We've got, we've got the idea that uh the, the
rule should be bifurcated. And so far, everyone that's
come up has agreed with that premise. So, by show of
hands in the audience. If you've not spoken on that
topic, is it because A: you agree with the idea it
should be bifurcated? Or B: you either don't care or don't want
to talk? So A: who thinks it is bifurcating, is ever.
For people on board with bifurcating the rule?
Is there anybody who thinks it's a bad. I, I didn't
offer that at the beginning. Or is there anyone
who just doesn't care? Is there anyone in opposition?
All right. That's good. And then so far we, when we
talk about with regard to the 50 kW. For those that
are silent, I think. So, everyone that we've heard from
has said it 50, 50 is as low as you should go.
But would prefer to go higher. Uh is that like
so. If you agree with the 50 is as low as we
should go, but you would prefer to go higher. Is that
a general opinion held by anyone by show of hands?
And if you, if you disagree with the take that
it should be or higher, anybody in opposition. All
right, perfect. You're already here, tell us about
it. Yes. So it's (item:4.3:54233, David Vignes with AEP) David Vignes with AEP. And we
are in support of having 2 rules, and we think that
is appropriate. The reason we want to lower limit
is we do not want to lose the ability to be able
to study uh, projects. A 50 kilowatt system or a 500
or a megawatt system is going to be different. Depending
on where it's located on the circuit. And so if there
is a, a 1 megawatt system at the end of a rural
circuit. Is a lot different impact than a 100, than a 1
megawatt system at the substation. And so that is really
our distinction. That we would like the lower limit
to be able to, to continue to do those studies as needed,
depending on the circuit conditions.
What limit would you recommend?
You know, I would say around 100 to 150 is generally
the largest residential that we've seen. Um but I think
that would be an appropriate limit.
So even our opposition is for a higher limit than 50
or at least consensing around that point. Eric, what you
got. (item:4.3:54233, Eric Goff's follow-up to lower wattage discussion) Um I understand the point that you're making on
that issue. Um I, I would just want to reiterate Oncor's
suggestion earlier. That they would want to have the
right to study, if they needed to for some reason. And
the details of that could be complex. But that might
be a way to thread the needle, that we're talking about
here.
And I guess to that point because it could be complex.
Would it be better just to keep it lower? So you guys
have the optionality.
If, if we can't add that complex language in and we
go with 1 megawatt. Or is 1 megawatt still better?
I think, we would prefer the lower limit um close to
100. But, you know, obviously what y'all decide is.
(item:4.3:54233, Pete Parsons with Texas Solar Energy Society) My name is Pete Parsons and I'm with the Texas Solar
Energy Society. Uh my only concern about, you know
250. Is I'm not sure that's going to take into account
commercial applications, we had recommended 500. Um
but I don't think we have a problem with going with
1 meg.
Any other questions or views on this little cluster
of topics that we're on? Oh.
Hello, can you hear me? Yes, sir. Uh (item:4.3:54233, Clayton Stice with ERCOT) Clayton Stice with ERCOT.
Uh ERCOT really has no opinion, on in terms of where
the standard is set. Um however, if you are contemplating
raising it up significantly above 250 kilowatts. We
would have note. That there are a number of systems
uh less than 500 kilowatts, that have chosen to register
with ERCOT. So I, I think that when you start talking
about a significantly larger threshold. We would and
registration with ERCOT, it's going to impact your
timelines. Maybe some cost study parameters, things
like that. So we would just like to note that. Systems
that choose to register with ERCOT under a megawatt.
Would also many Sections of 25.211, might be impacted
by that process.
Thank you.
(item:4.1:54233, Rob Bridges with CenterPoint Energy) Rob Bridges with CenterPoint Energy. I would just
like to state. That I would tend to agree more with
the AEP perspective, that was provided earlier. That we
would like to preserve that ability, to be able to study
those other potential different situations. In order
to maintain the reliability of our existing systems.
We agree with Oncor's approach of statement of possibility,
of providing some language within that. However, I'm
not certain that we would be able to come to a consensus
of that language. Which is where my recommendation
would be. To keep that limit at a lower level. Because
of the difficulty in coming up with the special exception
language. Yes.
Um if no one else has any proposals on this particular
topic. (item:4.2:54233, Mariah Benson with Commission Staff, asking for more information) I think on the front of the meter, behind the
meter or behavioral distinctions.
We would need more information on that, and pros and
cons. And again, where everybody else feels about that.
Versus just a single number as a cut off. If anyone
wants to provide additional comments on that. Otherwise
again, I think we would. I, I it, it feels like going
with front to the meter, behind the meter. Again, would
kind of have. It would be more complex in determining
which units are front of the meter versus behind the
meter. And we are not at this time inclined to go with
that. Unless again, there's more explanation provided
on why it's necessary.
And that is obviously you guys know how to get a hold
of us, uh outside of this context if you need to. Um
okay. Is are there any um any other discussion points?
Oh, ok. Just one point on on that. The, the difference
that we may need to take into account. And this is (item:4.2:54233, Mickey Moon's follow-up comments) Mickey
Moon, CenterPoint is that behind the meter generators.
Can be addressed to the extent we need to address them,
in our retail tariffs. As a TDU, whereas the in front
of the meter generators are outside the scope of our
retail tariffs. So to the extent any of the requirements
for interconnection and the technical requirements
are going to apply. Uh to in front of the meter or
standalone generators. That intermit with the distribution
system, we are going to be addressed to the tariff.
We'd need to address them in our wholesale tariff or
in a different tariff than our retail tariff. Whereas
the behind the meter generators, we continue to address
them in our retail rules of our retail tariff. Other
than the different costs, the interconnecting of behind
the meter versus front of the meter. Is there any other
relevant reason, why they should be treated differently?
And the tariff applicability
is the second reason. Um no, I can't think of any other. Thank you.
Anybody have any reactions or anything else to say
on our first discussion topic?
And or does anyone on Staff have questions they want
to pose to the group?
We did it guys, we're so far ahead of schedule. I'm
proud of everybody.
All right. Moving on to Discussion Question Two. Uh
Mariah, do you wanna introduce question? Um,
um.
(item:5:54233, Mariah Benson gives overview of Proposal Two) So the second proposal Staff laid out. Was for the Technical
Standards in existing 25.212. Um we propose a cut
off of 1 megawatt between the two standards. At this
time, we aren't sure if it would be in two rules or
just stay in existing 212. Less than one megawatt
would, would be published in a manner consistent with
the discussion drafts we publish. Such that we lay
out the specific standard we want followed for facilities
less than 1 megawatt. For facilities over 1 megawatt,
we would throw authority to an applicable authority
in the power region. In the ERCOT region, it would be
ERCOT. Outside of ERCOT, that's something we're still
trying to figure out who it would be. But basically,
it would allow them to set the requirements for resources
over one megawatt.
The floor is open for reactions.
Hi, everybody. Um (item:5.1:54233, Monica Batra-Shrader with Enchanted Rock Energy) this is Monica Batra-Shrader on behalf of
Enchanted Rock. Um and we would ideally like the cut
off um to be 2 megawatts, between small and large
um uh entities. Um essentially this would provide a
small system classification on our low voltage sites.
Which are 90% 3 Gens which um is or 1.2 megawatt systems
um and lower. And so, depending on the requirements
of a large system. We don't necessarily want to be
burdened with the same requirements of, you know, a
10 megawatt system, for example. Um and also it's in
the current um rule set 25.212 (b)6. That states
above 2 megawatts, the utility may require transport
trip. And um so I think we wanna maintain that, that
lower threshold. Um or be classified as, as a small
um generating uh facility. And um uh let's see. Yeah
I guess that's, that's my comments. Questions?
(inaudible)
Can you guys hear me? (item:5.1:54233, Bill Blevins with ERCOT) Bill Blevins with ERCOT. Um so
we've been tracking um I guess this adoption of uh
the ride through requirements. We think that's
going to be very helpful to the ERCOT region um to
adopt those. Um I guess at the question of one megawatt.
Um we would probably want to just have an addition
or register with ERCOT. Because those are the ones that
are going to be providing services to us. And we may
change our rules, as we need to going forward. For folks
that are providing those type of services. I think,
so the one megawatt made sense to us, at first. And then
plus addition of smaller resources. Because we do have
some that are below a megawatt, that have chosen to
register.
(item:5.1:54233, Martha Henson with Oncor) Martha Henson with Oncor. We largely agree with Staff's
recommendation here for the Technical Standards. Uh
the only thing I would note though. Is that it could
be helpful to have consistency with the ERCOT definitions.
Relative to the size of certain DERs. So that would
mean basically. That Technical Standard A, would apply
to greater than 1 megawatt DERs. And Technical Standard
B, would apply to 1 megawatt and smaller DERs. Um
so you just flip the equal sign to the, to the bottom,
bottom bucket there. Um this is essentially how DERs
that actively participate in the wholesale market.
And which have other protocol and operating guide requirements.
Are described in ERCOT's definitions today. So the
short of it is, the equal to 1 megawatt, 1.0 megawatt.
Would belong with the, the Group of B, Technical
Standards. But other than that, I think it makes a
lot of sense to have the same cut point. For both the
interconnection standard and the technical standards.
And also agree with ERCOT's position on the registration
of these as well.
Any other comments on this topic?
Somebody disagree with these people who are up here.
Come on, let's have some action. Any action? Nice. Staff
any questions?
We get what we need to? Yep.
Um, okay. Thanks for coming up, you guys.
(inaudible)
interconnection standard.
Um all right. For interlude, I suppose for the
third, you know. So it's uh we have our third question.
Which is, are there any additional topics that are
um that we think deserve workshop treatment? And I
know that we got some that are filed. But if anyone
wants to come up and do that. And you know we, we
we've been moving quick enough uh through this. That
if anyone else has any pressing items, that they'd like
to talk about, we can make that happen. Just wanted to, (item:6:54233, Craig Bennett with CPS Energy concerning Local Government Code & MOUs) Craig Bennett
again, for CPS Energy. Just wanted to add one additional
comment, since I'm not sure what the next question is.
Um so this might be appropriate to, to subsequent questions
or comments that the Commission Staff is asking for
input on. But I think it's also applicable here when
we talk about Technical Standards. Um because Technical
Standards gets to really some of the facilities. And
some of the requirements that relate to facilities
and appliances and different things. And, and we've
raised this in our comments previously. In that the
Commission has to be very careful. In terms of how it
chooses to apply. Um I mean, we have proposed that
whatever standards get adopted, apply to IOUs and
not MOUs. But you have the significant potential conflict
with the Local Government Code. Which says that municipal,
municipalities that operate electric systems. Have control
over the facilities and appliances on their system.
So I, I know this again is not directly tied to the
difference of where you do the breakdown. But not knowing
what your next question is. And since we're talking
about Technical Standards. I just wanted to
highlight that factor. That any of the Technical Standards
that we talk about. Will have to recognize the Local
Government Codes very clear, statutory prescription.
That municipalities control the facilities and appliances
that are going to be on their electric systems.
Thank you, Craig. The uh that, that's a topic that uh
Staff and I are working on. Uh you know, the Staff
is working on. And we've been working with the, the
trade groups and, and CPS and others on, on that
topic. So, active uh wrestling of jurisdictional
issues going on. Um, okay. Eric? Uh (item:6:54233, Eric Goff with Texas Solar Power Association comments on multiple suggestions) Eric Goff, again for
the Texas Solar Power Association. Uh we have a few
suggestions we filed. Uh so, I'll be brief. Um but anything
of simplifying the interconnection process, uh especially
with the smaller facilities is good. So timelines
the latest uh Standards. We reference specifically UL
1741 um SB version 3. Um
And then the other side of the coin of allowing some
studies sometimes. But also acknowledging that in many
cases, we don't need to do studies for smaller systems.
And trying to waive those where possible. Um
are things we'd like to explore. There have been times
in the past as people have um demand has gone up. That
the time to be energized has increased, because there's
not a deadline or requirement. And while those issues
are eventually addressed by the utility, we think they
could be routinely addressed with a deadline. Um so
I, I know that creates some complexities for utilities
obviously. And we'd be happy to work through this in another
workshop.
(item:6:54233, Rob Bridges with CenterPoint Energy question on potential technical requirements) Rob Bridges with CenterPoint Energy again. Um I, I
just kind of wanted to open up a potential topic and
and I'm not sure if we're there yet or not. So, so
this is, this can definitely be tabled for another workshop.
Um but I, I didn't know if we wanted to delve into
these documents at all. To start discussing any, any
potential technical requirements or moving into anything
of that nature? Or, or are we there yet? I think is
a real question.
(item:6:54233, Mariah Benson asks question concerning possible small interconnection rules change) I don't think we're there yet for talking about the
technical requirements. Um another question to pose
to the group would be. For the small for interconnection
specifically 25.211 content. Should both of those
rules move forward right now, as a package? Or should
we hold off on updating the small interconnection rules.
Until after the large interconnection rules have been
updated, and the Technical Standards have been completed.
General question for anyone.
So general comments on timing and priority of the different
uh
the different projects. (item:6:54233, Stephanie Kroger with Hunt Energy Network suggests moving forward on Standard A updates) Stephanie Kroger with Hunt Energy Network. We would
respectfully suggest that we move forward with the
Interconnection Standard A and the Technical Standard
A for the larger resources. Those discussions have
been going on within informal working groups now for
well over a year. And the, the you know the issues
have been fully fleshed out. We think the Staff's draft
uh really did a great job of identifying the issues,
and really gave us a solid place to start. Um we have
some specific comments on that, which we laid out in
our comments that we filed back in, in January. I can
go through those, but um but y'all have them. Uh but
but we would say let's move forward with that. Because
we've had the time, we've got a great starting point.
And then take the time to work on the um the Standard
B's for the smaller uh resources.
Thanks, Stephanie
(item:6:54233, Martha Henson with Oncor concurring HEN's suggestion to focus primarily on large rules) Martha Henson with Oncor. We're actually fine with Stephanie's
proposal. It seems there's maybe a greater area of
uncertainty for the large ones. And so completely think
it's appropriate to spend the next phase of this working
on that new Rule A. We have 25.211. It seems
to us that updating that is maybe a little bit lower
priority, and can be secondary to the first rule for
the large.
(inaudible)
CenterPoint agrees with Oncor.
Surprise, surprise.
Yeah,
this is (item:6:54233, Bill Blevins with ERCOT suggesting small interconnection rules be processed as well) Bill Blevins, again from ERCOT. Um I, I think
we would like to see um the small get addressed as
well. Um because we've been tracking over the last
I guess 5 years, 6 years. How much the different
buckets of DG are growing? And I would say that it
continues to accelerate over these years. So we feel
like some of the issues that we're trying to address
at ERCOT on the transmission side, dealing with inertia
and handling storms and disturbances. There's some
value in adopting IEEE 1547 criteria. We did some studies
and provided those at our Reliability Operating Subcommittee.
That showed the value of uh adopting that for higher
levels of penetration. So, um we would like to see
both of them move forward if possible. And just to
clarify, we are planning to move forward with the Interconnection
Standards for um the smaller DERs. It was more the
Technical that we're considering delaying. Yeah, the
Technical one is the one that actually. Interconnection,
excuse me. Okay. As long as the, the Technical can adopt
those capabilities of the new uh DG that are coming.
We, we believe coming with the equipment today. I think
that would help the grid and that would be our preference.
Uh (item:6:54233, Eric Goff with TSPA supports ERCOT's suggestion) Eric again, on behalf of the TSPA. We're not
opposed for the Technical Standards for smaller systems.
being implemented quickly. Uh I think we filed comments
that say we support the implementation and we understand
why ERCOT values that. So, you know, it depends on your scheduling
and timing. But I don't think there'll be controversy
about the Standards for the uh smaller systems. And
so just to clarify again we, we are planning to move
forward with the Technical Standards, IEEE Standards
for the small systems. It's more the Interconnection
Standards, delaying that process. And do you, go ahead.
Yeah I mean, so we certainly are eager to see improvements
in the Interconnection process for small, as well. But
we understand uh why the larger one is a hot topic,
right now.
(item:6:54233, Pete Parsons with the Texas Solar Energy Society) Pete Parsons with the Texas Solar Energy Society. I
just would like to mention that um when we're working
on this language. You know, that we try to keep the
time period between when an application has been submitted
as, and when it actually gets connected. That we consider
the fact that time is money. And if you look at all
the soft costs. You know, that's really the only place
we can start to try to get the cost of solar down
for homeowners. So eliminating any kind of financial
barrier for soft costs can make a difference. So, you
know, again, time is money. If you have to wait, wait,
wait, wait, wait. Um it becomes it, it adds burden
to the installers and the entire process.
(item:6.1:54233, Craig Bennett, CPS Energy, with concerns on timing and deadlines) Craig Bennett again on behalf of CPS Energy. Um,
in regard to the timing issue though. Uh, we would
certainly push back against arbitrary deadlines, uh
establishing timelines. Because what you know, that
doesn't take into account is how many requests for
a battery interconnection might be received at once.
And we get multiple requests and we have to evaluate
the impact of each one on the system, both individually
and cumulatively. And that can't be done necessarily
just in an arbitrary timeframe. While we understand
I mean, we don't have a desire to move slowly. Um but
at the same time, we have to fully evaluate for the
safety and stability of the system. What the impact
is going to be if we. If it's just one, you might
say well, it's easy to fit within a timeline. But
if you get 5 or 6 requests, and we have to look
at each of those and how they're going to interconnect.
And what the impact is going to be on our system and
the transformers and what equipment is necessary having
an arbitrary timeline, I think sacrifices safety and
stability. Just for the purpose of an arbitrary timeline.
And so certainly, if somebody believes we're acting
inappropriately, there are complaint processes. There
are different things that can be used. But just putting
in an arbitrary timeline, I think we would push back
on because we're likely not getting just one request
at a time for interconnection. We're getting multiple
and we have to process the impact of those individually
and cumulatively on our system.
So we have Craig coming out hard against the time is
money. And just for clarification, you're still talking
about the small system, right? Uh I forget you. Well
we were talking just in general, when we talk about
timelines. (inaudible) Um and it, it, yes, that's right.
(item:6.1:54233, Pete Parsons, Texas Solar Energy Society, follow-up on timing concerns) My only pushback on that is. I'm hearing that in some
areas, it's taking as much as 7 to 8 months to get
connected. And I mean, maybe we could come up. Maybe
we could compromise and come up with something that
is reasonable. In terms of, you know, what the utilities
need in order to, you know, move ahead safely. But
limit the ones that just drag, drag, drag and um because
that's a problem. Yeah I mean, I can't speak to those
that drag. I know that we've not ever intentionally
dragged in terms of interconnections. And so I can't
speak to that. I just, I'm concerned with a one size
fits all of we're going to adopt a timeline here without
taking into the consideration of what that might do
in terms of impacting the ability of the utility to
properly analyze both stability and safety in terms
of the impacts of and ensuring, you know, service to
everybody in a stable system. From having multiple,
you know, interconnection requests at a similar time.
But I, I again. I certainly understand the concern
I think maybe that requires a little bit more discussion
about how that might be addressed. And I'm not sure
an arbitrary timeline is necessarily the right answer
That's just our position on that.
(item:6.1:54233, David Vignes, AEP, comments on timeline concerns & standard updates) This is David Vignes with AEP. We would agree with
CPS Energy as far as the timelines. There are cases
when there are 3 to 4 projects at the same substation.
And you have to know the technical requirements of
the first project before you can know if the third
or fourth project is viable at that substation. And
so that is our concern. In order to do them in a
nondiscriminatory manner, they need to be studied in
order. And so that is our biggest concern. There are
other states within our jurisdiction, that have a process
that there would be an A and a B interconnection. Which
would be the first two that apply for that substation.
And then anything beyond that would be kind of held
until you knew the results of the first study. And if
they were going to go into service. And then as a general
note, we do support moving forward with the Technical
Standards you know. We think that, that is appropriate
as far as those values. We would like to, you know,
ask that you would consider the revision that we have
filed on 211 and 212. In addition to the discussion
draft, that those would be taken into consideration.
And then also um specifically defining the Standards
that are gonna be used for the specific UL 1741
and IEEE 1547 Standards that would be used as
part of the Technical Standard.
And to clarify, what you mean by that. You'd recommend
in rule reference those documents? Correct, that just
the technical documents that have, have come up. Um
those were done as a joint venture with some of the
the TDUs. As far as the technical requirements and
that those would just be considered as we come up with
a, a final rule. (item:6.1:54233, Mariah Benson, Commission Staff, follow-up on standards updates) And, and so part of the reason we
are considering bifurcating 25.212 into two different
Standards. Is again for the larger ones, ERCOT can more
easily update their protocols. Um we're concerned just
putting in a reference to IEEE or other Standards.
That for in use customers, they would have to pay for
those publications to access those standards. Which
is something we don't want to put on in use customers.
Which is why we're trying to list them in our rule.
Um.
And generally we're kind of opposed to that. So I just
wanted to throw that out there in case you have response.
Yes, if we would support bifurcating the Standard.
I think it's appropriate to have a smaller and a larger
version of the rules. Um, but the technical requirements
that we would look at from an engineering standpoint.
Is to, you know, make sure that we do have reliability
on the system. And that our, our in use customers are
not affected adversely from DER. And again, I guess
just how would the induced customers know what standards
they need to meet, if they have to pay for those publications.
And I think those would be handled by the installers.
The installers are the ones that are gonna engineer
their systems and not the individual customer. And,
and sorry, just to clarify that. So you're saying
referencing those Standards are fine, because it's the
installers have to pay for those publications and not
the induced customers? Correct. And I think those,
most of those Standards are, are given, um the inverter
is specifically certified for that and that is publicized
So if that is a standard inverter or device, it's gonna
have that specific stamp on it.
(item:6.1:54233, Rob Bridges, CenterPoint, clarification on TDU meeting regarding Standards) This is Rob Bridges with CenterPoint to kind of piggyback
on the discussions from, from AEP. The TDUs, some
of the TDUs did get together and discuss the possibility
of a revision to this. And I believe that it was proposed
to the Staff, PUCT Staff. So um the to your point where, where
you're trying to go. I think what we tried to do and
that was not necessarily reference the IEEE document
itself. But reference the, the specific technical requirements
within that. And I think that's really what, what you
were trying to ask there. So we don't have a reference
to a document. We, we have a reference to a specific
Standard, if you will within that. So there's no need
to actually purchase a Standard in order to understand
what the specifics are. So we, we actually did
that with those specifics in mind. Thank you for the
clarification too.
(item:6.1:54233, Ramya Ramaswamy, Commission Staff, question enhanced communication) Um I just have a general question. Just to address the
2 different points that came about, about the timeline
of the interconnection. Um is there a way to like enhance
communication between uh the DSP and the end use customer?
Is that something that has ever come up before? Sorry
David, (inaudible) going on. The less I talk
the better? This is good.
Um what I'm uh (item:6.1:54233, Pete Parsons, Texas Solar Energy Society, suggests fair deadline) Pete Parsons with Texas Solar. Excuse
me, Texas Solar Energy Society. Um one thing I'm hearing
is um that again. That it can take, you know, up to
7 months to get connected. And if you're a homeowner
and you've just invested a substantial amount of money.
You've been tortured by the building code process and
now you're being tortured by interconnection. And even
what I'm hearing is that when complaints are filed
um, nothing happens. So there doesn't seem to be any
kind of enforcement. To, you know, response to complaints.
So if, if we could potentially look at some kind of
fair deadline. Um, for smaller systems maybe put a
a size in there. So that homeowners are not necessarily
adversely affected. Um and, um and give some teeth
to, you know, how these folks can. What they do when
they, where did the complaints go? So, thank you.
Um
I agree with what uh Pete said. Um And so to keep
it brief. (item:6.1:54233, Eric Goff with TSPA, suggests capacity analysis of the DSP system) We, we think that you can utilize some of
the features of these inverters. Um to simplify the
interconnection process as well. Um so they're, they're
designed to meet certain specifications. That should
be able to be relied upon by the DSP. In order
to simplify the overall interconnection process. Um
So for example, UL 1741 should make it easier to
uh do these every interconnection processes. Um, um we would
also encourage um the utilities to automate as much
as possible the interconnection process. Since there's, there's
so many um repeat processes. That go on as people install
rooftop solar. So, um we think that'd be helpful. We've
also suggested doing sort of, you know, some sort of
capacity analysis of the DSP system on an ongoing
basis, as it's done in other jurisdictions. So that
interconnecting entities have a good sense of where
they might or might not be issues. And if you're in
the area where there's not an issue according to the
DSP. It should be a more straightforward process. That's
more burden on the utilities to do those capacity analyses.
But it could simplify every single interconnection
that's done in those areas. That could ultimately be
a time saver if we threaten people correctly.
Yeah.
Um so next workshop topics. Anybody I, I know in comments
everybody said we needed workshops on multiple things
related to the DER rules we filed. I feel like we'll
be able to come up with some thresholds and move forward
with proposals for publication soon. Are there any
other topics, y'all would like to have workshops on?
Because we didn't get it right in the rule? Um that
need a broader group discussion?
Yeah.
Hello again, (item:7:54233, Monica Batra-Shrader, Enchanted Rock, suggests higher feeder loading limits) Monica Batra-Shrader, Enchanted Rock.
Um we filed some comments and I guess I'm just gonna
reiterate some of our, our points that we'd like to
uh discuss at, you know, a potential subsequent workshop.
So um the first, the first uh topic is per 16 TAC
25.211(h)3. Um essentially saying that um let's
see. So in practice, we've seen uh a threshold applied
as the 1/3 feeder loading rule. And this is a
hard cap on what a utility is willing to interconnect
for export for behind the meter DERs. And um we
think that the threshold is conservative and um that
we can accommodate higher levels of distributed generation
activity on a feeder. So we recommend discussion um
to update the Standard to facilitate higher flexible
feeder loading limits. Um, preferably as high as 2/3
uh feeder loading rule. So that's one topic.
And um, real fast Monica. Just to get a pool of the
room. Um Is anybody against that proposal? Like again
would that warrant outrage if we just moved forward
with it? Coming from southside I'm not, I'm not an engineer.
I don't know how this would potentially break the system.
So again, if it would break the system? Like, is anybody
opposed to that idea or?
Yeah. Okay. So people are opposed. So you would want
a workshop to discuss it to determine if it's correct
or not? Yes. Okay. Thank you. And um for that, that question
we are willing to bring in our interconnection engineer.
To provide some, you know, technical expertise and
insight um on the topics. And you know, our experience
across the utilities. Um so we're very open to, to
working with everyone on that. And then um another
topic that we'd like to discuss. Is establishing streamlined
and standardized processes for applications across
the utilities. Because um DER customers have to navigate
processes across the utilities under ERCOT. Um we have some, you know,
specifics that we have brought up in our comments.
But just as a high level, um you know, consistent processes
will allow DER developers. Who typically work with
modular repeatable systems and designs to scale quickly
and efficiently.
And any questions on that?
Um could you just elaborate more on these standardized
processes. Like what is not being captured in the draft
rules republished that you think needs more standardization?
(item:7:54233, Enchanted Rock gives response to question from Mariah Benson, Commission Staff) Um well, specifically in our experience, um data requests
and documentation requirements vary significantly across
the utilities, and should be standardized. Testing requirements
and processes vary by utility. And um a consistent and
transparent process for handling utility, internet
connection costs and sales of facilities um is recommended.
And um if and our, our very last point is. I know
the the cost recovery issue is was tabled. But uh we
just like to say that we support the utilities' interest
and discussion for cost recovery issues including CIAC.
And potential socialization of certain system upgrades
and for protection measures.
Any, any more questions? Thank you. Thanks y'all.
Hi, (item:7:54233, Craig Bennett, CPS Energy, suggests topic of interconnection template & requirements) Craig Bennett again on behalf of CPS Energy.
Um in regard to your question about what should be
addressed in in future workshops. I mean, I think really
the nuts and bolts and, and getting down into the weeds
on some of these issues related to the Interconnection
Agreement template and the requirements. Um the timeline
issues that we discussed. I mean, I think there are
so we're not um you know, unmindful of the concerns
raised about the length of time it may take to interconnect.
So we, we're certainly willing to sit at the table
and try to come up with solutions. But we think that's
the sort of thing that a workshop would be good. To,
to not just talk about because right now, you know
and I don't know what else you're going to be bringing
up. But it's getting into the weeds on those sorts
of issues. At the 2/3 feeder standard issue. Those
I think require getting down into the weeds on. And
and I think that's really where we need to get um have
where workshops show their best benefit. Is getting
some of the feedback on the actual verbiage itself.
Um as opposed to just kind of some generalities. And
I, I think uh have setting, you know, multiple
workshops with actual language to discuss. And, and
you know, some ideas for coming up with language and
how we could do that, I think is the best use of
workshops. So we certainly would support additional
workshops to try to do that. Rather than just have Staff
develop something, put it out there and then take comments
from parties. I mean, I think that we should have additional
workshops, workshops on those issues. And sorry, just
to clarify. The three things you mentioned 2/3
feeder issue, the timelines for the interconnection
and then the Interconnection Agreement template itself.
Were there other issues you think should have a workshop?
Uh well, I mean, I think to the extent that we're getting
into specific technical requirements. That are, you
know, gonna be new. Um I think it's worth discussing
those in a workshop. Before they just go out for comment
and rulemaking. Okay. Thank you.
Because everyone agrees that if, if you make a comment
in the workshop. Then you won't make it in the rule
making. So we don't have to file a written response
That's the,
that's the agreement that we're all entering into here.
Thank you. (item:7:54233, Lori Blacka, TSPA, gives support on prior suggestions) Um Lori Blacka on behalf of TSPA.
Um we just also wanted to offer our support for some
of the other comments for the issue of the CIAC. Um
those subs issues especially some that were mentioned
recently in open meetings. About some of those transparency
items that maybe could move forward on a faster timeline.
Than the overall cost issues um with that. So we would
be very supportive of a workshop on the CIAC,
CIAC issues. Um and I just wanted to respond briefly
about the timelines. Um that is such an important issue.
There are, you know, valid considerations on both sides
um getting these interconnections done more quickly.
And realizing sort of the technical and labor issues
that the TDSPs are experiencing. And I just wanted
to mention that a workshop might be very helpful on
that issue. Maybe we come to some compromise, some
reasonable deadlines or some reasonable process. We
briefly mentioned in our comments, perhaps the ability
of using third parties that have been certified by
the TDSPs. To help with these interconnection timelines
as well as the imposition of a voluntary um charge.
For people who would like to perhaps move their application
along quicker. Um that fee would go to be hiring additional
people um for the DSPs. To help them work through
these agreements. So we just wanted to um respond briefly
and say we would be supportive of workshop on those
issues as well.
(item:7:54233, Stephanie Kroger, Hunt Energy Network, suggests timeline for larger interconnections) So with respect to um timelines, uh the, the
way I've understood the conversation so far. Is that
that the discussions that we've been having really
relate to the smaller interconnections. For the large
uh larger interconnections. Um we've been through a
long process of collaboration with the utilities. To
try and work out what seems like a reasonable timeline.
I think that was picked up in the Staff's draft. A and
you know, we, we support having these, these timelines
it into the rule. That's kind of one point. Yeah, real
fast. Just uh just to clarify too. I think that's a
great point. If we're talking about large versus small.
On the TDU side is timelines for interconnecting
DERs over 1 megawatt. Something you guys want to discuss
in a workshop? Sure. Okay. Yes, CPS Energy says yeah. Yeah
The second point that I wanted to raise also goes to
the um to the Staff's draft. And kind of the larger.
And that is that in, in that draft, there was a cap
on um the megawatts that could be considered. In the
interconnection request of 10 megawatts. That's a cap
that does not exist in the ERCOT protocols. Um it was
removed out of IEEE 1547. And it's a cap that
we think is arbitrary frankly. And that we understand
that, you know, there may be situations in which a
utility system at a point of interconnection. Could
accept a larger capacity, but that ought to be on a
case by case basis. And the utility study process is
going to bear that out. So the idea of having this
10 megawatt cap is something that we would like to
have further discussion on.
Sounds good.
(item:7.1:54233, Mariah Benson asks for thoughts going forward) Okay, so I guess proceeding forward. We can go forward
with bringing back individual language on each of these
different points in a workshop. Alternatively, we could
kind of draft an entire rule and not necessarily publish
it for comment. But just have a rule on, on a drafted
or excuse me, have a workshop on a drafted rule. Um
I think your point about bringing back language specifically
we hear that and we can definitely do that. It will
take more time though. So again, it's just I, I guess
what I'm trying to ask y'all. Is would it be better
to talk about those before we start drafting it or
do you want to see language knowing that will take
more time before the next workshop? And that's something
we can figure out ourselves off, off mic. But
I mean, (item:7.1:54233, Craig Bennett, CPS Energy, supports Staff proceeding with language) I think CPS Energy, it would support having
language. I think that makes it more efficient because
I think ultimately, if we come together, it's going
to take a lot longer to try to develop language than
it will be if you've already done the work to at least
start with a base that we can adjust from. So I think
it's more efficient. I understand it may, I think ultimately
it takes the same period of time. It's just how it's
broken out. It may take you longer before we have the
next one to come up with it. But I think if we
have to workshop language, it will probably take multiple
workshops to try to get there and we end up spreading
things out,
right?
(item:7.1:54233, Stephanie Kroger, Hunt Energy Network, suggests moving forward with publication) And I would suggest for the for the larger interconnections
we have a direct rule. We have the staff strong man
we've got everybody's comments on it and that that
can either move forward into publication or, you know
if there's a workshop, we have the rule, we don't need
to go back and redraft.
And we would suggest that the discussion draft rule
probably should have a little bit more refinements
to further clarify some of the points that were discussed
with the TDUs and the battery community that are
not reflected in the rule. So we politely disagree.
(item:7.1:54233, CPS Energy follow-up) CPS would also politely disagree. And while we think
you do have something to start with, and we think that's
exactly the role it serves is the draft comments or
the draft language and then the comments that you've
already received, you can take into account as you're
revising to bring something back for. So, I mean, I
think that's the appropriate way to proceed and I do
think it's, you have a good starting point because
of the language that you've already proposed along
with the comments and you can make those tweaks. Um
to account for the comments you received and then start
from that point in a subsequent workshop.
Well, everybody, um I think that we're kind of wrapping
up on the, the topics that we're posed for today uh
by show of hands. Does anybody have anything else they
want to?
(item:7.1:54233, Bill Blevins, ERCOT, question on Technical Standard) I just had one other item, I guess just a question
so far with the Technical Standard. And the, and the
cut off point, I think we understood it pretty well.
There was one area that wasn't real clear to us. That
might need to be discussed. And that was this new style
of DER that we're doing a pilot with the ADER
Aggregation. Because they're technically, each unit
is very small, but then they will register with ERCOT.
And typically they're greater than a megawatt in their
aggregation. So, you know, which one of these do you
apply? I think ERCOT would initially believe that they
would follow the ERCOT rule, if they registered with
ERCOT as an aggregation. Um but I, I'm sure if you
ask people in the room. You might get different opinions.
Hm.
(inaudible)
If anyone wants to comment on that, they're welcome
to.
All right. So I think, you know, this is. Since Uri,
right. When we booted up the New Rules Division. This
is actually the first Staff-led Technical Workshop.
That we've, that we've done with the current era of
modern PUC Staffers. So I think in terms of how
many topics we can get through and everything else
is we're, we're all learning how to do this as we go.
So thanks for such a good turnout today. And I think
that if we have other, it seems like we could have
put more topics on this. And now we know that for,
for the future. But I think this has been a good exchange.
But if anyone afterwards who's done a lot of these
in the past. Is like, oh man, they should have done
it differently. Feel free to reach out to me. We're
always interested in how to make these things more
uh more effective and useful for everybody. Um so on
that note, I guess there's any, if there's any other
topics or closing remarks that are related to what
we have posted today. If not, we'll uh, you know,
put our heads together on a Staff level and think about
what the topic should be for the next one and what
that, what that schedule would be. So, is there any
closing topics?
(item:8:54233, David Smeltzer adjourns meeting) Very good. Uh, well uh thanks for coming everybody.
I think this is uh, thus endeth the first DER Workshop.
(inaudible)