Please contact the undersigned if you have any questions.

Transcription

1 Richard B. Miller Assistant General Counsel April 24, 2017 Via Hon. Kathleen H. Burgess, Secretary NYS Public Service Commission Three Empire State Plaza Albany, New York Re: Case 16-E-0060, Con Edison s Electric Rate Plan Dear Secretary Burgess: The Commission s Order Approving Electric and Gas Rate Plans, issued and effective January 25, 2017, in Cases 16-E-0060, 16-G-0061, and 16-E-0196, established the Consolidated Edison Company of New York, Inc. ( Con Edison or Company ) Electric Rate Plan. The Rate Plan provides for a Con Edison Distributed Generation Interconnection Procedures Collaborative and that the Company will file an informational report with the Secretary by six (6) months from the initial collaborative meeting, identifying the topics discussed, recommendations developed and the actions taken or to be taken to implement those recommendations. The Rate Plan further provides that for any recommendation that is not implemented, the Company will explain the reason(s) why the recommendation has not been or will not be implemented. Con Edison provided a draft of this report to the Collaborative on April 10, 2017 and reviewed the report at an in-person Collaborative meeting on April 12 th. Con Edison then provided a revised draft to the Collaborative on April 13 th and held a Collaborative conference call to discuss the revised draft on April 21 st. Please contact the undersigned if you have any questions. Yours very truly, Richard B. Miller cc: Active Parties, Case 16-E-0060 Consolidated Edison Company of New York, Inc. 4 Irving Place New York NY fax millerrich@coned.com

2 Con Edison Interconnection Procedures Collaborative: Informational Report April 24, 2017

3 TABLE OF CONTENTS Page I. Introduction and Rate Plan Overview... 1 II. Distributed Generation in Con Edison Service Territory... 2 III. Collaborative Meetings... 4 IV. Topics Discussed During Collaborative... 5 V. Recommendation Developed Through Collaborative and Actions Taken or To Be Taken to Implement Recommendations and Reason(s) for Not Implementing Recommendations Not Implemented... 5 Appendices A. Con Edison DG Documentation Checklist B. DG up to 5MW System Diagram Checklist C. Three Line Diagram Example D. Verification Testing and Inspection Checklist E. List of Collaborative Meeting Topics F. List of Collaborative Meeting Participants

4 I. Introduction and Rate Plan Overview The Consolidated Edison Company of New York, Inc. ( Con Edison or Company ) Interconnection Procedures Collaborative ( the Collaborative ), chaired by the New York State Distributed Generation Ombudsman, was agreed to by the Con Edison rate case parties and adopted by the Public Service Commission ( Commission ) as part of the Company s Rate Plan. 1 As provided in the Rate Plan, the Collaborative discussed the implementation of the following items related to Con Edison s interconnection of distributed generation ( DG ): 1. Development of checklists of requirements for customers and/or developers and the Company to provide transparency and an understanding of each party s obligations 2. Improvement to Con Edison s written materials for developers, including explanation of how Con Edison applies the applicable standards 3. Scheduling of business meetings to consider project specific issues; and 4. Development of a streamlined internal review process for failed DG inspections where the customer requests a review. As provided in the Rate Plan, additional issues 2 that the Collaborative members could discuss included: 1. Procedures and processes for streamlining and improving the interconnection process, including the potential for a single point of contact within Con Edison for each DG project (note if a single point of contact is established, the parties will discuss that point of contact s responsibilities); 2. Procedures for soliciting and submitting information, such as drawings or project plans to and from Con Edison, developers, customers and contractors 3. Timelines for review of project information 4. Customer requests for estimates of interconnection costs 1 Cases 16-E-0060 et al. Proceeding on Motion of the Commission as to the Rates, Charges, Rules and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service, Order Approving Electric and Gas Rate Plans (issued January 25, 2017), Order at Con Edison is required to follow the New York State Standardized Interconnection Requirements ( SIR ) in interconnecting distributed generation., The Rate Plan accordingly provided that the [a]s applicable, modifications to Con Edison s processes resulting from this collaborative shall be in accordance with the New York State Public Service Commission Standard Interconnection Requirements. As appropriate, and to the extent actions of the Commission and the Department of Public Service to improve DG interconnection related activities are known, the modifications to Con Edison s processes will be harmonized with such actions. Id. at pp

5 Con Edison agreed to implement changes in its procedures based on the Collaborative discussions and input from interested parties. As provided in the Rate Plan, Con Edison also explains in this report why it did not agree to some of the recommendations proposed by Collaborative members. Con Edison appreciates the constructive participation of developers, customers, and other stakeholders in this Collaborative. The changes it has agreed to implement will lead to positive improvements for DG developers and Con Edison customers and support the State s Reforming the Energy Vision ( REV ) goals. This Report discusses the Collaborative s outcomes, accomplishments, and areas requiring further discussion according to some Collaborative members. II. Distributed Generation in Con Edison Service Territory Table 1 below describes DG interconnections in Con Edison service territory as of February 28, Solar generation represents 98% of completed projects and 95% of projects in the queue, based on number of installations, and combined heat and power ( CHP ) generation represents 51% of completed projects and 53% of projects in the queue on a capacity basis. In 2016, solar represented 88% of all new installed DG capacity in Con Edison s service territory and Con Edison expects that in 2017 solar will overtake CHP for installed MW. Tables 2 and 3 provide a further breakdown of size ranges installed and in the queue for the two main DG technologies, solar and CHP. Over 95% of PV projects in the queue are under 50kW, and 84% of CHP projects in the queue are under 300kW.

6 Table 1: Installed and In-Queue DG in Con Edison service territory Installed In Queue Con Edison Installed and Queued DG (As of March 31st, 2017) Total Percentage (%) Technology Installs kw Installs kw Battery Storage 12 1, % 0.41% Fuel Cells 25 10, % 3.22% CHP , % 50.0% Solar 14, , % 46.3% Wind % 0.04% Total 14, ,817 Battery Storage 11 1, % 0.86% Fuel Cells 10 5, % 3.9% CHP , % 52.3% Solar 2,251 58, % 43.0% Wind % 0.0% Total 2, ,671 Table 2: Size distribution of solar projects in Con Edison service territory Current PV Installed and in Queue Size Range (kw AC) % of Installed Projects % of Installed Capacity % of Projects in Queue % of Queue Capacity 0-50kW 97.96% 66.95% 94.51% 24.71% kW 1.76% 18.32% 3.53% 17.33% kW 0.27% 12.81% 1.62% 35.79% kw 0.01% 1.93% 0.33% 22.16% Table 3: Size distribution of CHP in Con Edison service territory Current CHP Installed and In Queue Size Range (kw AC) % of Installed Projects % of Installed Capacity % of Projects in Queue % of Queue Capacity 0-50kW 6.87% 0.10% 12.96% 0.34% kW 74.25% 12.37% 71.30% 13.34% kW 8.58% 7.41% 7.41% 5.31% kw 5.58% 18.88% 2.78% 6.13% Above 5000 kw 4.72% 61.23% 5.56% 74.88% In order to support further growth of DG, the Collaborative built on several existing Con Edison resources for DG customers and developers. All of these resources are available via Con Edison s website. Con Edison welcomes input on its website so that it can improve and enhance the site. These include:

7 Solar Website Solar Video Interconnection Application Webpage Con Edison Guide for CHP Con Edison Large DG Guide (Systems Over 5MW) Presentations from Solar Interconnection Workshops (annual) Solar FAQs DG Specifications and Tariffs III. Collaborative Meetings The Collaborative officially began in October 2016 when the New York State Ombudsman, Elizabeth Grisaru (New York State Department of Public Service Staff) and Houtan Moaveni (New York State Energy Research and Development Authority), serving as co- chairs, commenced discussions for interested parties to develop improvements to Con Edison s internal

8 process for managing interconnections. 3 After the kick off meeting in October 2016, the Collaborative held monthly in-person meetings with developers, customers, and other stakeholders in November and December 2016 and in January, February, March, and April There was an additional online-only webinar held in March Con Edison posted the Collaborative schedule and presentation materials on its DG website. IV. Topics Discussed During Collaborative Con Edison prepared presentations for each meeting covering the topics listed in the Rate Plan. The presentations outlined the topics of the day and future work plan and schedules. The Collaborative engaged in discussion, provided feedback, asked further questions, and made suggestions for other topics or clarifications. The Collaborative discussed the topics included in the Rate Plan and additional items (e.g., detail on SIR workflow). A full list of the presentations and discussion topics is included in Appendix E. Con Edison will post on its Company web site the documents developed during this Collaborative, and it has included the checklists developed as appendices to this report. V. Recommendation Developed Through Collaborative and Actions Taken or To Be Taken to Implement Recommendations and Reason(s) for Not Implementing Recommendations Not Implemented The resolution of specific issues by the Collaborative for each Rate Plan topic is set forth below. Con Edison reviewed all of these topics with the Collaborative and incorporated the Collaborative s input as it deemed appropriate. The Collaborative agrees that the solutions Con Edison has agreed to implement will enhance the Company s DG interconnection process. As discussed in more detail below, however, Con Edison has not agreed to implement the recommendations advanced by Collaborative members who believe that it is necessary to develop resources such as checklists or guidelines to clarify the interconnection process for other projects such as large DG projects. It is important to note that Con Edison will continue to enhance the resources it created pursuant to this Collaborative, and its DG interconnection process, as it continues to receive more developer/stakeholder input and as technology and procedures evolve. 3 A notice for the first meeting was sent to the active parties list for Con Edison s rate case and the active developers in the Con Edison service territory. The Collaborative membership list was established after this first meeting and after this rate case parties and developers who comprised the members were provided with notice. The list of Collaborative members is attached hereto as Appendix F.

9 Rate Plan Initial Topics 1. Development of checklists of requirements for customers and/or developers and the Company to provide transparency and an understanding of each party s obligations: Con Edison has created the following: an application checklist based on SIR requirements; a checklist for requirements of system drawings and examples for DG up to 5 MW; a verification test checklist for solar projects; and FAQs for verification tests for solar projects. Con Edison received input from the Collaborative on these checklists that Con Edison incorporated to enhance transparency and consistency for customers/developers. The DG Documentation Checklist (Appendix A) is derived from the SIR and describes how those requirements translate into specific Con Edison procedures, and shows where to find all of the Con Edison procedural documents. The System Diagram Checklist (Appendix B) and Verification Testing and Inspection Checklist (Appendix D) include requirements for drawings and what developers should expect Con Edison to review during verification testing. In addition, the Verification Testing and Inspection Checklist covers what developers should have completed in order to request a verification test. The system design diagram checklist covers the majority of Con Edison DG installations while the verification test checklist covers all solar projects connected to Con Edison s secondary system. For projects not included in the SIR (i.e., above 5MW), Con Edison has a Large DG Guide 4 that describes requirements for those projects. Con Edison welcomes feedback from developers and stakeholders on how this guide could be improved or clarified. Additional Checklists Some Collaborative members suggested that Con Edison develop additional checklists for CHP and storage. Con Edison reviewed the CHP technology types in its queue and decided to create a system diagram and verification test checklists for inverter-based CHP up to 300 kw. The Company expects to complete this work by September 1, Approximately 91 CHP installation projects (84%) in the queue are below 300kW, and 97% of those projects are inverter-based. The Company believes that a checklist would not be able to cover all site-specific issues for certain technologies and systems that are more complex (e.g., synchronous CHPs, 4

10 combinations of DG technologies). For example, many large DG/CHP projects go through multiple changes and redesigns through the design and construction stages. In these cases, Con Edison has found that the best strategy is frequent, in-person meetings to review projectspecific requirements and iterations. In addition, the Con Edison CHP guide and Large DG Guide identify the issues that can arise in interconnecting CHP systems on the Con Edison System. Many CHP customers have used this guide because it is helpful in identifying the different factors involved in developing these projects. 2. Improvement to Con Edison s written materials for developers, including explanation of how Con Edison applies the applicable standards Technology Guides In 2011, Con Edison published two new DG guides, one for large DG not covered under the then current SIR, and another for CHP systems in general. The Company revised these guides in 2016 to reflect the new SIR DG size limits to cover projects below 5MW. These guides cover general requirements, procedures, Con Edison specifications, and contacts for further questions. The Company created these guides for CHP projects because they are often larger than solar projects and are more complex. Con Edison used these guides as a basis for the creation of a solar guide 5 and a fuel cell guide. 6 These guides also reflect content that Con Edison presents at its annual solar installer workshop at the Learning Center. During the Collaborative, Con Edison presented the outlines and then shared full drafts of the guides for comment. Con Edison has incorporated feedback received from the Collaborative and has posted the guides on the Company s website. 7 Con Edison also welcomes feedback from developers and stakeholders on the CHP and Large DG Guides. All these Guides will change and evolve as technology and markets change The Company is also integrating the March 9 Value of DER order, and will publish an updated version on the Con Edison DG website later in 2017.

11 Additional Guides Some Collaborative members recommended that the Company develop an energy storage guide, as well as guidance for DG systems over 5MW. In particular, New York City has recently set targets for energy storage and considers storage to be an important part of its energy policy. As discussed above, Con Edison already has an existing DG guide for projects above 5 MW and an existing CHP guide, and will continue to refine these guides based upon its interactions with developers and stakeholders. Con Edison agrees that an energy storage guide would be helpful, but has not seen many such projects interconnected or in the queue. Energy storage represents less than 1% of both installed and in queue DG. It is expected that storage will grow in coming years owing to Con Edison utility-sited and customer-sited storage projects and New York City s target to facilitate the deployment of 100 MWh of energy storage by The City believes that the presence of these projects and policy drivers will encourage FDNY and DOB to develop more standardized permitting guidance for various energy storage technologies, namely lithium ion batteries, which is expected to increase market penetration. Con Edison plans to develop an energy storage guide if there is expanded penetration in the storage market, similar to that of the solar market over the past few years. The City and other Collaborative members believe that Con Edison should develop a guide now in anticipation of market penetration but Con Edison disagrees because it is not clear at this time which storage technologies and configurations will advance even if there is increased market penetration. Con Edison notes that all of its DG technology guides will continually evolve in response to market and technology changes and application interactions. The Company is committed to helping all of its customers who are interested in installing DG resources. Members of the Collaborative also raised whether Con Edison could give technical interconnection classes for developers. Con Edison is evaluating the potential for these classes. Communications Templates Multiple Con Edison departments manage DG applications and conduct the SIR technical analyses. Con Edison is committed to providing a consistent experience for developers and

12 DG applicants going forward. To provide this consistency, Con Edison created standard communications templates that will be used by Con Edison Energy Services and Distribution Engineering to communicate the results of various steps in the SIR process to applicants. These templates will result in consistency across projects, engineers, and customer project managers ( CPMs ) and create a standard set of expectations for developers going through the interconnection process. Con Edison has also created a high-level workflow document that explains the new SIR process and the options an applicant has for moving through an interconnection project. The workflow document is available on the Con Edison website. 8 Members of the Collaborative also expressed interest in workflows for projects above 5MW. There is a workflow document on page 14 of the Large DG Guide. The City and other Collaborative members requested that Con Edison incorporate timelines into the workflows in the Large DG Guide. Con Edison will review addition of timeframes to the Large DG Guide. 3. Scheduling of business meetings to consider project specific issues The Collaborative discussed the value of project-specific meetings in cases of large groups of projects, or projects that present complex technical issues. Collaborative members also discussed whether Con Edison could increase its responsiveness to meeting requests. Con Edison explained to the Collaborative that it understands that business meetings can add value and clarification for DG developers. Generally, the CPM is the first point of contact to request a project meeting(s) and Con Edison seeks to respond to meeting requests in a timely manner. In addition, the DG Ombudsman s office, or the Energy Services manager, is always available for meetings on request, or other concerns that the developer believes have not been resolved by the CPM, and the contact information for each is available on the Con Edison website. In addition, the Company will hold regular meetings when appropriate. For example, any DG project above 5MW normally has regularly scheduled meetings with Energy Services 8 p. 49.

13 because these projects are complex and typically undergo several project scope and design iterations. 9 Collaborative members noted that the SIR pre-application discussions can be quite valuable in explaining the process, managing expectations, and identifying any unique constraints or scheduling needs in advance. Con Edison will continue to encourage developers to schedule these meetings if they have any concerns. The SIR (as of March 2016) provides for several meetings within the application process itself, including the Preliminary Screening Results Meeting and the Supplemental Screening Results Review Meeting. Additionally, meetings are helpful for more specialized billing situations, such as Remote Net Metering, Community DG Distributed Generation, or Offset Tariff. In these cases, Con Edison encourages developers to schedule meetings, through their project manager, with relevant billing departments in advance of final interconnection. Con Edison understands the importance of responding in a transparent, consistent, and timely manner to meeting requests, and seeks to meet developers expectations, as was further discussed during the Collaborative. Some stakeholders raised concerns about experiencing trouble in receiving feedback on DG inquiries. Con Edison emphasized that in cases where inquiries are not processed in a timely manner the applicant should reach out to the CPM s manager or to the DG Ombudsman s office as soon as possible. Some Collaborative members expressed concern that escalation to higher levels will not sufficiently address responsiveness concerns, and the City proposed for example, that Con Edison should use its project center to more closely monitor work. Con Edison believes, however, that informing customers and developers that they have access to both the CPM s manager and the DG ombudsman s office to resolve issues adequately addresses this concern. 10 Con Edison will continue to review whether its project center can be modified to help address this concern Incentives for timeliness and customer satisfaction for DG projects is being considered in the Con Edison Interconnection Earning Adjustment Mechanism Collaborative.

14 4. Development of a streamlined internal review process for failed DG inspections where the customer requests a review. Con Edison proposed a draft process to review failed inspections. The Collaborative provided input and Con Edison revised the process accordingly. The process provides for an applicant to appeal the results of a failed inspection and provide notification of the appeal to the following Con Edison employees: the project manager, the engineer, the respective managers, and the Con Edison DG Ombudsman. Con Edison will acknowledge the appeal within 2 business days and respond to the applicant with a resolution, and rationale for the resolution, within 10 business days. Con Edison s Energy Services will be responsible for managing the appeals process and will reach out to the applicant to either resolve the matter or request more information prior to providing a its response to the appeal within 10 days. Following resolution of the appeal, the process will revert to following SIR timelines where applicable. Con Edison has included the specifics of how to submit an appeal, and related timelines on both the Company s verification checklist and the technology guides (and on the Con Edison DG website). Additional Topics The Rate Plan stated that the Collaborative s members may discuss the following additional topics. 1. Procedures and processes for streamlining and improving the interconnection process, including the potential for a single point of contact within Con Edison for each DG project (note if a single point of contact is established, the parties will discuss that point of contact s responsibilities) The Collaborative members offered input on how past experiences with multiple project managers could be improved in the future. Customers stated that they do not want to be responsible for coordinating internal Con Edison workflows. To provide information to the Collaborative on how it manages workflows, Con Edison provided detail on how the Company manages different types of work. The CPMs are the central point of contact for all DG projects. Con Edison has created specialized groups to handle different types of service requests. A request for gas service to power a CHP system

15 is a different scope of work than a DG interconnection request, which is in turn different from the a new building service, and each of these will be handled by a CPM who has specialized knowledge in that type of work. Con Edison has recently centralized all DG applications above 50kW within one specialized group to further streamline the process. Accordingly, some customer projects require more than one CPM for each type of work required. As discussed above, this additional work could include gas service, upgrades to electrical service or new electrical service. For these kinds of customer projects, while there will be a single CPM for the DG project, that CPM will coordinate in a timely manner with the CPM(s) who are responsible for such additional work. For example, in existing buildings, the DG CPM will be the single point of contact for DG projects, but if the DG project includes a new service or work that is outside of the DG scope, the applicant will have more than one CPM. Con Edison committed in the Collaborative to having the DG CPM act as the primary contact for the applicant and coordinating the multiple case work so that the work can be completed in an efficient manner. Con Edison presented workflows on the coordination of work within a new building and within an existing building. 2. Procedures for soliciting and submitting information, such as drawings or project plans to and from Con Edison, developers, customers and contractors The Collaborative identified several items that would provide a better experience for users of Con Edison s existing online system for processing interconnection applications. Con Edison will include the following items in a July 2017 upgrade of the system: Specific identification of Community DG projects, and tailored requests for these types of projects (e.g., Community DG forms rather than Form G) Ability to communicate all project requests and communications through the portal to provide better tracking (e.g., replace s for inspection appeals with automated request form); and Improved tracking of drawing revisions and communications about approvals

16 In addition, in accordance with the Collaborative recommendation, Con Edison will add Rider H and Rider J forms for CHP projects in future updates. Several members of the Collaborative asked about communicating with Con Edison on project-related issues. To provide transparency and accurate record keeping, the Company suggests that all communications be uploaded to Project Center in addition to ing the CPM. Con Edison has updated the technology guides accordingly. In response to a request from some Collaborative members, Con Edison agreed to consider the adoption of a system that will automatically upload communications to the Project Center. 3. Timelines for review of project information Con Edison presented a basic SIR workflow document and reviewed timelines associated with each step with the Collaborative. Con Edison tracks each project as it moves through the interconnection process to monitor compliance with the SIR and takes action where appropriate. The Collaborative asked for information on systems above 5MW. These projects are complex and typically have longer timelines. The general workflows for these types of projects are located in the Large DG Guide. Con Edison is open to further feedback on the detail presented in the Large DG Guide. Some Collaborative members proposed that the Collaborative should continue for this Guide and other matters. The Company disagrees that the Collaborative is necessary in order for it to receive and respond to input on these guides. 4. Customer requests for estimates of interconnection costs The Collaborative discussed interconnection costs and how they are derived. Con Edison provided information on the two main components of interconnection cost: cost of study and cost of upgrades. The Collaborative asked for more insight into how interconnection study costs are developed, what information is given to developers who are going through an engineering study, and what drives upgrade costs. The engineering study that is referred to as the Coordinated Electric System Interconnection Review ( CESIR ) is the SIR step that will give most applicants information on how their projects will impact the Con Edison system and what needs to be done to mitigate those

17 impacts (e.g., service upgrade, network protector relay upgrades, communications equipment). The SIR provides that the utility will provide the applicant with the cost of conducting the CESIR within 5 business days of a request. For non-sir projects above 5 MW, the City requested that Con Edison will follow the same process and provide the applicant the cost of conducting the engineering study within 5 business days of a request. Con Edison does not believe it is possible to adopt a standard time frame for projects larger than 5 MW. Con Edison explained that the CESIR cost estimate is site specific and based on the following factors: Type of technology (e.g., inverter, synchronous) Size (kw) Operation (export, non-exporting) Interconnection type (network versus non-network) As a result of the Collaborative discussions, Con Edison will include information about the project when it provides the CESIR cost to the applicant as follows: The cost of your CESIR is based on your request to interconnect a <<1.2MW solar photovoltaic>> system with <<an inverter>>, <<exporting>> to <<an underground network electric distribution service>>. This will allow developers to confirm that the CESIR costs are in line with the project they submitted. Con Edison also agreed as a result of Collaborative discussions to include CESIR cost ranges in its guides. Con Edison explained that upgrade costs are site-specific and cannot estimate such costs before it completes the engineering study. However, Con Edison DG Ombudsman s office frequently gives out information on the service type and potential upgrade requirements (type, not cost) to developers. For instance, the office would tell a developer if its project is on a spot network and might require Con Edison s Communication Aided Tripping ( CAT ) solution. This type of information will be available in July 2017 on the CUNY New York Solar Map website, as part of the Grid Ready project with Con Edison.

18 Appendix A: DG Documentation Checklist The following table is intended to assist installers of Distributed Generation Projects understand the equivalent Con Edison documents or process items required to comply with the Appendix F Application Package Checklist as found in the New York State Standardized Interconnection Requirements and Application Process For New Distributed Generators 5 MW or Less Connected in Parallel with Utility Distribution Systems. Appendix F Equivalent Document or Location Application Package Checklist Process Requirement Completed standard application form (Appendix Completed Project Center B or C) Application New York State Standardized Acknowledgement Appendix H of SIR NYS SIR of Property Owner Consent Form For Systems above 50kW up to 5MW Only Refer to Appendix H for form Signed copy of the standard contract Appendix A (Standard Contract) NYS SIR or Project Center Letter of authorization, signed by the Customer, Customer Letter Of Con Edison website to provide for the contractor to act as the customer s agent, if necessary Authorization If requesting a new service, a site plan with the proposed interconnection point identified by a Google Earth, Bing Maps or similar satellite image. For those projects on existing services, Attach drawing/plan. Provided by developer. account and meter numbers shall be provided Description / Narrative of the project and site proposed. If multiple DG systems are being proposed at the same site/location, this information needs to be identified and explained in detail Include in Scope of Work in Project Center application. Project Center DG technology type Included in Project Center fields. Project Center DG fuel source / configuration Included in Project Center fields. Project Center Proposed project size in AC kw Included in Project Center fields. Project Center Project is net metered, remote, or community net metered Metering configuration Copy of the certificate of compliance referencing UL 1741 Copy of the manufacturer s data sheet for the interface equipment Copy of the manufacturer s verification test procedures, if required System Diagram - A three line diagram for designs proposed on three phase systems, including detailed information on the wiring configuration at the PCC and an exact representation of existing utility service. One line diagrams shall be acceptable for single phase installations Application Form G, or for CDG the Community DG Forms, also Include in Scope of Work in Project Center. Included as part of the line diagram and/or Form G Attach document. Attach document. Attach document. Attach drawing. Con Edison website. Provided by developer. Provided by developer. Provided by developer. Provided by developer. See Con Edison System Diagram Checklist. Provided by developer.

19 Appendix B: DG up to 5MW System Diagram Checklist This checklist will be used to conduct system diagram review prior to Con Edison giving approval to build. These checklist items are intended to cover the baseline requirements for the majority of cases; however, unique configurations or operating uses may have additional requirements. Component Details Check box Three Line Drawing Does drawing show three (3) lines for each phase, OR One (1) line with clear indications that all three phases are identical? P.E. Stamp If connecting to system voltage > 1,000 V, OR If qualifying as efficient CHP as per Form G, are drawings stamped by P.E.?* Equipment Locations Title Block Are locations (e.g., basement, roof, electrical room) clearly noted for disconnect switch ( 89L ), meter, and all inverters? Does the title block include: Customer name and address? Account and Meter Number? Revision number and date of last revision? DG System Drawing Is the DG Type (e.g., PV, Battery, Fuel Cell, etc.) clearly Details labelled on drawing? Is the A.C. nameplate kw clearly labelled? Is the 89L clearly labelled? Is the make and model of the inverter clearly labelled and does it match submitted technical specifications? Service Characteristics Is the Con Edison existing service type and configuration Drawing Details clearly labelled? (e.g. 120/208V, 120/240V, 265/460V) Is the grounding connection clearly labeled? If there is existing DG on site, is the connection to existing system shown on diagram? *Note that projects that connect to the Con Edison system < 1,000V do not require a P.E. Stamp. (page 12 of SIR)

20 D R A F T Appendix C: Three Line Diagram Example Example Three Line Drawing Components Equipment Locations Title Block DG System Drawing Details Service Characteristic Drawing Details

21 D R A F T Appendix C: Three Line Diagram Example (Continued)

22 D R A F T Appendix C: Three Line Diagram Example (Continued)

23 Appendix D: Verification Testing and Inspection Checklist for solar projects at existing company secondary facilities This checklist will be used to conduct on site verification testing prior to Con Edison giving final acceptance for interconnection. These checklist items are intended to cover the baseline field verification requirements; however, unique configurations, other distributed generation technologies, or operating uses may have additional requirements. Any additional requirements will be discussed prior to site verification testing. NOTE: If you disagree with a failed inspection, send an to your CPM and [distribution list address], which includes Energy Services and Distribution Engineering senior managers. The subject line should include the case number and Appeal of Verification Test. The should describe in detail, as related to the verification test checklist, why you disagree with the results of the inspection. Include any documentation or photographs that are necessary. In addition, upload the to the case in Project Center. You will receive an acknowledgement of your appeal in 2 business days via , and Con Edison will respond with a resolution and rationale within 10 business days. Component Drawing Version Pre-testing Prior to Requesting Site Verification Test: Applicant Checklist Details Has latest drawing version been submitted to Project Center and approved by Con Edison? Has applicant verified that all inverters are operational? (Note: applicant should verify whether testing restrictions are in place prior to pre-test) Local municipality sign-off Attendance Has the project passed the local building department inspection? The following personnel should be present: applicant, facilities representative with access, and any required technicians. Site Verification Test To Be Completed by Con Edison Engineering Component Details Check box (failed steps in grey boxes require reinspection) Disconnect Switch ( 89L ) Grounding Consistency with Submitted Drawing Are directions to 89L clearly marked at meter location? Is the 89L: clearly labelled? visibly broken when operated? load breaking? gang operated? lockable? Is the switchgear properly grounded? Is the inverter properly grounded (if necessary)? Are the panels properly grounded (if necessary)? Does the nameplate kw match approved drawing? Does the inverter make and model match the approved drawing? Is the DG system interconnected to Con Edison s system as shown in

24 Operation Check Reverse Power Relay (if applicable) the approved drawing? Does the customer DG system pass the 5 minute test? (carried out by the customer, witnessed by Con Edison) Is the inverter output (voltage and power) balanced? Is the reverse power relay connected correctly? Is the reverse power relay programmed correctly? Does the reverse power relay operate correctly? Is the approved (and latest) drawing laminated and posted near the meter?

25 Appendix D: Verification Testing and Inspection Checklist (continued) Verification Testing and Inspections: Frequently Asked Questions 5. What is verification testing and why is it necessary? As per Step 9 of the New York State Standardized Interconnection Requirements (March 2016), all DG systems above 50kW are to be tested prior to final acceptance and interconnection. This ensures that the system is installed as designed and is operating safely. 6. How should I prepare for verification testing? Applicants should have completed construction as per latest drawing approved by Con Edison and ensured that all inverters are working properly. The most recent drawings must be uploaded to Project Center and been reviewed by Con Edison. 7. How do I request a verification test? You should submit a request in writing via to your Customer Project Manager (CPM). 8. What happens if I fail a test? Any items above with a grey checkbox (e.g., inverter does not work) that do not pass will require reinspection. Once the deficiency has been corrected you will need to request another test. Other items, such as labeling, can be passed without re-inspection if a new drawing and/or photographs are submitted. Your CPM will provide details of those items. Any new submittals will be reviewed within 10 business days. 9. I disagree with the results of my inspection. How can I appeal? If you disagree with a failed inspection, send an to your CPM and [distribution list address], which includes Energy Services and Distribution Engineering senior managers. The subject line should include the case number and Appeal of Verification Test. The should describe in detail, as related to the verification test checklist, why you disagree with the results of the inspection. Include any documentation or photographs that are necessary. In addition, upload the to the case in Project Center. You will receive an acknowledgement of your appeal in 2 business days via , and Con Edison will respond with a resolution and rationale within 10 business days.

26 Appendix E: List of Collaborative Meeting Topics This appendix lists, at a high level, the topics and material that Con Edison presented at each meeting and key points of discussion and feedback from stakeholders and developers. November 2016: Con Edison Presentation Topics Overview of topics to be discussed by the Collaborative Review of existing materials and resources for developers (e.g., New York State Standardized Interconnection Requirements ( SIR ), Con Edison CHP guide, Con Edison DG website) Outline of next steps for Con Edison (e.g., create checklists, inspection FAQs, guides, written materials) Collaborative Discussion Topics Request that checklists should cover application requirements, including a Con Edison version of the SIR Appendix F, in addition to system diagram checklists and inspection checklists Request for procedures for DG that is sized above current SIR limits (5 MW) Con Edison versus Department of Buildings compliance, including inspectional jurisdiction and order Clarification on when Con Edison accepts a single-line versus a three-line diagram for drawings Consistency of communications from engineering reviews, avoiding iterative and multiple engineering reviews, and consistency between engineers Improved understanding of Con Edison technical standards for review Value found in past technical interconnection classes held by Con Edison Questions about closeout and meter set processes Process for regular business meetings December 2016 Con Edison Presentation Topics Outlines of solar and fuel cell guides Frequently Asked Questions topics for inspections Clarification on when single line versus three line system drawings are accepted Collaborative Discussion Topics Straw proposal requested from Con Edison on regular business meetings Questions on SIR workflow and difference between supplemental screens and Coordinated Electric System Interconnection Review ( CESIRs ) Updates to Con Edison Project Center to reflect process improvements (e.g., rate application forms specific to type of project) Questions on labeling for 89L disconnect switches Ensuring consistency of reviewed drawings with subsequent revisions and inspections 23

27 New York City Department of Buildings ( DOB ) participation Timelines for post-failed inspection procedures Clarifying when engineering reviews a project that passes Preliminary or Supplemental SIR screens January 2017 Con Edison Presentation Topics Application checklist: Con Edison version of SIR Appendix F Three-line diagram checklist and samples Verification test checklist Verification test FAQs Collaborative Discussion Topics Process for DG larger than 5MW Request for checklists covering additional technologies, e.g., CHP DOB and Con Edison coordination Preliminary discussions with developers for additional requirements Project Center updates and ability to track revised drawings Process for opening meter pan or CT cabinets February 2017 Con Edison Presentation Topics Process for regular business meetings SIR workflow Standardized templates for Con Edison completion of SIR steps: Preliminary Screening, Supplemental Screening, and CESIR Collaborative Discussion Topics Additional guidance and checklists for CHP Coordination between customer project managers ( CPMs ) on different systems (gas, electric, new service) Responsiveness of CPMs, standard procedures for replying to developers Workflows for under 50kW and above 5MW projects Guidance on how to go through SIR CESIR costs Appeals process for failed inspections March 13, 2017 (online Webinar only) 24

28 Con Edison Presentation Topics Solar Guide Fuel Cell Guide Collaborative Discussion Topics Questions on under 50kW process Guidance for DG above 5MW Guides should emphasize that all communications should go through Project Center Guides should discuss roles of all parties (CPM, engineer, Ombudsman, DPS, etc.) Request for guide on energy storage March 27, 2017 Con Edison Presentation Topics Coordinating DG cases with new or upgraded service cases Appeals process for failed inspections CESIR cost estimates Existing Con Edison guides for CHP and DG above 5MW Collaborative Discussion Topics Con Edison expedited process for solar under 25kW Definition of timelines for acknowledgement and resolution response for appeals for failed inspections Availability of general magnitude of cost for CESIRs Storage guide Checklist for CHP Guidance for systems over 5MW April 12, 2017 Con Edison Presentation Topics Review draft informational report on Collaborative Review additional Items Collaborative Discussion Topics Collaborative report comments 25

29 Appendix F: List of Collaborative Meeting Participants This is a list of participant organizations in the meetings, either in-person or by phone, as best represented from meeting minutes and sign-in sheets. This may not be all-inclusive but is compiled based on existing records. Con Edison New York State Department of Public Service New York State Energy Research and Development Authority RSP Systems City of New York Best Energy Power EnterSolar E Cubed Company LLC Consumer Power Advocates Association for Energy Affordability City University of New York County of Westchester New York Energy Consumers Council (NYECC) Local Unions Related New York State Department of State, Utility Intervention Unit 26