Colin Murchie Director of Government Affairs Solar Energy Industries Association, on behalf of the PA Small Generator Coalition

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1 Via US Mail April 29, 2005 Secretary s Bureau James J. McNulty Commonwealth Keystone Building 400 North Street Harrisburg Pa Re: Implementation of the Alternative Energy Portfolio Standards Act of 2004 Docket No. M Dear Mr. McNulty: Enclosed for filing are the comments of the Pennsylvania Small Generator Coalition in the above captioned proceeding. Pursuant to 52 Pa. Code 1.11, the enclosed document is to be deemed filed on April 29, 2005, which is the date it was deposited with the US Mail, as shown by the United States Postal Service stamp on the envelope, and filed electronically with the Commission s designated staff contact. If you have any questions concerning the enclosed comments, please feel free to contact me. Sincerely, Colin Murchie Director of Government Affairs Solar Energy Industries Association, on behalf of the PA Small Generator Coalition

2 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION Implementation of the Alternative Energy Portfolio Standards Act of 2004 : : Docket No. M COMMENTS OF THE PENNSYLVANIA SMALL GENERATOR COALITION 1 ON PJM EXCEPTIONS TO IEEE 1547 STANDARDS ON INTERCONNECTION Dated: April 29, 2005 TO THE PENNSYLVANIA PUBLIC UTILITIES COMMISSION: I. Introduction. On January 19, 2005, the Pennsylvania Public Utility Commission ( Commission ) conducted hearings regarding the implementation of Act 213 of 2004, the Alternative Energy Portfolio Standards Act ( the Act ). The hearings were conducted along with the Department of Environmental Protection ( DEP ). Chairman Holland, Commissioner Thomas, Commissioner Pizzingrilli and Secretary McGinty of the DEP actively participated in the Roundtable discussion. On March 31, 2005 the Commission distributed an issues list for small generation interconnection requesting comments in response to the issues presented in that list. On April 19, 2004, the Commission sponsored a working group meeting where selected interconnection issues were discussed among them exceptions to the IEEE 1547 standards contained in PJM Interconnection LLC s (PJM) rules on interconnection of generators not 1 The Small Generator Coalition includes: The Solar Energy Industries Association, PV NOW, Mid-Atlantic SEIA, Celentano Energy Services, Powerlight, Sun Edison, LLC, and the Joint Supporters, a voluntary association which for this purpose comprises: The E Cubed Company, LLC, Equity Office Properties Trust, US Microgrids (a PennCat Company), American DG, Tecogen, Capstone Turbines, Gas Technology Institute, and Allied Utility Network, and RETX Energy Services.

3 larger than 2 Megawatts (MW) in capacity. On April 20, 2004, the Commission posed a series of additional questions related to the exceptions to IEEE 1547 in the PJM rules asking working group members to respond with their support or objection to the adoption of these aspects of the PJM rules in Pennsylvania. The Pennsylvania Small Generator Coalition ( Coalition ) appreciates the Commission s invitation to provide these additional written comments on the exceptions to the IEEE standards found in the PJM rules. The Coalition is an unincorporated association of manufacturers, installers, developers and financiers of renewable energy and distributed generation equipment. II. Reponses to the Questions posed by the Commission In all respects, the Coalition submits there is no significant value presented by the PJM exceptions to IEEE 1547 that would overcome a presumption that a national standard is just that a standard. The Coalition is gravely concerned that the PJM exceptions will undercut the hard work and years of evaluation that went into developing the consensus IEEE 1547 standard a process that included utility representatives, small generator representatives, consultants, the Department of Energy and other technical experts from across the country. PJM is saying in essence that the group of national and renowned experts that created IEEE 1547 got it wrong in certain respects and missed critical technical issues on others. This proposition is unfathomable. A significant number of states (most recently New Jersey) rely on the IEEE standard without exception and the recent consensus filing before the Federal Energy Regulatory Commission (FERC) among utilities, NARUC, NRECA and the small generator coalition suggested IEEE 1547 was the appropriate national standard without exception. The American National Standards Institute has recently adopted IEEE 1547 as and ANSI standard. They did not identify any exceptions to the standard as part of their adoption. PJM has not disclosed the process it used to identify the need for any of the exceptions but it appears the threshold was minimal. It appears that PJM issued carte blanche to the utilities in seeking exceptions - if they merely asked, an exception was noted, without any procedure for clarification, technical justification, or dissent on the part of other stakeholders. In light of the value of a national interconnection standard to promoting 1

4 distributed generation, PJM should have employed a higher threshold before it undercut IEEE a. Issue 1: IEEE Standard Requirement which provides for integration with area EPS grounding. The PJM rules provide an exception for AP, PPL and UGI. This exception limits distributed generation interconnections to only those locations where the transformer configuration supplying the utility distribution circuit or distributed generator has a wye-grounded arrangement on the high side of the transformer (the two other typical transformer arrangements are delta and wyeungrounded). PJM stated during its presentation that it was unsure why the three utilities requested this exception and was then forced to speculate on the reason. The very fact that it is not substantially clear why these three utilities limit the transformer configurations for distributed generation is strong evidence that they should not have been granted an exception. The exception as written is unclear. While the PJM representatives explained that the exception was intended to apply only to those new distributed generation installations not located at an existing customer s site, this significant narrowing of the exception is not contained anywhere in the PJM document. More importantly, it is the understanding of the Coalition that PJM will be issuing a clarification to this exception as such clarification was approved at a meeting of PJM s Small Generator Interconnection Working Group on April 28, While that clarification will go a long way towards making the exception tolerable, the Coalition continues to question the need. The crux of the issue here is that alternative transformer configurations may allow for extremely high voltages on the high side of the transformer during certain short circuit conditions. This concern is not unique to AP, PPL and UGI, and was in fact discussed extensively during the transparent process leading to the development of IEEE The IEEE standard adequately addresses this concern by requiring the distributed generator to cease to operate within a very limited timeframe when the short circuit conditions exist. By so requiring, any overvoltage condition is limited to a short duration that will not damage utility equipment. In addition, the interconnection procedures in the New Jersey rules and the FERC consensus filing have included further safeguards which limit the contribution of short circuit current from distributed 2

5 generators (see N.J.A.C. 14:4-9.7 (c) and 9.8(e)). IEEE1547 combined with the screening criteria adopted in New Jersey is more than adequate to address overvoltage conditions under all utility transformer configurations. There is no need for these three utilities to include this exception and arbitrarily limit the installation of distributed generation. b. Issue 1.a. Exception to IEEE Standard Requirement Note 2. Isolation Device Requirement. The requirement for a redundant utility isolation device was discussed at length at the workshop meeting on April 19, The Coalition would reiterate the comments made there and emphasize that this customer installed redundant disconnect switch is not required under the IEEE 1547 standard 2, the National Electric Code, by UL under their interconnection standard 1741, under the proposed Federal Energy Regulatory Commission small generator interconnection rules nor the National Electric Safety Code 3 (the code governing utility line worker procedures). Moreover, in recognition of the minimal safety value in relation to cost, Delaware, Maryland and New Jersey do not require such a device for the simplest interconnections. When discretion over installation and optimal location of the disconnect is left to a utility -- which is not fiscally responsible for the costs involved in the installation thereof -- this discretion is frequently abused. Absurd requirements for the location of the switch are all-too-common barriers to proposed distributed generation installations. Irrespective of the level of absurdity, the small generator has no choice but to comply - otherwise the interconnection is denied. 2 The standard is circular on this issue saying that if the utility requires said switch, it is required under IEEE Discretion to require the switch is left to the specific utility which presumably is subject to the oversight or review by its regulators. 3 NESC requires a tag out device for utilities but the code clearly notes its applicability only on the utility side of the meter. There is nothing that prevents a utility from requiring a redundant disconnect on their side of the meter in addition to the many utility disconnection methods already available to isolate a circuit. While is it not completely clear, the PJM requirement seems to reach beyond the jurisdiction of the NESC requiring the isolation device to be installed on the customer side of the meter. As a substantive matter, it is important to utility line worker s to open and tag out any utility source of energy as the full current of the grid can flow through a utility circuit and overcome the grounding line workers use as protection. Conversely, no small generator in the 2MW and less range could ever overcome grounding. The tag out concern is not as relevant when the source of energy is a small generator. 3

6 For solar installations on the rooftop of a multistory building, utilities often require the disconnect be located at the revenue meter location. This requires a run of wiring from the rooftop down to the switch and then back again. For buildings above five stories, this can be prohibitively expensive. In some corporate campus settings, the distributed generation unit is located at a building well inside the campus borders. In instances where the meter is at the entrance to the campus, the utility may require a run of conduit from the building to the campus border then back again. Literally miles of extra wiring may be required in some circumstances at an extremely burdensome cost to the distributed generator. Several case studies bordering on the absurd were provided by Coalition member Ron Celentano. In each instance, the disconnect switch added substantial cost with virtually no increase in the safe operation of the solar energy system. In a case presented to the New Jersey Board of Public Utilities during their inquiry on the redundant disconnect, a solar installer noted he was required to drill two separate holes through thick concrete to mount the disconnect on the outside of a building. After hours drilling one hole, the utility claimed there was a possibility, the wires through a single hole might short circuit and render the redundant switch ineffective. His testimony during this inquiry was coupled with the uncontroverted claim that not a single disconnect switch had ever been used by utility personnel during a grid outage. 4 The Commission should recognize the valuable work and effort that is put into developing the National Electric Code (NEC) and defer to that code for its requirements on customer sited generation. In addition to the automatic disconnect required under IEEE 1547, the NEC requires at least one, and in the case of solar generators, two manual disconnects. The Code requires that the existing disconnects be accessible at all times to emergency personnel and specifies the proper location for the switches. It would set a dangerous precedent for the Commission, in this one area, to reach into the 4 Prior to the new interconnection rules issued on October 4, 2004, the BPU allowed utilities to require the external disconnect. Their new rules removed such discretion from the utilities based on the Board s conclusion that the switch did not materially improve safety. 4

7 dominion of local code officials and the NEC and attempt to alter the definition of accessible or to overrule the code with respect to the proper location of the disconnects. However, should the Commission decide to allow utilities at their discretion to require the external disconnect, it should not grant unbridled discretion. The Coalition would suggest the following limitations: Where a building has 24 hour access, the disconnect switch may be located at or near the generator inside the building. Where installation of an external disconnect would add more than one percent to the installation cost of the distributed generation project, either the switch should be allowed to be located in an alternative location that is less costly, or the utility should be required to pay the installation costs above one percent. Where the external installation would occur in an area known to have security issues, the switch may be located close to the generator and internal to the building or other mutually agreed secure area. None of these limitations would affect the NEC requirements that manual disconnects be accessible at all times to emergency personnel. The Coalition sees no reason why utility personnel would not be considered emergency personnel when they are responding to an unplanned outage and thus have access to the Code required disconnects. c. Issue 2. Exception to IEEE Standard Requirement telemetering requirement The Coalition does not take issue with this requirement, as it is only a requirement for those generators that will be participating in a PJM market. As all generators meeting that criterion will be interconnected pursuant to PJM rules, we fail to see any applicability or relevance of this exception to a Pennsylvania interconnection rule. 5

8 Certainly the Commission does not see a need for telemetering for net metered systems. Moreover, there is not blanket requirement for an qualified PURPA generator to use telemetering. While there may be a minor few state tariffs that require telemetering pursuant to the tariff, no such requirement should be included in the interconnection rules for all small generators. d. Issue 3. Exception to IEEE Standard Requirement addressing the location for voltage sensing There are several problems with the exception as stated in the PJM rules. Chief among them is that it assumes all generators will be three-phase. For many smaller generators, particularly residential sized systems, the generator will be single phase and monitoring voltage on all three phases, where they do not exist, is nonsensical. For inverters and other small packaged systems, the generators will not include a transformer. While it is not specifically stated, the PJM exception appears to be limited to only those installations where the generator will need to install a new transformer as part of the installation. As with other PJM exceptions, their rule needs to be clarified before it is suitable for inclusion in any state regulation. Inverter-based equipment and other small generator units that are certified and listed by UL or other national testing laboratory will include voltage sensing equipment inside the equipment package. This means the only location where voltage measurement can occur is at the point where the generator is interconnected. To require voltage measurement at any other location would not only violate the certification by UL, it would be prohibitively expensive. This is the only location where the certification body (expected to be UL or another nationally recognized testing laboratory) can certify that the voltage monitoring is occurring within the parameters specified by IEEE The Commission should exclude this exception from its rules or limit its application to only those new three phase generator interconnections that will require a new transformer as part of the installation (few if any solar installations will require installation of a transformer). 6

9 e. Issue 4. Exception to IEEE Standard Requirement addressing harmonics The Coalition believes the language presented here is not an exception to the IEEE standard on harmonics but merely a restatement of the standard. To the extent it is only a restatement, it adds no additional clarity and we believe it unnecessary. To the extent it is intended to be a departure from the standard, it should be rejected. Harmonics will be one of the many items UL or other laboratory tests when it certifies distributed generation equipment. To alter the requirements of IEEE 1547 would put a small generator in an impossible position; either it has to develop equipment that would comply with the PJM rule and violate the UL requirements, or it would be prohibited from using UL certified equipment in certain areas of PJM. This underscores the need and benefit of a solid standard without exceptions. f. Issue 5. Exception to IEEE Standard 5.5 provides for testing schedule This exception to IEEE 1547 is taken by PJM to maintain the existing testing schedule for generators as found in the PJM tariff on file with FERC. Since Pennsylvania will not be submitting its requirements for interconnection for FERC approval, there is little relevance of the PJM testing requirement to generators interconnected and no conflict if state jurisdictional generators follow the IEEE standard. PJM created and maintains its testing schedule as an adjunct of its markets activities and has requirements for testing related to certain aspects of their wholesale market scheme. Since, by definition no small generator interconnected under state rules will be participating in the PJM markets, 5 there is no need to apply their testing schedule to state based interconnections. The Coalition would recommend Pennsylvania maintain the original IEEE 1547 testing requirement 5.5 which states in part that the generator must be tested at intervals specified by the manufacturer. Because the manufacturer s testing requirements will be provided to the UL when the generator is submitted for testing, listing and certification for interconnected operation, adhering to the IEEE standard will ensure that UL has a comprehensive understanding of how the generator equipment will 5 PJM requires that generators participating in its energy and capacity markets be interconnected under the PJM rules. 7

10 be used in practice. In some instances, specifying a testing period different than what the manufacturer requires may void warranties on the generator equipment and adversely affect the UL listing. Following the IEEE standard for state based interconnections will have no impact on the PJM rules. As with may aspects of their tariffs, the PJM rules are designed to accommodate PJM markets and can do so even with different tariffs and rules implemented by state regulators. III. Comments on the Best Interconnection Model Members of the Coalition have suggested before and the Coalition would reiterate our belief that the superior interconnection model in the region is the New Jersey rules (see N.J.A.C. 14:4-9). While we are not claiming perfection in the New Jersey rules and would emphasize that all types of generators can be safely and reliably interconnected under the New Jersey rules (not just the Class 1 renewable generators identified in their rule), we submit it will be much more likely that the Commission will create a workable interconnection standard if it is based on the New Jersey model. The PJM rules are a step backwards from New Jersey. While compatible in that both rules rely on IEEE 1547 as the foundation, the New Jersey rules include a screening process for interconnecting generators that builds on the foundation of the IEEE standard. New Jersey includes a well balanced schedule of fixed fees for processing interconnections and sets a firm timetable for completing the process. These important elements are absent in the PJM rules. Unlike PJM, New Jersey includes a special expedited schedule and process for the smallest and easiest interconnections those inverters under 10kW. The interconnection process for the next level (Level 2 up to 2 MW) segregates the easy interconnections and ones that require no construction of utility equipment (transformers, poles, wires, etc.) from more complex interconnections. If the generator passes the stringent screens in Level 2, it is approved for interconnection without the need for costly additional equipment or studies. 8

11 New Jersey includes a generator certification component based on UL or other testing laboratory listing under the UL 1741 standard. PJM does not even recognize the value of UL listing in their rules. As proof of the comprehensiveness, delicate balance of all the interacting components, and removal of barriers to interconnection found in the New Jersey rules over 200 generators have been interconnected 6 since their promulgation. These generators and are providing power to the distribution grid in New Jersey and offsetting transmission congestion. By sharp contrast and to the best of our collective knowledge, not a single generator has been interconnected under the new PJM rules and it remains to be seen whether significant barriers remain in their model. IV. Conclusion The Coalition once again applauds the Commission for undertaking this complex inquiry on a technically difficult but extremely important set of issues which will create the foundation for meeting the alternative energy requirements under the Act, and for creating the necessary rules to allow distributed generation to make a significant contribution to the State s electricity needs. The Coalition is happy to make any of its members or technical experts available to the Commission to address any and all inquiries on interconnection. Respectfully submitted on behalf of the Pennsylvania Small Generator Coalition, Colin Murchie, Director of Government Affairs, SEIA th Street, NW Suite 510 Washington, DC cmurchie@seia.org 6 Based on SunEdison conversations with Demme Mechanical Inspections, the contractor certifying interconnections for the BPU. 9