net metering and interconnection a policy perspective brad klein staff attorney envt’l law &...
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Net Metering and Interconnection A Policy Perspective
Brad KleinStaff Attorney
Envt’l Law & Policy Center
March 28, 2007
Policy and market mechanisms affecting distributed generation (DG)
Interconnect Standards
Output-Based Emissions Standards
Sitting and Permitting
Green Power Marketing
Public Benefits Funds
Demand-side Bidding
Real-Time/Congestion
Pricing
Net Metering
Tax Provisions
Renewable Portfolio
Standards
Production Incentives
Transmission Access and
Pricing
Diagram from Dick DeBlasio, NREL (2004)
Interconnection Basics
Interconnection = the physical connection between the customer-sited generator and the utility grid.
Interconnection problems one of the “principal obstacles” to effective adoption of DG (NREL, 2000)
– Redundant and excessive technical requirements
(e.g. safety studies, equipment testing and approval, engineering analysis, transmission studies, system upgrades)
– Uncoordinated and expensive procedural requirements, fees, and application process delays
– Insurance and indemnification requirements.
Standardized Interconnection Rules
Establish clear and uniform technical requirements & approval procedures
FERC Small Generator Interconnection Procedures (Orders 2006 a & b)
– Apply to “small” generators = 20 MW and under– Generally apply to transmission level interconnections
State rules– Usually administered by state utility commission– Generally apply to distribution level interconnections– “Model” state rules: e.g. IREC (2005); MADRI (2005); ELPC
Interconnection Rules – important elements
Standardized technical requirements– Often based on IEEE 1547 and UL 1741 standards
“Expedited” review pathways – “plug & play” for small (e.g. <10 kW) pre-certified equipment– Streamlined review if pass technical screens– Separate pathway for non-exporting applications (e.g. CHP)
Clear fees and timelines Standardized application forms and interconnection
agreements No discriminatory / redundant requirements (e.g.
external disconnect switches, additional insurance requirements)
States with Standardized Interconnection Rules
Standards for net-metered systems only
Standards for net-metered systems and other DG
(November 2006)
Net Metering – basics
Economic arrangement to simplify the reconciliation of value of customer produced power.
“True” net metering: 1:1 offset of power consumed by power produced
(contrast to “dual” metering as in MO)
Net Metering – Policy considerations
Eligible technologies? – Wind, solar, biomass, digesters, fuel cells, etc?– System size caps? (2 MW is now “best practice”)
Aggregate caps?– often limited to 0.1% to 5% of utility max peak load
Metering considerations– Flat rate, time of use, who pays?
Reconciliation of NEG?– Monthly, annual, carry forward, utility give-back?
Treatment of RECs?
Net Metering
State-wide net metering for certain utility types (e.g., IOUs only)
Net metering offered by one or more individual utilities
Net metering is available in
41 states + D.C.
NH: 25MA: 60RI: 25 *CT: 100
50
www.dsireusa.org February 2007
8,000
100
100
1,000
25
50
100
402025/100
2,00040 150
10/100
25 no limit
25/100
25/100
10
500
VT: 15/150
10/400
PA: 50/1,000/2,000 NJ: 2,000DE: 25MD: 500DC: 100VA: 10/500
15
10
100
25
50
10
30
*
State-wide net metering for all utility types
* *
*
*
**
*
*
*
**
*
***
*
#s indicate system size limit (kW); in some cases limits are different for residential and commercial as shown
*
20/100
*
**
25
Net Metering – Best Practices
Max system capacity > 2 MW All renewables eligible (+ CHP) All utilities must participate All customer classes eligible No limit on aggregate capacity Annual reconciliation of NEG, or no expiration Interconnection standards No application fees, special charges, or tariff
changes Customer retains RECs
Energy Policy Act of 2005
Section 1254: InterconnectionPUCs and certain nonregulated utilities must “consider” an interconnection standard. Must complete “determination” by 8/8/07.
Section 1251: Net MeteringPUCs and certain nonregulated utilities must “consider” a net-metering standard. Must begin “consideration” by 8/8/07. Must complete “determination” by 8/8/08.
(The other new PURPA standards relate to fuel diversity; fossil fuel generating efficiency; and time-based metering and communications – see EPAct §§ 1251-52)
EXAMPLES
Iowa -- interconnection– Iowa Utility Board Docket NOI-06-4– Issue: Should standards apply to Rural Electric
Cooperatives? Illinois -- interconnection
– Illinois Commerce Commission Docket 06-0525– Issue: How should standards be implemented?
Statewide administrative rule? utility tariff? utility website?
Missouri – See Warren Wood’s presentation at 1:30
Resources
IREC: www.irecusa.org – Tracking state “consideration” of EPAct standards– Model net metering and interconnection rules– State-by-state tables of state rules & policies
DSIRE: Database of State Incentives for Renewables and Efficiency – www.dsireusa.org