News Stories

Connect DER   “Our comments aim to echo the comments provided by Tesla and Enphase, the Texas Solar + Storage Association (TSSA) and the Solar Energy Industries Association (SEA), and the Texas Advanced Energy Business Alliance (TAEBA) in direct or indirect support of the establishment of a process for meter socket adapter (MSA) approval. Additionally, Connect DER aims to respond directly to comments made by Oncor to address Oncor’s concerns and correct inaccuracies pertaining to meter socket adapters.”

Hunt Energy Network  “It is imperative that ERCOT distribution utilities adopt the pro-resource-interconnection mindset that has made the ERCOT transmission system the model for the nation. From the initial comments in this proceeding, it is sadly clear we are not there yet. The Commission’ s strong and sustained leadership will be needed to effect this change, just as it was a generation ago on the transmission grid.”

Texas Solar+Storage Association & Solar Energy Industries Association “[T]he Staffs Discussion Draft package takes substantial strides to bring additional clarity and transparency to DER interconnection processes. Our initial comments on §25.210 were aimed at bringing even more structure, clarity and transparency to the process where there was still ambiguity. The Solar Associations therefore recommend that the Commission Staff reject attempts by utilities to weaken Staffs proposed language by reducing transparency and creating ambiguity as to timelines and processes associated with interconnection.”

“Further, the Solar Associations agree with Hunt Energy Network’s (HEN’s) comments regarding the need to standardize requirements and limit the ability of DSPs to set their own requirements, particularly as would be allowed with the broad exception in proposed §25.210(g), wherein a DSP could require additional protection equipment, such as expensive and overly redundant transfer-trip equipment. We agree, therefore, with HEN’s proposal to require the DSPs to specify any additional operation or protection requirements in their open access tariffs that would be required by the Commission.”

TX Solar Energy Society and Alison Silverstein Consulting  “the Commission’s proposed rule for interconnecting DER projects below 10 MW and below 250 kW, and the stakeholder comments on that proposal, demonstrate the technical and procedural complexity of such interconnections. Such complexity is appropriate for larger DER projects with widely varying equipment and capabilities, connecting directly to a distribution feeder or a transmission line, with owners or sponsors having extensive financial, technical and legal support and time. But all those requirements are unnecessary and highly burdensome for small DER projects under 50 kW that lie behind the customer’s meter at the DSP’s distribution level. Current, disparate DSP interconnection requirements and the complex application and processing requirements now proposed impose significant and excessive cost and time burdens on the DSPs as well as the DER applicants.”

“We reiterate the need for a separate process for interconnecting residential/small commercial DER projects under 50 kw at the distribution level. This process should incorporate and establish a uniform interconnection application, technical requirements and evaluation process statewide. Since these individual small residential and commercial systems collectively use a relatively limited set of commercially available equipment and controls behind the customer meter, their behavior and grid impact are consistent and predictable and require minimal utility analysis. Furthermore, these systems have limited impact on the distribution feeders they interconnect to. Therefore, these systems, the interconnection application and evaluation process, and all related DER–side and grid-side technical requirements, should leverage preapproved NLTR DER equipment and use automated systems for application submittal, DER system analysis (e.g., online diagram development and protection system evaluation), and predicting the impact of the incremental DER system upon host feeder safety and system reliability. Interconnection evaluation of these small systems should use careful — but not stifling — distribution technical screens to limit DSPs’ discretion to disapprove appropriate DER applications. This rule should allow exceptions for non-standard DER equipment or feeder conditions that don’t meet the state’s adopted technical screens and place an obligation on the DSP to work with the DER applicant to remedy an exception and get the project approved and online if possible.” 

“For the Commission’ s convenience, TXSES and Silverstein attach our proposed stand-alone DER interconnection rule for customer-sited DERs under 50 kW nameplate size and 25 kW export capability. We encourage the Commission to adopt this rule, or something like it, as a separate set of provisions apart from but companion to the proposed changes in TAC §25.210, §25.211 and §25.212.” 

“A standardized DER interconnection rule for customer-sited DERs should apply uniformly to all DSPs, including municipal utilities & coops. Establishing a uniform process for these small DER systems will enable the DSPs to improve the efficiency of their small DER application processing, speed DSP application review and costs, and reduce soft costs for DER installers and system costs for small DER customers.”

Oncor  “The Discussion Draft contemplates two distinct interconnection processes for DERs: the first is set forth in draft § 25.210 and would apply to all DERs with a nameplate capacity over 250 kW, and the second is set forth in draft § 25.211 and would apply to all DERs with a nameplate capacity of 250 kW or less. In their respective initial comments, Base Power Company (“Base Power) and several other commenters propose that the Commission further adopt a separate, expedited interconnection process centered around the use of a streamlined, standardized form for interconnecting DERs under 50 kW.2 Base Power recommends that this be accomplished in a rule that would mandate an exclusive process for interconnecting DERs under 50 kW, such that a utility may not impose additional requirements, request supplementary documents, or apply any criteria beyond what is explicitly established in Base Power’s proposed, streamlined rule.3 

“Oncor has concerns with this proposed carve-out from today’ s current interconnection process that would apply across the board to all DERs under 50 kW, regardless of their individual specifications and circumstances and irrespective of the type of DER.”

View all comments here. 

54233
(Rulemaking to establish technical requirements and interconnection processes for distributed energy resources (DERs))