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Parties filed initial comments on Staff’s discussion draft rules that propose to revise the interconnection process, and technical and operational standards, for Distributed energy resources or DERs operating in parallel to the distribution system.  Interested persons were directed to file initial by June 27, 2025.  Reply comments must be filed by August 8,2025. 

AEP Texas “recommends that the Commission strike § 25.210(e)(2)(C) from the list of requirements from a D SP’ s pre-screen study result. Providing this information on a pre-screen study would require an engineer to visit to each location and provide a detailed analysis. This requirement would increase the cost, complexity and lead time of a pre-screen. AEP Texas believes that this level of detail should be reserved for the electrical Impact Study.” 

Alison Silverstein Consulting recommends that PUCT (i) “establish a separate, simplified and streamlined set of procedures and requirements for interconnecting DER systems under 50 kW nameplate capacity and 25 kW export capacity” and (ii) applying “all substantive rules on interconnection, not just §25.210” to all utilities, including municipal and coops.

ERCOT: (i) “supports the Commission implementing the Institute of Electrical and Electronics Engineers (IEEE) standards in its DER requirements”; and (ii) “recommends § 25.210 apply to all Distribution Service Providers (DSPs), including municipally-owned utilities (MOUs) and electric cooperatives,” as “consistent application of technical requirements for DERs… will lead to more efficient installation and consistent performance”

Grid Resilience in Texas (“GRIT”)  regarding Section (f)(7), (f)(8), (g)(2)(C)(iv), (h)(3) GRIT “strongly recommends replacing “nameplate capacity” with “grid synchronous capacity” throughout the rule. Although there is a definition of nameplate capacity in 16 TAC §25.5, currently, many DSPs interpret and apply this definition differently. Nameplate ratings do not reflect the DER’ s actual grid impact or dispatchable capability. 

The use of grid synchronous capacity, as defined in ISO 8528, is a more accurate and technically appropriate measure. It ensures consistent and fair treatment of DERs and should be the default metric for interconnection studies, telemetry requirements, and operational limits. Standardizing this across all DSPs will create more certainty for DER providers in the interconnection process. 

Additionally, as it relates to Section (f)(7), GRIT believes a DER’ s percentage of the light line load is a better metric to prevent grid islanding compared to a generic capacity threshold.”  

Oncor recommended “using a larger nameplate capacity size of [1MW] rather than 250 kW as the threshold for determining the DERs that should be subject to the more comprehensive requirements under § 25.210” rather than § 25.211, “given that ERCOT requires [DG] with an installed capacity of greater than 1 MW that exports energy into a distribution system to register with ERCOT”; 

TSSA & SEIA “support greater standardization of interconnection processes (just as ERCOT REPs have benefitted from a pro-forma tariff for TDSP delivery services), and customers and DER providers will benefit from transparent, low-friction, standardized and streamlined interconnection processes that also ensure safety of utility workers and DER installers and their customers. We anticipate that such standardization will accelerate the addition of generation and energy storage resources to the grid at a time when load growth is rapid and all available resources are needed to ensure reliable and affordable service to Texans.”

TXSES appreciates the effort by Commission Staff to recognize that the size of interconnecting Distributed Energy Resources (DERs) matter and, as such, should have different standards and policies. However, TXSES believes that this must go further – small DER and photovoltaic systems that pose negligible risks should have their own standards and interconnection process to facilitate expedited, cost-effective installation. Small DERs ofless than 50 kW comprise over 87% the installed and reported unregistered DERs in the ERCOT market. 1 These small units serve primarily residential and small commercial customers, who seek energy resilience without the funding and time to spend on complex system engineering and legal processes. 

Since small (under 50 kW DER systems) pose limited technical risk but produce energy that supports broader ERCOT reliability, TXSES recommends the PUCT implement an additional set of standards for these smaller DER systems. We ask for a fast track interconnection process for DER systems under 50 kW nameplate capacity and under 25 kW of export capacity, that facilitates expedited interconnection that reduces unnecessary regulatory burdens, minimizes the time 1 Unregistered Distributed Generation Report: 2024 Annual Report 2025 Ql Update, 2025 Ql Unregistered Distributed Generation Report (May 7,2025). between contract execution, construction, and energization, and ultimately minimizes the cost to interconnect these facilities in a safe, reliable, and effective manner. This can be implemented either in a separate rule or incorporated into 25.211.”

See all comments here.

Discussion Draft Amendments (Pages 1-100) (05/14/2025)
Discussion Draft Amendments (Pages 101-127)
54233 (Opened on 10/24/2022)
(Technical Requirements And Interconnection Processes For Distributed Energy Resources (DERS))