Interconnection Review Procedures

Section 467.70  Interconnection Review Procedures a)         The applicant shall submit an interconnection request using Appendix B, along with the application fee specified in Appendix B. b)         Within 10 business days after receipt of an interconnection request, the EDC shall notify the applicant whether the request is complete. When the interconnection request is not complete, the EDC shall provide the applicant with a written list detailing the information required to complete the interconnection request. When additional information is required and reasonable, the applicant and the EDC shall agree on a schedule to provide the required information or the interconnection request is considered withdrawn. The parties may agree to extend the time for receipt of the additional information. The interconnection request is deemed complete when the applicant has provided the required information or the parties have agreed that the applicant may provide additional information later. c)         The queue position of an interconnection request is used to determine the cost responsibility for the system upgrades and interconnection facilities necessary to accommodate the interconnection. The EDC shall notify the applicant as to its queue position. 1)         If the applicant amends the interconnection request in a manner requiring that the EDC re-study the feasibility or impact of the interconnection, the interconnection request shall receive a new queue position based on the date that it was amended. 2)         If an EDC determines that other interconnection requests may affect the same facilities on its electric distribution system or transmission system as the DER facility either proposed or being revised in an applicant's interconnection request, the EDC may study these requests together without regard to their queue position. If an EDC considers interconnection requests together because they both affect the same facilities on the electric distribution system or on transmission networks, the EDC shall notify the applicant of that fact at the time studies are initiated. If the EDC considers two or more interconnection requests together, estimated costs allocated to each applicant shall not exceed the estimated cost associated with the interconnection request had the EDC reviewed the interconnection requests in sequence. d)         After the interconnection request has been assigned a queue position, the following procedures shall be followed to determine how a study review shall be conducted: 1)         The EDC shall offer the applicant the related study agreement forms included in Appendices C, D and E.  By mutual agreement of the parties, the scoping meeting, interconnection feasibility study, interconnection system impact study, or interconnection facilities study provided for in a study review and discussed in this Section may be waived or combined. 2)         A scoping meeting shall be held no later than 10 business days, or on a mutually agreed upon date and time, after the EDC has notified the applicant that the applicant has provided all the necessary information.  The meeting's purpose is to review the interconnection request and existing studies relevant to the interconnection request. 3) When the parties agree that an interconnection feasibility study shall be performed, the EDC shall provide to the applicant, no later than 10 business days after the parties' agreement or, if held, the scoping meeting, an interconnection feasibility study agreement (see Appendix D). The interconnection feasibility study agreement shall include an outline for the scope of the study and the study's estimated cost. If the applicant does not sign and return the study agreement within 25 business days, the application shall be deemed withdrawn and the queue position shall be forfeited. 4)         When the parties agree that an interconnection system impact study shall be performed, the EDC shall provide to the applicant, no later than 10 business days after the parties' agreement, an interconnection system impact study agreement (see Appendix E). The interconnection system impact study agreement shall include an outline for the study's scope and the study's estimated cost. If the applicant does not sign and return the study agreement within 25 business days, the application shall be deemed withdrawn and the queue position shall be forfeited. 5)         When the parties agree that an interconnection facilities study shall be performed, the EDC shall provide to the applicant, no later than 10 business days after parties' agreement, an interconnection facilities study agreement (see Appendix F). The interconnection facilities study agreement shall include an outline for the study's scope and the study's estimated cost. If the applicant does not sign and return the study agreement within 25 business days, the application shall be deemed withdrawn and the queue position shall be forfeited. 6)         Interconnection studies that the EDC conducts shall consider all other DER facilities that, on the date the interconnection study is commenced, are directly interconnected with the EDC's electric distribution system, have a higher queue position than the request being studied, or have a valid and active interconnection agreement. 7)         If the applicant signs and returns an interconnection study agreement, but subsequently notifies the EDC that it will not continue with its proposed large DER facility project for any reason, the EDC need not complete the study or provide the applicant with study results. e)         The following guidelines shall govern all required interconnection studies: 1)         Unless waived by an applicant, an interconnection feasibility study shall include analyses to identify potential adverse system impacts that would result from the proposed interconnection at the applicant's proposed point of interconnection. A)        The interconnection feasibility study shall include pertinent elements from among the following: i)          Initial identification of any circuit breaker short circuit capability limits exceeded because of the interconnection; ii)         Initial identification of any thermal overload or voltage limit violations resulting from the interconnection; iii)        Initial review of grounding requirements and system protection; and iv)        Description of, and non-binding estimated cost and construction schedule of, facilities required to interconnect the DER facility to the EDC's electric distribution system in a safe and reliable manner, including identification of potential increased expenses due to location, distribution system assets, or other relevant factors. Cost estimates provided in each instance must be itemized in line item format and must break down costs by equipment, labor and other cost categories. The cost estimates must also provide the component parts for direct, indirect, and other identified cost categories. B)        If an applicant requests that the interconnection feasibility study evaluates multiple potential points of interconnection, additional evaluations may be required. Additional evaluations shall be paid for by the applicant. C)        An interconnection system impact study is not required when the interconnection feasibility study concludes that there is no adverse system impact, or when the study identifies an adverse system impact, but the EDC is able to identify a remedy without the need for an interconnection system impact study. D)        A study results meeting will be held within 10 business days after study completion, if requested by the applicant. The study results meeting will be attended by technical representatives of the EDC and the applicant. The study results meeting shall not relieve the applicant from its obligations, nor does it toll the clock for the applicant, to take the actions required by the rules at that point of review. E)        The parties shall use an interconnection feasibility study agreement, included as Appendix D, unless both parties agree to use an alternative form. 2)         An interconnection system impact study evaluates the impact of the proposed interconnection on both the safety and reliability of the EDC's electric distribution and transmission system. This study identifies and sets forth in detail what system impacts interconnecting a new or revising an existing DER facility to the distribution system would have on the electric distribution and transmission system, if there were no system upgrades. A)        A distribution interconnection system impact study shall be performed when a potential adverse system impact is identified in the interconnection feasibility study. The interconnection system impact study shall include pertinent elements from among the following: i)          A load flow study; ii)         Identification of affected systems; iii)        A short-circuit analysis; iv)        An analysis of equipment interrupting ratings; v)         A protection coordination study; vi)        Voltage drop and flicker studies; vii)       A stability analysis; viii)      Grounding reviews; ix)        Impact on system operation; and x)         Alternatives for mitigating adverse system impacts on affected systems. B)        The final interconnection system impact study report shall provide the following: i)          The underlying assumptions of the study; ii)         A summary of the analyses; iii)        The results of the analyses, including detailed information on any impacts identified, the drivers and reasons for those impacts, including load, voltage, thermal and other limitations, as well as the boundaries of the impacts, to the extent possible; iv)        A list of any potential impediments to providing the requested interconnection service and information regarding technical thresholds that drive modifications; v)         Required distribution upgrades; vi)        A non-binding estimate of cost and time to construct any required distribution upgrades. Those cost estimates shall provide the component parts for direct, indirect, and other identified cost categories.  Cost estimates must be itemized and must break down costs by equipment, labor, overhead and other cost categories; and vii)       If the cost estimate exceeds 50% of the estimated cost set forth in the feasibility study, a written itemization, by equipment, labor, overhead and other cost categories, of the component parts that increased in cost and a detailed explanation for the cost increase. C)        The parties shall use an interconnection impact study agreement, included as Appendix E, unless both parties agree to use an alternative form. 3)         The interconnection facilities study shall be conducted as follows: A)        The interconnection facilities study shall estimate the cost of the equipment, engineering, procurement and construction work, including overheads, needed to implement the conclusions of the interconnection feasibility study and the interconnection system impact study. The interconnection facilities study shall identify: i)          The electrical switching configuration of the equipment, including transformer, switchgear, meters and other station equipment; ii)         The nature and estimated cost of the EDC's interconnection facilities and system upgrades necessary to accomplish the interconnection; and iii)        An estimate for the time required to complete the construction and installation of the facilities. B)        The EDC may agree to permit an applicant to arrange for a third party to design and construct the required interconnection facilities. In such a case, the EDC shall make all relevant information and required specifications available to the applicant to permit the applicant to obtain an independent design and cost estimate for the facilities, which shall be built in accordance with the EDC's specifications. The applicant shall ensure that any third party with whom it shares the EDC's relevant information and required specifications shall comply with applicable security and confidentiality requirements. C)        Upon completion of the interconnection facilities study, and after the applicant agrees to pay any just and reasonable costs for the interconnection facilities and system upgrades identified in the interconnection facilities study, the EDC shall provide to the applicant a standard DER interconnection agreement (see Appendix C) for the applicant to sign. The applicant has 10 business days to sign the agreement or the application is deemed withdrawn. D)        In the event that system upgrades are identified in the impact study that shall be added only in the event that higher-queued customers not yet interconnected eventually complete and interconnect their generation facilities, the applicant may elect to interconnect without paying for such upgrades at the time of the interconnection, provided that it agrees to pay for the upgrades at the time the higher-queued customer is ready to interconnect. If the applicant does not pay for the upgrades at that time, the EDC shall require the applicant to immediately disconnect its distribution generation facility to accommodate the higher-queued customer. E)        The parties shall use an interconnection facilities study agreement, included as Appendix F, unless both parties agree to use an alternative form. f)         When an EDC determines that it is appropriate to interconnect the DER facility, the EDC shall provide the applicant with a standard DER interconnection agreement. If the interconnection request is denied, the EDC shall provide the applicant with a written explanation as to its reasons for denying interconnection. If the EDC's written explanation demonstrates that the interconnection request was denied for valid reasons, the interconnection request does not retain its queue position. g)         Within 30 business days after receipt of the standard DER interconnection agreement, the applicant shall provide all necessary information required of the applicant by the agreement. The EDC shall develop all other information required of the EDC by the agreement. After completing the agreement, the applicant shall sign and return the agreement to the EDC. If the applicant does not sign and return the agreement within 30 business days after its completion, the interconnection request shall be deemed withdrawn, unless the applicant requests in writing to have the deadline extended by no more than 15 business days. The initial request for extension may not be denied by the EDC. If the applicant does not sign the agreement after the 15-business-day extension, the interconnection request shall be deemed withdrawn unless a further extension is agreed to by the parties. The EDC shall return a fully executed DER interconnection agreement within 10 business days.  If withdrawn, the interconnection request does not retain its queue position. When construction is required, the interconnection of the DER facility shall proceed according to milestones agreed to by the parties in the DER interconnection agreement. h)         The DER facility is not permitted to operate until: 1)         The requirements of the interconnection agreement are satisfied; and 2)         The DER facility is approved by any electric code officials with jurisdiction over the interconnection; and 3)         The applicant provides a certificate of completion (see Appendix A) to the EDC. Completion of local inspections may be designated on inspection forms used by local inspecting authorities; and 4)         The witness test is successfully completed if required by the EDC or if the witness test is waived according to Article 2.1.1 of Appendix C.