Pennsylvania Public Utility Commission s7

BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION

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Alternative Energy Portfolio Standard : Working Group Net Metering/ : Interconnection Sub-Working Group : Docket No. M-00051865 Issues List for Small Generation : Interconnection :

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Comments of PPL Electric Utilities Corporation ______

TO THE PENNSYLVANIA PUBLIC UTILITY COMMISSION:

Background

On March 31, 2005 a list of issues related to interconnection standards for small generators was distributed to working group members for the purpose of soliciting comments on technical requirements and processes. PPL Electric Utilities Corporation (“PPL Electric” or the “Company”) appreciates the opportunity to offer comments on these subjects. In the interest of efficiency, the comments below are organized as responses to the fourteen issues distributed on March 31, 2005.

Interconnection Technical Requirements

1. It appears that, at a minimum, the IEEE 1547 technical requirements, should serve as the basis for the technical interconnection requirements in Pennsylvania. Additionally, the Act requires the Commission to develop interconnection rules consistent with the rules of states within the PJM region. The PJM Small Generation Interconnection technical standards for 2MW or less, which include the IEEE 1547 standards, appear to be a viable option for the Commission to the Commission to adopt.

1 a. Please indicate any areas of the PJM technical requirements that need modification and why?

One necessary change that currently is being made by the PJM Small

Generator Interconnection Working Group (“SGIWG”) is to limit the applicability of

Attachment H of PJM’s current standards to distribution circuits. It should be recognized that because existing distribution systems were primarily designed to deliver energy to loads, and not to provide an outlet for generation, additional necessary modifications will be identified as experience grows. The SGIWG process is intended to manage the evolution of these standards.

b. Also, please indicate any superior technical requirements over the PJM rules within the region that instead should be adopted by the Commission.

The PJM standard represents a minimum standard and there is acknowledgement that it is appropriate for individual distribution companies to have tighter standards. For example, PPL Electric applies a tighter standard for harmonics to its customers than is called for in the PJM Small Generator Interconnection Standard.

To permit small generators to meet a less stringent standard would improperly jeopardize the power quality and reliability currently provided to customers.

c. The PJM Technical Standard provides for four exceptions and one addition to the IEEE 1547 standard. Please address any concerns with the exceptions/addition.

PPL Electric has no concerns regarding the exceptions and additions currently proposed. As the response to Issue #1a notes, PPL Electric expects that there will be changes to these standards in the future. PPL Electric also anticipates that

2 additional exceptions will be identified because distribution systems differ in design, with some being primarily radial and others involving loops and networks.

2. Act 213 defines small generation units as 2MW or less. The PJM Open Access Transmission Tariff and the FERC Small Generation Interconnection NOPR define small generation as units with a capacity of 20 MW or less. The New Jersey Interconnection Standards define small generation units as 10 MW or below.

a. Since the Act mandates that the Commission adopt rules consistent with the region, should the Commission adopt 10 MW or less as the appropriate size for the small generation interconnection process?

PPL Electric believes that 10MW or less is an appropriate cut-off for the subject standard. Attempting to develop a standard that covers generators above

10MW will significantly increase the number of exceptions. Moreover, the interconnection of generators with ratings above 10MW is likely to run into operational and equipment limitations that will require unique designs. Therefore, as a practical matter, the existence of a standard is not likely to expedite interconnection of generators rated above 10MW.

b. PJM currently has a technical standard for generators that are less than 2 MW and in the process of developing a technical standard for units between 2 and 10 MW. If the Commission were to adopt a 10 MW or less as the appropriate size, what should the technical requirements be for units between 2 and 10 MW?

PPL Electric believes that the most practical approach would be for the

Commission to simply adopt the PJM standards and not to attempt to develop and maintain its own standard. In this way, the Commission can avoid having to assure that its standard remains consistent with the PJM standard.

3 3. If the Commission were to require that pre-certified customer generating equipment must be tested by a nationally recognized testing laboratory and certified to meet the requirements of UL 1741 for pre-certification. Are there additional standards that pre-certified equipment must meet?

When addressing “pre-certified customer generating equipment”, it is important to recognize that while a small skid-mounted generating unit might be pre- certified, “customer generating equipment” also may consist of a system of components that have, individually, been pre-certified. However, in this latter circumstance, the combination of pre-certified components cannot necessarily be considered to be pre- certified as a system because the interaction of the individual components with each other has not been tested. This is particularly true of protection and control equipment for larger generators which must be tested not only with regard to the other generator components, but also with regard to distribution system components and the potential range of distribution system operations.

4. Please address the issue of the appropriate point of common coupling.

The point of common coupling is defined by IEEE Standard 1547 as “(the) point where a local electric power system (“EPS”) is connected to an Area EPS.” It also is discussed in IEEE Standard 519 as the point in the interconnection of a customer- generator facility with an electric distribution system at which the harmonic limits are applied. The purpose of establishing harmonic limits is to protect electric service customers from power quality issues that may be created by the customer-generator and to protect the customer-generator from exposure to harmonic-related equipment damage. This point should be at the first isolation device from the utility to the line

4 serving the customer facility and it is a point that indicates a change from utility ownership to customer-generator ownership.

5. Should customer generation systems be required to have an accessible, outdoor and lockable disconnect switch? IEEE 1547 provides for the requirement of this switch where the EDC deems it necessary, but the New Jersey technical standards disallow the EDCs to require this disconnect switch. Please address any safety issues related to requiring this switch, and/or the impact of allowing each EDC to require the switch based. Please explain the reasons as to why or why not a disconnect switch should be required.

The safety issue is the ability to create a “visible break” in order to ensure the safety of utility workers. In some instances, the National Electrical Code requires a disconnect switch and, in those circumstances, such a switch must be provided. In other circumstances, a visible break may be accomplished by other means and a disconnect switch may not be necessary. PPL Electric also notes that some EDCs may have work rules that are tied to their labor agreements that specify what constitutes an acceptable a visible break. PPL Electric believes that EDCs should be permitted to require such a switch.

6. Generation interconnection systems may result in islanding on the EDC circuits. To avoid islanding, what design requirements should be instituted?

The current version of IEEE 1547 reserves Section 1547.5 to address

“islanding.” PPL Electric believes that it is appropriate for the Commission to permit

EDCs to follow their existing practices regarding “islanding” until such time as Section

1547.5 is complete and it provides a reason to change those practices.

5 7. Under what circumstances should the EDC be able to disconnect a distributed generation unit form the distribution system? What should be the process for disconnection, including appropriate warnings?

EDCs typically address the disconnection of customers through the provisions of their tariff. Generally, disconnection is pursued as a last recourse in response to safety and non-payment issues. In PPL Electric’s currently effective retail tariff, Rule 10 specifies the circumstances under which the Company may terminate and disconnect electric service. These are summarized as follows:

a. Non-payment of an undisputed delinquent account.

b. The customer’s installation has become dangerous or defective.

c. The Company’s property on the customer’s premises has been interfered with.

d. Energy has been used that has not been registered on the meter.

e. Circumstances associated with the issuance of a writ of execution against the

customer, or an assignment or act of bankruptcy on the part of the customer.

f. Circumstances associated with the customer’s violation of rules, terms and

conditions, or contracts governing electric service.

PPL Electric believes that existing Commission rules and provisions in EDCs’

PUC-approved tariffs regarding the disconnection of electric service also should apply to customer-generators.

6 8. Please identify any additional safety and reliability issues that must be addressed.

As noted in response to Issue #1a, the need for new standards and revisions to existing standards will continue to be identified as experience with the interconnection of small generators grows. As stated earlier, PPL Electric believes that the PJM SGIWG provides an appropriate forum to manage that process.

Interconnection Process

9. Should the Commission adopt a standardized interconnection agreement format? What should be included in the agreement process?

PPL Electric believes that it would be beneficial to all parties for the

Commission to adopt a standardized interconnection agreement format. The Company further recommends that the Commission adopt the format that is ultimately adopted by

10.In the ANOPR comments, parties emphasized that review and response times to interconnection requests must be reasonable and adequate in order to maintain the balance between ensuring safety and reliability of the system and not creating a significant delay for interconnection. Can the New Jersey Interconnection review processes for the various levels of interconnection (Levels 1, 2, 3) be reasonably applied in Pennsylvania? If not, what modifications are necessary?

PPL Electric is concerned that the timeframes in the New Jersey interconnection review process are unnecessarily short. The Company continues to recommend, as it did in its February 2, 2005 comments on the Advanced Notice of

Proposed Rulemaking at Docket L-00040168, that the Commission accept the "super expedited" timeframes and protocols that are being proposed by FERC. Adopting

7 shorter timeframes will result in increased staffing over and above that necessary to meet the PJM requirements and the costs of that staffing will either be recovered through increased application fees or through general distribution rates. PPL Electric's belief, based on experience, is that the PJM timeframe of 35 business days for pre- certified equipment would not present a burden to customer-generators. The

Company’s experience has been that the issues that have contributed to the perception of delays actually involve incomplete applications and the use of systems that are not pre-certified.

11.What are the trigger points for impact studies? Should the trigger points for impact studies be standardized? If so, please propose the trigger points.

The triggers for impact studies generally involve the size of the generator and the voltage and loading of the line to which the generator is to be connected. PPL

Electric believes that these triggers can be standardized to some extent and that such standardization would be beneficial. Some exceptions will have to be permitted to account for differences in the design of existing distribution systems. The current

PJM/FERC effort on small generator interconnection is attempting to standardize the impact study triggers and PPL Electric recommends that the Commission adopt the standards that result from that effort, rather than attempting to produce its own separate standards.

8 12.Some comments in the ANOPR process suggest that application fees can be used to deter incomplete or frivolous applications. What are the cost components of interconnection that the application fees should address? How can costs be minimized in each territory and should, to the extent possible, the formulas for application fees be made uniform? How would an application fee requirement impact the economics of certain projects?

PPL Electric believes that an application fee is an appropriate means of recovering costs from the entity which causes those costs to be incurred. In the absence of application fees, the EDC’s costs associated with the processing of applications will have to be recovered through general rates. The Company believes that application fees should cover the costs that are expected to be incurred by the EDC if the application were complete and no impact studies were required. This would represent a minimum amount. PPL Electric does not believe that it is necessary for this fee to be standardized across all EDCs, but the Company acknowledges that the fees of different EDCs should reflect similar amounts of effort and, therefore, be similar dollar amounts.

13.What, if any, insurance requirements for small generation customers are necessary?

Section 63 of the PJM Open Access Transmission addresses insurance requirements for entities connected to PJM. These should be the requirements for small generators with the option for EDCs to waive specific coverages in instances where they are inappropriate e.g., requiring a residential customer to have Workers

Compensation insurance. A currently effective certificate of insurance should be sufficient to demonstrate proof of coverage.

9 14.Should there be a Commission dispute resolution processes specifically dedicated to interconnection and net metering issues?

PPL Electric believes that the Commission should not institute a separate

dispute resolution process until such time as the need for this process is clear. The

Company believes that the existing informal complaint process, with the Bureau of

Consumer Services’ expertise supplemented with expertise from other bureaus, e.g.,

Conservation, Economics and Energy Planning, may be sufficient to address the

issue.

Respectfully submitted,

______Paul E. Russell Associate General Counsel PPL Electric Utilities Corporation Two North Ninth Street Allentown, PA 18101 (610) 774-4254

Dated: April 14, 2005 at Allentown, Pennsylvania