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EnergyDemocracyNY.org CoShareNYS – A Member-based Network of Community Organizations and Local Energy Practitioners Moving Community Shared Solar Forward in New York State Adam Flint, Coordinator Community Owned Shared Renewables (CoShare) NY Energy Democracy Alliance How you can get involved • Email [email protected] to join the COSHARE listserv • Join our twice monthly conference calls every other Wednesday, 1-2pm. Next Call May 11th • Join a task force: Interconnection, Finance, more to come. . . • Join and contribute to the CoShareNYS.org toolbox • Help resource our work: expertise, resources, funding “Interconnecting Community Solar” Panelists: • Melissa Kemp; New York Solar Energy Industries Association (NYSEIA) [email protected] • Bill Oberkehr; PV Trainers Network [email protected] Sponsored by Co-Share: • Adam Flint; Coordinator • Louise Gava; Coordinator of Interconnection Working Group Interconnecting Community Solar Projects in New York The Latest Developments, Key Information for Success, and Pitfalls to Avoid Melissa Kemp, NYSEIA Policy Co-Chair and Director Government & Utility Affairs at Renovus Solar Community Solar Interconnection Webinar April 27, 2016 About NYSEIA NYSEIA is the only statewide membership and trade association dedicated solely to advancing solar energy use in New York state. The solar industry employs over 7,000 individuals in a wide range of living wage jobs that benefit communities and help reduce environmental impacts from fossil fuels. Led by a diverse Board of Directors, NYSEIA strives to achieve responsible and sustainable solar energy adoption throughout the state. Community Solar Interconnection Webinar April 27, 2016 Context for Webinar • New York is working to dramatically ramp up the deployment of solar and other renewable distributed generation to reduce carbon emissions and avoid the worst of climate change, improve the efficiency of the electrical system, reduce costs, improve health and security, and provide other benefits to residents across the state. Community solar is one important aspect of this transition. • Common roles for organizations and people are: • Customer procuring clean electricity • Landowner leasing land for project(s) • Entity or organization promoting and driving interest in a community to participate in a project/make this transition • Entity, organization, or individual promoting or developing updated important local policies such as zoning and property tax • Entity or organization sponsoring or developing projects Community Solar Interconnection Webinar April 27, 2016 Interconnection 101- Distribution Grid • The New York electric distribution grid typically includes three-phase and single phase aboveground or underground lines that serve loads at businesses, farms, homes etc. Some utilities include subtransmission lines as distribution lines as well, but highvoltage transmission lines are not included. • Community solar projects - enabled by two NY Public Service Commission (PSC) orders in July and October 2015 (Case #15-E-0082) - need to connect to the distribution grid in order to use the new net-metering policy. Community Solar Interconnection Webinar April 27, 2016 Interconnection 101 – Community Project Overview • Community projects can serve customers: • Located in the same NY Independent System Operator (ISO) zone, and • Located in the same electric utility territory • Projects can be sized up to 2MWac in size per interconnection point and tax parcel, and can be located on leased 3rd party land, customer owned land, or developer owned land • Projects can typically most easily and affordably be interconnected to 3-phase distribution lines but smaller projects can also use single-phase lines Community Solar Interconnection Webinar April 27, 2016 Interconnection 101 – Community Project Overview • General Starting Place for Project Size Based on Distribution Line Phase and Voltage: • If 35kV and 3 phase = 4-6 MW • If 15kV and 3 phase = 2 MW • If 5kV and 3 phase = 0.75 MW • If 35kV and 2/1 phase = 0.25 MW • If 15kV and 2/1 phase = 0.20 MW • If 5kV and 2/1 phase = 0.15 MW The above sizes depend significantly on the peak load on circuit and other technical details. Community Solar Interconnection Webinar April 27, 2016 Context Community Solar Interconnection Webinar April 27, 2016 Context Community Solar Interconnection Webinar April 27, 2016 Community Solar Interconnection Webinar April 27, 2016 Interconnection 101 – Location and Timing • Location is key, and determining interconnection feasibility is a critical early step for any project • Typically part of the earliest site development process that runs before or parallel to early customer development for leased or developer-owned land, and can be after certain initial milestones if customer-owned land. • Recommend very preliminary location tools to use: • Online simple mapping of utility circuit locations, phase, and voltage went live on and were shared between 8/319/1/15 in case docket. NYSEG mapping is here and National Grid mapping is here for example. • Visual inspection Community Solar Interconnection Webinar April 27, 2016 Community Solar Interconnection Webinar April 27, 2016 Community Solar Interconnection Webinar April 27, 2016 Current State of Interconnection in NY • The NY Interconnection Queue is the list of projects in order of submittal that have applied to connect to the distribution grid across the state. • Current NY interconnection queue is growing (likely in large part due to community solar interest) and is around 2,900 MW of solar and other non-wind DG as of 4/1/16 according to utility filings in PSC Matter 13-00205 SIR Inventory. • The current interconnection queue is larger than NY has experienced in the past and would be in excess of net-metering caps if they currently applied, but this number is likely not adequately representative of real proposed projects and this should be addressed and not used to drive policy. Community Solar Interconnection Webinar April 27, 2016 Current State of Interconnection in NY Community Solar Interconnection Webinar April 27, 2016 Rules and Process • The Standard Interconnection Requirements (SIR) are New York’s state-wide regulations intended to create uniform interconnection rules for connecting solar PV and other distributed generation (DG) systems to the electric distribution grid. The SIR provides application procedures, technical requirements, review processes, timelines, cost guidelines etc. • As we will detail below, significant updates to the SIR were worked on in 2015, and these were just announced by the PSC on March 17, 2016 and this new SIR go into effect formally this Friday April 29, 2016. You can access it here. • Initial goal is for the process and rules to work, be accurate, fair, and timely, so that we get projects successfully connected. Distribution system limitations will then be medium term limit for solar development in municipalities Community Solar Interconnection Webinar April 27, 2016 Challenges and Common Interconnection Issues to Date • No way to get information on circuits upfront without submitting an interconnection application and getting in the queue • Delays in the reports and studies in the process – In part driven by waves of application in response to regulatory changes • Different technical standards being used by utilities across the state to evaluate project feasibility and decide on necessary upgrades • Lack of transparency about and significant variation in upgrade costs across territories • Limited formal processes and rules for interconnection queue management resulting in many “projects” in queue for initial information or speculation, and delays and complexity as a result Community Solar Interconnection Webinar April 27, 2016 Recent SIR Update Announced March 17, 2016 (Case 15-E-0557) and includes these positive changes: • Introduction of pre-application report – Key data about circuit and substation of interest without submission of full interconnection application and entering interconnection queue • Inclusion of a set of standard screens state-wide in preliminary review with explicit language that if passed, the project goes directly to execution of interconnection contract with no upgrades and no study • If screens are failed, option for expedited supplemental review • Elimination of blanket upgrade requirements if pass initial or supplemental review Community Solar Interconnection Webinar April 27, 2016 Recent SIR Update (Cont) • If upgrades required after supplemental process or study, payment to execute contract reduced from 100% of upgrade costs to 25% • New requirements for greater detail on any upgrades proposed, itemized costs • Limitation of overall cost contingency to 25% • Projects up to 5MW are now allowed to be processed through the SIR, but the net-metering limit for projects is still 2MW, so it is unlikely that this 5MW upper limit will be used initially Community Solar Interconnection Webinar April 27, 2016 New SIR Process 1) Pre-application Report Request (Appendix D) – Request by applicant for 13 key pieces of information on the distribution circuit interested in connecting to. No customer name or site control required, and does not place you in the queue. –Fee is $750, Utility has 10 business days to complete, and Applicant has 15 business days to use fee credit 2) Application Submission and Preliminary Review – If the above is successful, submitting a formal interconnection application requires completed forms and initial 3 line electrical drawing (Appendix F). Free if completed pre-application report recently, otherwise fee. – Fee is zero or $750, Utility has 15 business days to complete, and Applicant has 30 business days to decide on next steps after results Community Solar Interconnection Webinar April 27, 2016 New SIR Process (Cont) 4) Executed Contract or Further Study - If pass standard screens in preliminary review (Appendix G), you should go directly to contract with no study or upgrades. If fail, option for Supplemental Review Screens or can go straight to full CESIR study. Fee is $2,500 for Supplemental and $5,000-$20,000 for CESIR, Utility has 20 or 60 business days respectively to complete, and Applicant has 30 or 60 business days respectively to decide on next steps after results 5) Deposit, and Execution of Contract: If have not already moved to contract, after completion of the CESIR study, applicant has the allowed business days to decide to move forward and pay 25% of upgrade costs to execute interconnection contract, which sets your place in the queue and locks in the project’s property tax status. The remaining 75% of costs are then due in an additional 120 days and then utility upgrades can start. Community Solar Interconnection Webinar April 27, 2016 New SIR Process (Cont) Example Total Times for the New Process Excluding Construction are: • 40-60 business days for simpler projects (up to 1MW at excellent sites) • 130 business days for more complex projects New Process vs Old Process: Please note that currently all projects in the queue before 4/29/16 are planned by DPS to be processed completely under the old process. As this is significantly disadvantageous for some projects and could slow the benefits of the new SIR, we are requesting that applicants be able to request that a project be reprocessed under the new SIR without having to submit a new application. Community Solar Interconnection Webinar April 27, 2016 Unique SIR Requirements for Community Solar • Some utilities have unique Community Distributed Generation Agreement or Host Certification forms, and some require special version of standard paperwork (Appendices A, B, and C) • Details on each utilities requirement can be found in their “Community Distributed Generation Operating or Procedure Manuals” published 11/9/15 in the docket for Case #15-E-0082 • All utilities have project sponsor creditworthiness requirements that are still being confirmed and clarified Community Solar Interconnection Webinar April 27, 2016 Work Going Forward • Along with the SIR update, there has been the recent creation of a State-level NY Interconnection Technical Working Group (ITWG) and State-Level Interconnection Ombudspersons to address the significant remaining improvements needed • These include: • Consistent and accurate implementation of the new SIR • Creation of a robust and complete set of interconnection queue management processes, including a requirement for site control before an application can be submitted, exact timelines at every part of the process which if not met by the developer result in automatic removal from the queue, and a clear process by which projects can move around each other in the queue if there are buffers around the timelines. • Creation of best practice standards on technical issues including Substation Level Reverse Power Flow, Remote Monitoring Requirements, Control and Protection Issues including DTT Requirements and Other Anti-Islanding Protection Schemes, and Voltage Flicker and Regulation Community Solar Interconnection Webinar April 27, 2016 Work Going Forward (cont) • Addition of enforcement mechanisms and incentives for utilities to meet interconnection process timelines and cost estimates and to innovate to help further reduce costs • Elimination of Customer name requirement for interconnection applications and/or ability to update customer name (Except for community projects that already have this as a standard) • Addition of process for updating preliminary reviews and CESIRs when minor changes to the system configuration occur • Hosting capacity maps Community Solar Interconnection Webinar April 27, 2016 Best Practices to Avoid Common Problems • Attention to site selection and early due diligence on interconnection feasibility (in addition to the land itself) to avoid non-starter situations • Share common non-starter situations with landowners, community, and municipal leaders – for example trying to put a 2MWac project on a single-phase or low voltage three-phase line • For the above, use the existing mapping tools and visual inspection, and then use the preapplication report • Always correctly and fully complete the preapplication report request form and interconnection application itself • Use in-house resources or cultivate partnerships to understand and process the technical interconnection reports and results Community Solar Interconnection Webinar April 27, 2016 Best Practices to Avoid Common Problems • Those resources can use and refer to NYSEIA’s “Summary of and Rationale for Processes and Screening Methodologies Included in the Recently Adopted New York State Standardized Interconnection Requirements (SIR)” • Meet developer/sponsor timelines in new SIR to maintain place in queue • Remove dead projects formally from queue until the new more robust and automated queue management processes are fully in place • Establish good working relationships with the utilities as much as possible we all share the same goals to interconnect solar and maintain safety and reliability of the system, but also don’t hesitate to reach out to NYSEIA or DPS for assistance if you are having an issue Community Solar Interconnection Webinar April 27, 2016 If Interested in Further Details • Looking for more information on the rationale for the new statewide screens and their implementation, how to make the best use of the new pre-application and preliminary technical review reports, or discussing the details of proposed management of the current queue? • Additional Upcoming NYSEIA Webinar: “The New Interconnection Rules in NY for Developers: How to Understand and Successfully Navigate the New Process and Changes on the Horizon” Next Tuesday, May 3, 2016 - 10:00am EDT Register by clicking here Community Solar Interconnection Webinar April 27, 2016 Questions? Next Webinar Wednesday, May 11th 10am Topic: ‘Solar Land Leasing and Municipal Best Practices’ Cosponsored by NDA and NYSEIA [email protected]