Small Hydro Regulatory and Permitting Requirements California

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1 Small Hydro Regulatory and Permitting Requirements California Lon W. House, Ph.D

2 Water & Energy Small Hydro Regulatory and Compliance FERC QF, Small Hydro License or Exemption EIA Generator Registration Requirements - California WREGIS QRE Generating Unit ID, annual GRE reporting CAISO Metering, Interconnection, Generating Resource Assessment, System Assessment CEC RPS Certification, Generating Plant ID Utility Interconnection, PPA Scheduling Coordinator SC agreement Purchaser - PPA SWRCB Nonconsumptive Water Use Right, 401 permit Local Permits generally exempt Environmental Documents CEQA, USACE 404 permit, CDFW 1602 permit

3 Qualifying Facility Certification 3 months 80 MW or less whose primary energy source is renewable (hydro, wind or solar), biomass, waste, or geothermal resources. In order to be considered a qualifying small power production facility, a facility must meet all of the requirements of 18 C.F.R (a), (c) and for size and fuel use, and be certified as a QF pursuant to 18 C.F.R Use completed Form No Applicants submitting a self-certification must comply with the Notice Requirements for QF certification applications.

4 Water & Energy Small Hydro Options Qualifying Conduit Hydropower Facility 3 months Certain hydropower facilities located on non-federally owned conduits with installed capacities up to 5 megawatts (MW) are not required to be licensed or exempted by the Commission. The applicant must file a Notice of Intent to Construct a Qualifying Conduit Hydropower Facility with the Commission with site plans, and show that the conduit is not primarily for the generation of electricity and was not licensed or exempted on or before August 9, Conduit Exemptions up to 9 months A small conduit hydroelectric facility up to 40 MW using a man-made conduit operated primarily for non-hydroelectric purposes may be eligible for a conduit exemption. The applicant must have all the real property interests necessary to develop and operate the project. The conduit on which the project is located is not included as a project work. Three step consultation process but with concurrence from all resource agencies, the applicant may seek waiver of the subsequent consultation requirements. 10-MW Exemptions up to 9 months A small hydroelectric project of 10 MW or less may be eligible for a 10-MW exemption. The applicant must propose to install or add capacity to a project located at a non-federal, pre-2005 dam, or at a natural water feature. The project can be located on federal lands but cannot be located at a federal dam. The applicant must have all the real property interests or an option to obtain the interests in any non-federal lands. Three step consultation process but with concurrence from all resource agencies, the applicant may seek waiver of the subsequent consultation requirements.

5 The survey Form EIA-860 collects generatorlevel specific information about existing and planned generators and associated environmental equipment at electric power plants with 1 megawatt or greater of combined nameplate capacity.

6 WREGIS tracks renewable energy generation from units that register in the system by using verifiable data and creating renewable energy certificates (REC) for this generation. This "accounting system" is designed to issue, register, and track RECs for use in verification of compliance with state programs (Renewable Portfolio Standards), and voluntary market programs. Utility PPAs require it. Also have to arrange annual QRE reporting/verification. Create a WREGIS Account and then register new generator. Note - All units must review WREGIS PA Advice letter form, submit the WREGIS Acknowledgement of Station Service form, and provide proof or documentation of the following to register the generator: For Generating Units 1 MW and larger located within the U.S.: i. EIA 860 for most recent year, Utility Interconnection Agreement, Manufacturer's specifications, and proof or documentation of revenue meter ID ii. Purchase Power Agreement iii. For newer units: a Notification of Commercial Operation (i.e. substantial Completion Certificate) For Generating Units smaller than 1 MW located within the U.S.: i. Utility Interconnection Agreement, and manufacturer's specifications, and proof or documentation of revenue meter ID ii. Purchased Power Agreement iii. For newer units, a Notification of Commercial Operation (i.e. Substantial Completion Certification)

7 . For distribution connected and Qualifying Facility (QF) resources, New Resource Implementation (NRI) will be the first point of contact at CAISO. Have to have interconnection agreement, contract for sale of electricity, and RIG done before NRI

8 . Buckets 1 and 2 Full Network Model Preparation Remote Intelligence Gateway (RIG) and Metering Submittals Interconnection Agreement Communication Block Diagram Three Line Drawings A Single Line Drawings Remote Intelligent Gateway Details Form Turbine Coordinates Generator Dynamic Model File Generator Positive Sequence Load Flow Data Network Application Information Non Bucket Item RIG Initial Spreadsheet Bucket 3 Regulatory Contracts, Model Testing, and Forecast Preparation Generator Resource Data Template Initial Spreadsheet Meter Configuration Worksheet Topographical Map Site Information Form Regulatory Contracts Information Request Sheet(s) Schedule 1 Template

9 . Bucket 4 Market Preparation Scheduling Coordinator (SC) Selection and Acceptance Letters Generator Resource Data Template Final Spreadsheet Participating Intermittent Resource Program Letter of Intent Export Fee Form California Energy Commission (CEC) Pre-certification Net Qualifying Capacity Request Form Control and Protection Documentation 24/7 Contact Information form Device Certificate Request Form for RIGs RIG and/or Metering Pretesting Notification RIG and Meter ISO Testing Scheduled CPS Subscribers Agreement for Remote Intelligent Gateways (RIGs) Energy Control Network Connectivity (ECN) Security Requirements and Agreement Bucket 5 Trial Operations Approval Getting To Synchronization RIG Resource Site Narrative Document Interconnection Customer Sync Letter Request Interconnection Approval Letter from Participating Transmission Owner Test Energy Schedule

10 Bucket 6 Trial Operations CAISO Internal Approval Process for Synchronization 24 Hour Notice for Initial Sync Contacting the ISO Real-Time Desk Meter Certification Documents Must Be Approved Before Commercial Operations Metering Calculation Worksheet CAISO Metering Certification form Metering Calculation to Point Of Receipt Document Site Verification Data Sheet Bucket 7 Commercial Operation Declaring Commercial Operational Date Metering and Telemetry Certificate of Compliance Participating Transmission Owner (PTO) Final Approval Letter Interconnection Customer COD Notification Generator Interconnection Agreement Exhibit E Letter Distribution Connected COD Letter Metering and Telemetry Certificate of Compliance Participating Transmission Owner (PTO) Final Approval Letter Metering and Telemetry Certificate of Compliance Participating Transmission Owner (PTO) Final Approval Letter Full Build-out of the Resource Completed Partial COM with Concurrent Trial Operation Interconnection Customer COD Notification Generator Interconnection Agreement Exhibit E Letter Distribution Connected COD Letter Interconnection Customer Commercial Operation for Markets Process & Notification Commercial Operation for Markets (COM) Letter Increasing Commercial Energy Interconnection Customer COD Notification Generator Interconnection Agreement Exhibit E Letter Distribution Connected COD Letter Water & Energy.

11 Small Hydro Certification Generating Plant ID

12 Interconnection Application is either a Rule 21 or WDAT (WDT for PG&E). Cost $800 (if not NEM). Duration 25BD -35 business days. Technical studies: Cost - depends. Duration - 5 weeks to 24 weeks. Processing Fee of $800, Study Deposit of $1,000 - Initial review - 15 BD - Supplemental review - 10 BD ($10,000) - Independent Study Process (cost varies) - System impact study - 60 BD (12 weeks) - Facilities study - 60 BD (12 weeks) Interconnection agreement negotiations commence following completion of studies. Cost - $0. Duration: 16 weeks

13 Interconnection Application must include the following: A completed Interconnection Request form for processing An Initial Review fee check or money order in the amount of $ 800, if applicable Single-line drawing showing the electrical relationship and descriptions of the significant electrical components such as the primary switchgear, secondary switchboard, protective relays, transformers, generators, circuit breakers, with operating voltages, capacities, and protective functions of the Generating Facility, the Customer s loads, and the interconnection with SCE s Distribution System. Show the location of all required net generation electric output. Drawings must conform to accepted engineering standards and must be legible. 11 x17 drawings are preferred Site plans and diagrams showing the physical relationship of the significant electrical components of the Generating Facility such as generators, transformers, primary switchgear/secondary switchboard, and control panels, the Customer s loads and the interconnection with SCE s Distribution System. Please show the location of all required net generation electric output meters and the A.C. manually operated disconnect devices on the site plans. Photos of the AC Disconnect, showing visible contact separation in the open position. If the point of interconnection is on the utility side of the main circuit breaker and/or it is a Virtual Net Energy Metering project, please provide switchgear, switchboard, or main panel cut-sheets/shop drawings detailing the bussing and proposed point of interconnection including any proposed modifications showing resultant clearances. The proposal must include a signed PE stamp and modifications must be re-certified by the manufacturer or a qualified third party. In addition, please provide pictures of the point of interconnection prior to modification. Pictures of the point of interconnection post-modification must be provided prior to scheduling of SCE commissioning test. If the project requires a net generation output meter (NGOM), provide meter socket cutsheets of the net generation output meter socket. If transformers are used to interconnect the Generating Facility with SCE s Distribution System, provide transformer nameplate information (voltages, capacity, winding arrangements, connections, impedance, et cetera). If a transfer switch or scheme is used to interconnect the Generating Facility with SCE Distribution System, provide component descriptions, capacity ratings, and a technical description of how the transfer scheme is intended to operate. If protective relays are used to control the interconnection, provide protection diagrams or elementary drawings showing relay wiring and connections, proposed relay settings, and a description of how the protection scheme is intended to function.

14 Utilities Power Purchase Agreement Options NEM Net Energy metering. have to have site load, full retail credit (for now), limits on generation, size limits. Tariffs NEM (PG&E form79-974), Rule 21 interconnection. Self-Gen no export. Have to pay departing load fees. Islanding issue. Rule 21 non-export interconnection and departing load tariffs. REMAT renewable feed in tariff. Solicitation every two months. Size limits. Penalties for non performance. ReMAT tariff and ReMat PPA. RESBCT local government renewable bill credit. Size limits. RESBCT Tariff, Rule 21 interconnection, RESBCT Agreement. SB43 options. RAM semi-annual renewable competitive auction. Auction sets price. Penalties for non performance. Standard PPA. RFO solicitation for specific needs. Performance requirements. Resource adequacy, energy storage, SONGS replacement, etc. RPS renewable portfolio standard solicitation. Renewable bundled energy and capacity and RECS. Solicitation as needed.

15 Additional Permits/Agreements SWRCB - nonconsumptive water use right certification (water quality certification) CDFW Section 1602 permit (streambed alteration) USACE (discharge) CEQA mitigated negative declaration Scheduling Coordinator Third Party Purchaser Meter Services QRE Reporting

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