Comparing Utility Interconnection Timelines for Small-Scale Solar PV
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1 Comparing Utility Interconnection Timelines for Small-Scale Solar PV Chelsea Barnes EQ Research, LLC Solar Focus Washington, D.C. Nov. 17, 2015 eq-research.com
2 The Problem: Waiting for Permission to Operate Delays are costly: Contribute to high soft costs $73.48/month for residential 5 kw system in Maryland Customer satisfaction Word-of-mouth marketing EQ Research LLC info@eq-research.com
3 A Growing Problem Residential Solar Growth EQ Research LLC
4 Study: Comparing Utility Interconnection Timelines D.C. 20 installers 13 states and Washington DC 30,088 applications in 2013 (33 utility territories) 57,482 applications in 2014 (34 utility territories) EQ Research LLC
5 # of Days Quantifying the Problem: PTO Wait Time Median Lowest Reported Highest Reported EQ Research LLC info@eq-research.com
6 Quantifying the Problem % increase on average % utilities increased PTO % utilities decreased PTO EQ Research LLC
7 Number of Days Difference in Average PTO from EQ Research LLC
8 The Good. Average # of Days CL&P (CT) National Grid (MA) JCP&L (NJ) Central Hudson (NY) National Grid (NY) NYSEG (NY) PG&E (CA) BGE (MD) MECO (HI) PacifiCorp (UT) EQ Research LLC info@eq-research.com
9 and the Rest ORU (NY) PSE&G (NJ) SDG&E (CA) SRP (AZ) TEP (AZ) NV Power (NV) SCE (CA) MID (CA) NSTAR (MA) PGE (OR) Con Ed (NY) SMUD (CA) ACE (NJ) Delmarva (DE) HECO (HI) LIPA (NY) HELCO (HI) APS (AZ) PacifiCorp (OR) WMECO (MA) Xcel (CO) LADWP (CA) Pepco (DC) Pepco (MD) Average # of Days EQ Research LLC info@eq-research.com
10 Policy Problems 24 of 34 utilities subject to regulated PTO timelines 14 out of 24 did not meet those deadlines Arizona, Delaware, DC, Maryland no PTO deadlines Policies vary widely 5-30 business days On-site utility inspection/testing may or may not be required MA only state with penalties for failure to meet PTO deadlines Dispute resolution procedures unavailable or unused EQ Research LLC
11 Problem Areas: Applications Paper process it outdated Pre- and postconstruction approval unnecessary EQ Research LLC
12 Problem Areas: Communication and Transparency Online application system solutions Staffing Coordination with local jurisdictions EQ Research LLC
13 Preparing for More DG EQ Research LLC
14 Recent Developments D.C. EQ Research LLC
15 Thank you! Chelsea Barnes EQ Research LLC EQ Research LLC
16 Grid Reliability Denials EQ Research LLC
17 Quantifying the Problem Survey data: 50 utility service territories with the most netmetered residential customers 2013 and 2014 # of applications submitted # average PTO waiting period # of applications denied due to grid reliability concerns EQ Research LLC info@eq-research.com
18 MDV-SEIA 2015 Solar Focus Conference Net Energy Metering and Interconnection Processes Presented by Inia Burginger, APR November 17, 2015
19 Pepco Holdings, Inc. Our Territory Service territory 8,340 square miles Customers served Atlantic City Electric NJ 546,000 (electric) 9,963 approved interconnections* Delmarva Power DE and MD 510,000 (electric) 128,000 (natural gas) 3,826 approved interconnections* Pepco DC and MD 815,000 (electric) 7,218 approved interconnections* Total population served ~ 5.6 million 21,007 interconnections approved* * As of Oct. 31, 2015 We support renewable energy and partner with our customers to ensure safe and reliable interconnection of renewable energy into the electric grid November 17,
20 NEM Application and Call Volumes are Increasing Sharply As of September 30, 2015 PHI Applications have nearly doubled in 2015 compared to 2014 We expect them to double again in 2016 End of federal tax credit Aggregated and community net metering programs Leasing programs and grants Association forecasts o MDV-SEIA, SEPA Call volumes substantial but leveling off 1,625 in October, down from 1,915 in September and up from average of 1,436 / month January-June Inquiries shifting from application status to billing questions November 17,
21 Regulatory Requirements Guidelines to all PHI Processes Interconnection requirements differ substantially state to state, region to region Regulatory requirements PHI follows are similar but different state to state DC Title 15, Chapter 40 of the D.C. Code of Municipal Regulations for Small Generator Interconnection Rules (SGIR) and the D.C. Customer Net Energy Metering Contract (NEM Contract) define Pepco s application process MD Code of Maryland Regulations (COMAR) for Small Generation Interconnection Standards (SGIS) defines the application process Pepco follows. COMAR for Net Metering Authority defines the qualifications for net energy metering in Maryland DE Title 26 of the Delaware Code, Chapter 10 and corresponding regulations adopted by the Delaware Public Service Commission define the net energy metering and interconnection application processes Delmarva Power follows NJ New Jersey Administrative Code Title 14, Chapter 8, Subchapter 4 defines net energy metering and Subchapter 5 defines the interconnection application processes Atlantic City Electric follows All PHI processes follow these regulatory guidelines very closely November 17,
22 The NEM and Interconnection Process Steps Actions To Take 1. Research Research the various types of renewable energy systems available and decide which system best fits consumption needs. Renewable energy-generating systems can be sized up to 200% in Maryland, up to 110% in Delaware, and up to 100% in New Jersey and the District of Columbia Customers should understand their electrical load and energy consumption Responsible Party Customer 2. Select Interview and select a licensed and reputable installing contractor Customer 3. Apply The customer should understand the documentation needed with the interconnection agreement (e.g., rebate forms, permit applications, inspection forms) The customer applies and submits Part I of our interconnection application and agreement along with the application fee and supporting documentation Applications without supporting documentation will be delayed. The customer can resubmit a corrected application and documentation 4. Approval The customer waits for our Approval to Install before installing any renewable generator equipment We will provide the customer a written screening result or Approval to Install Customer Customer PHI Utility Apply for Building Permit 5. Install Begin constructing and installing the renewable generator facility Customer 6. Inspect After installation, submit Part II of our interconnection agreement, including a copy of the certificate of completion and the inspection certificate We will review the customer s documentation to verify the interconnection application meets regulatory requirements Customer PHI Utility 7. Meter We will install the net-capable meter PHI Utility 8. Authorization We will send the customer an Authorization to Operate letter PHI Utility 9. Operate Receipt of the authorization letter means the customer can operate the renewable system Customer November 17,
23 Application Process Timeline and Checklist business days 40 business days 20 business days ~80 business days Steps Actions To Take Responsible Party Level 1 Applications 1. Research Research the various types of renewable energy systems available and decide which system best fits consumption needs. Renewable energy-generating systems can be sized up to 200% in Maryland, up to 110% in Delaware, and up to 100% in New Jersey and the District of Columbia Customers should understand their electrical load and energy consumption Customer Complete application Received to Acknowledgement (3-10 days) Engineering Review to Approval to Install (10-15 days) Customer Installs and has Inspected (avg 40 days) Application Part II Received, Meter Exchange, Authorization to Operate (20 days) 2. Select Interview and select a licensed and reputable installing contractor Customer 3. Apply The customer should understand the documentation needed with the interconnection agreement (e.g., rebate forms, permit applications, inspection forms) The customer applies and submits Part I of our interconnection application and agreement along with the application fee and supporting documentation Applications without supporting documentation will be delayed. The customer can resubmit a corrected application and documentation 4. Approval The customer waits for our Approval to Install before installing any renewable generator equipment We will provide the customer a written screening result or Approval to Install Customer Customer PHI Utility 5. Install Begin constructing and installing the renewable generator facility Customer 6. Inspect After installation, submit Part II of our interconnection agreement, including a copy of the certificate of completion and the inspection certificate We will review the customer s documentation to verify the interconnection application meets regulatory requirements Customer PHI Utility 7. Meter We will install the net-capable meter PHI Utility 8. Authorization We will send the customer an Authorization to Operate letter PHI Utility 9. Operate Receipt of the authorization letter means the customer can operate the renewable system Customer Apply for Building Permit November 17,
24 Application Completions Compliance with Regulatory Metrics Part I Applications Processed Within Regulated Timelines Pepco Delmarva Power Atlantic City Electric DC MD DE MD NJ % % % % % 1, % % % % % 1, % % % % % 1, % % 2,143 97% % % 2, Forecast 97% 1,110 97% 4,900 80% 1,280 84% % 6,270 November 17,
25 GPC/NEM Process Improvements Since July 2015 Established PHI Steering Committee to examine end-to-end interconnection processes impacting GPC, Billing, Engineering, and Meter Operations Realigned existing GPC Applications team into process groups Increases accountability within the teams and allows for teams to work across jurisdictions to meet regulatory timeframes Implemented enhanced phone tree for calls into GPC to direct customers to team handling their application; issues pertaining to billing are forwarded to NEM Billing experts (1) Application Status and General Inquiries, (2) Meter Exchange, (3) Permission to Operate, (4) Billing Inquiries Phone calls now answered live 10 a.m.-4 p.m. Hired 4 new GPC account coordinators to process applications; started in September Shifted resources internally to meet increased application volume Added technology WMIS-based online application processing and tracking system launched internally in late September to better coordinate applications with GPC, Engineering, Meter Operations and Billing departments November 17,
26 Planned NEM Process Improvements NEM Online Application System early 2016 benefits: Improves the accuracy and speed of the NEM application process Features auto-data validation, pull-down lists, and online signature and fee payment Provides accurate and timely compliance reports, plus business reporting tools Improves the customer experience and meets regulatory requirements Green Button Standard to provide customer usage data Enables MyAccount download functionality for customers Enables solar contractors access to replica of existing Third-Party Supplier Portal Post Acceptable Inverters List on GPC websites November 17,
27 NEM Process Changes Being Evaluated Move meter exchange earlier in the process Implement over-the-air meter reprogramming Eliminate truck rolls for meter exchanges Simplify application forms and processes as part of the Working Groups Clarify process for handling unauthorized installations November 17,
28 Use GPC Websites as Business Resources Interconnection Application and Agreement Forms Printable Informational PDFs Application Checklist FAQ Unauthorized Interconnections Links to Applicable Regulations, Rules, Tariffs, and Guidelines Restricted Circuit Maps Community Net Metering Aggregated Net Metering Renewable News and Useful Links Frequently Asked Questions ALL FORMS CAN BE DOWNLOADED November 17,
29 NEM and Interconnections Customer Educational Materials Request brochures from pepcoholdings.com All PDFs can be printed from Pepco.com/gpc Delmarva.com/gpc AtlanticCityElectric.com/gpc November 17,
30 Restricted Circuit Maps Popular interactive tool Type in premise address Red interconnection not available Orange interconnection available for systems up to 50 kw Yellow interconnection available for systems up to 250 kw Interconnection may be accommodated with system upgrade at developer s or customer s expense November 17,
31 Sign Up for Face-to-Face Meetings Especially helpful if you: Have incomplete applications returned to you We ll review your actual returned applications and provide helpful hints Want to understand the application process better Best for your system size estimators and staff who complete interconnection applications One meeting per company Invite as many staff as you d like, including call-ins Meet at your business location in our service territory Or at any PHI business location Sign up today at our Informational Table Or NEMEducation@pepcoholdings.com November 17,
32 NEM and Interconnections Webcasts Rotate among utilities Two per week (excluding holiday weeks) Mondays at noon Thursdays at 3 p.m. Register at: pepco.com/nemeducation delmarva.com/nemeducation atlanticcityelectric.com/nemeducation November 17,
33 Green Power Connection Contacts Read additional FAQs on the NEM and Interconnections websites Sign up for a face-to-face meeting Attend our NEM and Interconnections webcasts Contact us gpc-south@pepco.com (202) gpc-north@pepcoholdings.com (866) November 17,
34 Interconnection Process Improvements SOLAR FOCUS 2015
35 Interconnection Process Improvements Total system interconnection requests have been growing in many states, but growth patterns differ Maryland: Exponential growth past 18 months, particularly in residential DC: Steady installation rate in both commercial and residential New Jersey: Moderate growth in residential, slow down in commercial Many utility and developer interconnection processes are a function of volume Given the rapid increase, how can developers and utilities ensure that the system doesn t get bogged down with the volume? What technology and process improvements can be made to increase throughput? Throwing more resources at an non-optimized process doesn t always help Think of both physical process and back-office process 2
36 Total MW DC Installed MD Installs (MW) Rapid Growth in Maryland Maryland is experiencing exponential growth in its solar deployment, particularly in the residential sector Summer 2012: 1.1 MW / month Summer 2015: 8.9 MW / month All data from PJM-GATS, retrieved 11/16/15 0 1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW > 2 MW 3
37 Ttoal Systems Installed MD Installs (Systems) 18,000 16,000 Rapid Growth in Maryland While the total MW installed is balanced between residential, commercial, and utility scale, the total number of systems is highly concentrated in the residential sector Summer 2012: 180 res / month Summer 2015: 1,020 res / month 14,000 12,000 10,000 8,000 6,000 4,000 2, /1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW > 2 MW 4
38 Total MW DC Installed DC Installs (MW) 9 8 Steady Growth in DC Consistent growth in both residential and commercial sectors, with growth continuing at a linear pace /1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW 5
39 Ttoal Systems Installed DC Installs (Systems) 1,800 1,600 Steady Growth in DC DC installs have not transitioned to exponential growth, but have remained steady for the past several years 1,400 1,200 1, Summer 2012: 33 res / month Summer 2015: 39 res / month /1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW 6
40 Total MW DC Installed NJ Installs (MW) NJ Scale from Commercial NJ total installed capacity is much larger than MD (1,400 MW vs 350 MW), but most of the installs are in the commercial and utility sector However, growth in the commercial sector has slowed substantially in past few years, and while the residential sector has grown, it has not reached the recent rate of MD installations /1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW > 2 MW 7
41 Ttoal Systems Installed NJ Installs (Systems) 35,000 30,000 NJ Scale from Commercial Commercial installs have slowed substantially from 2012, while residential grows at a steady pace 25,000 20,000 15,000 Summer 2011: 86 com / month Summer 2015: 11 com / month 10,000 Summer 2012: 464 res / month Summer 2015: 605 res / month 5, /1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 < 20 kw 20 kw - 2 MW > 2 MW 8
42 Systems Installed per Month MD vs. NJ Residential Installs MD vs. NJ MD s rate of installation has surpassed NJ s on an absolute basis, and currently sits at 250% of NJ on a per capita basis Nearly all the increase has come in the past 18 months /1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015 NJ Res MD Res 9
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