Regulatory Focus: Establish Clear Rules for Interconnection Applications | Clean Power Hub

Regulatory Focus: Establish Clear Rules for Interconnection Applications

The application process for potential DER customers is important for ensuring a smooth interconnection process, from both the distribution utility and customer perspectives. The utility will wish to ensure that customers are aware of the regulatory requirements and procedures in order to decrease the processing burden of responding to too many questions, while the customer will want a clear understanding of the process. Solutions to address the application challenge have been developed, including providing a central information webpage with forms, checklists, contact information, and reference materials, as well as creating an online application process.

What You Need To Know

  • Interconnection application procedures and management processes can help ensure that customer expectations around fairness, transparency, communication, and efficiency are met.
  • An important component for providing transparency and promoting applicant self sufficiency is a website dedicated to providing relevant information for interconnecting DERs to the utility’s system.
  • An online application system has many benefits and may save money in power systems with a high rate of interconnection activity.

First, Read This

Interconnection application procedures for DERs are important to utilities, developers, and customers.

Rules governing interconnection application procedures and management offer guidance on the process for how developers and utilities must interact. These rules specify the various steps that each stakeholder must take in the overarching process of formulating, evaluating, and ultimately approving or rejecting applications to interconnect to the power system. Specific rules about the interconnection process may include aspects such as mandated time frames for utilities or developers to take various steps (e.g., screen an application, respond to an inquiry), standardized data requirements that developers must provide to utilities in an application, requirements of how much information utilities must provide developers about the process, standardized terms of interconnection agreements that are ultimately executed between the customer and utility, schedules of interconnection fees, and dispute resolution processes, among others.

Excerpt from page 37 of NREL: An Overview of Behind-the-Meter Solar-Plus-Storage Regulatory Design

Now, Read This

Though a manual process with hard-copy forms can be used, a centralized webpage is a good solution for fully automating application processing.

Central Information Webpage

An important component typically used to provide transparency and promote applicant self-sufficiency is a website dedicated to providing interested stakeholders with the relevant information for interconnecting DERs to the utility’s system. These sites should be easily navigable and include clear information about the interconnection process, application forms, and reference materials. The following are key elements typically found on these websites:

  • Application forms—Utilities may have a variety of application forms depending on project characteristics, screening processes, etc. The website can act as a guide to direct users to the appropriate forms. The page should be updated periodically to ensure out-of-date forms are no longer available. Online application systems may act as the application forms directly, in which case access to these portals should be clearly provided.
  • Application checklist—This is a customer-facing document that delineates each step in the application process while noting the timeline for major milestones, requirements, and associated fees. This document can outline the entire process from initial steps, such as requesting a pre-application report, to construction of upgrades and meter installations at the tail end of the process. A clear description of required fees (i.e., application, study, and upgrade fees) should also be included.
  • Contact information—Providing a single point of contact for all interconnection-related questions helps limit confusion about who fields what questions. The contact information may include an email address, phone number, or live-chat option. On the utility end, it is helpful to identify a single point of contact or dedicated team to answer all interconnection-related questions.
  • Reference materials—Resources such as example application documents (e.g., one-line drawings) or instructional videos will aid in educating customers and reducing the number of questions utility staff must respond to. This may also include links to a frequently asked questions (FAQs) page, incentive program information, interconnection rules, or a list of local developers. Some utilities host trainings and webinars for developers and customers to explain the process or recent changes to regulations and procedures.
  • Dispute-resolution processes—These processes provide a clear pathway for resolving disputes in a timely manner. This may include negotiations or mediations, involving a utility or public utility commission (PUC) ombudsperson, third-party technical expert (IREC 2017, Bird et al. 2018), or both. Transparency of interconnection processes, requirements, and fees can reduce the need for dispute-resolution mechanisms.

Excerpt from pages 5 and 6 of NREL: An Overview of Distributed Energy Resource Interconnection

Next, Read This

Some best practice processes have been identified for helping to ensure smooth interconnection processes.

Below, we discuss additional process improvements that can be implemented by individual utilities or through state regulatory requirements.

  • Pre-application reports—These reports use readily available information to provide detailed technical information about a point of interconnection. The information provided by the utility allows prospective applicants to identify potential interconnection limitations early in the process at a relatively low cost. Doing so may help utilities reduce the number of speculative applications received, thus reducing the total volume of applications to be processed.
  • Application clarity—Reviewing application forms to improve their clarity may reduce resources spent responding to customer questions.
  • Workflow efficiency—Evaluating the application documents may expose opportunities to simplify the forms and workflows to remove unnecessary steps and redundant data requests. Developing an internal application review checklist can aid in improving coordination and accountability by detailing the actions and personnel needed to complete each step of the application process.
  • Signatures and payment—Online payment options in addition to, or as an alternative to, cash or check payment can reduce the time needed to complete the transaction and the risk that payment is lost in transit. Similarly, removing requirements for wet signatures and allowing electronic signatures can reduce the time it takes to process an application.
  • Communication—Utilities and customers interact multiple times throughout the interconnection process. Internal application review checklists for utility use and external checklists for developers can help streamline communications with customers by creating a clear directive for what information is shared, how it is shared, and when. Such checklists may also specify internal communications processes, for instance, designating a point of contact to coordinate communications between the different parties in the utility and the customer. Many utilities designate a single point of contact or team to handle interconnection-related requests and questions.
  • Application tracking—A common customer expectation is a clear method for tracking the application status once the application has been submitted. Some utilities instruct applicants to do so by reaching out directly via phone, email, or in-person.... Another method is for the utility to post a public queue containing application status information that is periodically updated.... Online application systems typically provide a more versatile solution, allowing applicants to check the application’s real-time status at their convenience through the web portal.
  • Automation and integration—Automation helps minimize the number of steps that must be manually completed, thus reducing the time utility staff must spend on processing applications.... Integrating interconnection application data with mapping or analysis tools also provides opportunities to improve efficiency and reduce labor.

Online application systems are a significant improvement over legacy application-management methods for utilities with increasing or high volumes of interconnection applications. These systems provide customers, installers, and other stakeholders such as local permitting authorities with a central location to interact with applications. The portals provide an interface that can guide users through the application process step-by-step, prompting for information as needed.
They are typically used to coordinate communications among the stakeholder groups and can send internal and external automated status reports and workflow reminders. Further, online systems can be used to coordinate electronic payment, manage forms, and transfer data to internal databases.

Through these services, online application systems can facilitate all of the improvements discussed above. Online systems automate much of the process, reducing the time customers and utility staff need to complete each application. Automation can help with flagging incomplete information and providing status updates or workflow reminders....

The benefits of implementing an online system may not outweigh the cost in all cases, particularly in areas with low interconnection activity. These systems are a significant undertaking in terms of time and resources. Utilities must also consider how they are implemented. Some utilities have developed online application systems in-house, while others have purchased off-the-shelf products. Major benefits of off-the-shelf products include the speed of deployment and flexibility.

Excerpts from page 6 - 8 of NREL: An Overview of Distributed Energy Resource Interconnection

Finally, See This

The Electric Power Research Institute (EPRI) studied some utilities and their interconnection processes for DER to determine opportunities for streamlining the interconnection process. These opportunities are ranked from easy (“low hanging fruit”) to more difficult (“stretch goals”).

Suggested Actions & Next Steps

  • Research DER interconnection processes in your power system. Have you heard of any difficulties of processing DER applications? Have you heard from customers or developers about difficulties in properly submitting applications?
  • Contact these groups to get their views on where the process might be improved, using the suggestions above as examples.
Want to know what others have done to establish or improve DER interconnection processes?Ask your questions and share your experiences in the Clean Power Hub Community

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