Goals for 2003 Kansas Interconnection Standards Development

1
Goals for 2003 Kansas Interconnection Standards
Development

• Larry Holloway
• Chief of Energy Operations
• Kansas Corporation Commission

2
History

• Legislation
• Staff Analysis
• Order
• Process

3
Legislation

• HB 2018 Section 32
• Passed by 2003 Legislature
• K.S.A. 66-101a and amendments thereto
• Defines Commission jurisdiction
• K.S.A. 66-104 and amendments thereto
• Definition of a jurisdictional public utility
• K.S.A. 66-1,184
• Parallel Generation Act

4
Section 32 HB 2018

• On or before September 1, 2003, the state
  corporation commission shall establish standard
  provisions, including applicable fees, for
  agreements providing for interconnection between
  the facilities of an electric public utility, as
  defined by K.S.A. 66-101a, and amendments
  thereto, and a generator which generates
  electricity from renewable resources or
  technologies, as defined by section 2, and
  amendments thereto.

5
K.S.A. 66-101a and amendments thereto

• K.S.A. 66-101
• Commission jurisdiction over electric public
  utilities as defined in 66-101a
  
• K.S.A. 66-101a
• "Electric public utility" means any public
  utility, as defined in K.S.A. 66-104, and
  amendments thereto, which generates or sells
  electricity.

6
K.S.A. 66-104 and amendments thereto

• An electric public utility is all companies that
  produce, transmit or deliver power except for
  private use.
  
• Exceptions
• Deregulated rural electric distribution
  cooperatives (safety, wholesale and transmission
  still regulated).
  
• Municipal electric utility operations more than 3
  miles outside the city limits.
  
• Independent generators built after January 1,
  2001 have the option of being a public utility.

7
K.S.A. 66- 66-1,184

• Parallel Generation Act
• every public utility which provides retail
  electric services in this state shall enter into
  a contract for parallel generation service with
  any person who is a customer of such utility,
  upon request of such customer,
• utility means an electric public utility, as
  defined by K.S.A. 66-101a, and amendments
  thereto, any cooperative, as defined by K.S.A.
  17-4603, and amendments thereto, or a nonstock
  member-owned electric cooperative corporation
  incorporated in this state, or a municipally
  owned or operated electric utility.

8
Staff Analysis

• Kansas Requirements
• Federal Requirements
• Models
• NARUC
• NRECA
• Suggested procedural process

9
Kansas Requirements

• KCC required to establish interconnection
  standards for each jurisdictional utility by
  September 1, 2003.
  
• Standards to include all generation not just
  renewable.
  
• KCC working with jurisdictional and non
  jurisdictional electric utilities to adopt
  statewide interconnection standards.
  
• Jurisdictional Kansas electric utilities serve
  70 of the customers but only 40 of the area.
  

10
Federal Requirements(Transmission
Interconnections)

• Order 2003 (FERC Docket No. RM02-01)
• Final order July 24, 2003.
• Generation exceeds 20 MW.
• Proposed Rules for Small Generators (FERC Docket
  No. RM02-12)
  
• Generation 20 MW or less
• Staff recommended FERC Rules for non-FERC
  jurisdictional utilities.
  
• FERC website www.ferc.gov

11
Models

• National Rural Electric Cooperative Association
  (NRECA)
  
• Distributed Generation toolkit.
• http//www.nreca.org/nreca/Policy/Regulatory/DGToo
  lKit/index.html
  
• National Association of Regulatory Utility
  Commissioners (NARUC)
  
• Distributed Generation Interconnection Model
• http//www.naruc.org/Programs/dgia/dgiaip.pdf

12
Process Recommended by Staff

• 3 Phases
• First phase will address and develop general
  standards.
  
• Requirements for applications, contracts, etc.
• Second phase, if necessary to address and
  implement detailed standards.
  
• Generic application form, process, contracts,
  schematics.
  
• Third phase to implement final standards.
• Note This is a fluid process subject to change.

13
Suggested Phase 1 and 2 Process

• Staff issues a list of recommendations and
  issues
  
• Commission issues a list of questions
• Participants respond to questions (November 17,
  2003)
  
• Staff prepares summary of responses and provides
  recommendations.
  
• Commission issues a list of issues for technical
  conference
  
• Participant provide written response
• Commission conducts technical conference
• Participants and staff submit final
  recommendations
  
• Commission issues order

14
Commission Orders KCC Docket No.
04-GIME-080-GIEActive Dockets at
www.kcc.state.ks.us

• July 23, 2003 Order
• Jurisdictional utilities required to file
  individual interconnection standards by September
  1, 2003.
  
• All interested parties to respond to list of
  recommendations and questions by September 30,
  2003.
  
• Order 2, August 28, 2003
• September 1 filing deadline extended to October
  1, 2003
  
• September 30 comment deadline extended to
  November 17, 2003
  

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Requirements for Initial Interconnection Standard
Filings

• Review process flow chart
• Standards application form
• Specified maximum generator size for expedited
  procedure
  
• Small generator interconnection technical
  requirements including specifications, standard
  contract and application fee
  
• Description of approval process, including
  technical requirements, standard contract and
  fees, for large generator interconnections
  
• Time required for both small and large generator
  interconnection applications

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Questions and Recommendations

• Expedited process for certain generators
• Size, type, fees, studies, equipment, metering?
• Time for review
• NARUC, NRECA, or other models
• Application process
• Standard application forms
• Standard contracts
• Verification testing
• Need for insurance, dispute process,
  pre-certification
  
• FERC standards
• Isolated generation

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Process

• Jurisdiction utilities
• Non-jurisdiction utilities
• Other interested parties
• Formal participation
• Intervention in the docket
• Legal representation likely required
• Contact Mike Peters at [phone]
• Informal participation
• Respond to certain issues
• Participate in technical conference

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Informal Participation

• Request Participation
• Explain viewpoint on specific issues
• Request participation in specific technical
  conference
  
• Send comments and requests to
• Susan Duffy, Executive Director KCC
• 1500 Arrowhead Road
• Topeka, KS 66604
• Refer to Docket No. 04-GIME-080-GIE
• Questions? contact Larry Holloway [phone]