WEBVTT 00:00:11.800 --> 00:00:14.189 (inaudible) 00:00:18.579 --> 00:00:18.760 (inaudible) 00:00:22.138 --> 00:00:26.280 (item:1:54233, Welcome - David Smeltzer, Director of Rules & Projects) Hear ye, hear ye. Thus openeth the Staff Workshop in 00:00:26.289 --> 00:00:31.379 Project 54233, Interconnectional Requirements for Distributed 00:00:31.519 --> 00:00:36.219 Energy Resources. We have some topics that are posted 00:00:36.228 --> 00:00:39.478 uh for discussion. And I think that we uh I think if 00:00:39.490 --> 00:00:41.598 we're going to try and keep this pretty loose. As long 00:00:41.609 --> 00:00:46.090 as we're all being sort of civil and taking our turns. 00:00:46.200 --> 00:00:49.118 We think this discussion will be better if there's 00:00:49.130 --> 00:00:51.399 some back and forth opportunity. To ask questions or 00:00:51.408 --> 00:00:53.950 even ask each other questions. So that we can make sure 00:00:53.959 --> 00:00:56.569 we're, you know, running down all the rabbit trails. 00:00:56.579 --> 00:01:00.829 And so I think uh (item:2:54233, David Smeltzer - Director of Rules & Projects) my name is David Smeltzer. Hi, I'm the 00:01:00.840 --> 00:01:03.020 Director of Rules and Projects. Uh a couple of 00:01:03.029 --> 00:01:05.448 other Members of Staff up here. They may be asking 00:01:05.459 --> 00:01:08.620 questions. (item:2:54233, Mariah Benson - Market Analysis) Mariah Benson, Market Analysis. 00:01:10.150 --> 00:01:14.719 Yeah, (item:2:54233, John Poole & Sherryhan Ghanem - Engineering) I'm John Poole, Engineering. Sherryhan Ghanem, Engineering. 00:01:16.209 --> 00:01:19.379 Very good. And so um sort of the, (item:3:54233, Order of Business - David Smeltzer) the order of business. 00:01:19.388 --> 00:01:22.760 We'll open up one of the discussion uh topics. And then 00:01:22.769 --> 00:01:26.058 anyone that has an opinion or wants to ask questions. 00:01:26.069 --> 00:01:27.819 Go ahead and just come down to the front. Take one 00:01:27.829 --> 00:01:33.049 of the seats. Um, uh I'll sort of gesture in your direction 00:01:33.058 --> 00:01:34.510 when it's, when it's your turn to go. And if you will 00:01:34.519 --> 00:01:37.540 say your, your name and who you represent. Um, just 00:01:37.549 --> 00:01:40.250 for our record keeping purposes. Um, so we can reach 00:01:40.260 --> 00:01:42.308 back out with questions if we need to. And then at 00:01:42.319 --> 00:01:44.969 the end of anyone that has sort of, I guess opening 00:01:44.980 --> 00:01:48.219 comments on a question, that they would like to address. 00:01:48.230 --> 00:01:51.569 Uh Staff may ask questions in real time or you know 00:01:51.579 --> 00:01:54.040 at the end after everyone's spoken. If anyone has questions 00:01:54.049 --> 00:01:57.028 that they want to ask other people. Um I'll just do 00:01:57.040 --> 00:01:59.948 my best to acknowledge, as people raise their hands 00:01:59.959 --> 00:02:03.588 or wave uh in real time. Um so that we can just 00:02:03.599 --> 00:02:06.028 make it pretty functional. I mean, the last thing is 00:02:06.040 --> 00:02:09.500 uh we have some Staff proposals that are listed here. 00:02:09.508 --> 00:02:11.308 And I think that we have a request from Infrastructure. 00:02:11.319 --> 00:02:15.270 That if you have other proposals try and give us uh 00:02:15.278 --> 00:02:18.479 flush out. Why yours are good and why ours are bad? 00:02:18.490 --> 00:02:21.419 And so, to the extent that we can get a full consideration 00:02:21.429 --> 00:02:23.379 of the different thresholds and stuff. That would be 00:02:23.520 --> 00:02:26.139 helpful to us. And then if we still have time, we will 00:02:26.149 --> 00:02:29.110 uh under the third topic. If there are additional topics 00:02:29.118 --> 00:02:31.368 that you guys want to pose for discussion. For future 00:02:31.379 --> 00:02:35.770 workshops or whatever, we will um sort of record those. 00:02:36.129 --> 00:02:38.860 Uh and we can have discussion on that if it makes sense. 00:02:39.058 --> 00:02:41.360 So, uh I think that's right. 00:02:43.080 --> 00:02:46.149 So does anyone, so we. Our first, uh Mariah do you want 00:02:46.159 --> 00:02:50.409 to introduce the first topic? Sure. Um, (item:4:54233, Mariah Benson gives overview of Proposal One) the First Proposal 00:02:50.419 --> 00:02:53.550 Staff put forward is for the Interconnection Standards. 00:02:53.558 --> 00:02:59.050 What is currently 25.211. Uh we are proposing splitting 00:02:59.058 --> 00:03:02.179 the standards into 2 different rules. The first rule 00:03:02.189 --> 00:03:06.288 would be 25.211 existing. And it would continue to 00:03:06.300 --> 00:03:10.080 apply for small DERs and we're proposing small be 00:03:10.088 --> 00:03:12.990 anything under 50 kilowatts. The second we'd propose 00:03:13.000 --> 00:03:16.469 is a new rule to apply for Big DERs. Which 00:03:16.479 --> 00:03:20.460 would be anything over 50 kilowatts. Um and we're looking 00:03:20.469 --> 00:03:24.118 for comments on again the 50 kilowatt threshold. And 00:03:24.129 --> 00:03:26.028 if it should be two rules? One rule? What were the 00:03:26.038 --> 00:03:28.149 rules should be taken up on? Anything related to the 00:03:28.159 --> 00:03:30.520 proposal is what we're seeking comments on. 00:03:38.778 --> 00:03:41.729 We are gonna have a very short uh consensus reached 00:03:41.740 --> 00:03:42.349 on this. 00:03:44.058 --> 00:03:44.319 (inaudible) 00:03:45.889 --> 00:03:48.838 Yeah. And so just to clarify, anybody who has an alternative 00:03:48.849 --> 00:03:51.960 proposal, supports the proposal. Thinks it's a horrible 00:03:51.969 --> 00:03:56.338 proposal. Now is the time to come up and air your thoughts. 00:04:01.349 --> 00:04:05.069 (item:4.1:54233, Eric Goff with Texas Solar Power Association) Eric Goff on behalf of the Texas Solar Power 00:04:05.080 --> 00:04:10.569 Association. Um we support uh bifurcating the rule. 00:04:10.580 --> 00:04:14.159 Um we suggested a higher threshold than 50 kW in our 00:04:14.169 --> 00:04:18.949 comments, but aren't opposed to 50 kW. We, we think 00:04:19.579 --> 00:04:23.970 it should be um considered to be higher though. Because 00:04:24.600 --> 00:04:29.410 the, the issues at hand um, don't really arise if you 00:04:29.420 --> 00:04:34.259 get a larger threshold. So, while 50 kW isn't objectionable. 00:04:34.269 --> 00:04:36.889 We, we think that uh you know you could, you could 00:04:36.899 --> 00:04:41.889 go higher than that. Um, and then we also suggested 00:04:42.399 --> 00:04:46.829 specifics for um what that uh proposal would be. 00:04:46.838 --> 00:04:52.019 So to try, to uh reduce burdens as much as possible 00:04:52.028 --> 00:04:55.319 on the homeowner or the DER installer that's been trying 00:04:55.329 --> 00:04:58.209 to install that. We got in specifics in our comments 00:04:58.220 --> 00:05:00.399 there. I don't know that we need to do that right now. 00:05:00.559 --> 00:05:05.238 Um but if you want me to, we can. (item:4.1:54233, Eric Goff's follow-up on wattage question from Mariah Benson) Just to clarify, 00:05:05.250 --> 00:05:07.879 what would you recommend it be, if not 50 kilowatts? 00:05:07.939 --> 00:05:12.519 I think we said, um a megawatt in our comments. Um 00:05:12.858 --> 00:05:16.160 but um you know the, the higher, the better. I think 00:05:16.170 --> 00:05:21.298 it's appropriate. Um there are some things that, you 00:05:21.309 --> 00:05:24.488 know. It's, it's not black and white, it's a gradient. 00:05:25.509 --> 00:05:28.790 But to the extent that there are, it's a simple process 00:05:28.798 --> 00:05:32.040 for option A. The higher you feel comfortable going 00:05:32.048 --> 00:05:34.660 the better. Because you'll be able to have a lot more 00:05:34.670 --> 00:05:38.189 customers and the installers to follow a simpler process. 00:05:42.309 --> 00:05:43.199 Good afternoon. 00:05:44.730 --> 00:05:48.449 Good afternoon. I don't think that was on, was it? 00:05:49.088 --> 00:05:52.059 I think it was, but you can switch. All right. (item:4.1:54233, Martha Henson with Oncor) Good afternoon, Martha 00:05:52.069 --> 00:05:54.278 Henson with Oncor. I'm actually gonna agree with Eric, 00:05:54.290 --> 00:05:56.059 maybe for once. Um 00:05:58.619 --> 00:06:02.660 so in our comments that we filed in Project 54233 back 00:06:02.670 --> 00:06:06.298 in January. Oncor had also suggested two different 00:06:06.309 --> 00:06:09.660 rules for DERs. Although our cut point was based on 00:06:09.670 --> 00:06:13.988 DER behavior. Um so we do like the Staff proposal 00:06:14.000 --> 00:06:17.238 of having two separate rules. And although we know 00:06:17.250 --> 00:06:20.298 that Staff here is asking for a cut point based on 00:06:20.309 --> 00:06:23.278 size, not behavior. We're also very supportive of that. 00:06:23.730 --> 00:06:27.160 So Oncor's recommendation though is actually also a 00:06:27.170 --> 00:06:30.809 1 megawatt division point. So we think 1 megawatt 00:06:30.819 --> 00:06:34.079 makes more sense. To be the dividing point between the 00:06:34.088 --> 00:06:37.278 two rules. Such that the 1 megawatt and smaller 00:06:37.309 --> 00:06:42.059 DERs would go into the existing 211. Which we know 00:06:42.069 --> 00:06:45.619 needs to be updated. And then the greater than 1 00:06:45.629 --> 00:06:48.838 megawatt DERs, would belong in the new substantive 00:06:48.850 --> 00:06:52.858 rule. That perhaps the discussion draft in 54233, could 00:06:52.869 --> 00:06:56.528 serve as a starting point for. One thing that would 00:06:56.540 --> 00:07:00.119 be important though, in the rule for the smaller ones. 00:07:00.278 --> 00:07:04.369 We think that, that rule should allow for the interconnecting 00:07:04.379 --> 00:07:07.678 utility. To be able to separately address DERs, that 00:07:07.689 --> 00:07:12.088 pose some sort of unique complexity. That might necessitate 00:07:12.233 --> 00:07:15.814 a more detailed rule than, a more detailed review than 00:07:15.824 --> 00:07:18.944 that rule provision. Would, would most likely provide 00:07:18.954 --> 00:07:22.384 for the vast majority of 1 megawatt or smaller 00:07:22.394 --> 00:07:26.004 DERs. So that's just one additional suggestion for 00:07:26.014 --> 00:07:28.444 the, I guess Interconnection Standard, B. 00:07:31.798 --> 00:07:32.410 Thank you. 00:07:39.459 --> 00:07:44.730 So do our recent additions, do you guys have uh separate 00:07:44.738 --> 00:07:48.449 comments or responsive comments? Had a question and 00:07:48.459 --> 00:07:50.009 then a responsive comment, so. 00:07:51.809 --> 00:07:54.809 And I have, uh a responsive comment to the initial 00:07:54.819 --> 00:07:57.230 question. And maybe responding back to the others, as 00:07:57.250 --> 00:07:59.559 well. Okay. Yeah. So if you have to the initial question. 00:07:59.569 --> 00:08:02.269 Why don't you go take a shot at it? Okay. Uh (item:4.2:54233, Stephanie Kroger with Hunt Energy Network) Stephanie 00:08:02.278 --> 00:08:06.019 Kroger with Hunt Energy Network. Um I think also like 00:08:06.028 --> 00:08:09.608 the others, we support bifurcating the rule. Um and 00:08:09.619 --> 00:08:11.869 I think we suggested that in the comments that we filed 00:08:11.879 --> 00:08:15.569 originally too. We are, I don't know that we have a 00:08:15.579 --> 00:08:20.178 strong preference for whether it's uh 50 kW or 1 00:08:20.189 --> 00:08:23.920 megawatt. I do see, you know, some simplicity in having 00:08:23.928 --> 00:08:27.709 the same cut point in both rules. Uh but the other 00:08:27.720 --> 00:08:32.058 issue that I think needs to be addressed is. Um where 00:08:32.070 --> 00:08:35.369 the, the facility is located and whether it's front 00:08:35.379 --> 00:08:39.619 of the meter, stand alone, participating as DGR or 00:08:39.629 --> 00:08:43.558 ADESR or whether it's behind the meter. Um and 00:08:43.830 --> 00:08:46.899 part of that I mean. The language that is currently 00:08:46.908 --> 00:08:51.308 in the draft rule. Suggests that it only applies behind 00:08:51.320 --> 00:08:54.609 the meter. So I think we just need to be intentional 00:08:54.619 --> 00:08:57.529 about. Are we trying to apply this to both or are we 00:08:57.538 --> 00:09:01.450 trying to be specific? About not just a size but also 00:09:01.678 --> 00:09:04.379 you know, is it a stand alone resource? I think it 00:09:04.389 --> 00:09:06.950 clearly works for standalone resources. 00:09:08.820 --> 00:09:11.940 The behind the meter creates perhaps another level 00:09:11.950 --> 00:09:16.340 of, of um challenges. With the interconnection or issues 00:09:16.349 --> 00:09:18.190 not challenges but different issues. 00:09:22.769 --> 00:09:25.210 I, I don't know if others in the audience have questions 00:09:25.219 --> 00:09:29.750 about that. I know that something on Staff side. We 00:09:29.759 --> 00:09:32.619 have struggled with. Because at least we've heard about 00:09:32.798 --> 00:09:34.668 uh front of the meter and behind the meter, that are 00:09:34.678 --> 00:09:36.769 relatively the same size. But then when we talk about 00:09:36.779 --> 00:09:38.830 treating them differently, and to a certain extent what 00:09:38.840 --> 00:09:41.158 that really means. Could you just flush out a little 00:09:41.168 --> 00:09:44.119 bit? Like front of the meter, behind the meter? Why we 00:09:44.129 --> 00:09:47.678 need two different standards for them? (item:4.2:54233, Stephanie Kroger's follow-up on front/behind the meter question from Mariah Benson) What, and it 00:09:47.690 --> 00:09:50.469 may not be, that there has to be two. But, but the 00:09:50.479 --> 00:09:53.469 rule needs to be clear. If it's applying to both or 00:09:53.479 --> 00:09:57.500 if it's applying just to one. So, so front of the meter, 00:09:57.509 --> 00:10:02.288 DGR/DESR are standalone resources. They go 00:10:02.298 --> 00:10:05.320 through the ERCOT Commissioning Process. They're providing 00:10:05.330 --> 00:10:08.639 energy ancillary services into the market. Um and, 00:10:08.649 --> 00:10:11.759 and in our mind, the really the only difference between 00:10:11.769 --> 00:10:15.250 those resources and transmission level resources is 00:10:15.259 --> 00:10:18.149 the voltage. They're going through what's effectively 00:10:18.158 --> 00:10:23.849 a very similar process and qualification. Um with behind 00:10:23.859 --> 00:10:27.129 the meter, I think you just have a greater variation 00:10:27.139 --> 00:10:31.119 of um of types of resources, you know. You may have 00:10:31.129 --> 00:10:35.538 resources that are SODGs for example. Um or, 00:10:35.548 --> 00:10:39.090 or are interconnecting but not really injecting. Um 00:10:39.908 --> 00:10:42.700 and it may be that the same interconnection process 00:10:42.710 --> 00:10:47.219 can work for that. Uh but it just needs to be recognized 00:10:47.229 --> 00:10:50.719 that they are um different types of resources. And, 00:10:50.729 --> 00:10:56.808 and um many of those tend towards, tend towards the 00:10:56.820 --> 00:11:01.889 smaller, smaller resources as well. I guess from, from 00:11:02.070 --> 00:11:06.479 HEN's perspective. What we want to make sure is that 00:11:06.489 --> 00:11:10.048 we have a very clear, non discriminatory standardized 00:11:10.058 --> 00:11:13.750 process. For those resources that are going through 00:11:13.759 --> 00:11:16.000 the ERCOT process, and trying to participate in the 00:11:16.009 --> 00:11:16.529 market. 00:11:20.259 --> 00:11:25.989 (item:4.2:54233, Ramya Ramaswamy with Commission Staff asks clarifying question to Stephanie Kroger) Um Ramya Ramaswamy for Staff. Um so um, just to clarify. So you're 00:11:26.000 --> 00:11:30.558 saying this is whether it's 1 megawatt, 50 kilowatts 00:11:30.570 --> 00:11:33.500 it doesn't matter. You just want it to be very clear 00:11:33.509 --> 00:11:36.279 on whether it's front of the meter or behind the meter? 00:11:36.288 --> 00:11:40.548 I'm just trying to. (item:4.2:54233, Stephanie Kroger's follow-up comments) Yes, I don't think we have a strong 00:11:40.558 --> 00:11:45.149 opinion on the 50 kW versus 1 megawatt. Although 00:11:45.158 --> 00:11:47.869 again, I think there is some simplicity in using the 00:11:47.879 --> 00:11:50.908 same for both. Um but I, I don't know that we have 00:11:50.918 --> 00:11:53.479 a strong opinion on that. But we do want to be clear. 00:11:53.489 --> 00:11:55.769 When it's front of the meter and when it's behind the meter. 00:11:58.428 --> 00:12:01.200 So on this just so that while, while we're on that 00:12:01.210 --> 00:12:03.178 topic. Is there anyone else, that wants to talk about 00:12:03.710 --> 00:12:07.700 on the meter, front of the meter, behind the meter issues 00:12:07.710 --> 00:12:09.798 in response to what Stephanie was just discussing? 00:12:09.808 --> 00:12:10.899 If so, if so come on forward. 00:12:12.479 --> 00:12:14.000 Is that what? Sir, is that what you came up to talk 00:12:14.009 --> 00:12:15.408 about or no? No. Okay. 00:12:18.908 --> 00:12:23.038 (item:4.2:54233, Mickey Moon with CenterPoint) Yeah, Mickey Moon with CenterPoint. Um I agree with Stephanie. 00:12:23.048 --> 00:12:26.840 From a TDU perspective. Uh one of the differences between 00:12:26.849 --> 00:12:29.558 a behind a meter and in front of the meter. Is in 00:12:29.570 --> 00:12:33.009 behind the meter situation, uh the generator will be 00:12:33.019 --> 00:12:35.408 able to piggyback on the facilities. That we install 00:12:35.418 --> 00:12:40.190 for the Load, the Load metered customer. Whereas a standalone 00:12:40.379 --> 00:12:42.940 generator, in front of the meter generator. There's 00:12:42.950 --> 00:12:46.739 no Load customer facilities to be piggyback on. So 00:12:46.750 --> 00:12:49.769 the facility, the way you interconnect will be different 00:12:49.779 --> 00:12:53.808 as a TDU with those type of facilities. And I know 00:12:53.820 --> 00:12:57.629 cost is not uh subject in this rulemaking. But you're 00:12:57.639 --> 00:13:00.769 going to have different cost issues. Between the behind 00:13:00.779 --> 00:13:04.229 the meter generator and the front of the meter generator. 00:13:07.469 --> 00:13:07.960 (cough) 00:13:11.960 --> 00:13:14.308 Are you joining us for this topic? Yes. Before you 00:13:14.320 --> 00:13:17.019 moved on Craig Bennett. Hopefully, you can hear me without 00:13:17.029 --> 00:13:19.038 the microphone. But I'll try to make sure I bring it 00:13:19.058 --> 00:13:21.950 in. Just for the broadcast. Yeah, absolutely. Um (item:4.2:54233, Craig Bennett with CPS Energy comments on both subjects under Proposal One) Craig 00:13:21.960 --> 00:13:24.639 Bennett, I'm representing CPS Energy for purposes 00:13:24.649 --> 00:13:27.859 of this workshop today. Um we wanted to first off say 00:13:27.869 --> 00:13:32.308 that we support, um Oncor's position. About if we're going 00:13:32.320 --> 00:13:35.479 to have that break in terms of the standards. That it's 00:13:35.489 --> 00:13:38.259 more appropriate to have it closer to 1 megawatt 00:13:38.269 --> 00:13:40.759 or have use that as the standard. But we also think 00:13:40.769 --> 00:13:43.690 it's important to as Oncor mentioned. Talk about the 00:13:43.700 --> 00:13:46.399 function, that the function is more important than the 00:13:46.408 --> 00:13:49.639 size. And so in general, we support Oncor's comments 00:13:49.649 --> 00:13:53.969 on, on both of those matters. Um also, you know, in 00:13:53.979 --> 00:13:56.798 terms of when we talk about in front of the meter or 00:13:56.808 --> 00:13:59.678 behind the meter. It gets kind of tricky. And this 00:13:59.690 --> 00:14:02.700 is going to be a topic you'll hear from us frequently 00:14:02.710 --> 00:14:06.690 today, as an MOU. Is that once you start getting behind 00:14:06.700 --> 00:14:09.969 the meter with an MOU and front of the meter. You know 00:14:10.389 --> 00:14:13.469 the authority that the Commission has. Gets very interesting 00:14:13.479 --> 00:14:16.369 and different than it does with IOUs. And so that's 00:14:16.379 --> 00:14:19.183 something you to be cognizant of. And so, when you start 00:14:19.195 --> 00:14:21.514 talking about a distinction of front of the meter, behind 00:14:21.524 --> 00:14:23.825 the meter. That's going to be something, as with a lot 00:14:23.835 --> 00:14:25.695 of things today. You're going to have to keep in mind 00:14:25.705 --> 00:14:28.793 the different jurisdiction that the Commission has 00:14:28.803 --> 00:14:31.695 over an MOU. Than it does over other sorts of utilities. 00:14:34.979 --> 00:14:38.259 Very good. Other people on the big or behind the front 00:14:38.269 --> 00:14:41.849 of meter topic. Okay. Christine, I think you're next. I just 00:14:41.859 --> 00:14:44.769 had a question about the um. So we're also supportive 00:14:44.779 --> 00:14:47.440 of the concept of having a bifurcated role of resources 00:14:47.450 --> 00:14:51.178 above and below a certain um size, are treated somewhat 00:14:51.190 --> 00:14:54.229 differently. On the 50 kilowatt break point, our question 00:14:54.239 --> 00:14:56.239 was just that. Were you trying to pick that, because 00:14:56.250 --> 00:14:58.460 you thought it tracked more with where the break point 00:14:58.469 --> 00:15:00.619 is for a small commercial customer under your other 00:15:00.629 --> 00:15:04.109 rules? Not really, it just seemed like a common number 00:15:04.119 --> 00:15:06.500 coalesced around in comments filed. And we wanted to 00:15:06.509 --> 00:15:09.590 break it from 1 megawatt in the operational requirements. 00:15:09.599 --> 00:15:12.349 Just to create conversation and see if they should 00:15:12.359 --> 00:15:14.629 be broken. Or if again, for simplicity reasons they 00:15:14.639 --> 00:15:17.178 should be 1 megawatt. It was just to throw out something 00:15:17.190 --> 00:15:20.099 different. And then, we tend to probably agree with um Oncor's 00:15:20.109 --> 00:15:22.038 point of view, as well. As I think they're expressed 00:15:22.048 --> 00:15:25.239 maybe a one Megawatt, might make sense for these purposes. 00:15:25.250 --> 00:15:26.928 That tends to track well with what you're doing in 00:15:26.940 --> 00:15:30.048 your ADR pilot project. Where the individual DERs 00:15:30.058 --> 00:15:33.330 within an ADR. Are kind of sized underneath that 1 00:15:33.340 --> 00:15:34.649 megawatt threshold, so. 00:15:36.379 --> 00:15:39.739 All right. So let's do a, a quick classroom activity 00:15:39.750 --> 00:15:43.918 here. We've got, we've got the idea that uh the, the 00:15:43.928 --> 00:15:45.869 rule should be bifurcated. And so far, everyone that's 00:15:45.879 --> 00:15:48.460 come up has agreed with that premise. So, by show of 00:15:48.469 --> 00:15:51.070 hands in the audience. If you've not spoken on that 00:15:51.080 --> 00:15:54.099 topic, is it because A: you agree with the idea it 00:15:54.109 --> 00:15:57.288 should be bifurcated? Or B: you either don't care or don't want 00:15:57.298 --> 00:16:00.918 to talk? So A: who thinks it is bifurcating, is ever. 00:16:00.940 --> 00:16:02.769 For people on board with bifurcating the rule? 00:16:04.580 --> 00:16:06.558 Is there anybody who thinks it's a bad. I, I didn't 00:16:06.570 --> 00:16:08.820 offer that at the beginning. Or is there anyone 00:16:08.830 --> 00:16:12.750 who just doesn't care? Is there anyone in opposition? 00:16:14.369 --> 00:16:17.229 All right. That's good. And then so far we, when we 00:16:17.239 --> 00:16:20.548 talk about with regard to the 50 kW. For those that 00:16:20.558 --> 00:16:22.658 are silent, I think. So, everyone that we've heard from 00:16:22.668 --> 00:16:25.320 has said it 50, 50 is as low as you should go. 00:16:25.330 --> 00:16:28.820 But would prefer to go higher. Uh is that like 00:16:28.830 --> 00:16:31.288 so. If you agree with the 50 is as low as we 00:16:31.298 --> 00:16:34.798 should go, but you would prefer to go higher. Is that 00:16:34.808 --> 00:16:37.658 a general opinion held by anyone by show of hands? 00:16:39.369 --> 00:16:41.739 And if you, if you disagree with the take that 00:16:41.750 --> 00:16:46.048 it should be or higher, anybody in opposition. All 00:16:46.058 --> 00:16:47.729 right, perfect. You're already here, tell us about 00:16:47.739 --> 00:16:51.779 it. Yes. So it's (item:4.3:54233, David Vignes with AEP) David Vignes with AEP. And we 00:16:51.788 --> 00:16:54.330 are in support of having 2 rules, and we think that 00:16:54.340 --> 00:16:56.969 is appropriate. The reason we want to lower limit 00:16:56.979 --> 00:16:59.129 is we do not want to lose the ability to be able 00:16:59.139 --> 00:17:03.580 to study uh, projects. A 50 kilowatt system or a 500 00:17:03.590 --> 00:17:06.318 or a megawatt system is going to be different. Depending 00:17:06.328 --> 00:17:09.239 on where it's located on the circuit. And so if there 00:17:09.250 --> 00:17:11.900 is a, a 1 megawatt system at the end of a rural 00:17:11.910 --> 00:17:14.689 circuit. Is a lot different impact than a 100, than a 1 00:17:14.699 --> 00:17:18.318 megawatt system at the substation. And so that is really 00:17:18.328 --> 00:17:20.430 our distinction. That we would like the lower limit 00:17:20.439 --> 00:17:23.559 to be able to, to continue to do those studies as needed, 00:17:23.568 --> 00:17:25.189 depending on the circuit conditions. 00:17:28.180 --> 00:17:29.509 What limit would you recommend? 00:17:31.699 --> 00:17:35.029 You know, I would say around 100 to 150 is generally 00:17:35.039 --> 00:17:37.880 the largest residential that we've seen. Um but I think 00:17:37.890 --> 00:17:39.150 that would be an appropriate limit. 00:17:43.769 --> 00:17:46.299 So even our opposition is for a higher limit than 50 00:17:46.309 --> 00:17:48.189 or at least consensing around that point. Eric, what you 00:17:48.219 --> 00:17:51.618 got. (item:4.3:54233, Eric Goff's follow-up to lower wattage discussion) Um I understand the point that you're making on 00:17:51.630 --> 00:17:56.640 that issue. Um I, I would just want to reiterate Oncor's 00:17:56.650 --> 00:17:59.229 suggestion earlier. That they would want to have the 00:17:59.239 --> 00:18:02.719 right to study, if they needed to for some reason. And 00:18:03.209 --> 00:18:05.910 the details of that could be complex. But that might 00:18:05.920 --> 00:18:07.500 be a way to thread the needle, that we're talking about 00:18:07.509 --> 00:18:07.779 here. 00:18:12.348 --> 00:18:16.009 And I guess to that point because it could be complex. 00:18:16.259 --> 00:18:18.170 Would it be better just to keep it lower? So you guys 00:18:18.180 --> 00:18:19.509 have the optionality. 00:18:21.219 --> 00:18:24.259 If, if we can't add that complex language in and we 00:18:24.269 --> 00:18:27.130 go with 1 megawatt. Or is 1 megawatt still better? 00:18:29.598 --> 00:18:32.479 I think, we would prefer the lower limit um close to 00:18:32.509 --> 00:18:34.729 100. But, you know, obviously what y'all decide is. 00:18:40.969 --> 00:18:43.250 (item:4.3:54233, Pete Parsons with Texas Solar Energy Society) My name is Pete Parsons and I'm with the Texas Solar 00:18:43.259 --> 00:18:47.588 Energy Society. Uh my only concern about, you know 00:18:47.598 --> 00:18:51.439 250. Is I'm not sure that's going to take into account 00:18:51.449 --> 00:18:56.670 commercial applications, we had recommended 500. Um 00:18:56.868 --> 00:18:58.979 but I don't think we have a problem with going with 00:18:58.989 --> 00:18:59.519 1 meg. 00:19:04.559 --> 00:19:07.289 Any other questions or views on this little cluster 00:19:07.299 --> 00:19:09.750 of topics that we're on? Oh. 00:19:12.118 --> 00:19:15.479 Hello, can you hear me? Yes, sir. Uh (item:4.3:54233, Clayton Stice with ERCOT) Clayton Stice with ERCOT. 00:19:16.489 --> 00:19:20.459 Uh ERCOT really has no opinion, on in terms of where 00:19:20.469 --> 00:19:24.858 the standard is set. Um however, if you are contemplating 00:19:24.868 --> 00:19:30.239 raising it up significantly above 250 kilowatts. We 00:19:30.250 --> 00:19:36.059 would have note. That there are a number of systems 00:19:36.068 --> 00:19:39.259 uh less than 500 kilowatts, that have chosen to register 00:19:39.269 --> 00:19:43.039 with ERCOT. So I, I think that when you start talking 00:19:43.049 --> 00:19:46.630 about a significantly larger threshold. We would and 00:19:46.640 --> 00:19:49.640 registration with ERCOT, it's going to impact your 00:19:49.650 --> 00:19:52.529 timelines. Maybe some cost study parameters, things 00:19:52.539 --> 00:19:56.640 like that. So we would just like to note that. Systems 00:19:56.650 --> 00:19:59.160 that choose to register with ERCOT under a megawatt. 00:19:59.170 --> 00:20:03.519 Would also many Sections of 25.211, might be impacted 00:20:03.529 --> 00:20:04.439 by that process. 00:20:07.750 --> 00:20:08.239 Thank you. 00:20:10.459 --> 00:20:14.140 (item:4.1:54233, Rob Bridges with CenterPoint Energy) Rob Bridges with CenterPoint Energy. I would just 00:20:14.150 --> 00:20:17.939 like to state. That I would tend to agree more with 00:20:17.949 --> 00:20:22.108 the AEP perspective, that was provided earlier. That we 00:20:22.118 --> 00:20:24.809 would like to preserve that ability, to be able to study 00:20:24.818 --> 00:20:28.509 those other potential different situations. In order 00:20:28.519 --> 00:20:32.309 to maintain the reliability of our existing systems. 00:20:33.180 --> 00:20:36.930 We agree with Oncor's approach of statement of possibility, 00:20:36.939 --> 00:20:41.279 of providing some language within that. However, I'm 00:20:41.289 --> 00:20:43.838 not certain that we would be able to come to a consensus 00:20:43.848 --> 00:20:46.469 of that language. Which is where my recommendation 00:20:46.479 --> 00:20:50.969 would be. To keep that limit at a lower level. Because 00:20:50.979 --> 00:20:54.009 of the difficulty in coming up with the special exception 00:20:54.019 --> 00:20:55.328 language. Yes. 00:21:00.009 --> 00:21:02.900 Um if no one else has any proposals on this particular 00:21:02.910 --> 00:21:05.358 topic. (item:4.2:54233, Mariah Benson with Commission Staff, asking for more information) I think on the front of the meter, behind the 00:21:05.368 --> 00:21:08.140 meter or behavioral distinctions. 00:21:09.729 --> 00:21:12.930 We would need more information on that, and pros and 00:21:12.939 --> 00:21:15.430 cons. And again, where everybody else feels about that. 00:21:15.439 --> 00:21:19.670 Versus just a single number as a cut off. If anyone 00:21:19.890 --> 00:21:23.318 wants to provide additional comments on that. Otherwise 00:21:23.328 --> 00:21:26.469 again, I think we would. I, I it, it feels like going 00:21:26.479 --> 00:21:28.420 with front to the meter, behind the meter. Again, would 00:21:28.430 --> 00:21:32.358 kind of have. It would be more complex in determining 00:21:32.368 --> 00:21:34.680 which units are front of the meter versus behind the 00:21:34.689 --> 00:21:37.729 meter. And we are not at this time inclined to go with 00:21:37.739 --> 00:21:40.640 that. Unless again, there's more explanation provided 00:21:40.650 --> 00:21:41.809 on why it's necessary. 00:21:50.039 --> 00:21:52.000 And that is obviously you guys know how to get a hold 00:21:52.009 --> 00:21:55.799 of us, uh outside of this context if you need to. Um 00:21:55.809 --> 00:22:00.098 okay. Is are there any um any other discussion points? 00:22:00.108 --> 00:22:04.759 Oh, ok. Just one point on on that. The, the difference 00:22:04.769 --> 00:22:07.880 that we may need to take into account. And this is (item:4.2:54233, Mickey Moon's follow-up comments) Mickey 00:22:07.890 --> 00:22:13.019 Moon, CenterPoint is that behind the meter generators. 00:22:13.029 --> 00:22:16.299 Can be addressed to the extent we need to address them, 00:22:16.309 --> 00:22:21.229 in our retail tariffs. As a TDU, whereas the in front 00:22:21.618 --> 00:22:25.709 of the meter generators are outside the scope of our 00:22:25.719 --> 00:22:29.209 retail tariffs. So to the extent any of the requirements 00:22:29.219 --> 00:22:32.818 for interconnection and the technical requirements 00:22:32.858 --> 00:22:36.739 are going to apply. Uh to in front of the meter or 00:22:36.750 --> 00:22:40.098 standalone generators. That intermit with the distribution 00:22:40.108 --> 00:22:42.809 system, we are going to be addressed to the tariff. 00:22:42.818 --> 00:22:46.489 We'd need to address them in our wholesale tariff or 00:22:46.500 --> 00:22:49.328 in a different tariff than our retail tariff. Whereas 00:22:49.338 --> 00:22:52.818 the behind the meter generators, we continue to address 00:22:52.828 --> 00:22:56.969 them in our retail rules of our retail tariff. Other 00:22:56.979 --> 00:23:01.299 than the different costs, the interconnecting of behind 00:23:01.309 --> 00:23:04.410 the meter versus front of the meter. Is there any other 00:23:04.420 --> 00:23:06.910 relevant reason, why they should be treated differently? 00:23:08.199 --> 00:23:10.598 And the tariff applicability 00:23:12.170 --> 00:23:16.709 is the second reason. Um no, I can't think of any other. Thank you. 00:23:21.118 --> 00:23:23.680 Anybody have any reactions or anything else to say 00:23:23.689 --> 00:23:25.689 on our first discussion topic? 00:23:27.769 --> 00:23:30.598 And or does anyone on Staff have questions they want 00:23:30.608 --> 00:23:31.390 to pose to the group? 00:23:33.789 --> 00:23:35.719 We did it guys, we're so far ahead of schedule. I'm 00:23:35.729 --> 00:23:36.838 proud of everybody. 00:23:39.078 --> 00:23:42.019 All right. Moving on to Discussion Question Two. Uh 00:23:42.029 --> 00:23:46.469 Mariah, do you wanna introduce question? Um, 00:23:49.979 --> 00:23:50.209 um. 00:23:53.459 --> 00:23:58.009 (item:5:54233, Mariah Benson gives overview of Proposal Two) So the second proposal Staff laid out. Was for the Technical 00:23:58.019 --> 00:24:03.400 Standards in existing 25.212. Um we propose a cut 00:24:03.410 --> 00:24:06.939 off of 1 megawatt between the two standards. At this 00:24:06.949 --> 00:24:09.318 time, we aren't sure if it would be in two rules or 00:24:09.328 --> 00:24:13.189 just stay in existing 212. Less than one megawatt 00:24:13.199 --> 00:24:17.719 would, would be published in a manner consistent with 00:24:17.729 --> 00:24:20.650 the discussion drafts we publish. Such that we lay 00:24:20.660 --> 00:24:25.699 out the specific standard we want followed for facilities 00:24:25.709 --> 00:24:29.289 less than 1 megawatt. For facilities over 1 megawatt, 00:24:29.299 --> 00:24:33.594 we would throw authority to an applicable authority 00:24:33.604 --> 00:24:35.814 in the power region. In the ERCOT region, it would be 00:24:35.834 --> 00:24:39.414 ERCOT. Outside of ERCOT, that's something we're still 00:24:39.424 --> 00:24:42.025 trying to figure out who it would be. But basically, 00:24:42.035 --> 00:24:45.894 it would allow them to set the requirements for resources 00:24:45.904 --> 00:24:47.055 over one megawatt. 00:24:53.029 --> 00:24:55.000 The floor is open for reactions. 00:25:00.640 --> 00:25:04.559 Hi, everybody. Um (item:5.1:54233, Monica Batra-Shrader with Enchanted Rock Energy) this is Monica Batra-Shrader on behalf of 00:25:04.568 --> 00:25:10.338 Enchanted Rock. Um and we would ideally like the cut 00:25:10.348 --> 00:25:14.368 off um to be 2 megawatts, between small and large 00:25:14.630 --> 00:25:19.750 um uh entities. Um essentially this would provide a 00:25:19.759 --> 00:25:23.479 small system classification on our low voltage sites. 00:25:23.489 --> 00:25:30.568 Which are 90% 3 Gens which um is or 1.2 megawatt systems 00:25:30.949 --> 00:25:33.900 um and lower. And so, depending on the requirements 00:25:33.910 --> 00:25:36.650 of a large system. We don't necessarily want to be 00:25:36.660 --> 00:25:38.750 burdened with the same requirements of, you know, a 00:25:38.759 --> 00:25:44.348 10 megawatt system, for example. Um and also it's in 00:25:44.358 --> 00:25:49.670 the current um rule set 25.212 (b)6. That states 00:25:49.680 --> 00:25:52.630 above 2 megawatts, the utility may require transport 00:25:52.640 --> 00:25:58.368 trip. And um so I think we wanna maintain that, that 00:25:58.380 --> 00:26:04.309 lower threshold. Um or be classified as, as a small 00:26:04.318 --> 00:26:12.029 um generating uh facility. And um uh let's see. Yeah 00:26:12.039 --> 00:26:15.979 I guess that's, that's my comments. Questions? 00:26:17.500 --> 00:26:18.049 (inaudible) 00:26:20.989 --> 00:26:26.640 Can you guys hear me? (item:5.1:54233, Bill Blevins with ERCOT) Bill Blevins with ERCOT. Um so 00:26:27.029 --> 00:26:31.130 we've been tracking um I guess this adoption of uh 00:26:31.150 --> 00:26:33.588 the ride through requirements. We think that's 00:26:33.598 --> 00:26:36.680 going to be very helpful to the ERCOT region um to 00:26:36.689 --> 00:26:41.420 adopt those. Um I guess at the question of one megawatt. 00:26:41.890 --> 00:26:45.358 Um we would probably want to just have an addition 00:26:45.368 --> 00:26:49.088 or register with ERCOT. Because those are the ones that 00:26:49.098 --> 00:26:51.848 are going to be providing services to us. And we may 00:26:51.858 --> 00:26:55.568 change our rules, as we need to going forward. For folks 00:26:55.578 --> 00:26:59.180 that are providing those type of services. I think, 00:26:59.189 --> 00:27:02.858 so the one megawatt made sense to us, at first. And then 00:27:02.868 --> 00:27:06.838 plus addition of smaller resources. Because we do have 00:27:06.848 --> 00:27:09.719 some that are below a megawatt, that have chosen to 00:27:09.729 --> 00:27:10.338 register. 00:27:15.068 --> 00:27:19.328 (item:5.1:54233, Martha Henson with Oncor) Martha Henson with Oncor. We largely agree with Staff's 00:27:19.338 --> 00:27:22.289 recommendation here for the Technical Standards. Uh 00:27:22.299 --> 00:27:25.729 the only thing I would note though. Is that it could 00:27:25.739 --> 00:27:29.959 be helpful to have consistency with the ERCOT definitions. 00:27:29.969 --> 00:27:33.588 Relative to the size of certain DERs. So that would 00:27:33.598 --> 00:27:37.078 mean basically. That Technical Standard A, would apply 00:27:37.088 --> 00:27:41.229 to greater than 1 megawatt DERs. And Technical Standard 00:27:41.239 --> 00:27:45.489 B, would apply to 1 megawatt and smaller DERs. Um 00:27:45.500 --> 00:27:48.578 so you just flip the equal sign to the, to the bottom, 00:27:48.588 --> 00:27:52.500 bottom bucket there. Um this is essentially how DERs 00:27:52.509 --> 00:27:55.199 that actively participate in the wholesale market. 00:27:55.209 --> 00:27:57.818 And which have other protocol and operating guide requirements. 00:27:57.828 --> 00:28:01.430 Are described in ERCOT's definitions today. So the 00:28:01.439 --> 00:28:06.380 short of it is, the equal to 1 megawatt, 1.0 megawatt. 00:28:06.479 --> 00:28:10.019 Would belong with the, the Group of B, Technical 00:28:10.029 --> 00:28:12.239 Standards. But other than that, I think it makes a 00:28:12.250 --> 00:28:15.439 lot of sense to have the same cut point. For both the 00:28:15.449 --> 00:28:18.189 interconnection standard and the technical standards. 00:28:18.199 --> 00:28:21.368 And also agree with ERCOT's position on the registration 00:28:21.380 --> 00:28:22.489 of these as well. 00:28:27.930 --> 00:28:30.930 Any other comments on this topic? 00:28:32.650 --> 00:28:34.509 Somebody disagree with these people who are up here. 00:28:34.519 --> 00:28:38.430 Come on, let's have some action. Any action? Nice. Staff 00:28:38.439 --> 00:28:39.170 any questions? 00:28:45.000 --> 00:28:46.759 We get what we need to? Yep. 00:28:48.299 --> 00:28:50.000 Um, okay. Thanks for coming up, you guys. 00:28:53.519 --> 00:28:53.549 (inaudible) 00:28:56.029 --> 00:28:56.219 interconnection standard. 00:28:59.239 --> 00:29:06.049 Um all right. For interlude, I suppose for the 00:29:06.059 --> 00:29:08.608 third, you know. So it's uh we have our third question. 00:29:08.618 --> 00:29:11.098 Which is, are there any additional topics that are 00:29:11.118 --> 00:29:14.199 um that we think deserve workshop treatment? And I 00:29:14.209 --> 00:29:16.250 know that we got some that are filed. But if anyone 00:29:16.259 --> 00:29:18.400 wants to come up and do that. And you know we, we 00:29:18.410 --> 00:29:22.588 we've been moving quick enough uh through this. That 00:29:22.598 --> 00:29:25.709 if anyone else has any pressing items, that they'd like 00:29:25.719 --> 00:29:29.630 to talk about, we can make that happen. Just wanted to, (item:6:54233, Craig Bennett with CPS Energy concerning Local Government Code & MOUs) Craig Bennett 00:29:29.640 --> 00:29:32.818 again, for CPS Energy. Just wanted to add one additional 00:29:32.828 --> 00:29:35.259 comment, since I'm not sure what the next question is. 00:29:35.459 --> 00:29:39.328 Um so this might be appropriate to, to subsequent questions 00:29:39.338 --> 00:29:41.750 or comments that the Commission Staff is asking for 00:29:41.759 --> 00:29:44.650 input on. But I think it's also applicable here when 00:29:44.660 --> 00:29:48.068 we talk about Technical Standards. Um because Technical 00:29:48.078 --> 00:29:51.598 Standards gets to really some of the facilities. And 00:29:51.608 --> 00:29:53.838 some of the requirements that relate to facilities 00:29:53.848 --> 00:29:56.068 and appliances and different things. And, and we've 00:29:56.078 --> 00:29:59.108 raised this in our comments previously. In that the 00:29:59.118 --> 00:30:02.348 Commission has to be very careful. In terms of how it 00:30:02.358 --> 00:30:05.989 chooses to apply. Um I mean, we have proposed that 00:30:06.000 --> 00:30:09.098 whatever standards get adopted, apply to IOUs and 00:30:09.108 --> 00:30:14.979 not MOUs. But you have the significant potential conflict 00:30:14.989 --> 00:30:18.559 with the Local Government Code. Which says that municipal, 00:30:19.459 --> 00:30:22.660 municipalities that operate electric systems. Have control 00:30:22.670 --> 00:30:24.880 over the facilities and appliances on their system. 00:30:24.890 --> 00:30:28.420 So I, I know this again is not directly tied to the 00:30:28.430 --> 00:30:31.449 difference of where you do the breakdown. But not knowing 00:30:31.459 --> 00:30:33.078 what your next question is. And since we're talking 00:30:33.144 --> 00:30:35.045 about Technical Standards. I just wanted to 00:30:35.055 --> 00:30:38.114 highlight that factor. That any of the Technical Standards 00:30:38.125 --> 00:30:40.664 that we talk about. Will have to recognize the Local 00:30:40.674 --> 00:30:44.703 Government Codes very clear, statutory prescription. 00:30:44.713 --> 00:30:47.344 That municipalities control the facilities and appliances 00:30:47.354 --> 00:30:49.094 that are going to be on their electric systems. 00:30:50.858 --> 00:30:53.029 Thank you, Craig. The uh that, that's a topic that uh 00:30:53.039 --> 00:30:55.229 Staff and I are working on. Uh you know, the Staff 00:30:55.239 --> 00:30:58.660 is working on. And we've been working with the, the 00:30:58.670 --> 00:31:00.709 trade groups and, and CPS and others on, on that 00:31:00.719 --> 00:31:04.979 topic. So, active uh wrestling of jurisdictional 00:31:04.989 --> 00:31:10.170 issues going on. Um, okay. Eric? Uh (item:6:54233, Eric Goff with Texas Solar Power Association comments on multiple suggestions) Eric Goff, again for 00:31:10.180 --> 00:31:13.219 the Texas Solar Power Association. Uh we have a few 00:31:13.229 --> 00:31:18.890 suggestions we filed. Uh so, I'll be brief. Um but anything 00:31:18.900 --> 00:31:21.939 of simplifying the interconnection process, uh especially 00:31:21.949 --> 00:31:25.828 with the smaller facilities is good. So timelines 00:31:25.838 --> 00:31:29.439 the latest uh Standards. We reference specifically UL 00:31:29.449 --> 00:31:34.799 1741 um SB version 3. Um 00:31:36.449 --> 00:31:38.539 And then the other side of the coin of allowing some 00:31:38.549 --> 00:31:41.250 studies sometimes. But also acknowledging that in many 00:31:41.259 --> 00:31:43.588 cases, we don't need to do studies for smaller systems. 00:31:43.598 --> 00:31:46.489 And trying to waive those where possible. Um 00:31:48.078 --> 00:31:51.068 are things we'd like to explore. There have been times 00:31:51.078 --> 00:31:56.568 in the past as people have um demand has gone up. That 00:31:56.578 --> 00:32:01.578 the time to be energized has increased, because there's 00:32:01.588 --> 00:32:06.539 not a deadline or requirement. And while those issues 00:32:06.549 --> 00:32:08.640 are eventually addressed by the utility, we think they 00:32:08.650 --> 00:32:13.180 could be routinely addressed with a deadline. Um so 00:32:13.338 --> 00:32:15.729 I, I know that creates some complexities for utilities 00:32:15.739 --> 00:32:17.910 obviously. And we'd be happy to work through this in another 00:32:17.920 --> 00:32:18.519 workshop. 00:32:23.439 --> 00:32:26.709 (item:6:54233, Rob Bridges with CenterPoint Energy question on potential technical requirements) Rob Bridges with CenterPoint Energy again. Um I, I 00:32:26.719 --> 00:32:30.509 just kind of wanted to open up a potential topic and 00:32:30.519 --> 00:32:33.180 and I'm not sure if we're there yet or not. So, so 00:32:33.189 --> 00:32:36.969 this is, this can definitely be tabled for another workshop. 00:32:36.979 --> 00:32:40.170 Um but I, I didn't know if we wanted to delve into 00:32:40.180 --> 00:32:43.299 these documents at all. To start discussing any, any 00:32:43.309 --> 00:32:47.239 potential technical requirements or moving into anything 00:32:47.250 --> 00:32:50.299 of that nature? Or, or are we there yet? I think is 00:32:50.309 --> 00:32:51.009 a real question. 00:32:52.699 --> 00:32:54.559 (item:6:54233, Mariah Benson asks question concerning possible small interconnection rules change) I don't think we're there yet for talking about the 00:32:54.568 --> 00:32:57.890 technical requirements. Um another question to pose 00:32:57.900 --> 00:33:01.670 to the group would be. For the small for interconnection 00:33:01.680 --> 00:33:06.059 specifically 25.211 content. Should both of those 00:33:06.068 --> 00:33:10.049 rules move forward right now, as a package? Or should 00:33:10.059 --> 00:33:13.709 we hold off on updating the small interconnection rules. 00:33:13.719 --> 00:33:16.559 Until after the large interconnection rules have been 00:33:16.568 --> 00:33:19.920 updated, and the Technical Standards have been completed. 00:33:22.039 --> 00:33:23.549 General question for anyone. 00:33:25.410 --> 00:33:28.348 So general comments on timing and priority of the different 00:33:28.358 --> 00:33:28.660 uh 00:33:31.039 --> 00:33:34.650 the different projects. (item:6:54233, Stephanie Kroger with Hunt Energy Network suggests moving forward on Standard A updates) Stephanie Kroger with Hunt Energy Network. We would 00:33:34.660 --> 00:33:38.559 respectfully suggest that we move forward with the 00:33:38.568 --> 00:33:42.009 Interconnection Standard A and the Technical Standard 00:33:42.019 --> 00:33:46.170 A for the larger resources. Those discussions have 00:33:46.180 --> 00:33:50.289 been going on within informal working groups now for 00:33:50.299 --> 00:33:55.029 well over a year. And the, the you know the issues 00:33:55.039 --> 00:33:58.828 have been fully fleshed out. We think the Staff's draft 00:33:59.199 --> 00:34:03.269 uh really did a great job of identifying the issues, 00:34:03.279 --> 00:34:07.449 and really gave us a solid place to start. Um we have 00:34:07.459 --> 00:34:09.958 some specific comments on that, which we laid out in 00:34:09.969 --> 00:34:13.398 our comments that we filed back in, in January. I can 00:34:13.409 --> 00:34:16.889 go through those, but um but y'all have them. Uh but 00:34:16.898 --> 00:34:20.000 but we would say let's move forward with that. Because 00:34:20.010 --> 00:34:22.699 we've had the time, we've got a great starting point. 00:34:23.050 --> 00:34:27.449 And then take the time to work on the um the Standard 00:34:27.458 --> 00:34:30.550 B's for the smaller uh resources. 00:34:32.728 --> 00:34:33.398 Thanks, Stephanie 00:34:37.309 --> 00:34:39.829 (item:6:54233, Martha Henson with Oncor concurring HEN's suggestion to focus primarily on large rules) Martha Henson with Oncor. We're actually fine with Stephanie's 00:34:39.840 --> 00:34:42.539 proposal. It seems there's maybe a greater area of 00:34:42.550 --> 00:34:45.619 uncertainty for the large ones. And so completely think 00:34:45.628 --> 00:34:48.159 it's appropriate to spend the next phase of this working 00:34:48.168 --> 00:34:52.360 on that new Rule A. We have 25.211. It seems 00:34:52.369 --> 00:34:54.590 to us that updating that is maybe a little bit lower 00:34:54.599 --> 00:34:57.610 priority, and can be secondary to the first rule for 00:34:57.619 --> 00:34:58.188 the large. 00:35:00.679 --> 00:35:00.750 (inaudible) 00:35:02.699 --> 00:35:02.989 (inaudible) 00:35:05.469 --> 00:35:07.099 CenterPoint agrees with Oncor. 00:35:09.478 --> 00:35:11.409 Surprise, surprise. 00:35:14.349 --> 00:35:14.949 Yeah, 00:35:18.019 --> 00:35:21.590 this is (item:6:54233, Bill Blevins with ERCOT suggesting small interconnection rules be processed as well) Bill Blevins, again from ERCOT. Um I, I think 00:35:22.478 --> 00:35:26.269 we would like to see um the small get addressed as 00:35:26.280 --> 00:35:29.438 well. Um because we've been tracking over the last 00:35:29.449 --> 00:35:34.500 I guess 5 years, 6 years. How much the different 00:35:36.070 --> 00:35:41.199 buckets of DG are growing? And I would say that it 00:35:41.208 --> 00:35:46.469 continues to accelerate over these years. So we feel 00:35:46.478 --> 00:35:49.809 like some of the issues that we're trying to address 00:35:49.820 --> 00:35:54.090 at ERCOT on the transmission side, dealing with inertia 00:35:54.099 --> 00:35:58.458 and handling storms and disturbances. There's some 00:35:58.469 --> 00:36:06.139 value in adopting IEEE 1547 criteria. We did some studies 00:36:06.148 --> 00:36:09.269 and provided those at our Reliability Operating Subcommittee. 00:36:09.489 --> 00:36:12.228 That showed the value of uh adopting that for higher 00:36:12.239 --> 00:36:16.239 levels of penetration. So, um we would like to see 00:36:16.250 --> 00:36:19.269 both of them move forward if possible. And just to 00:36:19.280 --> 00:36:21.938 clarify, we are planning to move forward with the Interconnection 00:36:21.949 --> 00:36:26.909 Standards for um the smaller DERs. It was more the 00:36:26.918 --> 00:36:28.958 Technical that we're considering delaying. Yeah, the 00:36:28.969 --> 00:36:31.269 Technical one is the one that actually. Interconnection, 00:36:31.280 --> 00:36:35.739 excuse me. Okay. As long as the, the Technical can adopt 00:36:35.750 --> 00:36:39.780 those capabilities of the new uh DG that are coming. 00:36:39.789 --> 00:36:44.079 We, we believe coming with the equipment today. I think 00:36:44.090 --> 00:36:48.070 that would help the grid and that would be our preference. 00:36:50.469 --> 00:36:54.090 Uh (item:6:54233, Eric Goff with TSPA supports ERCOT's suggestion) Eric again, on behalf of the TSPA. We're not 00:36:54.099 --> 00:36:56.668 opposed for the Technical Standards for smaller systems. 00:36:56.679 --> 00:37:00.438 being implemented quickly. Uh I think we filed comments 00:37:00.449 --> 00:37:03.159 that say we support the implementation and we understand 00:37:03.260 --> 00:37:07.760 why ERCOT values that. So, you know, it depends on your scheduling 00:37:07.769 --> 00:37:10.688 and timing. But I don't think there'll be controversy 00:37:10.699 --> 00:37:15.039 about the Standards for the uh smaller systems. And 00:37:15.260 --> 00:37:17.619 so just to clarify again we, we are planning to move 00:37:17.628 --> 00:37:20.938 forward with the Technical Standards, IEEE Standards 00:37:20.949 --> 00:37:23.208 for the small systems. It's more the Interconnection 00:37:23.219 --> 00:37:26.769 Standards, delaying that process. And do you, go ahead. 00:37:26.800 --> 00:37:29.949 Yeah I mean, so we certainly are eager to see improvements 00:37:29.958 --> 00:37:32.619 in the Interconnection process for small, as well. But 00:37:32.628 --> 00:37:36.110 we understand uh why the larger one is a hot topic, 00:37:36.119 --> 00:37:36.628 right now. 00:37:42.760 --> 00:37:45.719 (item:6:54233, Pete Parsons with the Texas Solar Energy Society) Pete Parsons with the Texas Solar Energy Society. I 00:37:45.728 --> 00:37:48.599 just would like to mention that um when we're working 00:37:48.610 --> 00:37:52.679 on this language. You know, that we try to keep the 00:37:52.688 --> 00:37:55.708 time period between when an application has been submitted 00:37:55.719 --> 00:37:59.949 as, and when it actually gets connected. That we consider 00:37:59.958 --> 00:38:03.280 the fact that time is money. And if you look at all 00:38:03.289 --> 00:38:05.938 the soft costs. You know, that's really the only place 00:38:05.949 --> 00:38:09.510 we can start to try to get the cost of solar down 00:38:09.519 --> 00:38:13.550 for homeowners. So eliminating any kind of financial 00:38:13.559 --> 00:38:17.639 barrier for soft costs can make a difference. So, you 00:38:17.648 --> 00:38:19.978 know, again, time is money. If you have to wait, wait, 00:38:19.989 --> 00:38:25.110 wait, wait, wait. Um it becomes it, it adds burden 00:38:25.119 --> 00:38:28.110 to the installers and the entire process. 00:38:31.280 --> 00:38:34.099 (item:6.1:54233, Craig Bennett, CPS Energy, with concerns on timing and deadlines) Craig Bennett again on behalf of CPS Energy. Um, 00:38:34.110 --> 00:38:38.329 in regard to the timing issue though. Uh, we would 00:38:38.340 --> 00:38:41.050 certainly push back against arbitrary deadlines, uh 00:38:41.059 --> 00:38:44.599 establishing timelines. Because what you know, that 00:38:44.610 --> 00:38:47.208 doesn't take into account is how many requests for 00:38:47.219 --> 00:38:50.719 a battery interconnection might be received at once. 00:38:50.728 --> 00:38:53.800 And we get multiple requests and we have to evaluate 00:38:53.809 --> 00:38:56.570 the impact of each one on the system, both individually 00:38:56.579 --> 00:39:00.148 and cumulatively. And that can't be done necessarily 00:39:00.159 --> 00:39:03.030 just in an arbitrary timeframe. While we understand 00:39:03.260 --> 00:39:06.918 I mean, we don't have a desire to move slowly. Um but 00:39:06.929 --> 00:39:09.340 at the same time, we have to fully evaluate for the 00:39:09.349 --> 00:39:12.030 safety and stability of the system. What the impact 00:39:12.039 --> 00:39:14.250 is going to be if we. If it's just one, you might 00:39:14.260 --> 00:39:16.139 say well, it's easy to fit within a timeline. But 00:39:16.148 --> 00:39:19.159 if you get 5 or 6 requests, and we have to look 00:39:19.168 --> 00:39:21.539 at each of those and how they're going to interconnect. 00:39:21.550 --> 00:39:23.168 And what the impact is going to be on our system and 00:39:23.179 --> 00:39:26.510 the transformers and what equipment is necessary having 00:39:26.519 --> 00:39:30.728 an arbitrary timeline, I think sacrifices safety and 00:39:30.739 --> 00:39:34.269 stability. Just for the purpose of an arbitrary timeline. 00:39:34.280 --> 00:39:37.750 And so certainly, if somebody believes we're acting 00:39:37.760 --> 00:39:39.699 inappropriately, there are complaint processes. There 00:39:39.708 --> 00:39:42.539 are different things that can be used. But just putting 00:39:42.550 --> 00:39:44.750 in an arbitrary timeline, I think we would push back 00:39:44.760 --> 00:39:47.860 on because we're likely not getting just one request 00:39:47.869 --> 00:39:49.918 at a time for interconnection. We're getting multiple 00:39:49.929 --> 00:39:52.250 and we have to process the impact of those individually 00:39:52.260 --> 00:39:54.409 and cumulatively on our system. 00:39:56.889 --> 00:39:59.128 So we have Craig coming out hard against the time is 00:39:59.139 --> 00:40:01.469 money. And just for clarification, you're still talking 00:40:01.478 --> 00:40:05.708 about the small system, right? Uh I forget you. Well 00:40:05.719 --> 00:40:08.228 we were talking just in general, when we talk about 00:40:08.239 --> 00:40:13.179 timelines. (inaudible) Um and it, it, yes, that's right. 00:40:14.760 --> 00:40:17.840 (item:6.1:54233, Pete Parsons, Texas Solar Energy Society, follow-up on timing concerns) My only pushback on that is. I'm hearing that in some 00:40:17.849 --> 00:40:20.860 areas, it's taking as much as 7 to 8 months to get 00:40:20.869 --> 00:40:23.780 connected. And I mean, maybe we could come up. Maybe 00:40:23.789 --> 00:40:25.659 we could compromise and come up with something that 00:40:25.668 --> 00:40:29.550 is reasonable. In terms of, you know, what the utilities 00:40:29.559 --> 00:40:32.849 need in order to, you know, move ahead safely. But 00:40:33.500 --> 00:40:37.418 limit the ones that just drag, drag, drag and um because 00:40:37.429 --> 00:40:41.668 that's a problem. Yeah I mean, I can't speak to those 00:40:41.679 --> 00:40:44.409 that drag. I know that we've not ever intentionally 00:40:44.418 --> 00:40:48.809 dragged in terms of interconnections. And so I can't 00:40:48.820 --> 00:40:51.530 speak to that. I just, I'm concerned with a one size 00:40:51.539 --> 00:40:54.458 fits all of we're going to adopt a timeline here without 00:40:54.469 --> 00:40:57.449 taking into the consideration of what that might do 00:40:57.458 --> 00:41:01.675 in terms of impacting the ability of the utility to 00:41:01.684 --> 00:41:05.195 properly analyze both stability and safety in terms 00:41:05.204 --> 00:41:09.485 of the impacts of and ensuring, you know, service to 00:41:09.494 --> 00:41:14.125 everybody in a stable system. From having multiple, 00:41:14.135 --> 00:41:17.043 you know, interconnection requests at a similar time. 00:41:18.489 --> 00:41:21.139 But I, I again. I certainly understand the concern 00:41:21.148 --> 00:41:23.579 I think maybe that requires a little bit more discussion 00:41:23.590 --> 00:41:26.349 about how that might be addressed. And I'm not sure 00:41:26.360 --> 00:41:29.610 an arbitrary timeline is necessarily the right answer 00:41:29.789 --> 00:41:31.139 That's just our position on that. 00:41:33.599 --> 00:41:37.079 (item:6.1:54233, David Vignes, AEP, comments on timeline concerns & standard updates) This is David Vignes with AEP. We would agree with 00:41:37.090 --> 00:41:41.019 CPS Energy as far as the timelines. There are cases 00:41:41.030 --> 00:41:44.250 when there are 3 to 4 projects at the same substation. 00:41:44.369 --> 00:41:46.489 And you have to know the technical requirements of 00:41:46.500 --> 00:41:48.739 the first project before you can know if the third 00:41:48.750 --> 00:41:52.878 or fourth project is viable at that substation. And 00:41:52.889 --> 00:41:55.300 so that is our concern. In order to do them in a 00:41:55.309 --> 00:41:57.550 nondiscriminatory manner, they need to be studied in 00:41:57.559 --> 00:42:00.659 order. And so that is our biggest concern. There are 00:42:00.668 --> 00:42:03.628 other states within our jurisdiction, that have a process 00:42:03.639 --> 00:42:06.969 that there would be an A and a B interconnection. Which 00:42:06.978 --> 00:42:09.449 would be the first two that apply for that substation. 00:42:09.458 --> 00:42:12.478 And then anything beyond that would be kind of held 00:42:12.489 --> 00:42:14.728 until you knew the results of the first study. And if 00:42:14.739 --> 00:42:18.378 they were going to go into service. And then as a general 00:42:18.389 --> 00:42:21.079 note, we do support moving forward with the Technical 00:42:21.090 --> 00:42:24.918 Standards you know. We think that, that is appropriate 00:42:24.929 --> 00:42:28.688 as far as those values. We would like to, you know, 00:42:28.699 --> 00:42:31.789 ask that you would consider the revision that we have 00:42:31.800 --> 00:42:35.139 filed on 211 and 212. In addition to the discussion 00:42:35.148 --> 00:42:38.039 draft, that those would be taken into consideration. 00:42:38.750 --> 00:42:42.369 And then also um specifically defining the Standards 00:42:42.378 --> 00:42:45.800 that are gonna be used for the specific UL 1741 00:42:45.809 --> 00:42:49.648 and IEEE 1547 Standards that would be used as 00:42:49.659 --> 00:42:51.300 part of the Technical Standard. 00:42:53.449 --> 00:42:55.840 And to clarify, what you mean by that. You'd recommend 00:42:56.059 --> 00:43:00.579 in rule reference those documents? Correct, that just 00:43:00.590 --> 00:43:03.289 the technical documents that have, have come up. Um 00:43:03.300 --> 00:43:05.909 those were done as a joint venture with some of the 00:43:05.918 --> 00:43:09.570 the TDUs. As far as the technical requirements and 00:43:09.579 --> 00:43:12.059 that those would just be considered as we come up with 00:43:12.070 --> 00:43:15.909 a, a final rule. (item:6.1:54233, Mariah Benson, Commission Staff, follow-up on standards updates) And, and so part of the reason we 00:43:16.030 --> 00:43:20.378 are considering bifurcating 25.212 into two different 00:43:20.389 --> 00:43:24.239 Standards. Is again for the larger ones, ERCOT can more 00:43:24.250 --> 00:43:28.760 easily update their protocols. Um we're concerned just 00:43:28.769 --> 00:43:32.750 putting in a reference to IEEE or other Standards. 00:43:33.010 --> 00:43:36.188 That for in use customers, they would have to pay for 00:43:36.199 --> 00:43:38.469 those publications to access those standards. Which 00:43:38.478 --> 00:43:41.510 is something we don't want to put on in use customers. 00:43:41.519 --> 00:43:43.829 Which is why we're trying to list them in our rule. 00:43:44.179 --> 00:43:44.789 Um. 00:43:46.369 --> 00:43:48.958 And generally we're kind of opposed to that. So I just 00:43:48.969 --> 00:43:51.449 wanted to throw that out there in case you have response. 00:43:51.889 --> 00:43:54.579 Yes, if we would support bifurcating the Standard. 00:43:54.590 --> 00:43:57.269 I think it's appropriate to have a smaller and a larger 00:43:57.280 --> 00:44:01.300 version of the rules. Um, but the technical requirements 00:44:01.309 --> 00:44:03.300 that we would look at from an engineering standpoint. 00:44:03.309 --> 00:44:06.059 Is to, you know, make sure that we do have reliability 00:44:06.070 --> 00:44:08.648 on the system. And that our, our in use customers are 00:44:08.659 --> 00:44:11.688 not affected adversely from DER. And again, I guess 00:44:11.699 --> 00:44:14.260 just how would the induced customers know what standards 00:44:14.269 --> 00:44:16.958 they need to meet, if they have to pay for those publications. 00:44:17.389 --> 00:44:19.978 And I think those would be handled by the installers. 00:44:19.989 --> 00:44:22.070 The installers are the ones that are gonna engineer 00:44:22.079 --> 00:44:25.260 their systems and not the individual customer. And, 00:44:25.269 --> 00:44:27.780 and sorry, just to clarify that. So you're saying 00:44:27.789 --> 00:44:29.789 referencing those Standards are fine, because it's the 00:44:29.800 --> 00:44:31.909 installers have to pay for those publications and not 00:44:31.918 --> 00:44:35.188 the induced customers? Correct. And I think those, 00:44:35.199 --> 00:44:39.349 most of those Standards are, are given, um the inverter 00:44:39.360 --> 00:44:43.099 is specifically certified for that and that is publicized 00:44:43.110 --> 00:44:46.668 So if that is a standard inverter or device, it's gonna 00:44:46.679 --> 00:44:48.639 have that specific stamp on it. 00:44:51.929 --> 00:44:55.648 (item:6.1:54233, Rob Bridges, CenterPoint, clarification on TDU meeting regarding Standards) This is Rob Bridges with CenterPoint to kind of piggyback 00:44:55.659 --> 00:45:00.599 on the discussions from, from AEP. The TDUs, some 00:45:00.610 --> 00:45:04.978 of the TDUs did get together and discuss the possibility 00:45:04.989 --> 00:45:10.329 of a revision to this. And I believe that it was proposed 00:45:10.449 --> 00:45:16.840 to the Staff, PUCT Staff. So um the to your point where, where 00:45:16.849 --> 00:45:19.679 you're trying to go. I think what we tried to do and 00:45:19.688 --> 00:45:23.110 that was not necessarily reference the IEEE document 00:45:23.119 --> 00:45:27.280 itself. But reference the, the specific technical requirements 00:45:27.289 --> 00:45:29.679 within that. And I think that's really what, what you 00:45:29.688 --> 00:45:33.019 were trying to ask there. So we don't have a reference 00:45:33.030 --> 00:45:37.728 to a document. We, we have a reference to a specific 00:45:38.079 --> 00:45:41.849 Standard, if you will within that. So there's no need 00:45:41.860 --> 00:45:46.289 to actually purchase a Standard in order to understand 00:45:46.309 --> 00:45:49.418 what the specifics are. So we, we actually did 00:45:49.429 --> 00:45:53.090 that with those specifics in mind. Thank you for the 00:45:53.099 --> 00:45:54.039 clarification too. 00:45:57.039 --> 00:46:00.070 (item:6.1:54233, Ramya Ramaswamy, Commission Staff, question enhanced communication) Um I just have a general question. Just to address the 00:46:00.079 --> 00:46:02.840 2 different points that came about, about the timeline 00:46:02.849 --> 00:46:06.918 of the interconnection. Um is there a way to like enhance 00:46:06.929 --> 00:46:12.918 communication between uh the DSP and the end use customer? 00:46:12.929 --> 00:46:16.989 Is that something that has ever come up before? Sorry 00:46:17.000 --> 00:46:20.019 David, (inaudible) going on. The less I talk 00:46:20.030 --> 00:46:20.918 the better? This is good. 00:46:22.668 --> 00:46:25.728 Um what I'm uh (item:6.1:54233, Pete Parsons, Texas Solar Energy Society, suggests fair deadline) Pete Parsons with Texas Solar. Excuse 00:46:25.739 --> 00:46:29.860 me, Texas Solar Energy Society. Um one thing I'm hearing 00:46:29.869 --> 00:46:33.820 is um that again. That it can take, you know, up to 00:46:33.829 --> 00:46:36.760 7 months to get connected. And if you're a homeowner 00:46:36.769 --> 00:46:39.019 and you've just invested a substantial amount of money. 00:46:39.219 --> 00:46:41.760 You've been tortured by the building code process and 00:46:41.769 --> 00:46:44.269 now you're being tortured by interconnection. And even 00:46:44.280 --> 00:46:47.739 what I'm hearing is that when complaints are filed 00:46:48.168 --> 00:46:50.789 um, nothing happens. So there doesn't seem to be any 00:46:50.800 --> 00:46:55.750 kind of enforcement. To, you know, response to complaints. 00:46:56.059 --> 00:46:59.719 So if, if we could potentially look at some kind of 00:46:59.728 --> 00:47:04.878 fair deadline. Um, for smaller systems maybe put a 00:47:04.889 --> 00:47:07.860 a size in there. So that homeowners are not necessarily 00:47:07.869 --> 00:47:13.688 adversely affected. Um and, um and give some teeth 00:47:13.699 --> 00:47:16.519 to, you know, how these folks can. What they do when 00:47:16.530 --> 00:47:19.659 they, where did the complaints go? So, thank you. 00:47:22.510 --> 00:47:23.000 Um 00:47:24.530 --> 00:47:29.070 I agree with what uh Pete said. Um And so to keep 00:47:29.079 --> 00:47:31.780 it brief. (item:6.1:54233, Eric Goff with TSPA, suggests capacity analysis of the DSP system) We, we think that you can utilize some of 00:47:31.789 --> 00:47:36.429 the features of these inverters. Um to simplify the 00:47:36.438 --> 00:47:41.510 interconnection process as well. Um so they're, they're 00:47:41.889 --> 00:47:44.628 designed to meet certain specifications. That should 00:47:44.639 --> 00:47:48.050 be able to be relied upon by the DSP. In order 00:47:48.059 --> 00:47:51.239 to simplify the overall interconnection process. Um 00:47:51.250 --> 00:47:57.409 So for example, UL 1741 should make it easier to 00:47:57.989 --> 00:48:02.289 uh do these every interconnection processes. Um, um we would 00:48:02.300 --> 00:48:09.148 also encourage um the utilities to automate as much 00:48:09.159 --> 00:48:11.469 as possible the interconnection process. Since there's, there's 00:48:11.478 --> 00:48:19.159 so many um repeat processes. That go on as people install 00:48:19.168 --> 00:48:25.228 rooftop solar. So, um we think that'd be helpful. We've 00:48:25.239 --> 00:48:29.958 also suggested doing sort of, you know, some sort of 00:48:29.969 --> 00:48:32.659 capacity analysis of the DSP system on an ongoing 00:48:32.668 --> 00:48:36.000 basis, as it's done in other jurisdictions. So that 00:48:36.010 --> 00:48:38.769 interconnecting entities have a good sense of where 00:48:38.780 --> 00:48:41.139 they might or might not be issues. And if you're in 00:48:41.148 --> 00:48:43.179 the area where there's not an issue according to the 00:48:43.188 --> 00:48:46.168 DSP. It should be a more straightforward process. That's 00:48:46.179 --> 00:48:52.438 more burden on the utilities to do those capacity analyses. 00:48:52.449 --> 00:48:54.820 But it could simplify every single interconnection 00:48:54.829 --> 00:48:56.590 that's done in those areas. That could ultimately be 00:48:56.599 --> 00:48:59.079 a time saver if we threaten people correctly. 00:49:03.349 --> 00:49:03.369 Yeah. 00:49:11.139 --> 00:49:17.728 Um so next workshop topics. Anybody I, I know in comments 00:49:17.739 --> 00:49:20.349 everybody said we needed workshops on multiple things 00:49:20.360 --> 00:49:24.559 related to the DER rules we filed. I feel like we'll 00:49:24.570 --> 00:49:27.789 be able to come up with some thresholds and move forward 00:49:27.800 --> 00:49:31.139 with proposals for publication soon. Are there any 00:49:31.148 --> 00:49:33.889 other topics, y'all would like to have workshops on? 00:49:33.898 --> 00:49:37.599 Because we didn't get it right in the rule? Um that 00:49:37.610 --> 00:49:40.628 need a broader group discussion? 00:49:44.550 --> 00:49:44.579 Yeah. 00:49:47.750 --> 00:49:50.898 Hello again, (item:7:54233, Monica Batra-Shrader, Enchanted Rock, suggests higher feeder loading limits) Monica Batra-Shrader, Enchanted Rock. 00:49:50.909 --> 00:49:54.159 Um we filed some comments and I guess I'm just gonna 00:49:54.168 --> 00:49:57.878 reiterate some of our, our points that we'd like to 00:49:57.889 --> 00:50:01.389 uh discuss at, you know, a potential subsequent workshop. 00:50:01.418 --> 00:50:07.559 So um the first, the first uh topic is per 16 TAC 00:50:07.570 --> 00:50:15.000 25.211(h)3. Um essentially saying that um let's 00:50:15.010 --> 00:50:18.760 see. So in practice, we've seen uh a threshold applied 00:50:18.769 --> 00:50:21.360 as the 1/3 feeder loading rule. And this is a 00:50:21.369 --> 00:50:24.090 hard cap on what a utility is willing to interconnect 00:50:24.099 --> 00:50:28.559 for export for behind the meter DERs. And um we 00:50:28.570 --> 00:50:32.809 think that the threshold is conservative and um that 00:50:32.820 --> 00:50:35.829 we can accommodate higher levels of distributed generation 00:50:35.840 --> 00:50:39.539 activity on a feeder. So we recommend discussion um 00:50:39.550 --> 00:50:42.648 to update the Standard to facilitate higher flexible 00:50:42.659 --> 00:50:47.110 feeder loading limits. Um, preferably as high as 2/3 00:50:47.119 --> 00:50:52.019 uh feeder loading rule. So that's one topic. 00:50:52.030 --> 00:50:55.559 And um, real fast Monica. Just to get a pool of the 00:50:55.570 --> 00:51:00.239 room. Um Is anybody against that proposal? Like again 00:51:00.250 --> 00:51:03.039 would that warrant outrage if we just moved forward 00:51:03.050 --> 00:51:06.550 with it? Coming from southside I'm not, I'm not an engineer. 00:51:06.559 --> 00:51:09.750 I don't know how this would potentially break the system. 00:51:09.760 --> 00:51:12.030 So again, if it would break the system? Like, is anybody 00:51:12.039 --> 00:51:13.668 opposed to that idea or? 00:51:16.750 --> 00:51:20.208 Yeah. Okay. So people are opposed. So you would want 00:51:20.219 --> 00:51:22.309 a workshop to discuss it to determine if it's correct 00:51:22.320 --> 00:51:28.659 or not? Yes. Okay. Thank you. And um for that, that question 00:51:28.668 --> 00:51:31.199 we are willing to bring in our interconnection engineer. 00:51:31.208 --> 00:51:33.840 To provide some, you know, technical expertise and 00:51:34.090 --> 00:51:37.030 insight um on the topics. And you know, our experience 00:51:37.039 --> 00:51:41.099 across the utilities. Um so we're very open to, to 00:51:41.110 --> 00:51:44.719 working with everyone on that. And then um another 00:51:44.728 --> 00:51:47.708 topic that we'd like to discuss. Is establishing streamlined 00:51:47.719 --> 00:51:50.918 and standardized processes for applications across 00:51:50.929 --> 00:51:55.320 the utilities. Because um DER customers have to navigate 00:51:56.159 --> 00:52:00.590 processes across the utilities under ERCOT. Um we have some, you know, 00:52:00.599 --> 00:52:03.360 specifics that we have brought up in our comments. 00:52:03.369 --> 00:52:07.559 But just as a high level, um you know, consistent processes 00:52:07.570 --> 00:52:11.148 will allow DER developers. Who typically work with 00:52:11.159 --> 00:52:13.938 modular repeatable systems and designs to scale quickly 00:52:13.949 --> 00:52:14.820 and efficiently. 00:52:16.840 --> 00:52:19.610 And any questions on that? 00:52:21.179 --> 00:52:23.750 Um could you just elaborate more on these standardized 00:52:23.760 --> 00:52:27.489 processes. Like what is not being captured in the draft 00:52:27.500 --> 00:52:30.599 rules republished that you think needs more standardization? 00:52:31.199 --> 00:52:34.949 (item:7:54233, Enchanted Rock gives response to question from Mariah Benson, Commission Staff) Um well, specifically in our experience, um data requests 00:52:34.958 --> 00:52:38.228 and documentation requirements vary significantly across 00:52:38.239 --> 00:52:42.070 the utilities, and should be standardized. Testing requirements 00:52:42.079 --> 00:52:46.809 and processes vary by utility. And um a consistent and 00:52:46.820 --> 00:52:49.438 transparent process for handling utility, internet 00:52:49.449 --> 00:52:54.409 connection costs and sales of facilities um is recommended. 00:52:55.958 --> 00:53:00.820 And um if and our, our very last point is. I know 00:53:00.829 --> 00:53:04.539 the the cost recovery issue is was tabled. But uh we 00:53:04.550 --> 00:53:06.889 just like to say that we support the utilities' interest 00:53:06.898 --> 00:53:10.719 and discussion for cost recovery issues including CIAC. 00:53:10.728 --> 00:53:14.679 And potential socialization of certain system upgrades 00:53:14.688 --> 00:53:16.090 and for protection measures. 00:53:18.719 --> 00:53:22.329 Any, any more questions? Thank you. Thanks y'all. 00:53:23.849 --> 00:53:26.570 Hi, (item:7:54233, Craig Bennett, CPS Energy, suggests topic of interconnection template & requirements) Craig Bennett again on behalf of CPS Energy. 00:53:26.750 --> 00:53:29.878 Um in regard to your question about what should be 00:53:29.889 --> 00:53:32.699 addressed in in future workshops. I mean, I think really 00:53:33.039 --> 00:53:35.809 the nuts and bolts and, and getting down into the weeds 00:53:35.820 --> 00:53:38.500 on some of these issues related to the Interconnection 00:53:38.510 --> 00:53:42.039 Agreement template and the requirements. Um the timeline 00:53:42.050 --> 00:53:44.070 issues that we discussed. I mean, I think there are 00:53:44.079 --> 00:53:49.070 so we're not um you know, unmindful of the concerns 00:53:49.079 --> 00:53:51.789 raised about the length of time it may take to interconnect. 00:53:51.800 --> 00:53:54.188 So we, we're certainly willing to sit at the table 00:53:54.199 --> 00:53:56.228 and try to come up with solutions. But we think that's 00:53:56.239 --> 00:53:58.628 the sort of thing that a workshop would be good. To, 00:53:58.639 --> 00:54:00.929 to not just talk about because right now, you know 00:54:00.938 --> 00:54:02.559 and I don't know what else you're going to be bringing 00:54:02.570 --> 00:54:05.280 up. But it's getting into the weeds on those sorts 00:54:05.289 --> 00:54:08.860 of issues. At the 2/3 feeder standard issue. Those 00:54:08.869 --> 00:54:11.780 I think require getting down into the weeds on. And 00:54:11.789 --> 00:54:16.559 and I think that's really where we need to get um have 00:54:16.570 --> 00:54:19.590 where workshops show their best benefit. Is getting 00:54:19.599 --> 00:54:22.708 some of the feedback on the actual verbiage itself. 00:54:22.719 --> 00:54:25.458 Um as opposed to just kind of some generalities. And 00:54:25.469 --> 00:54:28.550 I, I think uh have setting, you know, multiple 00:54:28.559 --> 00:54:31.869 workshops with actual language to discuss. And, and 00:54:32.030 --> 00:54:34.550 you know, some ideas for coming up with language and 00:54:34.559 --> 00:54:37.559 how we could do that, I think is the best use of 00:54:37.570 --> 00:54:39.860 workshops. So we certainly would support additional 00:54:39.869 --> 00:54:43.039 workshops to try to do that. Rather than just have Staff 00:54:43.050 --> 00:54:45.500 develop something, put it out there and then take comments 00:54:45.510 --> 00:54:48.110 from parties. I mean, I think that we should have additional 00:54:48.119 --> 00:54:52.829 workshops, workshops on those issues. And sorry, just 00:54:52.840 --> 00:54:56.228 to clarify. The three things you mentioned 2/3 00:54:56.239 --> 00:54:58.889 feeder issue, the timelines for the interconnection 00:54:58.898 --> 00:55:01.570 and then the Interconnection Agreement template itself. 00:55:01.579 --> 00:55:04.969 Were there other issues you think should have a workshop? 00:55:05.599 --> 00:55:08.079 Uh well, I mean, I think to the extent that we're getting 00:55:08.090 --> 00:55:11.119 into specific technical requirements. That are, you 00:55:11.128 --> 00:55:14.119 know, gonna be new. Um I think it's worth discussing 00:55:14.128 --> 00:55:16.889 those in a workshop. Before they just go out for comment 00:55:16.898 --> 00:55:19.500 and rulemaking. Okay. Thank you. 00:55:21.809 --> 00:55:25.478 Because everyone agrees that if, if you make a comment 00:55:25.489 --> 00:55:27.119 in the workshop. Then you won't make it in the rule 00:55:27.128 --> 00:55:29.039 making. So we don't have to file a written response 00:55:29.050 --> 00:55:29.539 That's the, 00:55:31.050 --> 00:55:33.059 that's the agreement that we're all entering into here. 00:55:34.820 --> 00:55:38.219 Thank you. (item:7:54233, Lori Blacka, TSPA, gives support on prior suggestions) Um Lori Blacka on behalf of TSPA. 00:55:38.599 --> 00:55:41.728 Um we just also wanted to offer our support for some 00:55:41.739 --> 00:55:46.079 of the other comments for the issue of the CIAC. Um 00:55:46.090 --> 00:55:49.260 those subs issues especially some that were mentioned 00:55:49.269 --> 00:55:51.898 recently in open meetings. About some of those transparency 00:55:51.909 --> 00:55:55.070 items that maybe could move forward on a faster timeline. 00:55:55.079 --> 00:55:59.849 Than the overall cost issues um with that. So we would 00:55:59.860 --> 00:56:03.989 be very supportive of a workshop on the CIAC, 00:56:04.168 --> 00:56:08.590 CIAC issues. Um and I just wanted to respond briefly 00:56:08.599 --> 00:56:12.320 about the timelines. Um that is such an important issue. 00:56:12.510 --> 00:56:16.289 There are, you know, valid considerations on both sides 00:56:16.300 --> 00:56:18.418 um getting these interconnections done more quickly. 00:56:18.429 --> 00:56:23.329 And realizing sort of the technical and labor issues 00:56:23.340 --> 00:56:26.250 that the TDSPs are experiencing. And I just wanted 00:56:26.260 --> 00:56:29.059 to mention that a workshop might be very helpful on 00:56:29.070 --> 00:56:31.438 that issue. Maybe we come to some compromise, some 00:56:31.449 --> 00:56:35.269 reasonable deadlines or some reasonable process. We 00:56:35.280 --> 00:56:38.050 briefly mentioned in our comments, perhaps the ability 00:56:38.059 --> 00:56:41.619 of using third parties that have been certified by 00:56:41.628 --> 00:56:45.260 the TDSPs. To help with these interconnection timelines 00:56:45.269 --> 00:56:48.708 as well as the imposition of a voluntary um charge. 00:56:48.719 --> 00:56:52.289 For people who would like to perhaps move their application 00:56:52.300 --> 00:56:55.760 along quicker. Um that fee would go to be hiring additional 00:56:55.769 --> 00:56:59.539 people um for the DSPs. To help them work through 00:56:59.550 --> 00:57:03.550 these agreements. So we just wanted to um respond briefly 00:57:03.559 --> 00:57:05.918 and say we would be supportive of workshop on those 00:57:05.929 --> 00:57:06.840 issues as well. 00:57:09.119 --> 00:57:15.179 (item:7:54233, Stephanie Kroger, Hunt Energy Network, suggests timeline for larger interconnections) So with respect to um timelines, uh the, the 00:57:15.188 --> 00:57:17.978 way I've understood the conversation so far. Is that 00:57:17.989 --> 00:57:20.019 that the discussions that we've been having really 00:57:20.030 --> 00:57:24.500 relate to the smaller interconnections. For the large 00:57:24.510 --> 00:57:30.219 uh larger interconnections. Um we've been through a 00:57:30.228 --> 00:57:35.378 long process of collaboration with the utilities. To 00:57:35.389 --> 00:57:38.110 try and work out what seems like a reasonable timeline. 00:57:38.119 --> 00:57:40.639 I think that was picked up in the Staff's draft. A and 00:57:40.969 --> 00:57:45.309 you know, we, we support having these, these timelines 00:57:45.610 --> 00:57:49.079 it into the rule. That's kind of one point. Yeah, real 00:57:49.090 --> 00:57:51.429 fast. Just uh just to clarify too. I think that's a 00:57:51.438 --> 00:57:54.179 great point. If we're talking about large versus small. 00:57:54.188 --> 00:57:58.918 On the TDU side is timelines for interconnecting 00:57:58.929 --> 00:58:01.599 DERs over 1 megawatt. Something you guys want to discuss 00:58:01.610 --> 00:58:08.878 in a workshop? Sure. Okay. Yes, CPS Energy says yeah. Yeah 00:58:11.878 --> 00:58:14.800 The second point that I wanted to raise also goes to 00:58:14.809 --> 00:58:18.280 the um to the Staff's draft. And kind of the larger. 00:58:18.289 --> 00:58:22.139 And that is that in, in that draft, there was a cap 00:58:22.159 --> 00:58:25.909 on um the megawatts that could be considered. In the 00:58:25.918 --> 00:58:29.128 interconnection request of 10 megawatts. That's a cap 00:58:29.139 --> 00:58:33.599 that does not exist in the ERCOT protocols. Um it was 00:58:33.610 --> 00:58:38.369 removed out of IEEE 1547. And it's a cap that 00:58:38.378 --> 00:58:44.219 we think is arbitrary frankly. And that we understand 00:58:44.228 --> 00:58:47.849 that, you know, there may be situations in which a 00:58:47.860 --> 00:58:50.579 utility system at a point of interconnection. Could 00:58:50.590 --> 00:58:55.849 accept a larger capacity, but that ought to be on a 00:58:55.860 --> 00:58:58.570 case by case basis. And the utility study process is 00:58:58.579 --> 00:59:01.829 going to bear that out. So the idea of having this 00:59:01.840 --> 00:59:04.449 10 megawatt cap is something that we would like to 00:59:04.458 --> 00:59:05.780 have further discussion on. 00:59:09.728 --> 00:59:10.458 Sounds good. 00:59:21.208 --> 00:59:24.519 (item:7.1:54233, Mariah Benson asks for thoughts going forward) Okay, so I guess proceeding forward. We can go forward 00:59:24.530 --> 00:59:26.860 with bringing back individual language on each of these 00:59:26.869 --> 00:59:30.309 different points in a workshop. Alternatively, we could 00:59:30.708 --> 00:59:34.500 kind of draft an entire rule and not necessarily publish 00:59:34.510 --> 00:59:39.489 it for comment. But just have a rule on, on a drafted 00:59:39.500 --> 00:59:42.769 or excuse me, have a workshop on a drafted rule. Um 00:59:42.780 --> 00:59:46.000 I think your point about bringing back language specifically 00:59:46.010 --> 00:59:47.949 we hear that and we can definitely do that. It will 00:59:47.958 --> 00:59:50.269 take more time though. So again, it's just I, I guess 00:59:50.280 --> 00:59:52.398 what I'm trying to ask y'all. Is would it be better 00:59:52.409 --> 00:59:54.628 to talk about those before we start drafting it or 00:59:54.639 --> 00:59:57.478 do you want to see language knowing that will take 00:59:57.489 --> 01:00:00.949 more time before the next workshop? And that's something 01:00:00.958 --> 01:00:04.090 we can figure out ourselves off, off mic. But 01:00:05.769 --> 01:00:09.860 I mean, (item:7.1:54233, Craig Bennett, CPS Energy, supports Staff proceeding with language) I think CPS Energy, it would support having 01:00:09.869 --> 01:00:12.628 language. I think that makes it more efficient because 01:00:12.639 --> 01:00:15.099 I think ultimately, if we come together, it's going 01:00:15.110 --> 01:00:18.789 to take a lot longer to try to develop language than 01:00:18.800 --> 01:00:21.739 it will be if you've already done the work to at least 01:00:21.750 --> 01:00:24.215 start with a base that we can adjust from. So I think 01:00:24.224 --> 01:00:27.614 it's more efficient. I understand it may, I think ultimately 01:00:27.625 --> 01:00:29.824 it takes the same period of time. It's just how it's 01:00:29.833 --> 01:00:32.253 broken out. It may take you longer before we have the 01:00:32.264 --> 01:00:34.824 next one to come up with it. But I think if we 01:00:34.833 --> 01:00:37.425 have to workshop language, it will probably take multiple 01:00:37.434 --> 01:00:40.313 workshops to try to get there and we end up spreading 01:00:40.445 --> 01:00:40.695 things out, 01:00:42.889 --> 01:00:43.010 right? 01:00:44.679 --> 01:00:48.969 (item:7.1:54233, Stephanie Kroger, Hunt Energy Network, suggests moving forward with publication) And I would suggest for the for the larger interconnections 01:00:48.978 --> 01:00:51.378 we have a direct rule. We have the staff strong man 01:00:51.389 --> 01:00:53.809 we've got everybody's comments on it and that that 01:00:53.820 --> 01:00:58.398 can either move forward into publication or, you know 01:00:58.409 --> 01:01:00.780 if there's a workshop, we have the rule, we don't need 01:01:00.789 --> 01:01:03.469 to go back and redraft. 01:01:05.610 --> 01:01:08.128 And we would suggest that the discussion draft rule 01:01:08.139 --> 01:01:10.418 probably should have a little bit more refinements 01:01:10.429 --> 01:01:13.969 to further clarify some of the points that were discussed 01:01:13.978 --> 01:01:17.079 with the TDUs and the battery community that are 01:01:17.090 --> 01:01:20.119 not reflected in the rule. So we politely disagree. 01:01:21.550 --> 01:01:25.849 (item:7.1:54233, CPS Energy follow-up) CPS would also politely disagree. And while we think 01:01:25.860 --> 01:01:28.530 you do have something to start with, and we think that's 01:01:28.539 --> 01:01:31.688 exactly the role it serves is the draft comments or 01:01:31.699 --> 01:01:34.260 the draft language and then the comments that you've 01:01:34.269 --> 01:01:37.139 already received, you can take into account as you're 01:01:37.148 --> 01:01:40.909 revising to bring something back for. So, I mean, I 01:01:40.918 --> 01:01:44.260 think that's the appropriate way to proceed and I do 01:01:44.269 --> 01:01:46.688 think it's, you have a good starting point because 01:01:46.699 --> 01:01:50.050 of the language that you've already proposed along 01:01:50.059 --> 01:01:52.590 with the comments and you can make those tweaks. Um 01:01:52.599 --> 01:01:55.050 to account for the comments you received and then start 01:01:55.059 --> 01:01:57.918 from that point in a subsequent workshop. 01:02:02.869 --> 01:02:06.860 Well, everybody, um I think that we're kind of wrapping 01:02:06.869 --> 01:02:09.418 up on the, the topics that we're posed for today uh 01:02:11.610 --> 01:02:13.489 by show of hands. Does anybody have anything else they 01:02:13.500 --> 01:02:13.849 want to? 01:02:17.590 --> 01:02:21.969 (item:7.1:54233, Bill Blevins, ERCOT, question on Technical Standard) I just had one other item, I guess just a question 01:02:21.978 --> 01:02:26.070 so far with the Technical Standard. And the, and the 01:02:26.079 --> 01:02:29.329 cut off point, I think we understood it pretty well. 01:02:29.340 --> 01:02:32.478 There was one area that wasn't real clear to us. That 01:02:32.489 --> 01:02:37.309 might need to be discussed. And that was this new style 01:02:37.320 --> 01:02:40.809 of DER that we're doing a pilot with the ADER 01:02:40.820 --> 01:02:44.250 Aggregation. Because they're technically, each unit 01:02:44.260 --> 01:02:47.559 is very small, but then they will register with ERCOT. 01:02:47.760 --> 01:02:50.579 And typically they're greater than a megawatt in their 01:02:50.590 --> 01:02:53.739 aggregation. So, you know, which one of these do you 01:02:53.750 --> 01:02:57.978 apply? I think ERCOT would initially believe that they 01:02:57.989 --> 01:03:00.519 would follow the ERCOT rule, if they registered with 01:03:00.719 --> 01:03:04.769 ERCOT as an aggregation. Um but I, I'm sure if you 01:03:04.780 --> 01:03:07.300 ask people in the room. You might get different opinions. 01:03:11.708 --> 01:03:12.280 Hm. 01:03:14.648 --> 01:03:14.878 (inaudible) 01:03:17.820 --> 01:03:18.369 (inaudible) 01:03:25.418 --> 01:03:27.070 If anyone wants to comment on that, they're welcome 01:03:27.079 --> 01:03:27.478 to. 01:03:31.489 --> 01:03:34.539 All right. So I think, you know, this is. Since Uri, 01:03:34.679 --> 01:03:36.659 right. When we booted up the New Rules Division. This 01:03:36.668 --> 01:03:38.889 is actually the first Staff-led Technical Workshop. 01:03:38.898 --> 01:03:42.070 That we've, that we've done with the current era of 01:03:42.079 --> 01:03:44.550 modern PUC Staffers. So I think in terms of how 01:03:44.559 --> 01:03:46.750 many topics we can get through and everything else 01:03:46.760 --> 01:03:49.530 is we're, we're all learning how to do this as we go. 01:03:49.539 --> 01:03:52.280 So thanks for such a good turnout today. And I think 01:03:52.289 --> 01:03:54.340 that if we have other, it seems like we could have 01:03:54.349 --> 01:03:57.610 put more topics on this. And now we know that for, 01:03:57.619 --> 01:03:59.260 for the future. But I think this has been a good exchange. 01:03:59.269 --> 01:04:01.679 But if anyone afterwards who's done a lot of these 01:04:01.688 --> 01:04:03.789 in the past. Is like, oh man, they should have done 01:04:03.800 --> 01:04:05.309 it differently. Feel free to reach out to me. We're 01:04:05.320 --> 01:04:08.188 always interested in how to make these things more 01:04:08.599 --> 01:04:12.090 uh more effective and useful for everybody. Um so on 01:04:12.099 --> 01:04:14.168 that note, I guess there's any, if there's any other 01:04:14.179 --> 01:04:16.188 topics or closing remarks that are related to what 01:04:16.199 --> 01:04:19.820 we have posted today. If not, we'll uh, you know, 01:04:19.829 --> 01:04:22.590 put our heads together on a Staff level and think about 01:04:22.599 --> 01:04:24.128 what the topic should be for the next one and what 01:04:24.139 --> 01:04:26.659 that, what that schedule would be. So, is there any 01:04:26.668 --> 01:04:29.148 closing topics? 01:04:34.309 --> 01:04:38.590 (item:8:54233, David Smeltzer adjourns meeting) Very good. Uh, well uh thanks for coming everybody. 01:04:38.599 --> 01:04:43.539 I think this is uh, thus endeth the first DER Workshop. 01:04:44.958 --> 01:04:45.090 (inaudible) 01:04:50.398 --> 01:04:50.719 (inaudible)