By Patrice ‘Pete’ Parsons, TXSES Executive Director
On May 4, 2023, I attended the Public Utility Commission’s (PUCT) distributed energy resources (DER) workshop Docket 54233 as it considers updating DER interconnection standards and DER technical standards. The goal of the workshop was to get feedback from interested parties like TXSES, other non-profits and utilities.
Currently, PUCT staff recommends that all DERs in Texas be subject to uniform and defined interconnection standards and technical standards that will enable maximum DER development and provide necessary protections to maintain reliability.
State interconnection standards govern the process for clean energy systems to connect to the grid. If the process is slow, expensive, and/or unpredictable, it can impede investment and prevent a more rapid shift to clean energy, not to mention adding costs to the project since time equals money.
In January, the PUCT requested comments on proposed rules. Commission staff proposed the technical standards be split into two standards which could be codified in a single rule or two rules:
–Interconnection Standard A with a nameplate capacity greater than 50 kilowatts (kW); and
–Interconnection Standard B where 16 TAC § 25.211 is updated and applies to DERs with a nameplate capacity of 50 kW or less.
TXSES submitted comments to the technical standards recommending that the PUCT leave 25.211 and 25.212 in place as single rules and not combine them.
TXSES recommended that DG projects of up to 500kW or less is a distributed system and stay separate from large, utility-scale projects. At the workshop on May 4th, 2023, I spoke in favor of increasing the size to at least 500KW. After many comments from many stakeholders in attendance, the staff decided that distributed systems will be 1MW or less and utility-scale and DER systems will remain separate.
TXSES recognizes the need to implement a standardized interconnection process for distribution utilities across the state, ensuring a streamlined and uniform manner for any customer anywhere in the State to have their installed system interconnected in a timely manner. However, the proposed interconnection rules, while making large-scale, unregistered solar interconnection more accessible, strips away existing consumer protections, impose new burdensome interconnection study requirements and do not address the fundamental issues at the heart of interconnecting distributed solar on residential premises.
We also expressed concern in the meeting about how long it is taking for interconnection agreements to be processed (in some instances, we’ve heard as long as seven months). Time is money and installers should have a clear idea of the time it will take to process interconnection applications, and the individual who has paid for the installation should not have to wait an unreasonable amount of time to begin saving money. The PUCT has a timeline and as written allows for formal complaints to be submitted to the PUCT if a utility doesn’t comply in a timely fashion. Unfortunately, there is no enforcement.
Efficient interconnection standards and procedures will benefit Texas consumers by eliminating inconsistencies and decreasing soft costs ensuring a long-term, robust Texas distributed solar market.
The PUCT has agreed to a follow-up working meeting with stakeholders to determine a fair and reasonable amount of time for utilities to respond to the interconnection process.
I plan to be in attendance.