IEEE 1547 Interconnection Working Group

IEEE SCC21 Working Group
(P1547 Draft Standard For Interconnection)
31 Jan -1 Feb 2002, Arlington, VA.

Held in conjunction with the DOE Distributed Power Program Review [covered in a separate UFTO Note]

Officially established by IEEE Standards and integrated into SCC21, the P1547 project was launched 4/99, and the Working Group (WG) has been on a fast track ever since to get a standard written and accepted by stakeholders in a wide-open consensus process. Relentlessly, meetings have been held 4-6 times a year, around the country.

Complete documentation of 1547 activities can be found at:
http://grouper.ieee.org/groups/scc21/1547/archives/

An excellent overview and current status as of last Oct can be found in a paper by Dick DeBlasio in the proceedings of the IEEE T&D Expo 2001 (Atlanta). [I have the pdf.]

In the last year, Draft #7 was voted on in March, and #8 by a ‘recirculation’ ballot in October. The voting showed interesting patterns; in particular utilities were divided right down the middle. Other constituencies are clearly in favor. There were two huge flurries of email among WG members debating various points, one just before the Oct ballot, and again just before this meeting. The goal now is to complete Draft #9 and to have a successful ballot on it.

Chairman Dick DeBlasio’s introductory remarks* and charge to the group outlined a key source of the problem–a long list of issues which are most likely not appropriate to deal with in a Technical Standard are nonetheless being brought up repeatedly. People with reservations about impacts on the grid, penetration levels, contractual issues, etc etc. continue, sincerely or otherwise, to raise and debate these issues in the WG. There was also a red herring over a minimum vs. maximum standard — opponents claimed that once enacted 1547 could only be made less restrictive and not more — the truth is that IEEE standards invariably undergo revision time and again, before the ink is dry. A cynic might wonder how much of this concern is sincere, how much is due to misinformation, and how much is simply raw tactics to block DG.

Another complicating factor for the 1547 effort–it is the very first case under IEEE’s newly introduced “open balloting”. This means that any IEEE member can jump in fresh to the process and cast a vote without having been involved in previous discussions. Standards committees have long endured repeat dialogues covering ground that’s been dealt with before, but ballots with anyone able to vote is much more problemmatic.

* This agenda document has the remarks which explain the approach:
http://grouper.ieee.org/groups/scc21/1547/archives/agendas/Agenda20020131Ext.pdf
* Also see the middle section of Dick’s presentation to the DPP meeting:
http://www.eren.doe.gov/distributedpower/ReviewAnnual01Pres/0102_deblasio.pdf

New Working Groups

IEEE Standard making recognizes the difference between “shall” and “should” and “may”, and produces three types of documents: Standards, Recommended Practices, and Guides, which reflect these different levels of influence. As many of the issues being piled on to 1547 are more appropriately dealt with the second or third type rather than the first, two new working groups have been established and a third has been proposed. The idea is to strip out of 1547 anything that belongs in a different document, e.g. procedures, applications guidance, safety, etc. (In sheer size, 1547 drafts began at over 500 pages; it’s been shrinking but it’s still far above a length appropriate to a IEEE Technical Standard.)

– IEEE SCC21 P1589 — Draft Standard for Conformance Tests Procedures For Equipment Interconnecting Distributed Resources With Electric Power Systems
– IEEE SCC21 P1608 — Draft Application Guide For “IEEE Draft Standard 1547 Interconnecting Distributed Resources With Electric Power Systems”
– Potential new SCC21 PAR for DR communication/control

(P1589 is also a Standard, but it separates issues of testing from the Standard itself. The numbering may be changed to 1547.1, 1547.2 and 1547.3, to reinforce the association among them.)

After DeBlasio’s opening remarks, the opening session of the WG meeting continued with presentations on the new initiatives. Each of these new working groups are recruiting members at the present time.

P1589 (1547.2) Standard on conformance testing will specify the types of tests to be done to demonstrate compliance with 1547.1, in particular at the factory producing equipment and at commissioning. (It would not deal with post-installation testing, which is a matter between business parties involved in a particular setting.) Contact Jim Daley, 973-966-2474, jdaley@asco.com

P1608 (1547.3) Guide is to facilitate use of 1547, by providing characterizations of DG technologies. The development of this document will draw on dozens of existing resources, including 1547 resource materials, the 1001 IEEE standard for storage technology done in the 80’s (and withdrawn in ’98), various state procedures, utility handbooks, and other materials from EEI and EPRI. Contact Dick Friedman, 703-356-1300, nrf@rdcnet.com

New Comm/Control (1547.3) Guide will cover equipment and systems for both remote on onsite monitoring and control of DG, supporting a wide variety of transactions among any DG stakeholders. It will include CHP and coordination with building or enterprise energy management systems. Contact Frank Goodman, 650-855-2872, fgoodman@epri.com

Back to Draft-Writing

The rest of the first session saw the start of a difficult process of reviewing Draft #8, section by section, going over suggested changes, and deciding which materials could be moved into one or the other of the new documents. It recalled the old saying about laws and sausages, with the added fun of wordsmithing by (very large) committee.

Over the next day and 1/2, significant progress was made, with lots of material removed from the Technical and Test sections and the appendices, for inclusion in 1589 and 1608. A “strawman” for Draft #9 is set for the writing committee to tackle in the next two months. (It was also announced that there will be some adds and drops to the writing committee roster.) A full WG meeting in June will, it is hoped be followed soon with the ballot.
—-
Contact: Dick DeBlasio, 303-384-6452, dick_deblasio@nrel.gov
Tom Basso, 303-384-6765, thomas_basso@nrel.gov

(For background about the start of this effort, see:
UFTO Note – IEEE Stds for DR Interconnection, 09 Jul 1999)

IEEE 1547 Interconnection Working Group

Subject: UFTO Note – IEEE 1547 Interconnection Working Group
Date: Sat, 16 Feb 2002

IEEE SCC21 Working Group
(P1547 Draft Standard For Interconnection)
31 Jan -1 Feb 2002, Arlington, VA.

Held in conjunction with the DOE Distributed Power Program Review [covered in a separate UFTO Note]

Officially established by IEEE Standards and integrated into SCC21, the P1547 project was launched 4/99, and the Working Group (WG) has been on a fast track ever since to get a standard written and accepted by stakeholders in a wide-open consensus process. Relentlessly, meetings have been held 4-6 times a year, around the country.

Complete documentation of 1547 activities can be found at:
http://grouper.ieee.org/groups/scc21/1547/archives/

An excellent overview and current status as of last Oct can be found in a paper by Dick DeBlasio in the proceedings of the IEEE T&D Expo 2001 (Atlanta). [I have the pdf.]

In the last year, Draft #7 was voted on in March, and #8 by a ‘recirculation’ ballot in October. The voting showed interesting patterns; in particular utilities were divided right down the middle. Other constituencies are clearly in favor. There were two huge flurries of email among WG members debating various points, one just before the Oct ballot, and again just before this meeting. The goal now is to complete Draft #9 and to have a successful ballot on it.

Chairman Dick DeBlasio’s introductory remarks* and charge to the group outlined a key source of the problem–a long list of issues which are most likely not appropriate to deal with in a Technical Standard are nonetheless being brought up repeatedly. People with reservations about impacts on the grid, penetration levels, contractual issues, etc etc. continue, sincerely or otherwise, to raise and debate these issues in the WG. There was also a red herring over a minimum vs. maximum standard — opponents claimed that once enacted 1547 could only be made less restrictive and not more — the truth is that IEEE standards invariably undergo revision time and again, before the ink is dry. A cynic might wonder how much of this concern is sincere, how much is due to misinformation, and how much is simply raw tactics to block DG.

Another complicating factor for the 1547 effort–it is the very first case under IEEE’s newly introduced “open balloting”. This means that any IEEE member can jump in fresh to the process and cast a vote without having been involved in previous discussions. Standards committees have long endured repeat dialogues covering ground that’s been dealt with before, but ballots with anyone able to vote is much more problemmatic.

* This agenda document has the remarks which explain the approach:
http://grouper.ieee.org/groups/scc21/1547/archives/agendas/Agenda20020131Ext.pdf
* Also see the middle section of Dick’s presentation to the DPP meeting:
http://www.eren.doe.gov/distributedpower/ReviewAnnual01Pres/0102_deblasio.pdf

New Working Groups

IEEE Standard making recognizes the difference between “shall” and “should” and “may”, and produces three types of documents: Standards, Recommended Practices, and Guides, which reflect these different levels of influence. As many of the issues being piled on to 1547 are more appropriately dealt with the second or third type rather than the first, two new working groups have been established and a third has been proposed. The idea is to strip out of 1547 anything that belongs in a different document, e.g. procedures, applications guidance, safety, etc. (In sheer size, 1547 drafts began at over 500 pages; it’s been shrinking but it’s still far above a length appropriate to a IEEE Technical Standard.)

– IEEE SCC21 P1589 — Draft Standard for Conformance Tests Procedures For Equipment Interconnecting Distributed Resources With Electric Power Systems
– IEEE SCC21 P1608 — Draft Application Guide For “IEEE Draft Standard 1547 Interconnecting Distributed Resources With Electric Power Systems”
– Potential new SCC21 PAR for DR communication/control

(P1589 is also a Standard, but it separates issues of testing from the Standard itself. The numbering may be changed to 1547.1, 1547.2 and 1547.3, to reinforce the association among them.)

After DeBlasio’s opening remarks, the opening session of the WG meeting continued with presentations on the new initiatives. Each of these new working groups are recruiting members at the present time.

P1589 (1547.2) Standard on conformance testing will specify the types of tests to be done to demonstrate compliance with 1547.1, in particular at the factory producing equipment and at commissioning. (It would not deal with post-installation testing, which is a matter between business parties involved in a particular setting.) Contact Jim Daley, 973-966-2474, jdaley@asco.com

P1608 (1547.3) Guide is to facilitate use of 1547, by providing characterizations of DG technologies. The development of this document will draw on dozens of existing resources, including 1547 resource materials, the 1001 IEEE standard for storage technology done in the 80’s (and withdrawn in ’98), various state procedures, utility handbooks, and other materials from EEI and EPRI. Contact Dick Friedman, 703-356-1300, nrf@rdcnet.com

New Comm/Control (1547.3) Guide will cover equipment and systems for both remote on onsite monitoring and control of DG, supporting a wide variety of transactions among any DG stakeholders. It will include CHP and coordination with building or enterprise energy management systems. Contact Frank Goodman, 650-855-2872, fgoodman@epri.com

Back to Draft-Writing

The rest of the first session saw the start of a difficult process of reviewing Draft #8, section by section, going over suggested changes, and deciding which materials could be moved into one or the other of the new documents. It recalled the old saying about laws and sausages, with the added fun of wordsmithing by (very large) committee.

Over the next day and 1/2, significant progress was made, with lots of material removed from the Technical and Test sections and the appendices, for inclusion in 1589 and 1608. A “strawman” for Draft #9 is set for the writing committee to tackle in the next two months. (It was also announced that there will be some adds and drops to the writing committee roster.) A full WG meeting in June will, it is hoped be followed soon with the ballot.
—-
Contact: Dick DeBlasio, 303-384-6452, dick_deblasio@nrel.gov
Tom Basso, 303-384-6765, thomas_basso@nrel.gov

(For background about the start of this effort, see:
UFTO Note – IEEE Stds for DR Interconnection, 09 Jul 1999)

DOE Distributed Power Review

DOE Distributed Power Program
& IEEE Interconnection Working Group

29 Jan ?1 Feb 2002, Arlington, VA.

-Tue/Wed = DOE Distributed Power Program
-Thur/Fri = IEEE SCC21 Working Group [Covered in a separate UFTO Note]
(P1547 Draft Standard For Interconnection)

Distributed Power Program Review

^^^
The DPP website has the proceedings (and pdf downloads) for this meeting, and also for the last review meeting held in Golden CO, Oct’01.
http://www.eren.doe.gov/distributedpower/ (box in upper right corner.)
^^^

There is a requirement at DOE for “peer review”, so we’re seeing many of these meetings throughout the year. Last fall there was one for Distributed Energy Resources Program (DER), which includes the Distributed Power Program. (This confusing bit of terminology will be cleared up soon with a name change of the latter to something more accurately reflecting the focus on integration of DR in power systems, not DR itself.) OPT is the new entity formed last year to pull together a number of activities from across EREN.

Here is the line-up of these groups on the org chart:
– DOE
– EREN — Efficiency and Renewable Energy
– OPT — Office of Power Technologies
– DER — Distributed Energy Resources Program
– DPP — Distributed Power Program [name to change]

^^The DER Review was held in DC, 28-30 Nov 2001
http://www.eren.doe.gov/der/conference_01.html

^^Proceedings of the 2001 Hydrogen Program Review are posted at:
http://www.eren.doe.gov/hydrogen/docs/30535toc.html.

Other upcoming review meetings:
^^Hydrogen and Fuel Cells — Denver, 6-10 May
(We may try to combine this with an UFTO visit to NREL)
^^Microturbine and Industrial Gas Turbines — Fairfax VA, 12-14 March
http://www.eren.doe.gov/der/microturbines/pdfs/microt_indsturb_peerrev.pdf

———-

Presentations- Introductions and Overviews

Bob Dixon, head of OPT, opened the conference, commenting that September 11 is the main driving force in Washington. Energy security is a high profile part of it, which translates into redoubled interest in DG.

Bill Williams, IEEE-USA government liaison, outlined the many bills in Congress that deal with interconnection at both the bulk and DG level. He also noted that FERC has opened a rule-making for interconnection under 20 MW. (see below).

Richard Brent, Solar Turbines, pleaded the manufacturers’ concerns about there being different policies at every utility, in every state–sometimes different within the same utility. Many of these practices are still based on utility systems and technology of long ago.

Patricia Hoffman, head of DER, commented that just as with any infrastructure, the energy system needs to advance and evolve. One of the roles of DOE is to help bring consistency.

Joe Galdo, who leads the DPP Program, explained DPP’s mission to remove barriers to DG that arise from technology and regulation. The goal is to reduce installation cost, delay and hassle. The strategy is reflected in the array of projects supported, from the IEEE 1547, to system integration, interconnection and control, to institutional and regulatory barriers. A list of subcontracts awarded to date appears at:
http://www.eren.doe.gov/distributedpower/contracts.asp
See also “Research Activities” for a good overview:
http://www.eren.doe.gov/distributedpower/sublvl.asp?item=activities

Presentations – Technical Interconnection Standards and Testing

— First up, Dick DeBlasio gave an update on IEEE 1547. See separate UFTO Note on the Working Group meeting.

— Murray Davis of Detroit Edison reported on a study of penetration limits for DG on a distribution feeder. This ranks very high on the list of concerns about widespread deployment of DG. (Davis started with a quick aside that there would be no limit if grids were isolated–he’s submitted a paper to IEEE about this.) They did detailed modeling of two actual feeders using ASPEN and the Distribution WorkStation, and then modeled the impact of various amounts of DG placed at various locations. The striking conclusion, at least for these two particular feeders and for the two variables considered, is that DG penetration (or stiffness ratio, i.e. the amount of the DG compared to the size of the feeder) had no predictive value for when problems (e.g. over/under voltage) would arise. The line length, circuit particulars, and DG device sizes were far more significant. A feeder could accommodate as much as 10 times more total DG if it comes as many small units instead of 1 big one.

— NRECA has an aggressive program to support its members to do fuel cell demonstrations, with training, handbooks, databases, and a users group. Coops view DG as “a solution, not as a problem”. Together coops represent the largest “single” utility in the country, with 34 million customers in 46 states. The handbook will be available on the DOE website in the near future, and many more resources are available only to members of NRECA.
Contact Ed Torrero, 703-907-5518, ed.torrero@nreca.org

— DUIT — Distributed Utility Integration Test – This project is to come up with a plan, including a facility, to do testing of the interaction of DG with the electric system. A key element is the selection of a site or sites for the facility. To that end, a number of sites around the country at utilities and universities were evaluated as candidates. In addition, the Nevada Test Site received particular attention, in view of the extensive inventory of pre-existing buildings and equipment. (The NTS study came up with a conceptual design of a large “pole field” to be used to simulate actual distribution feeders. Rows and rows of utility poles could be patched together to provide everything from a single 30 mile feeder to countless different configurations.) (The DER Test Facility at NREL, which evaluates performance of DG interconnection systems, became operational Dec’01)
Contact Joe Iannucci, Distributed Utility Associates, joe@dua1.com, 925-447-0604.

— Certification Lab Pilot — EPRI-PEAC’s project is to define a path to “certified grid-compatible DER”. They’re writing an accreditation plan and an interconnection handbook. The effort includes actual testing of interconnection standards. For details, see the pdf download^^^, and:
http://www.epri-peac.com/project_opportunities/cert_grid_conn.html
Contact: Tom Key, 865-218-8082, tkey@epri-peac.com

— UL Standard for DG – Underwriters Lab is developing a standard for testing DG equipment, combining appropriate safety requirements with interconnection requirements from IEEE 1547, to produce a DG ANSI Standard that can be used to evaluate utility interconnected DG products for both electrical safety and utility interconnection to address the needs of Electrical AHJs and Utility Interconnection Engineers. This document will be UL 1741, The Standard for Inverters, Converters and Controllers for Use In Independent Power. Contact Tim Zgonena, UL, 847-272-8800 ext. 43051, timothy.p.zgonena@us.ul.com

Presentations – Codes and Regulations

— Regulatory Policy Options for DG — The Regulatory Assistance Project (RAP) is a non profit that educates and helps state regulators with electric utility regulation. With DOE funding they’re developing a series of issue papers and prototype standards documents for states to use as templates or starting points for DG interconnection, emissions, etc. One interesting observation: RAP suggests that restructuring can actually works against DG, when wholesale markets (ISOs) don’t offer payment for demand reduction, and distribution-only companies become more susceptible to revenue loss. The website has a wealth of material. Of particular interest, policy papers on DG and Electric System reliability, cost methodologies, customer value, and “Accomodating DG in Wholesale Markets”. Particularly note the Draft of a “Model DG Emissions Rule” which is getting a lot of comment. DOE is looking for more input from industry.
http://www.rapmaine.org/distribution.html
Contact: Cheryl Harrington, 207-582-1135, rapmaine@aol.com

— DG and FERC – Dan Adamson has done a detailed report on FERC’s role in DG, including policy directions and numerous cases that have come up over the last 10 years or more. Expect increasing complexity and litigation. Adamson believes that FERC has the authority to assert jurisdiction over interconnection of DG no matter how small, if it involves wholesale transactions, but not retail or self-generation. Last October, FERC announced an ANOPR on generation interconnection. On 11 January, consensus drafting groups submitted a lengthy filing, with big disagreements between transmission owners and small generators. A new strawman proposal was due Feb 1. Expect a NOPR for comment soon; FERC hopes to issue a final rule later this year. Even if FERC does get jurisdiction, they don’t have the staff expertise or resources to regulate at the distribution level, and will likely look to the new RTOs do handle the details. States will still have a big role in any case. And, many bills are before Congress; how they’d interact with FERC’s efforts needs to be watched closely. (There is a case before the Supreme Court that may decide much of this issue.

A detailed report will be made available soon on the DOE/DPP website. See more information at:
http://www.eren.doe.gov/distributedpower/news.asp?Item=105
Contact: Dan Adamson, 202-508-6600, danadamson@dwt.com
Also, go to the source: http://www.ferc.fed.us/Electric/gen_inter.htm
[Sign up for FERC’s “intranet” to see more details. Of note–most utilities’ participants seem to be in transmission or regulatory affairs… is your DG effort in the loop?]

— Local Permitting – This presentation gives a sobering picture of the situation at the local level. There are over 44,000 independent building inspection jursidictions. It can take 10 years or more to get a new technology mentioned in codes, and even then it is up to states which vintage of a code it wants to use. (For example, Nevada still uses the 1978 Electrical Code!?) Most Fire and Building inspectors have little or no experience or understanding of hydrogen, methanol, fuel cells, etc. so developers can have a tough time. DOE is sponsoring an Education and Outreach effort, doing workshops around the country for local inspectors and state officials. Contact Ann Marie Borbely-Bartis, 202-586-5196, anne-marie.borbely-bartis@ee.doe.gov

******** Late Breaking News ******
NARUC passed a resolution this week (13 Feb) to support development of a Model DG Rule — See below for particulars. — I can also send the actual text of the resolution on request.
*****************************************

Presentations – System Integration and Control

A series of ongoing projects address implementation and hardware, including demonstrations of whole building systems, enterprise-wide generation management, and aggregation of DG. Others are developing new hardware to increase capabilities, reliablity and cost-effectiveness of interconnection systems. [As this note is getting a bit too long–please see proceedings for the individual presentations, or contact me to discuss.]

Presentations – Industrial DG

This series of projects involve actual installations or market studies of individual industry sectors. Others addressed market potential in NY, CA and Chicago.

– Increasing the Use of DG in the Semiconductor Industry
Barry Cummings, Salt River Project
– Highly Varying Industrial Load
Dr. Robert Kramer, NiSource
– DG Integration with Telecommunications Facility
Doug Peck, Syska & Hennessy
– CHP Integration with Fluid Heating Processes in the Chemical and Refining Sectors
– CHP Installation at 29 Palms Marine Air Ground Combat
Henry Mak, So Cal Gas
– DG Improvements in Industrial Applications
Rich Biljetina, Industrial Center
– Chicago Industrial Energy Plan
John Kelly, Gas Technology Institute
– New York State Industrial DG
Nag Patibandla, NYSERDA
– Industrial DG Market Transformation Tools
Paul Bautista, Onsite Sycom

**************************
Naruc Adopts Resolution Endorsing Development of Model Interconnection Agreements and Procedures

Washington, February 13, 2002
The Board of Directors of the National Association of Regulatory Utility Commissioners (NARUC), this week at the NARUC 2002 Winter Meetings in Washington, D.C., endorsed the development of model interconnection agreement and procedures under the direction of its Committees on Electricity, Energy Resources and the Environment and Finance and Technology. Reiterating its support for open access to the nation’s electricity grid, and the importance of distributed energy resources to our energy future, NARUC noted in is resolution (attached) that:

– Coordination among the States could improve the consistency of treatment so important to the efficient integration of distributed energy resources; and

– Increased national consistency would lower entry barriers and enhance business economic efficiency, and,

– The ready availability of NARUC developed model agreements and procedures will aid in balancing those concerns; and the preparation of model interconnection agreement and procedures by NARUC could provide significant support and

– Efficiencies to those States which have yet to address the challenges of distributed energy resources, and the consideration, adaptation or adoption of such models could provide material assistance in achieving the coordination among the states called for by previous resolutions.

The DOE DPP program has previously support state commissions in their efforts to address the new challenges presented by integrating distributed generation into their energy system, and has been supporting this new initiative. The issue was timely at NARUC because of the FERC’s ongoing inquiry into developing a national rule setting forth interconnection procedures and a standard agreement for FERC jurisdictional interconnections, typically at the transmission level. Some controversy may develop where both state commissions and FERC assert jurisdiction of interconnection issues at the distribution level. For additional information contact Gary Nakarado, DP Program NREL, 303-275-3719 or Gary_Nakarado@NREL.Gov