ace=arial size=-1 color=blue>
« back to results for ""
Below is a cache of http://www.michigan.gov/documents/mpsc/30_and_Larger_April_20_Comments_194118_7.pdf. It's a snapshot of the page taken as our search engine crawled the Web.
The web site itself may have changed. You can check the current page or check for previous versions at the Internet Archive. Yahoo! is not affiliated with the authors of this page or responsible for its content.
April 20, 2007 Comments April 20, 2007 Comments



30 kW and Larger Interconnection Procedures Workgroup




Michigan Public Service Commission



This document contains comments on the following objectives:

1. Identify reasonable and achievable interconnection time deadlines.
2. Propose a system for determining whether interconnection costs are reasonable, actual costs.
3. Study the impacts and benefits of requiring utilities to consult with transmission providers when
certain interconnection applications are filed (for distribution-level interconnections).
4. Investigate the impacts and benefits of requiring all generators to maintain an acceptable power
factor.
5. Develop criteria for identification of areas of opportunity for distributed generation on each utility's
distribution system.
1 Comment Summary



Commenter Name
Page Number

1. William Stockhausen........................................................ 3

2. Greg Sirna........................................................................ 4

3. Michigan Regulated Electric Industry Comments ............ 5

4. ATC ................................................................................ 13
2 William Stockhausen




Thank you for the opportunity to comment.


In order to meet the upcoming RPS requirements the interconnection process for the 30 - 750 kW
segment will have to be more streamlined and cost effective.


The following parameters need to be relaxed to stimulate interest and effect viability for small renewable
power producers to come on line:


1) Extensive studies for engineering and systemic line effects that are costly and time consuming (doubly
true with rotary machinery vs inverter type) are unnecessary. These kinds of studies aren't done in this
power segment when the customer is a user rather than a generator.


2) Additional liability insurance can be dispensed with. There are no instances of linemen being injured
due to a small power producer keeping the line energized. Protective relaying and lineman training make
this a needless expense.


3) Some current stand by rates are exorbitant and also have a chilling effect for a co-gen or small power
producer. Stand by rates need to be eliminated entirely - they fly in the face of the whole RPS effort.


4) Utility grade relays are expensive and in excess of the protection needed in this power segment.
Industrial grade are sufficient.


Regards,


William Stockhausen

218 W. Dunlap St.

Northville, MI 48167

248-349-2833

3 Greg Sirna


I stated my thoughts to the MPSC last December. But I still think they apply
to today's discussion. I will be going through an interconnection with
Consumers Energy soon and I will than have a better understanding for the
procedures involved. My biggest concern is the metering. Last time I
interconnected with Consumers Energy I was charged $4,000 for the metering
(on the secondary side of the line, 480 volts). When my project failed and
the contract was canceled, the meters were removed (and more than likely used
somewhere else as there was nothing wrong with them), yet no money was
returned to me. So what did I pay for? This is a typical utility tactic.
Utility grade controls vs industrial grade controls for projects under 750
kws is an other mater that needs attention. There should be standardized
components available. As I said before the MPSC needs to walk through an
interconnection of there own to experience first hand the Utility tactics to
keep us off the grid.


Dec. 19, 2006
My thoughts on interconnection with the utilities are as follows: The cost
associated with just the application of the interconnection with the
utilities adds a burden for the small systems. The controls for the
generators between the customers and the utilities need to be simple
industrial grade not utility grade. The metering for the system should not be
complicated nor expensive. The utility should not be able to charge $4000 for
a set of meters that they retain ownership of. The interconnection package
should not be designed to cause the project to fail as the utility does not
want these project to make power as it is not in their financial self
interest to let others make and sell power. The one line drawings for
interconnection should be relegated to the project and simple with not
everything including the kitchen sink in it. There are a host of issues that
will arise when doing a project, the commission should implement their own
small project to see first hand the stalling overburdening tactics of the
utilities. Thank You Greg Sirna Centreville Hydro


4 MICHIGAN REGULATED ELECTRIC INDUSTRY COMMENTS
ON OBJECTIVES OF 30 kW AND LARGER
INTERCONNECTION PROCEDURES WORKGROUP



These informal comments are submitted by the Michigan Electric and Gas Association on
behalf of Michigan regulated electric utilities including MEGA members, the electric distribution
Cooperatives, The Detroit Edison Company and Consumers Energy Company. The MPSC Staff
(Staff) published a set of proposed objectives for a working group and requested initial
proposals by interested parties on how to achieve the objectives. This working group relates to
the interconnection procedures for projects sized at 30 kW and larger. The initial comments
were requested by Friday, April 20, 2007.

The following specific objectives were proposed:
1.

Identify reasonable and achievable interconnection time deadlines.
2.

Propose a system for determining whether interconnection costs are reasonable,
actual costs.
3.

Study the impacts and benefits of requiring utilities to consult with transmission
providers when certain interconnection applications are filed (for distribution-level
interconnections).
4.

Investigate the impacts and benefits of requiring all generators to maintain an
acceptable power factor.
5.

Develop criteria for identification of areas of opportunity for distributed generation
on each utilitys distribution system.
The following initial comments on each of these objectives are provided on behalf of the
industry group. The workgroup process will provide the opportunity for more detailed
discussion among interested parties and more detailed proposals.
Objective 1:
Identify reasonable and achievable interconnection time
deadlines.
The investigation and comments in MPSC Case No. U-15113 indicated a need to reconsider the
time deadlines in the Michigan interconnection rules. This will require discussion among all
participants in the working group. The deadlines should account for the impact of long lead
times for ordering equipment and making system modifications, if needed to complete an
interconnection. Although the smallest projects (under 10 kW) can usually be addressed in a
more expedited time frame, the time deadlines for other projects 30 kW and larger are typically
subject to site specific work requirements and other matters (right-of-way, equipment
availability, labor, operating agreement, testing) that may not directly correlate with the project
size categories used in the rules. Utilities may be able to stock some items of equipment with
long lead times. Depending on the circumstances, time requirements could extend out to six
months or more.
1

5 The conduct of a pre-application meeting between the utility and interconnection applicant
should facilitate more rapid interconnections and exchange of necessary information.
No overall deadline clock provision should start until a completed application is submitted and
sufficient time should be allowed for the initial review of the application for completeness. For
example, notification of receipt of the application in three business days would be the first step
and then notification of an incomplete application with identification of the missing information
would be required in ten business days. Only after all the missing information is provided
would the clock start on the completion deadlines.
Other items which would facilitate timely completion of interconnections would include
development of the approved equipment lists (relays), conceptual cost estimates based on
generic interconnection parameters (subject to change based on actual circumstances for a
specific project), and possibly a down payment for the engineering study and ordering materials
made prior to execution of the interconnection agreement. A letter of intent could be
considered for this last item.
One useful framework for discussion w