The potential for a federal renewable energy standard (RES) and carbon regulation, considered with the effect of state-imposed renewable energy standards, is fueling a strong, but challenging,...
Distributed Generation: Last Big Battle for State Regulators?
serve this market need.
Furthermore, McKinley dispels the misconception that DG is appropriate only for small users on the distribution system. Indeed, the membership of DPCA includes major corporations that plan to deploy on-site generation in sizes much greater than 50 megawatts.
But before DG can be deployed on the transmission network, McKinley says, nationwide differences must be settled in definitions between transmission voltage and distribution voltage across the United States.
Furthermore, "the sizes of the lines will also make tremendous difference in how units will be defined," she says. "In some areas of the country a generator at one point will be connected to the local utility system, and a similar unit elsewhere may be connected to the transmission system."
For example, says Evelyn Elsesser, representing the Energy Producers and Users Coalition and the Cogeneration Association of California, "when the Independent System Operator (ISO) took control in California, the utilities were required submit a split for transmission and distribution. If you recall, Pacific Gas & Electric's split was 66 kilovolts and Southern California Edison's is at 220 to 230 kV.
"If you take a cogenerator and define distributed generation injected at the distribution system, you may find a cogenerator in one territory that falls into your definition and a cogenerator in another territory who would not because they happen to fall on the transmission side of the interconnection," she says.
Elsesser says this will lead to a jurisdictional problem in which, "some facilities may be treated by FERC under the interconnection rules and some may be treated by [the California] commission," even though the facilities may be the same size.
"The ambiguities that occur between the distribution and transmission systems point to the necessity for uniform, national interconnection standards to ensure the creation of a seamless national electric grid," she says.
"The DPCA recognizes that the [FERC] does not have authority to establish interconnection policies at the state level," says Elsesser. "However, the coalition believes that uniform interconnection policies promulgated through the rulemaking would help to overcome barriers to entry for distributed energy technologies at the federal level, and would encourage fair and reasonable interconnection policies at the distribution level as well, to the benefit of all electricity consumers."
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