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Federal Interconnection Standards: Putting DG in a Box

Is FERC overstepping its jurisdiction and attempting to force a standard into a one-size-fits-all category?
Fortnightly Magazine - April 1 2003

all but a handful of DG applications for interconnection will be for smaller devices that fall under streamlined review procedures for non-export, low-impact interconnection.

The non-export exception is streamlined in states that adopted net metering rules. 3 For example, Massachusetts allows retail customers to export up to 60 kW on a simplified basis. However, states may not readily cede jurisdiction on net metering to FERC, which further narrows the population of DG that might fall under FERC's jurisdiction.

Order 888 has made the question of "what constitutes a transmission interconnection" a bit fuzzier. FERC's seven-step test for classifying distribution has decreased, jurisdictionally (if not functionally), the number of lines utilities now classify as transmission. It's not unusual for distribution assets to include lines up to or exceeding 69,000 volts. 4 Few facilities that are rated at 20 MW or below the ANOPR's upper limit will ever be connected at higher voltages. Absent third-party exports, FERC's consensus agreement may not be applicable for the vast majority of small DG that retail customers are likely to install.

In the ANOPR, FERC makes no effort to address the jurisdictional question, perhaps adding fuel to fire on the question of state versus federal rights. One might expect the DG coalition to prefer a federal standard. DG supporters also like the idea of having a consistent set of standards versus the range of standards that invariably will appear at the state level. States and utilities might suggest that lessons learned on DG integration could cause state standards to become more consistent over time.

A FERC standard fills the gap for states that do not plan to develop their own standard, because of DG activity (incentives to build DG dwindles for states with low electric rates) or reliance on a federal standard. Its actions also may act as a catalyst for states that have not yet developed interconnection standards. The NRECA too has developed an interconnection standard that could be used as a proxy in states without interconnection standards.

Unless FERC and states reach an understanding, or courts rule otherwise, DG developers and utilities may have to contend with competing standards with applicability that is less than certain for the range of interconnection applications that inevitably will arise. These concerns, however, may pale to the battles likely to arise as states wrestle with the question of back-up rates, credits for DG system benefits, and a host of institutional, legal, and regulatory issues that surely will accompany the maturity of the DG market.


  1. The DG suppliers and participants cited in this article include photovoltaic, wind, fuel cell, induction and synchronous generators, combined heat and power, and micro-turbine systems.
  2. Joint Comments of the Small Generator Coalition on Small Generator Interconnection ANOPR Consensus Documents and Annotations, .
  3. Utilities buy back power at the same retail rate they sell power to customers using a single meter that records net kilowatt-hour flows.
  4. 35,000-volt to 69,000-volt lines often are classified as subtransmission, which can be assigned to distribution or transmission.

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