Solar Focus Interconnection Process Improvement

Comparing Utility
Interconnection Timelines for

Small-Scale Solar PV
Chelsea Barnes – EQ Research, LLC
Solar Focus | Washington, D.C. | Nov. 17, 2015
eq-research.com
The Problem: Waiting for Permission to Operate
• Delays are costly:

• Contribute to high soft costs
• $73.48/month for residential
5 kW system in Maryland
• Customer satisfaction
• Word-of-mouth marketing
EQ Research LLC | www.eq-research.com | info@eq-research.com

A Growing Problem
Residential Solar Growth

Study: Comparing Utility Interconnection Timelines
D.C.
20 installers
13 states and Washington DC
30,088 applications in 2013 (33 utility territories)
57,482 applications in 2014 (34 utility territories)

Quantifying the Problem: PTO Wait Time
140
120
100
80
# of Days
Median
Lowest Reported
60
Highest Reported
40
20
0
2013 2014

Quantifying the Problem 2013-2014
2013  2014 2013  2014 2013  2014

68% increase 75% utilities 18% utilities
on average increased decreased PTO
PTO

Difference in Average PTO from 2013-2014
55
45
35
Number of Days
25
15
-5

The Good….
Average # of Days
0 5 10 15 20
CL&P (CT)
National Grid (MA) 2013

2014
JCP&L (NJ)
Central Hudson (NY)
National Grid (NY)
NYSEG (NY)
PG&E (CA)
BGE (MD)
MECO (HI)
PacifiCorp (UT)

…and the Rest
Average # of Days
0 15 30 45 60 75
ORU (NY)
2013
PSE&G (NJ)
SDG&E (CA)
2014
SRP (AZ)
TEP (AZ)
NV Power (NV)
SCE (CA)
MID (CA)
NSTAR (MA)
PGE (OR)
Con Ed (NY)
SMUD (CA)
ACE (NJ)
Delmarva (DE)
HECO (HI)
LIPA (NY)
HELCO (HI)
APS (AZ)
PacifiCorp (OR)
WMECO (MA)
Xcel (CO)
LADWP (CA)
Pepco (DC)
Pepco (MD)

Policy Problems
• 24 of 34 utilities subject to regulated PTO timelines

• 14 out of 24 did not meet those deadlines
• Arizona, Delaware, DC, Maryland – no PTO deadlines
• Policies vary widely
• 5-30 business days
• On-site utility inspection/testing may or may not be
required
• MA only state with penalties for failure to meet PTO
deadlines
• Dispute resolution procedures unavailable or unused

Problem Areas: Applications
• Paper process it
outdated
• Pre- and post-

construction
approval
unnecessary

Problem Areas: Communication and Transparency
• Online application system solutions

• Staffing
• Coordination with local jurisdictions

Preparing for More DG

Recent Developments
D.C.

Thank you!
Chelsea Barnes
EQ Research LLC
cbarnes@eq-research.com

Grid Reliability Denials

Quantifying the Problem
• Survey data:
• 50 utility service territories with the most net-
metered residential customers
• 2013 and 2014
• # of applications submitted
• # average PTO waiting period
• # of applications denied due to grid reliability
concerns

MDV-SEIA 2015 Solar Focus Conference
Net Energy Metering and Interconnection Processes
Presented by Inia Burginger, APR

November 17, 2015
Pepco Holdings, Inc. – Our Territory
 Service territory – 8,340 square miles
 Customers served
• Atlantic City Electric – NJ
− 546,000 (electric)
− 9,963 approved interconnections*
• Delmarva Power – DE and MD
− 128,000 (natural gas)
• Pepco – DC and MD
 Total population served ~ 5.6 million
• 21,007 interconnections approved*
* As of Oct. 31, 2015
We support renewable energy and partner with our customers to ensure

safe and reliable interconnection of renewable energy into the electric grid
November 17, 2015 2

NEM Application and Call Volumes are Increasing Sharply
PHI
 Applications have nearly
doubled in 2015 compared to
2014
• We expect them to double again
in 2016
– End of federal tax credit
– Aggregated and community net
metering programs
– Leasing programs and grants
– Association forecasts
o MDV-SEIA, SEPA
 Call volumes substantial but
leveling off
• 1,625 in October, down from
1,915 in September and up from
average of 1,436 / month
January-June
As of September 30, 2015
• Inquiries shifting from
application status to billing
questions
November 17, 2015 3
Regulatory Requirements – Guidelines to all PHI Processes
 Interconnection requirements differ substantially state to state,
region to region
 Regulatory requirements PHI follows are similar but different
state to state
• DC – Title 15, Chapter 40 of the D.C. Code of Municipal Regulations for
Small Generator Interconnection Rules (SGIR) and the D.C. Customer Net
Energy Metering Contract (NEM Contract) define Pepco’s application
process
• MD – Code of Maryland Regulations (COMAR) 20.50.09 for Small
Generation Interconnection Standards (SGIS) defines the application
process Pepco follows. COMAR 20.50.10 for Net Metering Authority defines
the qualifications for net energy metering in Maryland
• DE – Title 26 of the Delaware Code, Chapter 10 and corresponding
regulations adopted by the Delaware Public Service Commission define the
net energy metering and interconnection application processes Delmarva
Power follows
• NJ – New Jersey Administrative Code Title 14, Chapter 8, Subchapter 4
defines net energy metering and Subchapter 5 defines the interconnection
application processes Atlantic City Electric follows
 All PHI processes follow these regulatory guidelines very closely
November 17, 2015 4

The NEM and Interconnection Process
Responsible
Steps Actions To Take
Party
1. Research • Research the various types of renewable energy systems available and decide which system • Customer
best fits consumption needs. Renewable energy-generating systems can be sized up to 200%
in Maryland, up to 110% in Delaware, and up to 100% in New Jersey and the District of
Columbia
• Customers should understand their electrical load and energy consumption
2. Select • Interview and select a licensed and reputable installing contractor • Customer
3. Apply • The customer should understand the documentation needed with the interconnection • Customer
agreement (e.g., rebate forms, permit applications, inspection forms)
• The customer applies and submits Part I of our interconnection application and agreement Apply for
along with the application fee and supporting documentation Building Permit
• Applications without supporting documentation will be delayed. The customer can resubmit a
corrected application and documentation
4. Approval • The customer waits for our Approval to Install before installing any renewable generator • Customer
equipment • PHI Utility
• We will provide the customer a written screening result or Approval to Install
5. Install • Begin constructing and installing the renewable generator facility • Customer
6. Inspect • After installation, submit Part II of our interconnection agreement, including a copy of the • Customer
certificate of completion and the inspection certificate
• We will review the customer’s documentation to verify the interconnection application meets • PHI Utility
regulatory requirements
7. Meter • We will install the net-capable meter • PHI Utility
8. Authorization • We will send the customer an Authorization to Operate letter • PHI Utility
9. Operate • Receipt of the authorization letter means the customer can operate the renewable system • Customer
November 17, 2015 5

Application Process Timeline and Checklist
13-25 business days 40 business days 20 business days
~80 business days
Responsible
Steps Actions To Take
Party
1. Research • Research the various types of renewable energy systems available and decide which system best fits • Customer
consumption needs. Renewable energy-generating systems can be sized up to 200% in Maryland, up
to 110% in Delaware, and up to 100% in New Jersey and the District of Columbia
Level 1 Applications • Customers should understand their electrical load and energy consumption
Complete application 2. Select • Interview and select a licensed and reputable installing contractor • Customer
Received to
Acknowledgement 3. Apply • The customer should understand the documentation needed with the interconnection agreement (e.g., • Customer
(3-10 days) rebate forms, permit applications, inspection forms)
• The customer applies and submits Part I of our interconnection application and agreement along with
Apply for
the application fee and supporting documentation
Engineering Review to Building Permit
• Applications without supporting documentation will be delayed. The customer can resubmit a corrected
Approval to Install
application and documentation
(10-15 days)
4. Approval • The customer waits for our Approval to Install before installing any renewable generator equipment • Customer
• We will provide the customer a written screening result or Approval to Install • PHI Utility
Customer Installs
and has Inspected 5. Install • Begin constructing and installing the renewable generator facility • Customer
(avg 40 days)
6. Inspect • After installation, submit Part II of our interconnection agreement, including a copy of the certificate of • Customer
completion and the inspection certificate
• We will review the customer’s documentation to verify the interconnection application meets regulatory • PHI Utility
Application Part II requirements
Received,
Meter Exchange, 7. Meter • We will install the net-capable meter • PHI Utility
Authorization to
Operate 8. Authorization • We will send the customer an Authorization to Operate letter • PHI Utility
(20 days)
9. Operate • Receipt of the authorization letter means the customer can operate the renewable system • Customer
November 17, 2015 6

Application Completions –
Compliance with Regulatory Metrics
Part I Applications Processed Within Regulated Timelines
Atlantic City
Pepco Delmarva Power
Electric
DC MD DE MD NJ
2011 81% 183 84% 329 54% 183 61% 107 29% 1,673
2012 100% 367 99% 511 97% 227 99% 160 88% 1,314
2013 99% 418 95% 814 99% 385 94% 188 97% 1,629
2014 89% 534 92% 2,143 97% 783 97% 425 97% 2,737
2015
97% 1,110 97% 4,900 80% 1,280 84% 940 81% 6,270
Forecast
November 17, 2015 7

GPC/NEM Process Improvements Since July 2015
 Established PHI Steering Committee to examine end-to-end
interconnection processes impacting GPC, Billing, Engineering, and
Meter Operations
 Realigned existing GPC Applications team into process groups
• Increases accountability within the teams and allows for teams to work across
jurisdictions to meet regulatory timeframes
 Implemented enhanced phone tree for calls into GPC to direct customers
to team handling their application; issues pertaining to billing are
forwarded to NEM Billing experts
• (1) Application Status and General Inquiries, (2) Meter Exchange, (3)
Permission to Operate, (4) Billing Inquiries
• Phone calls now answered live 10 a.m.-4 p.m.
 Hired 4 new GPC account coordinators to process applications; started in
September
 Shifted resources internally to meet increased application volume
 Added technology
• WMIS-based online application processing and tracking system launched
internally in late September to better coordinate applications with GPC,
Engineering, Meter Operations and Billing departments
November 17, 2015 8

Planned NEM Process Improvements
 NEM Online Application System –
early 2016 – benefits:
• Improves the accuracy and speed of
the NEM application process
• Features auto-data validation,
pull-down lists, and online signature
and fee payment
• Provides accurate and timely
compliance reports, plus business
reporting tools
• Improves the customer experience
and meets regulatory requirements
 Green Button Standard to provide customer usage data
• Enables MyAccount download functionality for customers
• Enables solar contractors access to replica of existing Third-Party
Supplier Portal
 Post Acceptable Inverters List on GPC websites
November 17, 2015 9

NEM Process Changes Being Evaluated
 Move meter exchange earlier in the process
 Implement over-the-air meter reprogramming
• Eliminate truck rolls for meter exchanges
 Simplify application forms and processes as part of the Working
Groups
 Clarify process for handling unauthorized installations
November 17, 2015 10

Use GPC Websites as Business Resources
www.pepco.com/gpc www.delmarva.com/gpc
www.atlanticcityelectric.com/gpc
 Interconnection Application and

Agreement Forms
 Printable Informational PDFs
• Application Checklist
• FAQ
• Unauthorized Interconnections
 Links to Applicable Regulations,
Rules, Tariffs, and Guidelines
 Restricted Circuit Maps
 Community Net Metering
 Aggregated Net Metering
 Renewable News and Useful Links
 Frequently Asked Questions
ALL FORMS CAN BE DOWNLOADED

NEM and Interconnections Customer Educational Materials
Request brochures
from
NEMEducation@
pepcoholdings.com
All PDFs can be printed

from
Pepco.com/gpc
Delmarva.com/gpc
AtlanticCityElectric.com/gpc

Restricted Circuit Maps
 Popular interactive tool
 Type in premise address
 Red – interconnection not
available
 Orange – interconnection
available for systems
up to 50 kW
 Yellow – interconnection
available for systems
up to 250 kW
 Interconnection may be
accommodated with system
upgrade at developer’s or
customer’s expense

Sign Up for Face-to-Face Meetings
 Especially helpful if you:
• Have incomplete applications returned to you
– We’ll review your actual returned applications and provide helpful hints
• Want to understand the application process better
 Best for your system size estimators and staff who complete
interconnection applications
 One meeting per company
• Invite as many staff as you’d like, including call-ins
 Meet at your business location in our service territory
• Or at any PHI business location
 Sign up today at our Informational Table
• Or email NEMEducation@pepcoholdings.com

NEM and Interconnections Webcasts
 Rotate among utilities
 Two per week (excluding holiday weeks)
• Mondays at noon
• Thursdays at 3 p.m.
 Register at:
• pepco.com/nemeducation
• delmarva.com/nemeducation
• atlanticcityelectric.com/nemeducation

Green Power Connection Contacts
 Read additional FAQs on the NEM and Interconnections websites

 Sign up for a face-to-face meeting
 Attend our NEM and Interconnections webcasts
 Contact us
www.pepco.com/gpc
gpc-south@pepco.com
(202) 872-3419
www.delmarva.com/gpc
www.atlanticcityelectric.com/gpc
gpc-north@pepcoholdings.com
(866) 634-5571

Interconnection Process
Improvements
SOLAR FOCUS 2015
Interconnection Process Improvements
Total system interconnection requests have been growing in many states, but growth patterns
differ
◦ Maryland: Exponential growth past 18 months, particularly in residential
◦ DC: Steady installation rate in both commercial and residential
◦ New Jersey: Moderate growth in residential, slow down in commercial
Many utility and developer interconnection processes are a function of volume

◦ Given the rapid increase, how can developers and utilities ensure that the system doesn’t get bogged
down with the volume?
What technology and process improvements can be made to increase throughput?

◦ Throwing more resources at an non-optimized process doesn’t always help
◦ Think of both physical process and back-office process
2
MD Installs (MW)
140
120
Rapid Growth in 100
Maryland
Total MW DC Installed
80
Maryland is experiencing exponential
growth in its solar deployment,
particularly in the residential sector
60
• Summer 2012: 1.1 MW / month
• Summer 2015: 8.9 MW / month

40
20
0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
All data from PJM-GATS, retrieved 11/16/15
< 20 kW 20 kW - 2 MW > 2 MW
3
MD Installs (Systems)
18,000
16,000
14,000
Rapid Growth in
Maryland
12,000
Ttoal Systems Installed

10,000
While the total MW installed is
balanced between residential,
commercial, and utility scale, the total 8,000
number of systems is highly
concentrated in the residential sector
6,000
• Summer 2012: 180 res / month

4,000
• Summer 2015: 1,020 res / month
2,000
0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
< 20 kW 20 kW - 2 MW > 2 MW
4
DC Installs (MW)
9
Steady Growth
in DC
6
5
Consistent growth in both residential
and commercial sectors, with growth
continuing at a linear pace 4
0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
< 20 kW 20 kW - 2 MW
5
DC Installs (Systems)
1,800
1,600
1,400
Steady Growth 1,200
in DC

1,000
DC installs have not transitioned to
exponential growth, but have
remained steady for the past several 800
years
600

• Summer 2015: 39 res / month 400
200
0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
< 20 kW 20 kW - 2 MW
6
NJ Installs (MW)
800
700
NJ Scale from
600
Commercial 500
NJ total installed capacity is much
larger than MD (1,400 MW vs 350 400
MW), but most of the installs are in

the commercial and utility sector
300
However, growth in the commercial
sector has slowed substantially in past
few years, and while the residential 200
sector has grown, it has not reached
the recent rate of MD installations
100
0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
< 20 kW 20 kW - 2 MW > 2 MW
7
NJ Installs (Systems)
35,000
30,000
NJ Scale from 25,000
Commercial

20,000
Commercial installs have slowed
substantially from 2012, while
residential grows at a steady pace
15,000
• Summer 2011: 86 com / month

10,000
• Summer 2015: 11 com / month
• Summer 2012: 464 res / month 5,000

0
1/1/2008 1/1/2009 1/1/2010 1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
< 20 kW 20 kW - 2 MW > 2 MW
8
MD vs. NJ Residential Installs
1200
1000
800
MD vs. NJ
Systems Installed per Month

MD’s rate of installation has surpassed
NJ’s on an absolute basis, and 600
currently sits at 250% of NJ on a per

capita basis
Nearly all the increase has come in the 400

past 18 months
200
0
1/1/2011 1/1/2012 1/1/2013 1/1/2014 1/1/2015
NJ Res MD Res

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Comparing Utility

Interconnection Timelines for

• Delays are costly:

EQ Research LLC | www.eq-research.com | info@eq-research.com

Residential Solar Growth

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

2013  2014 2013  2014 2013  2014

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

National Grid (MA) 2013

Central Hudson (NY)

National Grid (NY)

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

• 24 of 34 utilities subject to regulated PTO timelines

EQ Research LLC | www.eq-research.com | info@eq-research.com

• Pre- and post-

EQ Research LLC | www.eq-research.com | info@eq-research.com

• Online application system solutions

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

EQ Research LLC | www.eq-research.com | info@eq-research.com

Net Energy Metering and Interconnection Processes

Presented by Inia Burginger, APR

We support renewable energy and partner with our customers to ensure

November 17, 2015 2

November 17, 2015 4

November 17, 2015 5

~80 business days

November 17, 2015 6

Part I Applications Processed Within Regulated Timelines

November 17, 2015 7

November 17, 2015 8

November 17, 2015 9

November 17, 2015 10

 Interconnection Application and

ALL FORMS CAN BE DOWNLOADED

November 17, 2015 11

All PDFs can be printed

November 17, 2015 12

November 17, 2015 13

November 17, 2015 14

November 17, 2015 15

 Read additional FAQs on the NEM and Interconnections websites

November 17, 2015 16

Many utility and developer interconnection processes are a function of volume

What technology and process improvements can be made to increase throughput?

Rapid Growth in 100

• Summer 2015: 8.9 MW / month

Ttoal Systems Installed

• Summer 2012: 180 res / month

Steady Growth 1,200

Ttoal Systems Installed

• Summer 2012: 33 res / month

MW), but most of the installs are in

NJ Scale from 25,000

Ttoal Systems Installed

• Summer 2011: 86 com / month