Survey Says: Interconnection Data is Unavailable — Episode 177 of Local Energy Rules

Date: 15 Feb 2023 | posted in: Energy, Energy Self Reliant States | 0 Facebooktwitterredditmail

Deploying local solar is a crucial step toward achieving a low-cost clean electricity grid. Individuals and communities are willing to make the investment, but they lack the information to develop projects with urgency.

For this episode of the Local Energy Rules Podcast, host John Farrell is joined by Justin Baca, Vice President of Markets and Research at the Solar Energy Industries Association, and David Gahl, Executive Director of the Solar and Storage Industries Institute. They discuss how an information gap trips up small solar developers. They also explain their letter to the U.S. Energy Information Administration, which asks for more federal data collection from electric utilities and transmission operators.

Listen to the full episode and explore more resources below — including a transcript and summary of the conversation.

David Gahl: The data access piece gives industry folks and advocates the ability to challenge utility assumptions, right? I mean, and that’s probably another huge benefit of having this information available just to have an independent check on the information that the utilities put out there. Just seems to me that I, I’ve run across this in cases across the country where, you know, the utility, really their utility forecast or the utility analysis in whatever instance is sort of treated as gospel when we know there are some questionable assumptions that went into what they are producing for regulators. So this might give us some new tools with advocacy across the country.
John Farrell: Widely deploying distributed renewable energy like rooftop and community solar can create jobs, reduce energy bills, and dramatically cut the cost of achieving a low carbon electricity grid. But all of these kinds of projects face a common barrier: interconnection, or plugging into the electric grid. An ILSR survey suggests that interconnection is among the most challenging barriers increasing project costs and delaying their completion. But even the best data sources on this issue are incomplete. Joining me in January, 2023, David Gahl, the executive director at the Solar and Storage Industries Institute, and Justin Baca, Vice President of Markets and Research at the Solar Energy Industries Association, explain their request to the Federal Energy Information Administration to collect better data from utilities and how it could significantly improve the opportunity to add more distributed energy to our electricity systems. I’m John Farrell, director of the Energy Democracy Initiative at the Institute for Local Self-Reliance, and this is Local Energy Rules, a bi-weekly podcast sharing powerful stories about local, renewable energy. David and Justin, welcome to Local Energy Rules.
Justin Baca: Glad to be here.
David Gahl: Thanks for having us.
John Farrell: So there’s this huge opportunity out there with solar, distributed solar in particular. And one of the things that ILSR has found, we’ve done a couple of check-ins on the process of installing distributed solar over the past couple years. One, we did a survey of developers across the country, and then we also did kind of analysis of data that is provided through the National Renewable Energy Lab Solar Trace data on interconnection, like the timelines and the costs. And it reminds me of that movie Apollo 13, where they say, Houston, we have a problem. But unlike the movie where they clearly were able to identify, you know, you’re venting oxygen and you’ve gotta solve this problem, I feel like we don’t really know what it is or who’s responsible because the data that’s available about interconnection is so inconsistent. It’s like there were four separate NASAs and each one has data on different parts of the spacecraft. Which leads me to the action that you took. So could you talk about why did the Solar Energy Industries Association, why did the Solar and Storage Industries Institute write a letter to the Federal Energy Information Administration? What problem did you see that needed to be addressed?
David Gahl: The Solar and Storage Industries Institute and SEIA worked together on a letter to the Energy Information Administration to help collect better data about the state of interconnection problems across both the large scale, you know, bulk transmission grid and the distribution grid as well from conversations that we’ve had with SEIA member companies and firms that are associated with the Solar and Storage Industries Institute. You know, we hear a lot of stories about projects getting derailed by interconnection delays, about high costs of interconnection upgrades, about processes that don’t work very well, but there’s not great data as you suggested, John, about the state of these problems. And also, as you pointed out, we have balancing authorities or RTOs that collect information about the transmission system. We have hundreds of electric distribution companies that have their own processes for connecting smaller systems to the grid. And it creates a real complicated thicket of trying to sort out where are these problems? How can we streamline processes? And we thought starting with better data that the Energy Information Administration collects would be foundational to ultimately reforming some broken processes.
Justin Baca: Yeah, and I’ll add to that, that you referenced, John, the Solar Trace data, that is probably the best data we have right now on distributed interconnection. However, it only comes from a handful of companies. So it’s far from comprehensive and it only covers certain markets. And so the Energy Information Administration has statutory authority to collect data on energy in the United States broadly. So they have the authority to produce not only a data set that will cover the data we need, but they can do it comprehensively in the same format so that we can compare one jurisdiction to another on an apples to apples basis. I would say also that we don’t wanna have to do this state by state or jurisdiction by jurisdiction anyway, just because that’s a lot of work and it’s really just not gonna be comparable from one to the other.
John Farrell: You’ve kind of already led into my second question about the Energy Information Administration. Could you just give a little bit of background? What is this federal agency, what are some of the other data that they collect? What are the useful things that they’re putting out there that are helping in the work that you’re doing to try to promote the adoption of solar at large and small scale?
Justin Baca: So the Energy Information Administration was established in the 1970s to collect information on energy in the United States broadly. So they cover everything from coal, oil, gas, nuclear, electricity sectors, everything from resource extraction to electricity generation to consumption, including, you know, consumption of gasoline, right? They track data from large developers, distribution utilities, transmission utilities, you name it. Their data finds its way into all sorts of places, and it’s immensely useful. And I’ve seen instances where regulators seeking <laugh> information from the utilities they regulate are not able to get that data from those utilities, but the Energy Information Administration already has it and publishes it. So they provide a huge service to policy makers at the federal level, but also at the state level. And I wanna also say that the task that the staff at EIA have been given is immense. Collecting information on this <laugh> massive energy industry is huge, and they do it with far fewer people than you would expect, and I have immense respect for that. And one other thing they do that folks will recognize is they produce annual energy outlook every year that goes over a number of scenarios for our energy future that finds its way is the basis for a lot of policy decisions.
David Gahl: So adding to that, the Energy Information Administration every three years goes through this process of reevaluating the data they actually collect. And so they update the tools that they use to pull in all kinds of information on different subjects. And this past year in 2022, they launched a process to update what are called the Electric Power and Renewable Electricity surveys. And so as Justin and I talked about it, we came to the conclusion that this would be a great opportunity to collect some more information about interconnection as well as some other topics of interest to the solar and storage industries to have this more comprehensive baseline of data available to advocates such as Justin and the folks at SEIA, but also folks at the state level around the country who are working on a variety of different issues. And so we’ve submitted several rounds of comments now, encouraging the EIA folks to update the information that they’re collecting, and in particular try to collect more data about key issues and key problems that are slowing the deployment of solar and storage across the country.
John Farrell: Before we get into that juicy detail about what you were asking them to do, I was hoping to just take a minute – I’ll start with you David – just to ask like, how did you get into this work? I think one of the things a lot of people that listen to this are curious about is they hear folks on the podcast and it’s like, oh, this is what they’ve always done. I mean, for me, I feel like it’s true. I’ve been here for 15 years at the Institute for Local Self-Reliance, but other folks have kind of had an interesting progression into the industry. And David, I’m just kinda curious like what got you into this? What has made it interesting for you to be involved with this Solar and Storage Industries Institute? And then, Justin, I’ll come to you next.
David Gahl: I started off my career in the New York State legislature as I had the environmental and energy portfolio for one of the houses of the legislature here in the Empire State. And I’d always an affinity to environmental issues. It was a terrific opportunity to actually have some influence over policy at the state level, which led me down the path of learning more about climate change and ultimately trying to spend a lot of my professional career encouraging the development of renewable energy so that, so we can avoid the worst effects of climate change. And that’s where it started and I don’t regret a minute of it over the last 20 years.
John Farrell: Thanks David. Justin, what got you to SEIA?
Justin Baca: Like you, I’ve almost been doing this forever, <laugh>, I’ve been doing this for about 15 years. I came to SEIA straight outta grad school, which I went to knowing that I wanted to transition into the energy space after previously doing public lands advocacy. I’ve always been interested in energy, particularly interested in solar energy, having grown up in New Mexico <laugh> and being very aware of how strong the sun can be. It’s been a fascinating 15 years doing research for SEIA. I spend a lot of time with EIA data and see a lot of opportunities and missed opportunities to help the industry and the economy function better with greater transparency.
John Farrell: Well, that’s a perfect transition back to our conversation about the EIA and the comments that you developed. Maybe I’ll this back to David to start. Could you talk a little bit about what were the range of issues that you were interested in the EIA collecting data on? I know it wasn’t just about interconnection, you’re also interested in information about utility shutoffs and then maybe give a couple of examples about specific things that you’re looking to be shared.
David Gahl: Yeah, so we spent a lot of time in the comments on interconnection as you suggested. And in particular, I just wanted to make note of the fact that some of these data would even help U.S. Department of Energy interconnection efforts. They have something that’s called the Interconnection Innovation Exchange, where they’re trying to sort through some of these issues. But again, they’ve even been stymied by lack of decent data. So having some of this information would even help other agents, you know, other entities within the federal government to push these issues forward. But as you suggested, John, it’s not the only thing that we raised. We, we talked a lot about getting more information about transmission and distribution grid operations themselves. Like what’s the state of some of these transmission lines? How much headroom do they actually have? Making that information available to developers could potentially head off some interconnection issues at the large scale before they even stymie or ultimately cancel projects.

And then, as you suggested too, some information about system operations, like if there are better data about close calls at the distribution system level, for instance, if there are, at times when the grid operators realize that they may be running very close to their margins or they may, they may be looking at a series of potential shutdowns across their territories, having that information available developers will make for better grid management and will ultimately help put those resources where they belong to avoid those kinds of situations in the future. So some of that information about utility system outages is really important and even close calls and outages would be really helpful as well. And then I’m gonna tee this up for Justin because this is really his deep area of expertise, but just more information about solar manufacturing. The information that the EIA publishes is pretty, pretty heavily redacted when it comes to shipments of cells, what the modules look like, what the component parts look like. And I’ll send it over to Justin now because he’s the real expert here. <laugh>.

Justin Baca: Yeah, it’s a really opportune time to talk about data collection on manufacturing. You know, when we first drafted these comments, the Inflation Reduction Act had not yet passed, right? And had not been enacted. And one of the things we said was, you should really collect a lot more data on solar manufacturing, and you might have to do this anyway because the Inflation Reduction Act passes. There’s gonna be all these incentives out for domestic manufacturing and it’ll be based on production levels. So you can coordinate with our other agencies on this data collection. And we really need this data to have a better sense of just how effective our efforts are at reshoring manufacturing and gaining some resilience in our supply chains. We’re asking for, as David said, a lot less redaction but also a much more comprehensive look at the supply chain.

I will say also on the deployment side, one of the goals here is to enable third parties to do some hosting capacity analysis as opposed to relying solely on hosting capacity analysis done by distribution and transmission system operators. If we have the data so that others that can perform that analysis, we could identify on our own places in the grid that are ripe for additional deployment and hopefully address some of those interconnection delays before they become problems. And also look for solutions, right? If we only have one gatekeeper that has the ability to see this data and look for solutions, we’re not gonna find as many solutions as if everyone can do that. So that, that’s a big thing.

And then you had also asked, John, about the data we’re collecting. We suggested EIA collect on consumption and rate structures, right? Right now, EIA only collects revenue by customer class and sales by customer class for each utility. So, uh, say PG&E, the number of customers they have, how many megawatt hours those customers bought, and what the revenue is, right? So what you can get at that is average utility revenue per kilowatt hour for residential customers. But we know that that isn’t the price signal that customers see, right? They see their rate schedule, which is a fixed charge, and they see a volumetric charge. And if you’re a commercial customer, you might see a demand charge. And what we’d like to see is EIA collecting the actual rate structure for all of the different types of rate structures and then the revenues by line item for each of those rate structures so that we can see what price signals customers are really responding to and the way that these tariffs actually impact customers.

And this gets to some of our interests, not only as an industry looking to serve customers, but also for our social justice mission. We care about the tariffs that are being put on lower income customers. And this gets to the shutoffs as well. I mean, we see in New York right now the state’s getting ready to help cover the cost of unpaid bills, but we want to see how many customers were actually shut off from service because of unpaid bills. And right now that data is not readily available.

John Farrell: We’re going to take a short break. When we come back, we talk about the response from the Federal Energy Information Administration to the data requests, why it’s important to have data in hands other than the monopoly utilities, and what kinds of changes this data could enable at the state and regional level. You are listening to a Local Energy Rules podcast with David Gahl, Executive Director at the Solar and Storage Industries Institute, and Justin Baca, Vice President of markets and research at the Solar Energy Industries Association.

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John Farrell: What was the EIA’s initial response to the comments? So you said, you know, the first, I think the first comments were filed in the summer of 2022. They got back to you as I recall, and gave some feedback about what they thought about the feasibility of doing this. Maybe it’s worth noting again, Justin, your comment previously, it’s a small but mighty agency that’s got a lot on its hands. What was their initial reaction to the comments that you had? Were there some things that they were favorable towards or others that they weren’t? What in general did they say?
David Gahl: Well, I’ll start. They initially pushed back on some of our requests for additional data and then said that in the, sort of in a limited window of time they had to update their data collection efforts, that they, they couldn’t collect all the information that we were seeking. But in conversation with them, they did suggest that there could be ways that they could structure their surveys, add to their survey tools. For instance, if they added some, some dropdown menus, for instance, they would say, Hey, why was this project canceled? Well, it was because of an interconnection delay. Or, you know, you could add some fields in their existing tools that would allow them to collect data in a pretty efficient way building off their existing system. So I think that those were productive conversations as we were able to kind of dive into some of the details there.

I suspect that in this finalized round of the electricity surveys, they will adopt some of the changes that we’ve recommended. Not everything that we wanted, but at least having some of that baseline data, for instance, on interconnection would be super important. We’re hoping to see a series of additional changes over time because, especially with the passage of the inflation reduction act over the summer, it’s clear that EIA has to collect more data about renewable energy systems and their contribution to the grid and they’re going to have to keep making changes, probably not on a three year timetable, but on a more frequent basis because there’s just more to report on and, and the financial incentives and the drivers for renewable energy will require more data to help form policymakers about the effect of the law.

Justin Baca: It came off to me as very constrained by their IT infrastructure frankly, right? They, they’ve got a certain <laugh> survey tool they can use that was built out years ago and in the time table they’re working with, they can only make fairly modest changes. But, you know, to Dave’s point, they are planning on doing more in the future with more time. They can make more substantial changes.
John Farrell: I’m curious about, one thing that I think Justin, that you brought up a little bit ago, it was around the solar hosting capacity. So one of the things that you mentioned about the requests that you were making from the EIA was around this idea of hosting capacity. So essentially for folks who are not familiar, first of all, I’ve got a great podcast interview in Local Energy Rules back a ways on hosting capacity if folks wanna dig into that in particular. But the essential idea is where is there room to plug things into the grid already and where are there places where capacity is really tight?

What you talked about, in particular, I thought was interesting Justin, was this idea that if third parties had more of the information and could do more of their own analysis, we don’t have to rely on, gosh, it’s only like a half dozen or a dozen utilities across the country that seem to regularly be doing hosting capacity analysis. Some of them are maybe not very interested in it of course because the stuff that gets plugged in might not be things that makes them money though it’s an interesting sort of conflict of interest or tension for them around this.

I mean you also mentioned too, I guess I’ve this idea that there are state regulators who want information about the utilities they oversee and it’s sometimes easier for them to get it from the federal government than it is to get it from the utility that ought to be just giving them data when they want data, right? Like they are being regulated. I dunno if you could talk a little bit more about sort of this tension that there is for utility companies in operating a system in a monopoly fashion, as is true of all distribution grids at least. And if there may be some other examples or things, situations like this where it’s been very helpful to open up the books a little bit and let participants in the market have more access to data.

Justin Baca: Yeah, I mean, and it’s not just about being able to produce hosting capacity where the utility isn’t providing it, it’s also about having a different review on hosting capacity. For those who’ve been around as long as us and remember what happened within Hawaii, within Hawaiian Electric territory, they had stopped allowing interconnections at one point because they were getting up to, I think it was 110% minimum daytime load. And it was a process of HECo working with NREL and also some inverter manufacturers with a lot of data, sharing their data with NREL to come up with an analysis that showed, hey, we can actually probably go twice that high, right?

That was something where a lot of data was brought to bear and agreed upon view on what hosting capacity really is. I think we could do that in more places. Right now we just don’t have data at all and be great to get some and to be able to combine that eventually with actual inverter data or other system data would provide more options to use all the headroom we have available instead of using like a ultra-conservative made up engineering margin, right? <laugh>, It’s like, oh, 120 percent’s probably right number. We’d rather have some real analysis behind that.

John Farrell: I remember, since I have also long enough in the tooth to remember this discussion, some people described their initial rule as the 15% rule. And just to give people a sense of how they did this, it was sort of common knowledge or conventional wisdom that the daytime minimum load was about 30% of the peak rating of a distribution line and for a safety margin, they just divided it by two and said 15% is how much distributed solar you could put on this system. So it was really, there was almost no data at all involved other than somebody somewhere had must have come up with that rule of thumb about 30%. And then they just divided it by two God bless engineers, though, who were looking for safety margin, but it really is no way to operate a modern system. David, is there anything that you would want to add on this idea about like the data and the sort of conflicts of interest or data access and the ways in which it can enhance our ability to operate our grid more efficiently?
David Gahl: You’ve both touched on this, but I think, I think the data access piece gives industry folks and advocates the ability to challenge utility assumptions, right? I mean, and that that’s a probably another huge benefit of having this information available just to have an independent check on the information that the utilities put out there. Just seems to me that I’ve run across this in cases across the country where, you know, the utility, really the utility forecast or the utility analysis in whatever instance it is, is sort of treated as gospel when we know there are some questionable assumptions that went into what they are producing for regulators. So this might give us some new tools with advocacy across the country.
Justin Baca: And I would add to that Dave, that frankly, you know, utilities have a finite staff as well, right? They may have a small number of engineers that are available to work on this stuff and that just creates bottlenecks and we wanna remove bottlenecks.
John Farrell: It’s a good transition to something that I remember seeing in the EIA’s response to your initial comments, which was one of the concerns they had was creating a burden on distribution utilities. It sounded like from the standpoint of like responding to the survey, it made me laugh and ILSR also commented in this process and one of the things that I noted was that of course distribution utilities, in any utility like that that has a monopoly, can hire as many people as they need to do the job and their customer base is captive. It’s not like they’re gonna get priced out of the market by another competing utility for collecting that data. I guess do you, how do you feel about that response? Like do you feel there is a reasonable issue there, though? Is this like an IT issue for distribution utilities in the way that it might be for the EIA of like, okay, maybe we need to have a little bit of grace for them doing this, or do you feel like that idea of burden is a little bit overblown?
David Gahl: I think it’s overblown. I mean I think the electric distribution companies are answering all kinds of questions about their systems anyway, this is some additional questioning on top of that. It’s not that much more information. It did seem like it was not a great argument, but I think it, the other piece of this too is that there’s a fair amount of respondents to these survey tools from the solar industry on certain forms and certain surveys where the reporting burden is actually on industry participants and they’re interested in providing additional data and having the ability to do that. And Justin can speak more about this because he’s closer to it.
Justin Baca: Yeah, I mean particularly on the utility scale side, all projects larger than one megawatt AC are supposed to submit EIA form 860 and form 860M within 12 months of beginning commercial operations, maybe even 12 months of beginning construction. And so because a sizable majority of new power plants coming online over the next decade are gonna be solar power plants, it means that the solar industry is gonna shoulder the majority of the reporting burden on this. And the solar industry wants this information and it’s worth giving looking at this from a paperwork reduction act perspective, <laugh>, where the industry is asking to have the burden placed on it.

From the distribution utilities perspective, look, these utilities bill every single one of their customers every month, they know where their customers are, they know how much electricity they use, they know how much they build for each line item on the tariff, right? And unless they’re doing all that by hand, <laugh>, their computer can easily spit out summaries of those figures and I bet those summaries are spit out for someone at each of those companies on a regular basis. And EIA now has a record of having API access for data submission from balancing authorities, right? Their form 930, which they enacted one or two cycles ago, accepts hourly and I think maybe even sub hourly data on electric grid performance, right? And this is less burdensome than that, especially if it’s automated.

It, you know, the Paperwork Reduction Act sort of envisions people having this reporting burden of paperwork. But what we’re talking about here is automating stuff <laugh>, right? And so it could actually be lower burden. Yes, you set it up and you may have to maintain it, but after that it’s probably ends up being a lower burden than answering these questions one off from regulators and whoever else on a irregular basis.

John Farrell: Speaking of regulators, what is interesting to me about this is that we have 50 different state regulatory frameworks for the electricity market. This our, our traditional model is to do this at the state level. We have the problem of we don’t really want to have to go and try to set up data collection regimes in 50 different states because making sure that they were all the same and that that data is comparable would be a disaster. So we go to the federal government and we get the data hopefully from EIA with this survey, should they eventually incorporate it into their surveys? So they’ll collect this data, but who sets the policy ultimately? Like what changes could come from this and at what level are we likely to see the changes? Is it gonna be back at the state level that we would see potential policy change enacted if, for example, we learned things about interconnection cost and data and are there good examples of reforms that could streamline things?

I’m thinking of a couple just off the top of my head. One is, I think it was in Vermont, it was years ago, set up sort of a presumptive interconnection for small scale solar. Basically like if the utility doesn’t object within, I don’t know, it was 10 or 30 days or something, then you get to plug in your project. And then I guess I’m also thinking about Hawaii, obviously there’s been a lot of iterations. Justin, you already mentioned kind of the history there where the utilities profits now are dependent on performance metrics that may include things like helping to facilitate interconnection of solar, which obviously could be informed by the kind of data that could be collected. So what sort of policy changes do you envision could be coming out of this and who would be doing them and are there good examples that you’re seeing out there?

David Gahl: I think there are three theaters where policy reforms could happen. First we, let’s start at the state level. All public utility commissions have tariffs that guide the interconnection of distributed resources. And so I think these additional data, if they would show that there are significant increased costs for trying to connect either large distribution or rooftop systems to their grids kind of raises a question about, okay, if the upgrade cost to the system is really expensive, who should be shouldering the burden of that cost? Should it be only on the developer? Should it be on the developer? And then the other rate payers? How does that formula get determined? And so it raises this whole series of questions about if the goal is to connect a whole bunch more of these systems quickly, then the questions about cost and questions about who bears an appropriate portion of that cost come to the fore.

I think the second area for potentially form activity would be at the RTO level. So if these data show that there are, you know, similar problems that you saw at the distribution level, then the RTO processes and their working groups and in their operational planning, they could come up with streamlined interconnection procedures. So they could come up with some ways to address the high costs of upgrades there too. Even within the governance structure of an RTO.

John Farrell: Just really quick, the RTO for folks that aren’t familiar, the regional transmission organization, so on the high voltage transmission, the larger projects.
David Gahl: And so the third theater would be actioned by the Federal Energy Regulatory Commission. I mean they ultimately decide the broad policy for how the RTOs operate, for instance. And they could take up a series of reforms where they would sort of set a policy standard and then the individual RTOs would have to adopt what FERC sets as the national policy. So this could play out a lot of different ways, but ultimately everybody needs good data, make good decisions. And that’s in part why we got interested in this exercise.
John Farrell: One of the things that’s really interesting to me going back at the state level there is that, and to your point David, about this question about how costs are allocated when a grid needs upgrades. What I find really interesting is I feel like on the side of load growth, so if just in terms of using more energy, if I buy more electric appliances, if I use more electricity, historically those costs have just been socialized, right? When the utility has more customers using more energy, they’ll just upgrade transformers or substations and all pay for that collectively.

And so I guess I’m kind of curious if there are ways in which that practice on the side of load growth ought to be applied to some degree around this idea of interconnecting generation, especially when at the smaller scale it’s really hard to plan for all of the different ways that people could be doing this. I mean, this kind of gets maybe to that issue of hosting capacity as an analysis of like helping people plug in where there is space, but at some point we are potentially gonna generate more locally than the grid was built to deliver locally and we’re sort of sharing across different local areas and regions. I don’t know, I’m getting pretty far into the weeds here, but I guess I’m just sort of curious about this broad idea that we socialized the cost of using more energy and here we are talking about people sort of using their own money to bring in power generation into the system and a whole bunch of different points. But as our current practices largely that make those folks pay to deliver that cost to the grid as opposed to socializing it the way we’ve done with using energy.

David Gahl: Yeah, and I just come back to the goals. I mean for the most part, state regulators across the country or state legislatures across the country for that matter, have set these pretty ambitious renewable energy transition goals. So they want to reduce greenhouse gas emissions by 70% by the year 2030, for example in New York. And if you’re serious about reaching that goal, you have to take, you have to connect systems quickly and you have to connect systems at volume.

And so I think your point’s an excellent one, John, that we need to be thinking about what’s a proper allocation of cost among the rate payers to achieve that overall objective. And does it mean potentially having more rate payers pay for the cost of interconnection upgrades so that we can interconnect systems more quickly? That seems like it’s a good idea to me. And Massachusetts has sort of headed down this path already. They have a couple of interconnection proceedings over at their department of public utilities where they’ve set sort of an upper limit for connecting smaller systems and then any cost above that limit would actually be socialized to the rate base in that particular area. So that seems like a promising model for trying to get systems connected more quickly and should really be looked at by other states.

John Farrell: Justin, is there more that you would add in terms of thinking about what policy reforms or ideas might come out of having access to this data as well as any examples that you have that you think that are worth mentioning?
Justin Baca: I would say that just having the data, because we’re gonna try <laugh> lots of things, you know, we’re gonna have 50 different states come at this from probably more than 50 different angles and finding out which ones work well, being able to say which ones work well will help us hone in on the right solutions, right? Otherwise we don’t have a way of comparing one to another. We’re just gonna keep making new mistakes. I think it’s just helpful for us to actually learn from each other’s experiences that way.
John Farrell: What’s the next step here, if that’s helpful?
Justin Baca: I would say the next step is to find out what EIA does with this round, but then really work with them and with industry to try to come up with the right approach for the next round of updates for these forms, right? This is gonna be an iterative process. Showing EIA what would be useful if the policy makers and industry is gonna be an ongoing exercise.
John Farrell: Is there anything for other folks who have been involved in clean energy, climate, solar advocacy, kind of as you were getting to David, to these goals that folks have won through hard work at advocacy at the state level, is there something that they could do to be helpful here? Like will there be another comment process that’s open, for example, so if you’re working at the state level, maybe you take a break and you also join in on some comments at the federal level to say, hey, we would find this useful. In the spirit of what you were saying, Justin, we would like to experiment with policy approaches here, but we don’t even have enough information to do this. Will there be other opportunities to intervene?
David Gahl: Absolutely. So this round of comments on the electric power and renewable electricity surveys that’s wrapping up. We expect EIA to finalize its survey process within the next couple of months. But as Justin pointed out earlier, EIA has already communicated to us that they understand they will need to continue to collect more data on these topics. And so this will get reopened. And so I would encourage state advocates around the country that are listening to this, that this may be a place to spend a little time. Notices pop up in the federal register. And as you see sort of calls to action from SEIA, for instance, this would be a good opportunity for you to make your voice heard and weigh in on some of these topics to help us ultimately get the data we need to drive reform and help the deployment of solar and storage across the country.
John Farrell: I’ll make sure too that on our show page for people who, like myself, who are not familiar with parsing the federal register, what to look for in terms of those opportunities as well when they do pop up. Justin and David, thank you so much for coming to talk about this work of extracting more data about a very active sector of our electricity business.
Justin Baca: Thanks for having us.
David Gahl: Thanks John.
John Farrell: Thank you so much for listening to this episode of Local Energy Rules about the need for better interconnection data with David Gahl, executive director at the Solar and Storage Industries Institute and Justin Baca, vice president of markets and research at the Solar Energy Industries Association. On the show page, look for links to ILSR’s Solar Developer Survey and our analysis of the limited national interconnection data that shows a lot of variation in cost and timelines for solar projects to get grid connected. We’ll also have links to the comments sent to the Energy Information Administration by SEIA and SI2 as well as ILSR’S comments on the same issue. And we’ll have a link to the search page at the Federal Register where you can see future opportunities to comment. Please also feel free to reach out to me, to Justin, or to David if you’d like to join in. Also on ILSR’S website, you can find my interview with Yochi Zakai about hosting capacity and why it’s valuable data for expanding solar access. You can also find a recent conversation that I had with developer Dan Juhl about the challenge of connecting SolarWind hybrid projects to the grid, or my talk with Howard Crystal and Liz Veazey about a petition to the Federal Trade Commission to investigate monopoly utility abuses, including their power over interconnection.

Local Energy Rules is produced by myself and Maria McCoy with editing provided by audio engineer Drew Birschbach. Tune back into Local Energy Rules every two weeks to hear more powerful stories of communities taking on concentrated power to transform the energy system. Until next time, keep your energy local and thanks for listening.


An Information Gap Hinders the Growth of Small Solar

Thanks to the availability of small-scale, distributed solar systems, residents, businesses, and communities have become power players in the expansion of our electricity supply. Utilities, on the other hand, are not used to sharing the responsibility of electricity generation. Their data collection and grid management policies were not designed to facilitate the entry of competitors.

In ILSR’s 2021 Local Solar Developer Survey, most developers reported delays and unexpected costs when trying to connect their projects to the electric grid. Baca and Gahl argue that some of these problems come from data asymmetry — utilities hold all of the information about the grid and their customers.

It is hard for distributed energy advocates to measure the scale of the problem, since utilities do not report data on interconnection delays or why projects are abandoned. The National Renewable Energy Laboratory publishes some data on interconnection timelines, but our analysis is limited, as the data sample is small.

The U.S. Energy Information Administration (EIA), which broadly collects data on the U.S. energy system, has the authority to fill in some gaps.

SEIA and SI2’s Letter to the Energy Information Administration

The Solar Energy Industries Association and the Solar and Storage Industries Institute have asked the U.S. Energy Information Administration to collect better data in their Electric Power and Renewable Electricity surveys. In particular, they asked for more information about interconnection delays, abandoned projects, customer disconnections for nonpayment, grid transmission capacity, and solar manufacturing.

We thought starting with better data that the Energy Information Administration collects would be foundational to ultimately reforming some broken processes.

— David Gahl

If they had greater access to information about the grid and its hosting capacity, third party solar and storage developers could even support utilities by plugging into the electric grid where additional capacity is needed.

If we only have one gatekeeper that has the ability to see this data and look for solutions, we’re not gonna find as many solutions as if everyone can do that.

— Justin Baca

Although the EIA pushed back on some of their requests, Baca and Gahl do expect some changes to the survey — which the EIA will finalize in the coming months.

Episode Notes

See these resources for more behind the story:

For concrete examples of how towns and cities can take action toward gaining more control over their clean energy future, explore ILSR’s Community Power Toolkit.

Explore local and state policies and programs that help advance clean energy goals across the country, using ILSR’s interactive Community Power Map.

This is the 177th episode of Local Energy Rules, an ILSR podcast with Energy Democracy Director John Farrell, which shares stories of communities taking on concentrated power to transform the energy system.

Local Energy Rules is Produced by ILSR’s John Farrell and Maria McCoy. Audio engineering by Drew Birschbach.

This article originally posted at For timely updates, follow John Farrell on Twitter, our energy work on Facebook, or sign up to get the Energy Democracy weekly update.

Featured Photo Credit: BlackRockSolar via Flickr (CC BY 2.0)

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Maria McCoy

Maria McCoy is a Researcher with the Energy Democracy Initiative. In this role, she contributes to blog posts, podcasts, video content, and interactive features.