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

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>.

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.

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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.

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.

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.

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.

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?

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.

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.

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.

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