Promoting Electrotechnology Careers and Public Policy

Testimony on Interconnection
of Distributed Resources

before the

Senate Energy and Natural Resources Committee
United States Senate

By

Thomas R. Schneider, Ph. D.

Vice Chair, Energy Policy Committee
The Institute of Electrical and Electronics
Engineers - United States of America

June 22, 1999

Good Afternoon. I am Thomas R. Schneider, the Vice Chair of the Energy Policy Committee of The Institute for Electrical and Electronics Engineers - United States of America (IEEE-USA). I have been a member of The Institute of Electrical and Electronic Engineers (IEEE) for more than 26 years. My academic background includes an undergraduate degree from Stevens Institute of Technology and a doctorate from the University of Pennsylvania. My professional career includes postgraduate research in renewable energy, work in planning and research at an electric and gas utility, PSE&G, and more than 20 years with the Electric Power Research Institute (EPRI). At EPRI, I served as program manager for energy storage, director of an end-use technology department and executive scientist for strategic science and technology. From 1985-87, I served as President of the Lighting Research Institute. Currently I am in private practice consulting on energy, technology, resources and strategy.

On behalf of IEEE- USA, I would like to thank the Committee for the invitation to testify. We also commend the Committee for its efforts to illuminate the issues that will be discussed today.

This testimony represents the position of The Institute of Electrical and Electronics Engineers - United States of America and has been reviewed by members of IEEE's Standards Association and Power Engineering Society. These views will largely focus on the issue of interconnection standards and their relevance to pending legislation, especially Section 405 of S. 1047, the Comprehensive Electricity Competition Act.

IEEE-USA promotes the career and public policy interests of the 225,000 US members of the IEEE, the world's largest technical professional society.

IEEE-USA offers the following general principles concerning development and implementation of interconnection standards for distributed generation:

• Professional society, consensus standards are the best approach. Standards developed in this process assure reasonableness and technical quality. Broad participation in the development and review of the document provides for consensus with the scope and content of the standard. Adoption of consensus standards simplifies interstate commerce and common engineering practice within the USA. In addition, coordination with International Standards is also important in cases where the interstate grid system interacts with systems in Canada and Mexico.

• Quality standards take time to develop. It is important to recognize the development of quality standards has been done quite effectively through the volunteer consensus process outlined above. Developing standards by a proven process provides higher quality and is preferable to fixing a low quality standard developed because of time constraints or legislative mandates.

• The standards process can be accelerated. Additional financial support to fund necessary engineering studies and possibly "out of pocket' expenses of volunteer committee members can expedite the process. Historic precedents exist for this support. This would also conform to the intent of OMB Circular A-119, revised February 19, 1998, which specifically encourages agency (such as DOE) support of standards development, domestically and internationally.

• Congress and DOE are encouraged to support the development of standards on interconnection technology as a common public good. Network interconnections are critical to the economics of distributed resources and the safety and reliability of the power system.

With respect to these general principles and observations based on past and current standards setting activities, IEEE-USA offers the following comments on S. 1047, Section 405:

`SEC. 405. INTERCONNECTIONS FOR CERTAIN FACILITIES. `(a) DEFINITION- As used in this section `facility' means-- `(1) a small-scale electric power generation facility that is designed to serve customers at or near the facility, or `(2) a facility using a single fuel source to produce at the point of use either electric or mechanical power and thermal energy. `(b) INTERCONNECTION- A distribution utility shall allow a facility to interconnect with the distribution utility if the facility owner is located in the distribution utility's service territory and complies with the final rule issued under subsection (c). `(c) Within one year from the date of enactment of this section, the Secretary shall issue a final rule to implement subsection (b) and issue related safety and power quality standards. To the extent feasible, the Secretary shall develop the standards through a process involving interested parties. `(d) The Commission shall enforce the rule established under subsection (c) using its authority under this Act.'.

If the language in Sec. 613 (2)(b,c) becomes law, we anticipate productive cooperation between the Department and the ongoing IEEE standards efforts. However, we are concerned the time frame for issuance of a final rule by the Secretary will not allow the time necessary to develop proper standards to assure optimum safety and power quality.

We believe that, at a minimum, a distributed generation interconnection standard should address operational and safety issues. A standard of this nature would also need to be flexible enough to allow for the inclusion of site-specific details to be incorporated into the interconnection. The future success of distributed resources will be determined by many factors - and interconnection standards will be one key element along with the eventual economics of the equipment, fuel prices, market forces, government policy, etc.

There is a clear need for a comprehensive standard, tests and test methods as technology continues to evolve. The absence of a high quality, fair and equitable interconnection standard could indeed be a serious barrier to new distributed resources. For this reason, efforts were started in the early 1980's by IEEE, DOE and other groups such as the EPRI, to understand and clarify the issues related to this topic.

Currently all fifty states are looking at their interconnection standards needs, as are the electric power producers and manufacturers of distributed resource equipment. These signs also point to the need for a national interconnection standard and the IEEE looks forward to assisting in meeting these needs.

In a modern context, IEEE has been addressing emerging new distributed resources for nearly two decades through technical sessions and panels in several of the societies. Indeed, my own first IEEE publication, in 1976, was on the utility interface of distributed storage. Two of the most popular sessions at the February 1999 meeting of the IEEE Power Engineering Society were on Micro-turbines and Fuel Cells. Similar interest is visible in the activities of IEEE's Industrial Applications Society.

Starting in the early 1980's, considerable efforts were begun to develop guidelines, practices and standards for these technologies. The first IEEE guide in this subject, IEEE STD. 1001, was approved in 1988. As early as 1983 DOE funded an investigation in this field. A more detailed study, sponsored by EPRI and published in 1998, updates and expands on that earlier study. Also in 1998, the earlier IEEE effort was expanded in light of recent advances in several of the technologies and the prospects for near-term commercialization.

IEEE Standards

Through its Standards Association, IEEE is a world leader in the development and dissemination of voluntary, consensus-based, industry standards involving today's leading-edge electrotechnologies. The organization is committed to broadening the scope of the standards products and services it produces to embrace the demands of new technologies and to respond to market needs.

IEEE Standards supports international standardization and encourages the development of acceptable standards. IEEE develops and publishes standards that include, but are not limited to the following: definitions and terminology; methods of measurement and test; systems; products; technology; ratings structures; temperature limits and application guides; recommended practices; and safety.

The approval and publication of an IEEE standard implies that the document represents a consensus of the parties who have participated in its development and review. Since every attempt is made to involve all interests in the activity, it can be presumed that the document represents a consensus of interests concerned with the scope of the standard.

IEEE Standards Coordinating Committee 21 (IEEE SCC21)

SCC21 oversees the development of standards in the area of fuel cells, photovoltaics, distributed generation, and energy storage. The expanded scope of SCC21 was approved by the IEEE Standards Board on June 25, 1998. SCC21 coordinates efforts in these fields among the various IEEE societies and other appropriate organizations to insure that all standards are consistent and properly reflect the views of all applicable disciplines.

SCC21 reviews all proposed IEEE standards in these fields before their submission to the IEEE Standards Board for approval and coordinates submission to other organizations.

There are 19 Working Groups under SCC21. Perhaps the most critical one is Working Group 1547 - Standard for Distributed Resources Interconnected with Electric Power Systems. This working group was charted last year. This standard establishes criteria and requirements for interconnection by distributed resources with electric power systems. The purpose is to provide a uniform standard for interconnection of distributed resources with electric power systems and requirements relevant to the performance, operation, testing, safety considerations, and maintenance of the interconnection. The organizational meeting of SCC21 was held in December of 1998 - (hosted by DOE in Washington, DC) - and Working Group 1547 organized. The IEEE Standards Board approved the project on March 13, 1999. The working groups met April 26-27 and will next meet June 28-30. The membership is approaching 200.

The IEEE and IEEE-USA

The IEEE is a transnational technical professional society whose membership currently includes more than 320,000 individual electrical, electronics and computer engineers in 147 countries.

The IEEE-USA mission is to recommend policies and implement programs specifically intended to serve and benefit the members, the profession, and the public in the United States, in appropriate professional areas of economic, ethical, legislative, social and technology policy concern.

Summary

In conclusion, IEEE-USA urges the committee to recognize that development of high quality interconnection standards and protocols is a process that needs adequate time to develop through participation of the many interested parties. Professional-society, consensus standards are the best approach. Standards developed in this process assure reasonableness and technical quality.

We urge the committee to include language that will allow adequate time and support for standards that will assure our current high standard of power quality and safety. The IEEE-USA looks forward to working with you to develop appropriate language on interconnection standards.

Again, thank you for your interest and I look forward to responding to your questions.

The Institute of Electrical and Electronics Engineers - United States of America
2001 L Street, N.W., Suite 700, Washington, DC 20036-5104
Office: (202) 785-0017 * Fax: (202) 785-0835 * E-mail: ieeeusa@ieee.org

| Top of Page | Policy Log | Public Policy Forum | IEEE-USA |

Last Update: May 29, 1999
Staff Contact: Raymond Paul, r.paul@ieee.org