Building Careers and Shaping Public Policy

27 March 2003

The Honorable Sherwood Boehlert Chair,
House Committee on Science
U.S. House of Representatives
2246 Rayburn House Office Building
Washington, DC 20515

Dear Representative Boehlert:

On behalf of the Institute of Electrical and Electronics Engineers-United States of America (IEEE-USA), I would like to request that the Science Committee adopt sections 2122 and 2128 from the House of Representatives version of H.R.4 in the 107th Congress as it marks up this year's energy bill. This language recommends that Congress and federal and state agencies support the adoption of interconnection standards developed by a consensus of professional societies on a voluntary basis, such as those established by IEEE's Standards Coordinating Committee-21 P-1547, a working group that was chartered in 1998 for developing the interconnection standard.

This working group, comprised of 350 technical experts representing a broad cross section of interested stakeholders, is currently establishing the technical criteria and requirements for interconnection of distributed resources with electric power systems. Work on the standard is expected to be finalized by May of this year. Standards developed by such consensus-based processes assure reasonableness and high technical quality and encourage the likelihood of broad acceptance. The lack of technical standards has been the biggest barrier to the economic interconnection of renewable resources and distributed generation. Interconnection standards are absolutely essential to making renewable resources economical by lowering their installed costs and facilitating their economies of scale.

We would like to reiterate what David Garman, Department of Energy Assistant Secretary for Energy Efficiency and Renewable Energy, testified before the Senate Energy and Natural Resources Committee on July 19th of 2001:

The Department of Energy has been supporting efforts by the industry through the IEEE to develop voluntary national interconnection standards. This effort has been in effect for the past several years and has involved extensive working group deliberations involving staff from electric utilities as well as equipment manufacturers and distributed energy project developers. The technical standard being developed by the IEEE could well provide a basis for the rulemaking process and, the minimum, should be referenced to ensure that the progress that has been made by this group is not lost or duplicated unnecessarily.

This need was further specifically cited in the Department of Energy's National Transmission Grid Study in 2002:

Current utility procedures for interconnecting distributed generation to the electricity grid are generally expensive and transparent. The Institute of Electrical and Electronics Engineers (IEEE) is working to establish technical standards in its draft standard IEEE P1547. This effort must be completed soon to help promote distributed generation solutions. Standardized interconnection procedures (agreements, rules, and business procedures) are also needed to reduce costs and clarify requirements (Chapter 4, p. 44).

The language of Section 2122 will ensure a smooth transition to using the document in legislation, rule-making, etc. that will accelerate the interconnection process. The government encourages industry standards (see OMB circular A-119) and with the IEEE, a professional society known for it electrotechnology standards, utilization through government encouragement will make it happen faster and eliminate the possibility of other entities from further delaying interconnection through duplication of effort already expended and successfully accomplishing the mission already achieved.

This is an opportunity to use real industry consensus inputs that required the special expertise needed and provided by the government and industry. If there has ever been a partnership, this has been one that exemplifies the word. The congress should recognize these efforts and minimize further barriers by adopting or recognizing this entity the IEEE and the efforts of SCC21 p1547 Standards development.

IEEE-USA is an organizational unit of The Institute of Electrical and Electronics Engineers, Inc, created in 1973 to promote the careers and public policy interests of the more than 230,000 electrical, electronics, computer and software engineers who are U.S. members of the IEEE. If we can be of further assistance, please contact Bill Williams in our Washington office at (202) 785-0017 x 8331 or email at bill.williams@ieee.org.

Sincerely,

James V. Leonard, P.E.
2003 President

Attachment A

The critical language the 107th Congress House version of HR 4 is as follows.

Definition of distributed power.
SEC. 2122. DEFINITIONS.
For purposes of this subtitle-

(2) the term "distributed power source" means an independent electric energy source of usually 10 megawatts or less located close to a residential, commercial, or industrial load center, including-
(A) reciprocating engines;
(B) turbines;
(C) microturbines;
(D) fuel cells;
(E) solar electric systems;
(F) wind energy systems;
(G) biopower systems;
(H) geothermal power systems; or
(I) combined heat and power systems.

SEC. 2128. VOLUNTARY [NATIONAL] CONSENSUS [TECHNICAL] STANDARDS.

Not later than 2 years after the date of the enactment of this Act, the Secretary, in consultation with the National Institute of Standards and Technology, shall work with the Institute of Electrical and Electronic Engineers and other standards development organizations toward the development of voluntary consensus standards for distributed energy systems for use in manufacturing and using equipment and systems for connection with electric distribution systems, for obtaining electricity from, or providing electricity to, such systems.

(Similar letter sent to all members of the House Science Committee)