Michigan Interconnection Rules Staff Strawman Overview

Michigan Interconnection Rules Staff Strawman Overview Julie Baldwin Nicholas Evans July 16, 2019 Rules Framework Strawman title: Interconnection, Distributed Generation, and Legally Enforceable Obligation Standards Allotted R 460.901 through R 460.1101 Part 1. Part 2.

Part 3. Part 4. General Provisions Interconnection Standards Distributed Generation Standards Legally Enforceable Obligation Standards Strawman Progress Definitions Applicability Adoption of Standards by Reference Alternative Dispute

Resolution Appointment of Experts Waivers Public Queue Interconnection Procedures Online Applications and Electronic Submission Communication Pre-Application Process Interconnection Application Modification

Site Control Fast Track Process Fast Track Process Overview Size eligibility still under review Matches FERC SGIP as currently written Initial screens Subset of screens applicable to 20 kW and under interconnections Potentially, additional screens may be added which are only applicable to 20 kW and under If the interconnection passes the screens Interconnection customer to pay good faith cost estimate (if any),

proceed to installation, local government inspection, commissioning tests, interconnection agreement and final approval to operate Proceed to Facilities Study, if necessary Fast Track Process Overview (cont.) If the interconnection fails any of the initial review screens Proceed to supplemental review screens Customer options meeting Proceed to supplemental review screens Move to study process Withdraw application

Fast Track Process Overview (cont.) Supplemental review screens Interconnection customer may specify the order of screens and pays actual costs of the review If the interconnection passes the supplemental screens Interconnection customer to pay good faith cost estimate (if any), proceed to installation, local government inspection, commissioning tests, interconnection agreement and final approval to operate Proceed to Facilities Study, if necessary Fast Track Process Overview (cont.)

If the interconnection fails the supplemental screens Proceed to study process Consider electric utility-recommended modifications, if any Withdraw application Example Category 1 Timeline Processing Step Application Received Application Complete Fast Track Initial Review Screens Interconnection Customer notifies Electric Utility when project is installed

and any required local code inspection and approval is complete Utility witnesses commissioning test and inspects site Interconnection is approved and electric utility provides the interconnection agreement Electric Utility provides approval to operate Number of Days Electric Utility notifies interconnection customer of receipt Notification within 10 business days

Review complete and interconnection customer notified within 20 business days Determined by interconnection customer Not Specified Within 5 business days of commissioning test and site inspection To be determined Queueing Do we want a separate queue for Category 1 and 2 projects (up to 150 kW)? Should Fast Track Initial Review, Fast Track

Supplemental Review, and Study Process proceed in the same queue? Should the utility decide on a queue process and explain the mechanics in interconnection procedures? Some remaining issues Procedures vs. Rules Use the term DER or something else (need to incorporate energy storage)? Are there too many timelines for reasonable tracking? More thought needed to determine the optimal number of days for each step. Need Michigan-specific adaptation of initial &

supplemental review screens? Fast Track size eligibility Queueing Next Steps Staff will email the first part of the strawman to the workgroup today Staff will present the remainder of the strawman at our final stakeholder meeting on August 28 Plan to request comments on the full strawman by a date in September (TBD) Another round of comments will be requested, if needed

Thank you! Questions?