Toronto: A wide-ranging development of the standards for connection of generation to the Hydro One distribution system is under consideration by Hydro One. Earlier this year, Hydro One released a set of documents outlining its proposals, and invited interested parties to provide comments and attend a stakeholder workshop. The first round of responses from generators have now been tabled.
About 350 written comments have been received from about 30 respondents. Hydro One plans to have all responses posted on its website by mid June. The questions indicate that the reaction from generators has been varied. There seems to be a mix of satisfaction that efforts have been made to provide clarity on connection requirements and consult on important questions, and concerns about some of the specifics being proposed.
Ontario Power Generation Inc. provided comments and also released a letter summarizing its concerns with the proposed standards. It identified three major areas of concern:
1. The applicability of the new standards to existing equipment and installations
2. The potentially arbitrary nature of some of the technical requirements, particularly given the absence of cost/benefit analysis, and
3. The possibility that the new requirements may create additional barriers to the development of renewable power projects.
It appears there is still some work to do to clarify the specific conditions under which the proposed standards would be applied to existing or modified installations. Not surprisingly, existing installations often find it difficult to find the money to meet new requirements if the facility was built to meet the standards in place at the time of commissioning and financed on the same basis.
With respect to the “potential arbitrary nature of many of the proposed technical requirements,” OPG says that “the proposed technical requirements should not be unilaterally imposed by Hydro One and need to appropriately balance the interests of the distributor, in relation to the management, operation and reliability of the distribution system, and the interests of the generators connected to the distribution system.” It cites the “lack of discussion to justify the requirements relative to a cost/benefit analysis.”
On the broader question of how the proposed new standards would affect the prospects for new generation development, OPG had the following to say: “It appears that many of the requirements will not provide for an expeditious interconnection to Hydro One’s distribution system, which may be counter to other initiatives, already underway, which are intended to streamline the connection process. In fact, the requirements may create additional barriers to the development of new generation projects, which would be an undesirable outcome. Hydro One should ensure that any changes to the technical interconnection requirements should facilitate the development of new generation projects in the province and not create additional barriers that would unintentionally undermine other policies related to renewable generation.”
OPG also identified a number of specific concerns with the proposed standards in the areas of ferro-resonance, generator controls, protection requirements, configuration of interconnecting transformers, and telecommunication, monitoring and reporting.
The AgriEnergy Producers Association of Ontario held a meeting on the subject with Hydro One. Some of its members have produced a range of comments, which are to a great extent consistent with the comments above.
Ian Bradley, Manager of P&C Programs for Hydro One notes that the utility, “understands that there is still some work to do to clarify the specific conditions under which the proposed standards would be applied. Hydro One also recognizes that existing installations often find it difficult to find the money to make modifications to meet new requirements and is working with the ministry, OEB and internally related to this. With respect to the cost benefit question, Hydro One is interested in proponents identifying the specific incremental cost issues they see with the requirements. Hydro One will work actively and openly to find optimal solutions to contain costs while ensuring load customers are protected.”
Hydro One held a workshop on May 13, 2009 to provide an opportunity for multi-lateral discussion. The agenda and presentations from this workshop can be found on the Hydro One website at the address below.
(See also “Hydro One invites comment on new set of DG standards,” from IPPSO FACTO, April 2009.)
A full set of background documents, including the proposed new standards themselves, are posted on the Hydro One website at www.HydroOne.com/DG.