Specifically, the Commission seeks comments on this list of questions and any other topics that interested parties believe should be included in potential regulations on the interconnection of electric loads.
The questions include--
1. What electric load interconnection issues should be addressed via regulation? Please list the specific issues and how a regulation would be beneficial.
2. Should regulations concerning load interconnection be formulated and applicable by customer class, interconnection voltage or tariff rate?
3. Should load interconnection requests have different review levels based on load size, similar to generation interconnection review levels? If yes, please provide the load size range for each level of review and the rationale for these levels.
4. If there is generation collocated with the load, should there be an expedited process for the generation to be interconnected at the same time the load is interconnected?
5. Some electric distribution companies (EDCs) provide online portals for the interconnection of distributed energy resources. Should the same be provided for load-interconnecting applicants to submit all applications and supporting documents? Please list the benefits or drawbacks.
6. What are some methods that may be used to discourage applicants from submitting duplicative projects with different EDCs?
7. In order to establish a position in the EDC's queue, would requiring a load interconnection applicant to pay a fee, based on the level of review, be effective in minimizing duplicative projects with different EDCs?
8. Should projects be able to move ahead of other projects in the queue based on completion of certain milestones? If so, please offer the criteria and conditions that should be considered and any that should not be a determining factor.
9. What if any protocols should be in place for circumstances where an applicant can jump ahead in the queue?
10. For the load interconnection applications, should the EDCs charge an application fee? If yes, please answer the following:
a) Should a fee be required for load sizes above a certain minimum threshold and should such a fee increase based on the size of load? If so, what should that threshold be?
b) What payment methods should EDCs accept?
c) Should EDCs allow for electronic payments without administration fees?
d) Should an EDC's costs for processing load interconnection requests be aligned with the cost structure for load interconnection application fees?
e) Should there be more oversight of load interconnection application fees to avoid any potential arbitrary fees?
11. Once a load interconnection request is submitted, what information should the EDC provide to the applicant, and by what means and frequency? Examples may include queue position, status of load study, anticipated timeline for completion, etc.
12. Should there be prescribed timelines and timeframes for completing the various steps in the load interconnection application review process? If so:
a) Please provide a list of steps in the process and a reasonable time to complete each step. Please include various studies that may be required as part of the review process.
b) What is a reasonable timeframe to complete a load interconnection application review?
c) What timeline should exist for EDCs to complete the review of collocated load and generation requests, if any?
d) If an EDC exceeds its expected review timeline, what actions should the EDC be required to take?
13. Should there be separate queues for both generation and load interconnection requests? Why or why not?
14. How should the Commission address situations where there are exigent circumstances delaying a project's review or approval to interconnect from proceeding? Examples of these circumstances may include unexpected developments, need for additional studies, changing guidelines, etc.
15. Should EDCs be required to provide hosting capacity maps?
a) If yes, what are the benefits, if any, of requiring EDCs to develop hosting capacity maps containing EDC feeder data and locations for substations, distribution transformers, line voltage, and related distribution assets?
b) What are the concerns regarding this requirement, if any?
c) What aspects should be considered for these hosting capacity maps? Examples may include the frequency of updates, transparency, filtering and toggling mechanisms, size and number of applications for a certain location, identified system constraints, complaint process, etc.
16. Should EDCs be required to publish a public list of projects in an EDC's load interconnection queue?
a) What are the benefits, if any, of requiring EDCs to post on its website a list of projects in its load interconnection queue that includes the project's queue position, nameplate capacity, and circuit identifier in a manner that protects the identity of the project owner and the location of the project?
b) What are the concerns regarding this requirement, if any?
c) What aspects should be considered for these public lists of projects? Examples may include timing for updates, transparency, filtering and toggling mechanisms, complaint process, etc.
How To Submit Comments
Comments referencing Docket No. L-2025-3059032 shall be submitted to the Public Utility Commission, Attn: Secretary, Commonwealth Keystone Building, 2nd Floor, 400 North Street, Harrisburg, PA 17120 within twenty (20) calendar days from the date of publication of this Secretarial letter in the Pennsylvania Bulletin.
Any questions regarding this letter should be directed to Darren D. Gill, Deputy Director, Bureau of Technical Utility Services at 717-783-5244 or dgill@pa.gov.
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