At our next Technical Conference session, we will continue our discussion of the self‑build proposal. As part of this discussion, Pepco will report back on the telemetry‑related questions raised during the meeting and in the CHESSA presentation, including:
What does Pepco’s current process for approving contractors for distribution system upgrade construction involve?
- Would it be feasible for interconnection customers to complete the process?
- Are there labor concerns that might be implicated?
How many types of interconnection facility (customer side of the point of common coupling) jobs are there that Pepco currently requires its own contractors do? How many types of interconnection facility equipment does Pepco currently require be procured by the utility?
- Is there a list of the most common types?
- Could they be reviewed systematically to determine whether interconnection customers might be allowed to do more of this procurement and/or work?
- What interconnection documents/guidelines would need to be updated to allow this?
We will also continue our discussion of Pepco’s responses to the District Government’s technical required information
In addition, we will discuss any proposed amendments to the Commission’s dispute-resolution rules that stakeholders wish to propose based on the discussion at the May 12 session. I am attaching a copy of the current interconnection rules. The section on disputes is 4009.
CHESSA/IREC Report
CHESSA, IREC, and Pepco are continuing to work on the report requested by the Commission, which includes recommendations for defined SLAs governing Pepco’s processing times, issuance of ATOs, and scheduling of construction activities. We anticipate that the report will be filed with the Commission Secretary within the next couple of weeks.
Continued Process Reforms
As we discussed at the May 12 session, the Commission has directed the Commission Staff to address recommended permanent reforms at the Formal Case No. 1050 Technical Conference: (1) combining cost estimate and cost letter steps; (2) allowing earlier ATO application submission to trigger witness test waiver periods; (3) establishing a firm regulatory deadline for ATO issuance once commissioning is complete; (4) recommendations for the treatment of sunsetting tax credits that apply to commercially owned DER systems, including residential systems under power purchase agreements; and (5) developing a permanent standard, phased interconnection agreement for future use.
We will need to address these matters in an upcoming session. Please be thinking about the recommendations you would like to propose and discuss.
Final Report Outline
In Order No. 22312, the Commission directed Pepco to provide a technical conference report detailing the discussions, along with any consensus recommendations made by stakeholders regarding the discussion items. We kindly request that Pepco prepare an outline for that report for review and discussion at the June meeting.
If you have any questions or need additional information, please feel free to reach out.