Joint Comments on Staff Discussion Draft Documents for Distributed Energy Resources

The Public Utility Commission of Texas (PUCT) is considering new rules to govern the interconnection of distributed energy resources (DERs) in the state. As part of this process, the Texas Solar + Storage Association (TSSA) and the Solar Energy Industries Association (SEIA) have submitted joint comments on the staff discussion draft documents. The associations support standardizing interconnection processes to facilitate the adoption of DERs in Texas, citing the benefits of DERs in reducing load growth, ensuring reliable and affordable service, and promoting innovation.

Key Takeaways:

  • The TSSA and SEIA support applying the same standards to municipally-owned utilities and electric cooperatives as those applied to investor-owned utilities.
  • The associations appreciate the Commission's hard work in developing the discussion draft rule package and welcome the opportunity to comment and work with stakeholders to develop customer-centered rules.
  • Standardizing interconnection processes can accelerate the addition of generation and energy storage resources to the grid, ensuring reliable and affordable service to Texans.
  • The Solar Associations continue to support a proposed standard interconnection allowance for distribution-connected resources, which would offer all of the benefits that having a standardized interconnection allowance provides for transmission-connected resources.
  • Hosting capacity analysis (HCA) would provide greater transparency about the technical and commercial feasibility of possible points of interconnection sites and provide vital information to assist with grid planning.
  • The associations firmly believe that allowing access to utility HCs could be accomplished in a safe and secure manner that would not burden utilities.
  • The Commission should direct utilities to allow and recognize the use of Power Control Systems (PCS) in their interconnection processes.

Statistics:

  • 1,200 member companies of SEIA
  • 250kW as the threshold for large DERs
  • $1.5 million as a proposed standard interconnection allowance
  • 25 other states allowing grid operators to provide hosting maps to interconnection DER operators
  • 53% of Texas electricity generation from renewable sources (Source: ERCOT)
  • 1.2 million megawatt-hours of solar energy production in Texas in 2020 (Source: ERCOT)

Sources:

  • Texas Solar + Storage Association (TSSA)
  • Solar Energy Industries Association (SEIA)
  • Public Utility Commission of Texas (PUCT)
  • ERCOT
  • [https://interchange.puc.texas.gov/Documents/54233/86/1423328.PDF](https://interchange.puc.texas.gov/Documents/54233/86/1423328.PDF)
  • [https://www.puc.texas.gov/Page.aspx?id=7087](https://www.puc.texas.gov/Page.aspx?id=7087)
  • [https://www.ercot.com/news/grid-deployment-solar-energy](https://www.ercot.com/news/grid-deployment-solar-energy)