Discussion
of Issues
Issue 1:
Should the Commission approve Tampa Electric
Company’s petition for a standard interconnection agreement for interconnected customer-owned
battery subsystems?
Recommendation:
Yes. The Agreements require customers owning and
renting battery subsystems to adhere to terms which ensure the safety of the
Utility’s personnel. Approval of this petition will not relieve the Utility of
any requirements during a future rate case proceeding. Therefore, staff
recommends that TECO’s petition for approval of a standard interconnection
agreement for interconnected customer-owned battery subsystems should be
approved as filed.
Staff Analysis:
TECO’s proposed Agreements are intended for
customers owning and renting battery subsystems. In the Owner’s Agreement, a
battery subsystem is described as a battery system consisting of one or more
storage batteries and battery chargers (including inverters, converters, and
associated electrical equipment); this includes batteries charged by solar
photovoltaic arrays. These battery subsystems will supply power only for the
customer’s own use and will not export power into the Utility’s supply grid for
more than 100 milliseconds. During a faulted condition on the Utility’s system,
the customer’s battery subsystem will be isolated but it will still be able to
provide electricity to the customer. A faulted condition can occur for reasons
such as contact with vegetation, lightning, weather, animals and/or vehicles. The
Utility currently anticipates interconnecting 73 customer-owned battery
subsystems and the Owner’s Agreement will allow the safe interconnection of
these subsystems. As long as the customer’s interconnection complies with the
provisions set forth in the Owner’s Agreement, the Utility does not expect any
negative impacts to its electrical grid. Some of the provisions of the Owner’s
Agreement include requiring the customer to have the battery subsystem
inspected and approved by the authority having jurisdiction and providing proof
of this inspection and approval to the Utility, requiring the customer to
maintain the specified amount of general liability insurance for personal
injury and property damage, and requiring the customer to install an isolation
switch to allow the Utility to completely separate the battery subsystem from
the Utility’s system, if necessary, for safety purposes.
The provisions of the Renter’s Agreement notify the
customer renting property where battery subsystems are located that the owner
of the property remains responsible for all provisions in the Owner’s Agreement
that the owner signed with the Utility. The Renter’s Agreement also requires
the customer to abide by and comply with all applicable provisions of the Owner’s
Agreement that relate to safety and that govern the use, operation and maintenance
of the battery subsystem.
The benefit of the Agreements to the ratepayers owning
battery subsystems and renting property where battery subsystems are located is
allowing their subsystems to safely interconnect and operate in parallel with
the Utility’s electrical grid by meeting the provisions set forth in the Owner’s
Agreement. Under the Owner’s Agreement, operation of the battery subsystems in
parallel with TECO’s electrical grid would not be permitted without meeting the
specified requirements. Therefore, the Owner’s Agreement will facilitate
customers’ desires to own and operate battery subsystems and the Utility
personnel working at or near the premises will benefit from the safety measures
included in the Owner’s Agreement. The required installation of a visible
isolation switch helps to ensure that the battery subsystems are operated in a
safe manner by allowing the Utility to open the switch under necessary
conditions. Conditions which may require the switch to be opened are:
·
Utility system emergencies or maintenance
requirements;
·
Hazardous conditions existing on the Utility’s
system due to the operation of the customer’s battery subsystem.
·
Adverse electrical effects (such as power
quality problems) on the electrical equipment of the Utility’s customers caused
by the battery subsystem.
·
Failure of the customer to maintain the required
insurance for the duration of the Owner’s Agreement.
The switch is to be readily accessible to the Utility and
capable of being locked in the open position with a Utility padlock. The
Utility will reimburse the customer for the cost of the switch installation for
battery subsystems at or below 15 kW AC maximum capacity, not to exceed the
amount listed on the Utility’s website. Approval of this petition will not
relieve the Utility of any requirements during a future rate case proceeding.
Under the Owner’s Agreement, the customer agrees to permit
the Utility to inspect the battery subsystem and its components as well as the
required documentation, before and after the battery subsystem goes into
service, and to witness the initial testing of the customer’s battery subsystem,
if the Utility chooses. Once the Utility has received written documentation
from the customer that the requirements of the Owner’s Agreement have been met
and the correct operation of the isolation switch has been demonstrated to a
Utility representative, the Utility will send a written notice within 10
business days that parallel operation of the battery subsystem can begin. Staff
has reviewed the Owner’s Agreement and the Renter’s Agreement and recommends
that the provisions of the Agreements are reasonable and are in place to
protect the ratepayers as well as the Utility personnel. TECO’s Owner’s
Agreement and Renter’s Agreement, in type-and-strike format, are included as
Attachment A to this recommendation.
Conclusion
The Agreements require customers owning and renting
battery subsystems to adhere to terms which ensure the safety of the Utility’s
personnel. Approval of this petition will not relieve the Utility of any
requirements during a future rate case proceeding. Therefore, staff recommends
that TECO’s petition for approval of a standard interconnection agreement for
interconnected customer-owned battery subsystems should be approved as filed.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If no person whose substantial interests are
affected by the proposed agency action (PAA) files a protest within 21 days of
the issuance of the PAA Order, a Consummating Order should be issued and the
docket should be closed. (Murphy)
Staff Analysis:
If no person whose substantial interests are
affected by the PAA files a protest within 21 days of the issuance of the PAA
Order, a Consummating Order should be issued and the docket should be closed.
