Okay, I'm going to wimp out here and deal with the Interconnection (PDF recommendation) and Fossil Fuel Efficiency (PDF recommendation) standards together, since I have the least to say about them.
That said, the Interconnection standard in particular shows one of the problems with how CWLP is approaching these standards. At several points across some of the standards, staff indicate that they don't foresee much demand for interconnections, or smart metering, or net metering. What they miss is that CWLP has a choice other than passively acknowledging demand for this sort of participation: it can spur demand by encouraging interconnections, small-scale generation, and further fuel diversification.
Interconnection
Interconnection deals with the rules that govern how people can connect to CWLP's grid within Springfield city limits. There are safety and reliability issues with this, since proper installation and maintenance are crucial. As I understand it, CWLP is recommending adoption of two different engineering standards, based on the size of the generation unit. The smaller size (a 250 kVA limit) is up to about the size of neighborhood transformers that serve several houses. The larger size (a 1 MVa limit) would be up to about the size of a transformer that would serve a big box store. Beyond that size, CWLP wouldn't allow interconnctions. This sets, among other things, maintenance requirements on anyone who wants to connect to the grid.
Here's what we're looking at right now for CES's summary statement on the interconnection standard: We agree that CWLP should adopt this standard, and only request that the following issues be addressed in their recommendation to city council:
- Provide a sense of scale of the 250 kVA and 1 MVA thresholds.
- Leave open the possibility of developing standards for interconnections beyond the 1 MVA limit.
- Outline more explicitly what maintenance and tests will be required of small-scale generators, such as for homeowners and small businesses.
Fossil fuel efficiency
This standard relates to what measures CWLP intends to implement to make their coal-fired units more efficient. As I understand it, their recommendation is that they adopt this standard, because they're always looking for efficiency improvements, but that they're not committing to a particular plan (because it's always contingent on what the economics of the moment allows) or to particular efficiency gains (since those gains are often muddied by other factors that require CWLP to change how it operates, in addition to whatever infrastructure changes it makes).
We had no comments on this standard, which I'm sure CWLP was grateful for. We agree that they should adopt it, and trust them to be a good steward of squeezing what they can out of their coal.