From the PUC of Texas docket 54224 filing 30:
https://interchange.puc.texas.gov/search/documents/?controlNumber=54224&itemNumber=30
2. Prior to finalizing and adopting the rule, the Commission should merge the distribution interconnection cost allocation issue into the 54233 rule with the following modifications:
a. I suggest we apply the same philosophy to distribution grid interconnection as we recently did for transmission interconnection and provide an interconnection allowance for distributed generation and storage resources.
b. If the allowance above is agreed to, I would suggest $1.5million per interconnection allowance for resources connected below 138 kV. Staff could try to model this amount as they did the transmission allocation and determine an appropriate amount.
c. Interconnection costs above the allowance would be recovered from the resource through a Contribution In Aid of Construction (“CIAC”).
d. As already set forth in the strawman rule, the DSPs should be required to provide a detailed estimate of the interconnection costs so that there is not a new barrier to entry created through an inflation of interconnection costs. At the transmission level, this is managed by ERCOT and thus is not an issue. However, interconnecting customers must be able to contest these costs.
e. An issue that was briefed in 54224 that should be resolved here is what monthly charges can be levied to distribution-connected energy storage resources, which are not imposed storage resources at the transmission voltage. The issue was raised in the Oncor rate case, Docket No. 53601 over a year ago, and when we declined to consider the policy considerations (but approved the tariff), we promised to consider and resolve the policy issue for all DSPs. We still have not done so and we owe it to all parties to provide policy guidance.
f. If this policy is to apply to municipal and cooperatives, the commission must consider how to develop a wholesale cost recovery mechanism for these interconnections with the assurance that DG resources are serving the Ercot wholesale market.
