B. State Approaches to Identifying Export Control Methods
Currently, interconnection procedures in the United States generally have one of three different ways of addressing the concept of export control for storage and other DERs. First, some procedures do not recognize the concept of export limiting at all. The FERC SGIP contains little discussion or acknowledgement of non- or limited-export projects. Thus, a number of states that have followed the FERC SGIP model,((See, e.g., NC Util. Comm., Dkt. E-100, Sub 101, North Carolina Interconnection Procedures (Aug. 20, 2021), https://desitecoreprod-cd.azureedge.net/_/media/pdfs/for-your-home/212287/ncip-approved-oct-15-2020.pdf?la=en&rev=cd85b126dd0345019917e2464beb861b; OH Admin. Code 4901:1-22.)) and several other states, do not have any process associated with reviewing non- or limited-export projects. The second group have a distinct review tier for non-exporting projects (typically Level 3), like the IREC 2019 Model. However, these rules typically do not identify what methods of controlling export are acceptable with any level of specificity.((See, e.g., IL Admin. Code tit. 83, § 466.80(c)(2) (“The distributed generation facility will use reverse power relays or other protection functions that prevent power flow onto the electric distribution system”); Admin. Code r. 199.45.7(3); (“The distributed generation facility will use reverse power relays or other protection functions that prevent power flow onto the electric distribution system. . .”; 2013 IREC 2019 Model (“An Applicant may use the Level 2 process for a Generating Facility with a Generating Capacity no greater than ten MW that uses reverse power relays, minimum import relays or other protective devices to assure that power may never be exported from the Generating Facility to the Utility.”))) Finally, the third group are those that followed the California Rule 21 model, which includes a distinct screen for non-exporting projects.((CA Pub. Util. Comm., Southern California Edison, Rule 21 § G.1.i; NV Pub. Util. Comm., Dkt 17-06014, NV Power Co. Rule 15 § I.4.b.)) This screen identifies, with more detail, what methods of export control are acceptable to qualify as non-export for purposes of the screen. None of these three categories has historically included any consideration of limited-export projects.
The approach taken in California has a distinct advantage in that it is the only one that provides utilities and applicants with a clear list of the acceptable methods for controlling export. However, that list of acceptable export controls is embedded in a screen for non-exporting projects only and thus it has not provided a convenient vehicle for the incorporation of controls used for limited-export, as compared to non-export, systems.
The following subsection III.C provides a description of the export control methods that have been traditionally recognized in interconnection procedures and/or standards, such as those in California and Nevada.