The Maryland Public Service Commission should approve, subject to conditions, a 50-MW solar generating facility in Dorchester, County, Md., Christopher Lo, an electrical engineer in the commission’s Engineering Division, said in Oct. 26 direct testimony filed on behalf of commission staff.
He recommended that the commission:
- Grant a certificate of public convenience and necessity (CPCN) for the facility to Richfield Solar Energy, LLC, which is a wholly owned subsidiary of Invenergy LLC
- Require the filing of a request for CPCN amendment with the commission for any generation capacity in excess of 50 MW
- Require the executed distribution interconnection agreement (IA) involving Richfield and Delmarva Power & Light be filed with the commission prior to the start of construction
- Require the signed wholesale market participant agreement (WMPA) executed by Richfield with PJM Interconnection and Delmarva Power be filed with the commission prior to the start of construction. PJM developed the WMPA as a contractual means to address certain distribution level interconnection requests, Lo said, adding that the WMPA provides a transparent process to all parties to enable PJM to properly track and study that category of generator interconnection and to facilitate the generator’s participation in PJM’s organized wholesale markets. Lo noted that the WMPA option is available to those generation projects that are seeking to interconnect with the PJM transmissions system through a state regulated local electric distribution system prior to commercial operation
- Require Richfield, its successors and assigns to provide a 60-days written notice to the commission of any non-wholesale electricity sale to a Maryland retail electric customer, and comply with all regulations regarding such sale
- Require Richfield, its successors and assigns to provide written notice of any change in ownership of all, or any portion, of the project, at least 30 days prior to the closing date of any sale to a third party
- Include any additional conditions proposed by the other state agencies having jurisdiction in the proceeding
Describing the project, Lo said that the proposed facility would provide about 19 MW of peak capacity being recognized by PJM as a capacity resource. He noted that a capacity resource has the right to schedule capacity and energy deliveries at a point of interconnection into PJM markets, under a bilateral contract or through participation in the PJM capacity market. A capacity resource can provide capacity and energy to load serving entities to meet their load obligation, under the PJM reliability assurance agreement that is binding on all PJM members, Lo said.
PJM studied the interconnection request as a 19-MW generator interconnected with the Delmarva Power distribution system. Lo added that the generator lead line would connect to the Delmarva Power system as a direct connection into the Todd 69-kV substation and PJM evaluated it for compliance with reliability criteria for summer peak conditions in 2020.
The original interconnection request indicated an estimated in-service date of Dec. 31. Lo also said that system upgrades are required to accommodate 50 MW of generation into the electric system; that work may include modifying the ring bus at the Todd substation, the addition of a new 69-kV breaker, three disconnect switches, three current transformer/voltage transformer combination units, and a substation bus.
Discussing the current status and queue position of the project, Lo said that Richfield has a generator interconnection queue number of AB2-172, having submitted an interconnection request to PJM in April 2016. Approval of the CPCN application would permit construction to begin as early as 1Q19, with completion and operational startup in late 2019, Lo said.
PJM and Delmarva Power have completed two parts of the three-part interconnection study process to identify any upgrades needed to interconnect the project without negative impacts to the electric power system’s stability or reliability and confirmed the ability to interconnect the project to the Todd 69-kV substation. Lo added that the remaining facilities study is in process of completion, and that through the study process, Delmarva Power and PJM have determined that the Todd substation adjacent to the project site has adequate capacity to accommodate the injection of the project’s power into the distribution system with minimal upgrades.
Discussing how the project would connect to the Delmarva Power distribution system, Lo said that a new 34.5-kV distribution feeder would run from the generation facility to a step-up substation located within or near the project site; the step-up substation would then connect to the Todd substation. Also, a circuit breaker would be installed within 500 feet of the Todd substation to facilitate the relay protection scheme between Delmarva Power and the project at the point of interconnection.
Among other things, Lo said that Richfield would be responsible for all costs of the interconnection upgrades noted in the PJM interconnection studies, and that Delmarva Power customers would not bear responsibility for cost or work associated with the upgrades. The design and construction of all facilities to complete the interconnection would be the responsibility of Delmarva Power, Lo noted.
He also said that a system impact study projects no adverse impact on reliability and stability of the electric system in Maryland.