Agency Report to JCAR-Page 2
promulgate rules governing distributed generation (DG). See also, MCL 460.1173(6)(b). Likewise,
the Institute of Electrical and Electronics Engineers (IEEE) recently updated its technical standards
for interconnection, the IEEE Standard for Interconnection and Interoperability of Distributed Energy
Resources with Associated Electric Power Systems Interfaces (IEEE 1547-2018), which has
prompted other states to revise their own interconnection rules and standards. Moreover, the Federal
Energy Regulatory Commission (FERC) has recently addressed the integration of energy storage
facilities in its Order 841 issued on February 15, 2018, which directs regional transmission
organizations and independent system operators to establish market rules for energy storage facilities
to participate in wholesale energy, capacity, and ancillary services markets. Order 841, 162 FERC ¶
61, 127; 18 CFR 35.28 (2018).
Finally, in the October 27, 2015 order in Case No. U-17973, the Commission determined that it
needed to update the standards applicable to utilities and qualifying facilities (QF) operating pursuant
to the Public Utility Regulatory Policies Act of 1978, 16 USC 2601 et seq., 16 USC 824a-3
(PURPA). PURPA was enacted by Congress in 1978 to increase energy conservation and energy
efficiency by allowing for renewable resources to interconnect with and sell their generation to
utilities. PURPA is largely carried out by the states. 16 USC 2621(b)(2); 16 USC 824a-3(f). For
example, the rates paid to QFs are set by the Commission. 16 USC 824a-3; MCL 460.6j(13)(b). The
Commission expects that the new rules will decrease the time required to interconnect a distributed
energy project into the electric distribution system.
Thus, both PURPA and the new DG law (as well as the legacy net metering law) concern the topic of
interconnection with the energy grid. Industry standards for interconnection have been updated since
the 2009, and these rules for net metering are outdated and are not sufficiently detailed. Larger
generators tend to be interconnecting with the utility under PURPA requirements. In this rulemaking,
the Commission is rescinding the 2009 interconnection rules. In a related and simultaneous
rulemaking, the Commission will promulgate new rules addressing interconnection requirements for
generators of all sizes, DG standards, and legacy net metering, to address the concerns described
herein.
This proposed rule rescission was previously included in 2019-087, which was voided on March 10,
2020.
4. Summary of proposed rules:
The Interconnection and Distributed Generation Standards are rules that detail how projects owned by
customers, developers, and in some situations, the utility, connect to the utility distribution system.
These rules provide a standardized process and schedule so that interconnections can be
accommodated in an orderly and timely manner. The rules also ensure that interconnections are done
reliably and safely, in order to protect workers, utility and third-party owned equipment, and the
public. The Interconnection and Distributed Generation Standards are an update to the Electric
Interconnection and Net Metering Standards necessitated by advances in distributed energy resource
technology and an increase in distributed generation penetration on the distribution systems in
Michigan. The Interconnection and Distributed Generation Standards are promulgated pursuant to
the same authority as, and replace, the Electric Interconnection and Net Metering Standards, which
will be rescinded concurrently with the approval of these rules.
MCL 24.242 and 24.245
