Ieee Final 012919
Ieee Final 012919
THE GRID
SMARTER
Primer on Adopting the
New IEEE 1547 -2018 Standard for
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J A N UA R Y 2019
AUTHORS:
January 2019
* This white paper was reviewed by the Electric Power Research Institute (EPRI). As an independent, nonprofit organization, that conducts public interest energy
and environmental research, technology development, and demonstration projects, EPRI does not endorse any standards or give any regulatory advice.
PHOTO CREDITS: cover, NREL; page 6, NREL; page 10, Dumont Green, NYSolar Smart/CUNY; page 16, SolarEdge; page 20, Center for Sustainable Energy; page 24, Center
for Sustainable Energy; page 25, SolarEdge; page 27, IREC.
MAKING THE GRID SMARTER - 2
© IREC 2019
IEEE 1547 -2018 Standard for Distributed Energy Resources
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Table of Contents
Executive Summary....................................................................................................................... 4
II. Anticipated Timeline for Full Rollout of IEEE Std 1547 -2018...................................................... 8
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IV. Reference Point of Applicability and Evaluation, Commissioning and Verification of DERs..... 11
V. IEEE Std 1547 -2018 Categories, Functions and Issues for Consideration................................ 13
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Table of Figures
Figure 1: Anticipated Timeline for the Rollout of IEEE Std 1547 -2018............................................ 8
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Executive Summary
In April 2018, the Institute of Electrical and Electronics Engineers (IEEE) published the IEEE
Standard 1547 -2018 for Interconnection and Interoperability of Distributed Energy Resources with
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Associated Electric Power Systems Interfaces (IEEE Std 1547 -2018 or the Standard), which is a
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voluntary, nationally-applicable Standard that will transform how distributed energy resources
(DERs) interact with and function on the electric distribution system. It is the long-awaited update
to IEEE Standard 1547 -2003, IEEE Standard for Interconnecting Distributed Resources with Electric
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H. System Controls
help ensure new DERs andmeet
Power
the most updated
Limitation at the
performance PCC provide enhanced grid
standards,
functionality, and avoid high volumes of legacy
systems that do not provide such capabilities.
State adoption and implementation of this
Standard will require the attention of state
regulators – who will be tasked with formally adopting the new StandardSmartat theInverter
state level – as well as
utilities who will integrate them into internal interconnection protocols. In addition, DER industry
representatives, technology manufacturers, state and federal agencies, national laboratories and
advocates will play key roles in the consideration and adoption of the new Standard. In contrast with
the 2003 Standard, which provided one set of requirements for all DERs, IEEE Std 1547 -2018 TM
stakeholder processes to ensure that the perspectives of all impacted stakeholders, including
consumers adopting DERs, are accounted for and reflected.
This Secondary
primer provides an overview and
Networks explanation
Default Voltage Functions A. Category
of the major revisions in IEEE Std 1547 -2018
Explanation TM
D. Power Qualit
through adopting and implementing the Standard. While not attempting to provide in-depth
details of the entire Standard, this document provides an accessible overview and insights on the
following topics:
●● The key requirements and implications of IEEE Std 1547 -2018 and impacts on its adoption
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and implementation for regulators, utilities, DER developers, customers and the grid;
●● The anticipated timeline for the full rollout of IEEE Std 1547 -2018, including the
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for DERs and issues surrounding their integration and harmonization across different
networks and between technologies;
●● Updates to power quality requirements, including new limits for rapid voltage changes,
flicker and overvoltage;
●● Issues surrounding grounding practices, islanding, secondary networks, fault current, and
power limitations at the point of common coupling (all of which will likely impact state
interconnection procedures and protocols);
●● DER testing and verification, including DER design and as-built evaluations, as well as
commissioning and periodic tests and DER settings verifications; and
●● Key takeaways and overarching policy issues states and regulators should consider as they
work to adopt and implement IEEE Std 1547 -2018.
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With IEEE Std 1547 -2018 published and a few remaining years before full rollout (2022), now is
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the time for states and regulators to begin to implement the updated Standard. Early consideration
and integration of IEEE Std 1547 -2018 and related standards will ensure states have ample time
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to navigate the complex issues that involve stakeholder coordination and pave a smooth path for
widespread deployment of smarter DER technologies. With this reference guide in hand, those
working to address and integrate the updated standards will be better equipped to streamline the
implementation process and optimize the rules governing the grid. w
In April of 2018, the Institute of Electrical and Electronics Engineers (IEEE) published a major
revision of the national Standard for interconnection of DERs known as the IEEE Standard 1547 - TM
2018, IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with
Associated Electric Power Systems Interfaces (IEEE Std 1547 -2018 or the Standard).1 The Standard
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requires DERs to provide capabilities for specific grid supportive functionalities, including voltage
and frequency ride-through, voltage and frequency regulation, as well as communications and
control functionality. In addition, they may provide enhanced functions, such as ancillary services.
When utilized, these capabilities can help increase the amount of DERs that can be accommodated
on the grid, improve power quality for all customers, and ensure that DERs can continue to be a
reliable and optimized grid resource as penetration increases.
These new requirements will enable DERs to communicate with and receive signals from the grid
operator or a third party (aggregator). Although applicable for any type of DER, the majority of
new DERs interconnecting to the gird in the coming years are expected to be inverter-based DERs
with so-called “smart inverters” or “advanced inverters” that can comply with the new Standard.
Using more sophisticated communication infrastructure, these smart inverters can be controlled and
monitored remotely. Among other advantages, these communications and controls will enable DERs
to convey performance data with the utility (or an aggregator) to increase situational awareness and
more quickly diagnose and address any operational or maintenance issues.
IEEE Std 1547 -2018 represents a considerable shift from the 15-year old IEEE Standard 1547 -
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2003, IEEE Standard for Interconnecting Distributed Resources with Electric Power Systems (IEEE Std
1547 -2003) in that the 2018 version has no single default set of DER capabilities and settings.
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1 In June of 2018, IEEE published errata that corrected an erroneous sign in the frequency-droop formula of Table 23 of Clause 6.5.2.7.
manufacturers, customers and utilities. As they work to adopt and implement the new Standard,
state utility regulators will play an important role in ensuring that all stakeholders’ interests are
balanced, with the overall goal of increasing the safety, security, resilience and reliability of the grid.
Once widely implemented, IEEE Std 1547 -2018 will result in the following primary changes:
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●● The interconnection process used for DERs connecting to the grid will change.
●● The large number of optional functions and settings will require development of a
process to verify the DER settings in the commissioning process.
●● DERs will have the ability to automatically respond to certain grid conditions, which will
help avoid potential negative impacts and optimize their grid benefits.
●● More DERs will be capable of connecting to the grid under higher penetration scenarios,
assuming their control functions are set up adequately to accommodate the grid conditions.
●● Standardized communication protocol capabilities could allow for wider control of DERs
through integration with Supervisory Control and Data Acquisition (SCADA) systems or
Distributed Energy Resource Management Systems (DERMS).
●● Customers installing DERs may see shifts in their distributed generation output under
certain scenarios, which might require the adoption of new consumer protection measures.
The optionality inherent to IEEE Std 1547 -2018 may be more challenging to apply uniformly, with
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potential for different implications for certain functions based on DER system size, technology or
local grid conditions. This document provides an overview and explanation of the major revisions in
IEEE Std 1547 -2018 and a synopsis of some of the issues that states will need to consider as they
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With IEEE Std 1547 -2018 now formally published, work to publish revisions to the accompanying
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IEEE Standard 1547.1 , IEEE Standard Conformance Test Procedures for Equipment Interconnecting
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Distributed Resources with Electric Power Systems (IEEE Std 1547.1 ), is underway. IEEE Std 1547.1
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will guide manufacturers as they test and certify their products to the IEEE Std 1547 -2018 Stan- TM
dard. IEEE Std 1547.1 is expected to be published in 2019-2020. Underwriters Laboratories (UL)
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will then update its product certification standard, Inverters, Converters, Controllers and Interconnec-
tion System Equipment for Use with Distributed Energy Resources (UL 1741), to which all equipment
must be tested and certified. UL is coordinating closely with IEEE and has stated the revision to
UL 1741 will likely be available within a few weeks following publication of the revised IEEE Std
1547.1 . From that point, it is anticipated that it will then take up to 18 months for all DER prod-
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ucts to comply with the updated requirements and be made commercially available (see Figure 1).
Figure 1: Anticipated Timeline for the Rollout of IEEE Std 1547 -2018 TM
In addition to considering the above timeline, local, state or regional DER market conditions may
inform whether a more expedited process to adopt the new Standard (or parts thereof ) is warranted
in advance of the development of IEEE Std 1547.1 and UL 1741 updates. For example, California
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and Hawaii expended significant effort to initiate smart inverter implementation efforts in advance
of the adoption of IEEE Std 1547 -2018 due to the prevalence of DERs on their respective utilities’
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grids. Implementation efforts in both states are still underway, and harmonization with IEEE Std
1547 -2018 will be required.2
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For most states, given the increased menu of options within the updated Standard, it will likely be
a worthwhile exercise to begin a stakeholder process or formal proceeding in the near-term in order
to ready the state and utilities for the full rollout of IEEE Std 1547 -2018. Namely, to ensure the TM
streamlined integration of DERs with enhanced capabilities and functions envisioned by IEEE Std
1547 -2018, it will be important to ensure that rules are in place by the time certified DER devices
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are available on the market. As part of its order adopting updated interconnection standards for its
regulated utilities, the Minnesota Public Service Commission has already convened a workgroup
to evaluate the integration of the IEEE Std 1547 -2018 as part of the state’s development of
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2 Currently, the requirements are state-specific and are predicated on the smart inverter test protocols of UL 1741 Supplement SA instead of
IEEE Std 1547.1™.
3 Minnesota Public Service Commission, Docket Nos. E-999/CI-01-1023 and E-999/CI-16-521, Order Establishing Updated Interconnection Pro-
cess and Standard Interconnection Agreement (August 13, 2018).
Regulation
Interconnection Rules
The use of DERs is expanding quickly as more people are
Functions
seeking to adopt distributed grid-integrated technologies in
their homes, businesses, communities and public institutions.
IEEE Std 1547 -2018 is a core standard that will maintain
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2003 will need to be updated to reflect these recent revisions. Clearly defining DER settings in
III. Integration of IEEE
statewide interconnection rules4 will help increase efficiency, minimize confusion, and reduce costs.
States or utilities that have not yet adopted interconnection rules could begin the process today with
Std 1547™-2018 into
IEEE Std 1547 -2018 in mind, rather than retroactively adopting it (which could be inefficient and
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options. Utilities and state regulatory commissions will need to evaluate, select and assign different
“performance categories” for different DERs. In addition, as applicable, states and utilities will need
to consult and coordinate with the Regional Reliability Coordinator and Regional Transmission
Organization (RTO), Independent System Operator (ISO), or other transmission operator on
certain issues within IEEE Std 1547 -2018 relating to reliability and performance. Starting now to
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adopt IEEE Std 1547 -2018 will give state regulators, utilities, DER developers and customers the
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time necessary to navigate some of the more complex issues to integrate and enhance the adoption of
smarter grid technologies.
To make the most of the standard and prepare for higher DER penetration in the future, regulators
and utilities should consider the opportunity to utilize certain functions before achieving higher
penetration of DERs, so as to optimize future DER growth and avoid negative impacts as
4 As applicable to those utilities regulated by state public service commissions. Other utilities not regulated by a state regulatory commission
could integrate IEEE Std 1547™-2018 into their applicable interconnection rules and tariffs (voluntarily or as directed by state statute).
penetration increases. For example, as discussed below in Section V.B, high penetration of DERs
on certain circuits can potentially affect the voltage of the grid, which could negatively impact
power quality if not managed. IEEE Std 1547 -2018 requires DERs to be capable of participating
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in voltage regulation, through a number of functions that may be activated. Voltage regulation can
help mitigate any negative grid impacts while also allowing DERs to connect to locations on the
grid where once they might not have been able to do so. States and utilities will need to determine if
and when voltage regulation functions should be turned on (since voltage regulation is disabled by
default in the new Standard), which function should be utilized, which settings should be used, and
how enabling these functions will interact with interconnection rules. The implementation of voltage
regulation functions will also warrant consideration of the impacts on and protections for individual
DER customers. The voltage regulation example is just one of many that states will be tasked with
evaluating as part of their adoption of IEEE Std 1547 -2018. TM
Even though the full implementation of the updated Standard will take a few more years, it is not
too soon for states, utility regulators, utilities and stakeholders to begin the process to adopt and
integrate it into interconnection rules.
Alongside existing interconnection best practices, IEEE Std 1547 -2018 can support the optimized
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integration of new technologies, while maintaining grid safety and reliability. Even states and utilities
with low levels of DER deployment could adopt IEEE Std 1547 -2018 in order to build up the
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functional capabilities, while still specifying settings close or equal to those from IEEE Std 1547 - TM
2003. For states with multiple regulated utilities, statewide adoption of IEEE Std 1547 -2018 will TM
provide greater consistency across utilities and enable a more streamlined rollout of the Standard,
which will benefit consumers, utilities and DER developers alike. w
C. Comm
IV. Reference Point of Applicability and Evaluation, & Intero
Commissioning and Verification of DERs
the physical point on the electric grid where compliance with the
Standard’s requirements will be assessed. This point is known as
the reference point of applicability5 and it determines which method
is used to evaluate compliance with the Standard. For most large
Communications/
DER systems, this will be the Point of Common Coupling (PCC),
which is the point of connection between the DER customer and
Interoperability
the utility.6 However, for some systems, especially smaller DER
projects7, the reference point of applicability for the IEEE Std
C. Communications, Controls
1547 -2018 requirements may be the Point of DER Connection
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on E. & Interoperability
2018, exclusive of anyIslanding Commissioning
load present in the respective portion of the customer’s site. &
Verification
s for IEEE Std 1547 -2018 details specific DER evaluation and commissioning testing requirements, and
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the tables therein indicate which evaluations or commissioning tests should be performed based on
IV. Reference Point of A
the reference point of applicability (and whether or not fully tested, fully compliant DER units are
utilized). Further details on the extent of those evaluations and commissioning tests will be given in
the next version of IEEE Std 1547.1 . Generally speaking, the DER project size, configuration and
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equipment determine the reference point of applicability and corresponding compliance methods.
Evaluation, Commission
For example: Verification
●● For DER projects that regularly export more than 500 kVA9 (i.e., larger systems or
dedicated generating facilities), the requirements of IEEE Std 1547 -2018 must be met at TM
the PCC. In addition to evaluation by the utility to verify compliance, additional equipment
commissioning testing may be required.
●● For smaller DERs, using the PoC as the reference point of applicability allows the DER
equipment type testing certification to be utilized as the main method by which compliance
with the Standard is verified. The PoC might be the terminals of an inverter, for example,
and utilizing a UL 1741 certified and listed inverter would be sufficient to demonstrate
Standard compliance.10
Commissioning &
5 See IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces,
Verification
IEEE Std 1547 -2018, subclause 4.2.
™
6 Typically, at the utility revenue meter.
7 Either a) DER nameplate rating ≤ 500 kVA, or b) average load demand greater than 10% of DER nameplate and where it does not export more
Verification gives some guidance and does not specify mandatory requirements.
V. Reference
to be performed asPoint of Applicability and
Interconnection rules should allow for the appropriate level of evaluation and commissioning testing
part of the interconnection review process, dependent on the variables described
Verification
Verification of functional settings (e.g., trip and voltage regulation settings) is an important
14
aspect of commissioning that becomes more complicated by the additional functions and variety
of settings that IEEE Std 1547 -2018 allows. Many inverters include settings profiles (a.k.a.,
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for functional settings will help simplify the DER project verification process, since smart inverters
will automatically be equipped with these default setting profiles. However, to the extent states
and utilities across the country adopt different trip and functional settings, new processes and/
or verification measures may need to be developed to ensure that the DERs are commissioned
appropriately.
At this juncture, efforts continue to simplify the process of quickly conveying settings from a utility
(a.k.a. utility-required profile) to the DER (a.k.a. manufacturer-automated profile) in a standardized
format (e.g., using digital means). Stakeholders should remain aware of those evolving discussions
and adjust processes as necessary over time. w
11 Lack of “interference” is defined in IEEE Std 1547™-2018 as having an impedance less than 0.5% between PoC and PCC.
12 The evaluation and commissioning tests can be simplified if the DER unit is certified in combination with the supplemental equipment.
13 Interstate Renewable Energy Council, Priority Considerations for Interconnection Standards: A Quick Reference Guide for Utility Regulators,
p. 6, August 2017, available at: https://irecusa.org/priority-considerations-for-interconnection-standards. “The Fast Track process consists of
several technical screens intended to easily identify proposed interconnections that will not threaten the safety and reliability of the electric
system, and allow these systems to proceed through an expedited review process. Although the technical screens decide whether a project
will be able to interconnect without a full study, an overall size limit for Fast Track eligibility offers applicants a useful indicator as to whether
or not their system is at all likely to pass those screens and serves an administrative function for utilities to help sort projects into the proper
study track. In the former iteration of the FERC SGIP and in many states’ procedures, Fast Track review is limited to systems up to 2 MW.
More recently, FERC and several states have moved away from a broadly applicable cap to a more nuanced, table-based approach, which
accounts for location-related factors that affect the likelihood of the generator to have adverse impacts on the electric system. Specifically, the
table-based approach allows the size limit to increase as the voltage of the line increases and if a generator is closer to the substation.” And “If
an interconnection applicant fails one or more of the Fast Track screens, many states’ procedures allow it to undergo ‘supplemental review’ or
‘additional review’ to determine whether or not it could interconnect without full study. . . In its most recent revision to SGIP, FERC integrated
a more transparent supplemental review process that relies on three screens, including a penetration screen (Screen 1), set at 100 percent of
minimum load. In most cases, if the proposed generation facility is below 100 percent of the minimum load measured at the time the genera-
tor will be online, then the risk of power back-feeding beyond the substation is minimal and thus there is a good possibility that power quality,
voltage control and other safety and reliability concerns may be addressed without the need for a full study. The other two screens allow for
utilities to evaluate any potential voltage and power quality (Screen 2) and/or safety and reliability impacts (Screen 3).”
14 See IEEE Std 1547™-2018, clause 11.
MAKING THE GRID SMARTER - 12
IEEE 1547 -2018 Standard for Distributed Energy Resources
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ns Category Explanation
and Assignment
IEEE Std 1547 -2018 identifies two performance categories15 relevant to DER grid functionality:
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the Normal Operating Performance Category and the Abnormal Operating Performance Category.
The Normal Operating Performance Category specifies how the DER should perform with regards
to voltage control during normal grid operations. The Abnormal Operating Performance Category
specifies DER performance during a grid disturbance such as a transmission fault or loss of a
generator. Within each, there are options to further clarify the performance and functional capability
levels. The
Default assignment of these categories will determine the interconnected DERs’ capability to
Settings
respond to changing grid conditions and support and maintain electric grid power quality and
stability.
Certain DER technologies are capable of different levels of performance. As one example, inverters
used with solar photovoltaic (PV) and energy storage systems are capable of the highest level of
grid performance for both normal and abnormal conditions. Other technologies may not be able
to accommodate the highest level of performance. As such, the category assignment and level of
performance may need to be determined on a technology-specific or use case-specific basis. Annex B
IEEE Std &1547 -2018 contains further discussion of how categories might be selected. The two
of Commissioning
Verification
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2018 requires all DERs to be capable of providing reactive power in order to regulate and
maintain voltage within the American National Standards Institute (ANSI) C84.1 range A,
which is considered the normal range for the U.S. electric grid (hereinafter normal range).
The normal category mostly determines how well the DER can support local voltage to stay
within the normal range.
ISO or transmission operator when making decisions regarding the abnormal category. For
the Standard to simultaneously be technology neutral and enable high penetration of DERs,
different categories allow for different levels of performance. For example:
o Category I is intended for certain types of DERs which are expected to remain at
lower penetration on the grid (e.g., flywheel storage) or are not capable of higher
performance but provide some societal benefits (e.g., combined heat and power).
Commissioning & o Category II is intended to allow for protective settings similar to IEEE Std 1547 -
TM
Verification
2003, while still requiring sufficient performance capability to address the bulk
electric system and reliability issues arising from increasing DER penetration, as
well as distribution-level events such as Fault-Induced Delayed Voltage Recovery
(FIDVR) to a certain extent.
o Category III is intended to address very high DER penetration and distribution
reliability issues, including adjacent feeder faults and more extreme FIDVR, in
addition to bulk-system reliability. Category III offers the highest level of ride-
through capability but does not allow for business-as-usual protective settings
such as IEEE Std 1547 -2003 (due to limited ranges of adjustable settings).
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Changing the category assignment for a DER after it has been interconnected to the grid poses
potential challenges that should be duly considered in the process to adopt IEEE Std 1547 -2018. TM
While changing DER settings to a different value than originally specified may be technically
possible, it may not be done efficiently without widespread communications infrastructure in
place. In addition, DER technologies that are certified to a lower performance category may not be
configured with the full range of capabilities and would be unable to shift to operate in compliance
of higher performance categories. For this reason, the category assignment and performance
capability levels within each and applicability for different DER technologies should be given careful
consideration at the outset of the Standard’s adoption efforts. Note that DERs that are certified to
a higher performance category can, in most cases, meet the requirements of a lower performance
category.
17 The requirements are consistent with FERC Order No. 842. Distribution utilities are discouraged from desensitizing the frequency-droop func-
tion by specifying a frequency dead band much wider than the default setting of 36 mHz.
18 The frequency of the grid on the mainland of the United States is quite stable, and thus any resulting reductions in generation should be, for
most customers, de minimis.
19 It should be noted that the three major interconnections (Eastern, Western and ERCOT) in the U.S. have not ventured outside the stated limits
with any regularity in the past.
higher volumes of DER on certain circuits can potentially cause the voltage of the grid to be affected,
which could negatively impact power quality if not managed. As such, one of the major reasons
for updating IEEE 1547 was to explicitly require DERs to be capable of participating in voltage
regulation. It is important to note that other factors outside of DERs can impact voltage on the
grid, including: a utility’s voltage regulation practices, feeder design, and other DERs on the system.
Different locations on a circuit will have different voltage regardless of the presence of a DER, with
locations nearer to a substation orDefault
Communications/ voltage regulation device generally having higher voltage, and
Settings
Interoperability
locations further away having lower voltage.
Notwithstanding these external factors, according to IEEE Std 1547 -2018, states and utilities need TM
to determine if and when voltage regulation functions should be turned on, which function should
be utilized, and which settings should be used.21 As previously noted, voltage regulation is disabled by
default, so careful consideration should be given to determine what mode is desired.
Within IEEE Std 1547 -2018, there are several functions that may be activated in order to regulate
TM
defaults and adjustable ranges for each of the voltage regulation functional settings, to the extent they
are enabled.22 Each of these functions interact with the grid differently and have differing impacts on
the generation output of DERs. It should also be noted that the effectiveness of the reactive power
functions depends on the characteristics of the circuit to which the DER is connected, so some
variance in settings based on location may be desirable.23
Sine Wave
PCC
20 The intentional adjustment of voltage with the goal of maintaining it within the normal range.
21 See IEEE Std 1547™-2018, clause 5.
22 The standard also prescribes “reactive power priority” over less effective “active power priority,” the latter of which was utilized in California’s
interconnection rules (Rule 21).
23 For instance, the reference voltage for the volt-var function, Vref, could be chosen based on circuit location.
●● Constant power factor mode:24 In this mode, the power factor—which is the ratio of active
power (a.k.a. real power or true power)25 to apparent power26—is set to the desired value
and remains the same, even as the power output from the DER fluctuates. It can be set to
either absorb or inject reactive power. Absorbing reactive power tends to decrease voltage,
while injecting reactive power tends to increase voltage. Of note, constant power factor is
the default mode for voltage
Communications/ Defaultregulation
Settings in IEEE Std 1547 -2018 and the default setting is
TM
Interoperability
1.0 (unity), which does not provide voltage regulation. Typical power factor settings that
are useful for voltage regulation are 0.95 - 0.98 absorbing. Category A DERs can reach 0.97
absorbing, while Category B DERs can reach 0.90 absorbing.
●● Voltage-reactive power mode (a.k.a. volt-var): In this mode, the DER modulates its
absorption or injection of reactive power in relation to the measured grid voltage. There can
be a “dead band” near normal voltage where no reactive power is absorbed or injected.
Values for the gain (or droop) setting of the function other than the default values must be
carefully chosen because a high gain (small droop) value may cause the control to become
n unstable while a low gainCommissioning
Islanding (high droop)& may be ineffective.
Verification
●● Active power-reactive power mode (a.k.a. watt-var): In this mode, the DER modulates
its absorption or injection of reactive power in relation to its active power output (and
absorption of active power for DERs that can store energy).
●● Constant reactive power mode: In this mode, the DER absorbs or injects a specified
amount of reactive power regardless of its active power level (i.e., reactive power remains
constant as power output from the DER fluctuates).
Sine Wave
PCC
Of note, in addition to the reactive power functions, there is a mode that utilizes a reduction in
active power to decrease voltage (normally only once voltage is outside of the normal range, or ANSI
C84.1 range A). This mode is known as voltage-active power mode (a.k.a. volt-watt).
Series
Of the above reactive power functions, the IEEE Std 1547 -2018 default is the constant power
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factor mode, with a setting of “unity” (i.e., no reactive power). Therefore, no voltage support nor its
benefits will be realized with the IEEE Std 1547 -2018 default settings. States and utilities seeking to
TM
enable and utilize voltage regulation functions will want to clarify in rules which voltage regulation
function DERs should utilize and adjust from IEEE Std 1547 -2018 defaults accordingly. Only one
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of the four reactive power functions can be activated at a time for an individual DER, while volt-watt
may be activated independently of the reactive power functions.
24 This is also expressed as the cosine of phi (cos), the phase angle between the current and voltage waveforms, which is more technically correct
than “power factor.”
25 Active power does the actual work in the load. Active power is measured in watts (W) and is the power consumed by electrical resistance.
26 Apparent power is the combination of reactive power and active power. Apparent power is the product of a circuit’s voltage and current, with-
out reference to phase angle, and is measured in volt-amperes (VA).
States and utilities seeking to enable and utilize voltage regulation functions
will want to clarify in rules which voltage regulation function DERs should
utilize and adjust from IEEE Std 1547 -2018 defaults accordingly.
TM
Constant power factor mode, watt-var mode, and constant reactive power mode all have largely
predictable effects on both the distribution grid and on DER generation. All three modes will cause
var flow27, regardless of whether var flow is needed to regulate voltage. Excessive var flow reduces the
efficiency of power delivery and reduces the active power capacity of a circuit. The volt-var mode
aims to proportionately increase reactive power as voltage gets further from normal, thus reducing or
eliminating var flow on the circuit when it is not needed. The default settings for volt-var (including
response time) in IEEE Std 1547 -2018 are meant to be applicable in a wide range of scenarios
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27 Var flow is the presence of reactive power on the distribution grid conductors and equipment. Though it does not deliver active power, it still
causes heating effects on the conductors.
28 Nominal voltage is 120V on a 120V base. Generally, it is the center of the normal service voltage range specified by ANSI C84.1 range A.
29 A specific value for Vref can be set, or alternatively can be autonomously calculated by the DER based on local measurement.
30 Hosting Capacity is the amount of DERs that can be accommodated on the distribution system under existing grid conditions and operations
without adversely impacting operational criteria or requiring significant infrastructure upgrades. For more information about hosting capacity
analyses, see IREC’s Optimizing the Grid: A Regulator’s Guide to Hosting Capacity Analyses for Distributed Energy Resources, available for free
download at: https://irecusa.org/publications/optimizing-the-grid-regulators-guide-to-hosting-capacity-analyses-for-distributed-energy-re-
sources/.
31 Such impacts include the ability of the substation or transmission system to supply vars necessary to support the reactive power requirements
of the DERs, and the reduction of active power capacity of conductors.
To address potential impacts on DER customers resulting from the implementation of voltage
regulation functions, regulators may want to consider adopting some consumer protection measures.
To begin with, states and utilities can establish reporting procedures to track customer generation
losses resulting from the utilization of voltage regulation functions, which can help regulators
determine the scale and frequency of customer impacts over time. Regulators should consider clarifying
the following issues to help inform the adoption of customer protection measures in the future:
n Islanding Commissioning &
●● Guidelines for tracking andVerification
reporting any customer generation losses;
●● Methods and techniques for estimating losses and/or the extent of voltage excursions;
●● Regular utility reporting, filed with the utility commission, of when, where, how often voltage
regulation functions are utilized;
●● Identification and consideration of possible corrective measures in the event losses
are deemed excessive or unwarranted (e.g., DER settings adjustments, monetary
reimbursement, etc.).
Sine Wave
PCC
In considering the consumer impacts of voltage regulation functions, regulators should aim to strike
the appropriate balance of optimizing the functionality for the benefit of the grid and customers,
while minimizing negative impacts on the economic value of an individual customer’s investment.
Series
Lastly, it is important to note that voltage regulation functions on the distribution system
are optimized, particularly at higher DER penetration, if all or most of the DER systems are
participating in voltage regulation. Implementing voltage regulation only for new DERs after higher
DER penetration has been achieved may dramatically reduce the effectiveness of this function. In
addition, such late-stage adoption of voltage regulation functions may disproportionately affect new
DER customers seeking to connect to the grid after a significant amount of non-voltage regulating
DER projects are connected. Hawaii, for example, learned that the grid would have been able to host
higher penetration of DERs if they had been able to deploy these functions early on.33
32 For any active power level, reactive power production requires more current from the inverter. If all available current is being used to produce
active power (i.e. at maximum active power) and the inverter is called on to produce reactive power, it must reduce active power so that some
current capability can be utilized to provide the required reactive power. Some inverters have an apparent power (kVA) rating larger than the
active power (kW) rating, allowing them to supply some reactive current even at maximum active power output. Since residential inverters are
often connected on the load side of a customer’s load center or panelboard, the maximum inverter current is limited by the circuit breaker
used, per National Electrical Code rules. Depending on the size of the breaker and panelboard bus, it could be undesirable to utilize an inverter
with a kVA rating higher than the kW rating.
33 Giraldez, Julieta, et al., Simulation of Hawaiian Electric Companies Feeder Operations with Advanced Inverters and Analysis of Annual Photo-
voltaic Energy Curtailment, National Renewable Energy Laboratory and Hawaiian Electric Company, pp. 80-82, September 2017, available at:
https://www.nrel.gov/docs/fy17osti/68681.pdf.
a local DER communication interface, with a minimum set of communications capabilities which
could allow even more benefits to be realized, as well as allowing settings to be adjusted over time.
n Islanding Commissioning &
State interconnection rules (and inVerification
some cases utility interconnection handbooks or guidance
documents) will need to specify which DERs will be required to integrate with communications
systems (e.g., DERs that meet a certain kVA threshold), and what communications protocol
the utilities will use at the DER communication interface. Ideally, there would be requirements
for consistency across utilities, where possible, in order to minimize costs and confusion in
the marketplace. Additionally, consideration should be given as to whether or not a particular
physical communications port should be available at the DER.34 Since communications services
can be also be provided by third-party aggregators that control numerous DERs, requirements or
Sine Wave
PCC agreements that address the aggregator relationships to the DER owner and the utility should also
be considered. Lastly, additional consideration should be given to when and how utilities utilize
these communications functions to control DER functionality, which may impact the operation
of the DER. States and utilities should be specific about the conditions under which DERs may
Series be remotely curtailed, turned off, and/or when changes to certain settings or functions may be
warranted. Any controls that affect DER generation will have consumer protection implications
(as noted above) that will need to be proactively addressed and documented in interconnection
agreements.
34 IEEE Std 1547™-2018 standardizes the use of an Ethernet port with TCP/IP transport layer for any of the three protocols, with an option for an
RS-485 port for SunSpec Modbus.
IEEE Std 1547 -2018 requires all categories of DERs to support at least one of three
TM
communication protocols through a specified local DER communication interface: IEEE Std
2030.5 (SEP2), IEEE Std 1815 (DNP3), or SunSpec Modbus.35 IEEE Std 1547 -2018 also
TM TM TM
requires DERs to support specific parameters for monitoring information and for managing
functional settings (including protection and controls). In the absence of communications
infrastructure, access to the settings of the DER must be available through a hardware or software
panel on site. Of note, given the inherent challenge of adjusting these settings after a DER has been
n commissioned
Islanding (an in-person visitCommissioning
toVerification
the DER & location would likely be necessary), it is important to
adopt settings that will not likely require adjustment after commissioning.
Traditionally, larger DER projects and/or those with special interconnection agreements (e.g., DERs
participating in wholesale markets) have been required to have communications and controls enabled
in order to interface with the grid operators. However, these technical capabilities have not yet been
standardized. Over time, it is expected that the communication protocols will continue to harmonize
and be capable of communicating across different networks and between technologies that have
distinct settings (a.k.a. interoperability36). These updated requirements for communications and
Sine Wave
PCC
interoperability will help optimize DERs on the grid and improve safety and reliability. Transitioning
to IEEE Std 1547 -2018 compliant local DER communications interfaces will require time for
TM
and alignment with IEEE Std 1547 -2018, states may want to evaluate the deployment of
TM
communications and controls infrastructure in the context of existing or planned Smart Grid,
Grid Modernization, Distribution Resource Plan, and/or Integrated Resource Plan proceedings.
35 IEEE Std 2030.5™ is the IEEE Adoption of Smart Energy Profile 2.0 Application Protocol Standard; IEEE Std 1815™ is the IEEE Standard for
Electric Power Systems Communications-Distributed Network Protocol (DNP3); SunSpec Modbus is a standard that defines a set of common
register values for devices such as three-phase inverters, single-phase inverters, meters, environmental units, and related measurement devic-
es, see https://sunspec.org for more information.
36 See IEEE Std 1547™-2018, clause 10.
37 Performance or cybersecurity requirements related to DER management networks are outside the scope of IEEE Std 1547™-2018.
D. Power Quality
of which relate to power quality. In addition, the Standard alters and clarifies harmonic distortion
38
limits. These requirements ensure that other utility customers located on the same circuit as a
DER, as well as the utility equipment, are not negatively affected. These requirements pertain to all
categories without any optionality, so no decisions need be made regarding their application within
interconnection rules. References or requirements for power quality in existing interconnection rules
or utility handbooks should be updated to align with these new IEEE Std 1547 -2018 provisions. TM
The overvoltage limits in IEEE Std 1547 -2018 ensure that DER complies with effective grounding
TM
Verification
and when grounding banks or grounding transformers are needed to limit ground fault overvoltage.40
While equipment requirements for effective grounding for rotating machines are commonplace,
recent research has shown that inverter-based DERs do not have similar responses in terms of
overvoltage events.41 IEEE Std C62.92.6 -201742 helps explain the concepts of inverter response
TM
and how grounding does or does not affect overvoltage. Whether effective grounding requirements
are addressed in a state or utility’s interconnection rules or not, it may be prudent to review utility
practices in order to ensure that excessive grounding is not required for DERs and that DER
customers do not bear the cost and time burden associated with unnecessary equipment.
System Controls and Sine Wave
The overvoltage limit in IEEE Std 1547 -2018 also addresses another effect known as load rejection
Power Limitation at the PCC TM
overvoltage. In the scenario where a circuit breaker or other device initiates an island condition,43
cutting off a portion of the load to which a DER was initially providing power, there is insufficient
load available to consume the DER power being fed onto the grid. This results in an overvoltage
situation
IREC Smart Invertercalled load rejection overvoltage. Historically, concerns over load rejection overvoltage have
Icon Series
led utilities to limit DER penetration or take other conservative actions to prevent damage to other
customers’ or the utility’s equipment. Initial research on inverter load rejection overvoltage response
conducted by NREL noted “over-voltages were less severe than some observers had feared and have
allayed some utility concerns.”44 Hawaiian Electric has required load rejection test data for inverters
for several years. IEEE Std 1547.1 will require similar testing and the DER must remain within the
TM
stated limits of IEEE Std 1547 -2018. This, in turn, will impact interconnection studies and the
TM
technical screening process for DERs seeking to connect to the grid. As such, states and utilities will
need to address how interconnection requirements might change in light of these new mandatory
limits that all DERs will be subject to once IEEE Std 1547 -2018 is fully rolled out.TM
E. Islanding
Standard, the time limit (a.k.a. clearing time) for DERs to detect islands and cease energization may
be extended from the current 2 seconds up to 5 seconds, by mutual agreement of the utility and the
DER customer. In cases where risk of islanding for longer than 2 seconds is an identified possibility,
this longer time may allow anti-islanding methods to operate or for the voltage to collapse on its
own, eliminating the island. The 5 second time limit may require that any recloser upstream of the
DER also have sufficiently long reclose time (i.e., greater than the DER clearing time or greater than
the time at which the island would collapse). Another option is to use voltage-permissive reclosing,
Sine Wave
where the reclose is blocked if an island is present on the isolated feeder section. Where it can be
determined that an increased DER clearing time can be utilized without negatively affecting safety
and reliability, recloser settings can be coordinated to accommodate DER connection that may
otherwise be subject to Direct Transfer Trip (DTT)47 or other costly upgrades. The benefit of this
ies increase in DER clearing time would apply to all DER downstream of the relevant recloser, though
it may only initially be proposed as a mitigation strategy for a single DER (or group of DERs) that
may be at risk of having to go through a costly or time-intensive interconnection study.
IEEE Std 1547 -2018 also addresses, to a more limited extent, intentional islands (a.k.a. microgrids)
TM
that are fully behind the PCC48 (a.k.a intentional Local Electric Power System (EPS) island) or that
include a portion of the Area EPS (a.k.a intentional Area EPS island). Intentional Area EPS islands,
sometimes called “utility microgrids,” could include DERs from multiple owners, load-only
customers and utility equipment. IEEE Std 1547 -2018 specifies special requirements for DERs
TM
that participate in intentional Area EPS islands. Utilization of such capabilities is subject to mutual
agreement with the DER owner and the utility.
The Standard gives special exemptions to DERs in intentional islands from the ride-through
performance and trip requirements and allows them to disconnect from the grid and form an island
as long as certain power balance criteria are met.
As states, communities and utilities seek to improve and enhance grid resilience and reliability,
especially during inclement weather or severe electric system disruptions, adopting state regulations
and standards surrounding intentional islands can provide important clarity for how these islands
interact with and function on the existing grid. For example, it may be prudent to include some
language in state and utility interconnection requirements to make it clear that such intentional
islands are explicitly allowed and subject to certain appropriate technical requirements.
45 Islanding is the condition in which a distributed generator continues to power a portion of a circuit even though power from the electrical grid
is no longer present.
46 See IEEE Std 1547™-2018, clause 8.
47 DTT usually consists of a fast communications link from breakers or reclosers upstream of the DER to a relay at the DER location which can
disconnect the DER whenever the upstream devices disconnect. These are generally bespoke solutions that can include new telephone wire or
other communications channels to be put in place, as well as additional equipment or adjustments at the utility device and DER locations.
48 Point of Common Coupling (the point of connection between the DER customer and the utility, typically at the utility revenue meter).
interconnecting to secondary spot networks and secondary grid networks.49 Any existing language
in interconnection rules addressing network interconnection may need updating based on the new
Standard. However, the additional requirements are more akin to secondary networks design and
DER operations considerations and do not alter requirements from IEEE Std 1547 -2003. The new TM
language does allow DERs to be connected to Area Networks, where that was not addressed in the
er Protection earlier Standard. IEEE Std 1547.6 provides more explanation on recommended practices.
Islanding Commissioning &
TM
Verification
G. Fault Current
rter Icon Series voltage and current data for faults obtained during certification testing.50 No additional changes
to the interconnection process are likely necessary, beyond specifying this data requirement.
However, as this data is collected over time,
Consumer Protection attention should be paid as
Islanding to whether
Commissioning & changes to the
Verification
interconnection processes are warranted based on the utilities’ evolving understanding of inverter
fault current.
exporting onto the grid beyond designated specifications (e.g., for DERs that are designed to be non-
exporting51 or limited exporting52).53 However, the Standard does not give specific guidance on how
these system controls should be implemented. As such, further definition of related requirements
mayInverter
IREC Smart be prudent to include in interconnection rules to address these systems.
Icon Series
For example, IEEE Std 1547 -2018 notes that the reference point of applicability may be
TM
determined based on whether or not the DER is prevented from exporting power more than
500 kVA for longer than 30 seconds. This implies that a DER may include a plant controller that
measures export power and controls the DER units to serve on-site load, while ensuring a specific
power limit is not exceeded. Similar controls may be used to implement the volt-watt function,
such that on-site load can be served even when voltage is high. The concept might also be extended
to the limit active power function, where an external control demands power export reduction.
Furthermore, a DER system may also include export-limiting controls in order to comply with
other relevant compensation policies pertaining to exported or excess generation (e.g., net energy
metering).
As another option to control the output of a DER, IEEE Std 1547 -2018 allows for the possibility TM
of a “configured” nameplate rating54 to be used. This relatively new concept would allow for the use
of a configuration setting to limit the nameplate capacity of the DER to a lower capacity than its
actual nameplate capacity, and this setting would effectively prevent the DER from exporting power
beyond the configured nameplate rating at the reference point of applicability (e.g., the PoC).
51 DER systems primarily designed to serve on-site customer load that never or rarely export energy onto the grid.
52 DER systems designed to never or rarely export energy beyond a certain limited power level.
53 See IEEE Std 1547™-2018, subclauses 4.2, 4.6.2 and 5.4.2 footnote 65.
54 See IEEE Std 1547™-2018, subclause 10.4
55 When non-exporting or limited-export DERs inadvertently export limited amounts of power for very short durations, it is typically due to
transient mismatch between system output and load consumption (when unanticipated load fluctuations occur). This can occur for customers
whose systems are sized to closely match their load, or those with larger loads that may abruptly turn off while being supplied by the DER
system. Importantly, inadvertent export is different from “islanding”.
56 For instance, Hawaiian Electric Rule 22, Appendix II; PG&E Rule 21, section Mm; and NV Energy Rule 15, section I.4.b.
Functions
As states work to adopt and implement IEEE Std 1547 -2018, the
TM
●● ConsumerDefault
ImpactsSettings
and Protections: Utilizing IEEE Std 1547Consumer
TM
Protection
-2018 enabled functions
can (dependent on the settings) reduce a DER system’s generation at certain locations,
will impact the review process for all DER, and states should work to ensure as much
consistency and harmonization as possible among the different utilities within their
jurisdiction. State public service commissions can set forth “preferred” IEEE Std 1547 - TM
2018 settings that apply to all regulated utilities in the state, which will help ensure
greater consistency across service territories and increased clarity for stakeholders
navigating the interconnection process. Enabling advanced functions for DERs will also
help ensure a smoother glidepath to adopt and integrate more DERs on the grid over
time. In certain situations, individualized site-specific settings may be a viable option for
DER customers seeking to interconnect in lieu of an identified grid upgrade. However,
state interconnection rules will need to provide clarity around the circumstances under
which this can occur to maintain a fair and equitable process for all DER customers.
upgrades are often dealt with through interconnection procedures, sometimes referred
to as material modifications57. IEEE Std 1547 -2018 acknowledges that “substitutive
TM
The rules governing the grid have been evolving for many years and will continue to evolve as more
DERs are integrated and optimized as resources. With IEEE Std 1547 -2018 published and a few
TM
remaining years before full rollout, now is the time for states and regulators to begin to implement
the updated Standard. The optionality included in the new Standard will require thorough discussion
of the technical, process and consumer impacts of adopting the new Standard. The Standard will not
only affect DER customers, developers, and utilities, but project financiers and investors. There are
additional issues outside the scope of this primer that will need to be addressed in addition to those
directly related to adoption of the Standard. Stakeholder engagement and thoughtful navigation of
the process will help ensure a smooth and transparent transition from old to new grid paradigms.
States that work swiftly to address the new Standard will be better equipped to integrate new
technologies, optimize the benefits of DERs, and improve system power quality. Even states that may
not expect a significant increase in DER interconnections over the next decade, can ensure adequate
DER capabilities by adopting IEEE Std 1547 -2018. Now is the time to commence the process and
TM
pave the path for a more distributed and clean energy future. w
States that work swiftly to address the new Standard will be better
equipped to integrate new technologies, optimize the benefits of
DER, and improve system power quality.
Abnormal Operating Performance Category – Specifies DER performance during a grid voltage or
frequency disturbance such as a transmission fault or loss of a generator.
Active power – The real power consumed by electrical resistance; measured in watts.
Active power-reactive power mode (watt-var) – In this mode, the DER modulates its absorption or
injection of reactive power in relation to its active power output (and absorption of active power for DERs
that can store energy).
Apparent power – The combination of reactive power and active power; measured in volt-amperes, it is
the product of a circuit›s voltage and current, without reference to phase angle.
Area Electric Power System – The electric power distribution and delivery system that includes facilities
typically owned by a utility.
Clearing time – The time limit for DERs to detect a condition which requires tripping (such as an island)
and cease energization.
Commissioning testing – The evaluation of a DER system after installation but before final energization
to inspect the system and verify that it was installed properly and to confirm that it functions as designed.
Constant power factor mode – Mode in which power factor is set to the desired value and remains the
same, even as the power output from the DER fluctuates.
Constant reactive power mode – In this mode, the DER absorbs or injects a specified amount of reactive
power regardless of its active power level (i.e., reactive power remains constant as power output from the
DER fluctuates).
Effective grounding – Limits the fault current via neutral connections to ground, grounding banks or
reactors to allow a limited and safer amount of overvoltage; effectively grounded systems limit overvoltage
to 139% of nominal.
Evaluation – The review of the design of the DER system and/or a review of the “as-built” DER system,
typically performed by a utility engineer.
Fault current – An abnormal electric current between conductors or conductors and ground, typically
due to physical contact.
Flicker – The changing light intensity (e.g., a change in brightness from a lamp) caused by voltage
fluctuations.
Frequency regulation – The adjustment of active power input during temporary frequency disturbances;
also referred to as “frequency-droop” or “frequency-power” when in relation to DER.
Frequency-droop – See “frequency regulation.”
Ground fault overvoltage – A phenomenon that occurs when a single line faults to ground on a system
that has lost its ground reference, where a breaker has opened and before DER disconnects or ceases
production, which can potentially cause large transient or temporary overvoltages on the order of 173% of
nominal.
Hosting capacity – The amount of DERs that can be accommodated on the distribution system under
existing grid conditions and operations without adversely impacting operational criteria or requiring
significant infrastructure upgrades.
Inadvertent export – The unscheduled export of power onto the grid from non-exporting or limited-
export DERs; it is typically due to transient mismatch between system output and load consumption (when
unanticipated load fluctuations occur) and lasts for very short durations.
Intentional Area Electric Power System Island – A microgrid that includes a portion of the Area
Electric Power System.
Intentional Local Electric Power System Island – A microgrid that is fully behind the point of common
coupling.
Interconnection rules – Regulations that govern the processes required for generating facilities to
connect to the grid; also called “interconnection standards” or “interconnection procedures.”
Electric Power Research Institute, IEEE 1547 – New Interconnection Requirements for Distributed
Energy Resources: Fact Sheet, June 2017, available at: https://www.epri.com/#/pages/
product/000000003002011346/.
Electric Power Research Institute, IEEE Standard 1547 – Communications and Interoperability: New
TM
Requirements Mandate Open Communications Interface and Interoperability for Distributed Energy
Resources, July 2017, available at: https://www.epri.com/#/pages/product/000000003002011591/.
Electric Power Research Institute, IEEE Standard 1547 Power Quality Considerations for
TM
Electric Power Research Institute, Recommended Settings for Voltage and Frequency Ride-Through
of Distributed Energy Resources, May 2015, available at: http://www.epri.com/abstracts/Pages/
ProductAbstract.aspx?ProductId=000000003002006203.
Giraldez, Julieta, et al., Simulation of Hawaiian Electric Companies Feeder Operations with Advanced
Inverters and Analysis of Annual Photovoltaic Energy Curtailment, National Renewable Energy
Laboratory and Hawaiian Electric Company, September 2017, available at: https://www.nrel.gov/docs/
fy17osti/68681.pdf.
Hoke, Andy, et al., Inverter Ground Fault Overvoltage Testing, National Renewable Energy Laboratory
and SolarCity Corporation, August 2015, available at: https://www.nrel.gov/docs/fy15osti/64173.pdf.
IEEE Std 1547 -2018 (Revision of IEEE Std 1547 -2003), IEEE Standards Coordinating Committee 21
TM TM
Interstate Renewable Energy Council, Model Interconnection Procedures, April 2013, available at:
https://irecusa.org/publications/model-interconnection-procedures/.
Interstate Renewable Energy Council, Optimizing the Grid: A Regulator’s Guide to Hosting Capacity
Analyses for Distributed Energy Resources, Stanfield, Sky, et al., Dec. 2017, available at: https://irecusa.
org/publications/optimizing-the-grid-regulators-guide-to-hosting-capacity-analyses-for-distributed-
energy-resources/.
Nelson, Austin, et al., Inverter Load Rejection Over-Voltage Testing, National Renewable Energy
Laboratory and SolarCity Corporation, February 2015, available at: https://www.nrel.gov/docs/
fy15osti/63510.pdf.
www.irecusa.org