Connection Impact Assessment (CIA) guidelines and best practices
As part of the Two-Year Review of the Feed-In Tariff Program, generators and distributors identified the need for greater clarity and transparency of the connection process for distribution-connected generation projects. The resulting recommendation from the Two-Year Review Report in March 2012 was:
Establish best practices and processes for local distribution companies (LDCs) and transmitters that will improve communication, transparency and coordination between the Ontario Power Authority (OPA), LDCs, transmitters and generators regarding the Connection Impact Assessment (CIA) process and status of applications.
The Ministry of Energy, has developed a set of best practices in consultation with the Ontario Energy Board (OEB), Ontario Power Authority (OPA), Independent Electricity System Operator (IESO), Electricity Distributors Association (EDA), and several generator organizations to increase transparency and predictability for generators as well as to help both LDCs and generators better understand how the connection process can influence development timelines and milestones.
The review resulted in two key documents:
- A set of best practices recommended for any organization involved in preparing impact assessments.
- A visual description of the parts of the Distribution System Code and regulation applicable to the timelines for CIA applications, is available on the Ontario Energy Board’s website.
The Electricity Distributors Association, the Ministry of Energy and their partners in this effort encourage LDCs and generators to adopt and implement these best practices to improve the transparency, coordination and understanding of the CIA process.
Connection Impact Assessment Process: Industry Best Practices For Distribution-Connected Projects
In response to a recommendation resulting from the Two-Year FIT Program Review, the Ministry of Energy, together with the OPA, the OEB, the IESO, and distributors, and with the help of the Electricity Distributors’ Association, developed the following set of best practices to increase transparency and predictability for generators in the Connection Impact Assessment (CIA) process as well as to help both distributors and generators better understand how the connection process can influence development timelines and milestones.
Best Practices Regarding Connection Impact Assessment For Distribution-Connected Projects
- Generator connection information package: the requirements of generator connection information packages, as described in section 6.2.3 of the Ontario Energy Board Distribution System Code (last revised June 13, 2013) (DSC), are proposed to include the following:
- Incurring project costs: generation connection information packages explicitly and prominently state that prospective customers incur costs at their own risk if spent prior to receiving an Offer to Connect from their distributor1 and, if applicable, receipt of an OPA contract.
- Single line diagrams (SLDs): package should state that SLDs should be reviewed and signed-off by a Professional Engineer.
- Availability of generation packages: provide generator connection information package on the distributor’s website.
- Guidance document for generators: For guidance purposes only, it is an identified best practice for a distributor to provide samples of typical completed CIA applications for capacity allocation exempt small, small, and mid-sized embedded generation facilities, as well as an example of a completed and successful CIA application for a large project. It is an identified best practice that the guidance document clarifies to generators that changes to connection circumstances may trigger CIA revisions. Providing examples of circumstances that would trigger a CIA revision, where possible, is also an identified best practice.
- Technical requirements for connecting to a distribution system: The technical requirements for being connected to the distributor’s distribution system, including the distributor’s feeder, substation and any imposed upstream technical capacity limits as well as metering requirements are made separately available on the distributor’s website.
- Clarity of distributor connection impact assessment (CIA) completion timeline: A visual description of relevant timelines is available to applicants on the OEB’s website [PDF – 144KB]. It is an identified best practice that all distributors’ websites and the OPA’s website link to it as well.
- Duration of comment period for small, mid-sized, and large projects (6.2.16): In order to align with the 90 day period set out in DSC, section 6.2.16, distributors should adopt the best practice of a 50 day comment period from any transmitter or applicable distributor when feasible, e.g. for mid-sized facilities proposing to connect to a non-embedded distributor. In any circumstances where the 50 day comment period is not feasible, comments should be returned in as timely a manner as circumstances permit.
- Early identification of incomplete applications: Distributors communicate to customers a target to ensure 90% of applications are assessed for completeness within a set number of business days, established by the distributor. If incomplete, the distributor contacts the generator seeking further information.
- Incomplete applications: It is an identified best practice that the prescribed timeline for completing a CIA be viewed as beginning on the date the distributor deems the application is complete.
- When to begin conducting the CIA: The distributor or transmitter does not begin the connection impact assessment until the application is deemed to be complete.
- Transmission station analysis in the distributor CIA: The distributor CIA for CAE Small,2 Small,3 and Mid-sized4 generators requires assessment of transmission stations by the transmitter. Transmission station assessment by the transmitter for small and mid-sized generators is completed within the prescribed timeline of the distributor CIA.
- Sequencing of embedded and host distributor CIAs: If a host distributor5 CIA is required, it is an identified best practice that the host distributor CIA is completed in parallel with and by the same date as the embedded distributor6 CIA. The embedded distributor forwards a complete application to the host distributor within the timeframe established in best practice #4 and informs the host distributor of the date that the host distributor CIA is to be completed by.
- Sequencing of transmitter customer impact assessment (CIA) and IESO system impact assessment (SIA): When a transmitter CIA and IESO SIA are required for large generators, both assessments begin after the distributor CIA is completed. The distributor, or embedded distributor in the case where there is a host and embedded distributor, applies to the IESO on behalf of the generator within five days of completing the distributor CIA. Within ten days of the IESO receiving the application, the IESO and applicable transmitter jointly review the SIA / CIA application for completeness and inform the distributor of any missing information. Once deemed complete, the IESO and transmitter conduct their respective assessments in parallel. As described in section 2(2) of O. Reg. 326/09, the IESO provides the assessment of the impact or potential impact of the connection on the integrated power system to the distributor within 150 days of receiving a complete application. It is an identified best practice that the assessment includes assessment by both the IESO and the transmitter.
- Update generator of status of distributor CIA: On the day a CIA or SIA application is deemed complete, the distributor notifies the generator in writing that their application is complete and the date by which the required CIAs and SIA (if applicable) will be completed. The CIA completion date may be specified in a CIAStudy Agreement if applicable, or by email.
- If an application is incomplete, it is an identified best practice that the distributor informs the generator of missing or unclear information, clarifying that the service standard timeline for the assessment cannot begin until the application is considered to be complete from the distributor’s perspective. Reference may be made to best practices #4 and #6.
- On the day the CIA application is deemed complete, it is identified as a best practice that the distributor also notifies the generator of who else is conducting a CIA (e.g. host LDC / transmitter) and confirms that such a request for a CIA has been made. For large generators, it is an identified best practice that the distributor also confirms to the generator that a SIA is required.
When communicating the CIA or SIA completion timelines to generators, it is an identified best practice that the distributor considers making reference to the sections of the DSC and O. Reg.326/09 prescribing the timeline.
- Threshold transmitter CIA: It is an identified best practice that distributors and host distributors use a threshold transmission CIA wherever possible. According to the information provided by Hydro One, a threshold transmission CIA can be used when the transmitter allocates transmission capacity to a distributor for accommodating inverter based generation, under certain conditions. For more information, see ‘Threshold CIA Process Review and Update’[PDF – 77.5KB]
Disclaimer: The group responsible for creating this document has identified the contents of this document as best practices which you are free to consider and utilise. The contents of this document do not constitute legal advice and are not provided as a substitute for independent legal advice. These materials are not a legal interpretation of the statutes, regulations, codes or rules to which they refer, nor are they legally binding on any member of the public or on any entity or authority referred to within the documents. Any adoption or use of these materials is discretionary, and the Government of Ontario does not accept legal responsibility or liability for the accuracy of their contents, or any outcomes obtained or not obtained due to the use or failure to use these best practices.