This post outlines the specific removability and replaceability requirements that the SBR will impose on portable batteries and light means of transport ("LMT") batteries (e.g., batteries for electric bicycles) marketed in the EU/EEA as of around September/October 2026. The new requirements will oblige producers of appliances to introduce design changes to their appliances and the batteries they incorporate. Moreover, clarifying the details of such requirements is likely to create much controversy and debate among the European Commission, Member States and other stakeholders within the next two years. In effect, the SBR leaves it to the Commission to adopt guidelines interpreting the different removability and replaceability requirements.
The post also briefly mentions the political compromise that the European Parliament and Council reached on the removability and replaceability of electrical vehicle batteries and "starting, lighting and ignition" ("SLI") batteries, and its emphasis on ensuring that such batteries be removable and replaceable by "independent professionals" (and not just authorized dealers).
Removability and Replaceability Requirements for Portable Batteries and LMT Batteries
While we expect that the EU legal linguistic experts will have to introduce some edits, Article 11 of the SBR imposes different removability and replaceability requirements for portable batteries than for LMT batteries.In turn, it would exempt from the removability and replaceability requirements portable batteries where continuity of power supply is necessary and a permanent connection between the device and the portable battery is required to ensure the safety of the user and the appliance, or for products that collect and supply data as their main function, if this is necessary for "data integrity reasons."
Portable Batteries
The SBR defines portable batteries as any battery that is sealed, weighs below or equal to 5 kg, is not designed specifically for industrial uses, and is not an electric vehicle, LMT or SLI battery. As from 42 months after the entry into force of the SBR, producers marketing devices incorporating such portable batteries must ensure that the batteries are "readily removable and replaceable" by the "end user" at any time during the lifetime of the device. Thus, the general rule for portable batteries is that it must be possible for the end user, and not a qualified professional, to remove and replace the batteries "at any time during the lifetime of the product." This wording also suggests that the Commission and Member States could take the position that portable batteries should be removable from appliances and replaceable "at any time" even if the appliance has a shorter life than that of the batteries.
Article 11(1) of the SBR also clarifies that a portable battery is "readily removable" by an end user, if it can be removed "with the use of commercially available tools" without requiring the use of: "specialized tools" unless they are provided free of charge with the product, "proprietary tools," "thermal energy" or "solvents." A recital of the SBR also explains that "commercially available tools are tools available on the market to all end users without the need for them to provide evidence of proprietary rights and that can be used with no restriction, except for health and safety reasons."
Producers marketing electronic devices incorporating portable batteries will also be required to ensure that their devices are accompanied by instructions and safety information on the use, removal and replacement of the batteries. The instructions and safety information must be posted online in a publicly available website in a manner that is easily understandable for end users.
Article 11 establishes two exceptions to the general rule that portable batteries must be removable and replaceable by end users. Devices incorporating portable batteries may be designed in such way as to make their batteries removable and replaceable only by "independent professionals" if they are:
1.万博体育app手机登录specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion and that are intended to be washable or rinseable.
Article 11(2) adds that this derogation is only applicable where removability and replaceability by an independent professional is necessary to ensure the safety of the user and the appliance. A recital of the SBR further tightens the derogation, stating that it "should only apply when it is not possible, by way of redesign of the appliance, to ensure the safety of the end user and the safe continued use of the appliance after the end user has correctly followed the instructions to remove and replace the battery" (emphasis added). Arguably, the Commission will have to refer to socio-economic and technical feasibility considerations when adopting guidance defining the scope of what is "not possible."
The same recital also suggests that a device is designed to "operate primarily" in a water environment if it is "specifically designed to be used, for a majority of the active service of the appliance" in a water environment.
2.professional medical imaging and radioactive devices.
Article 11 also empowers the European Commission to introduce additional derogations for other types of devices whose portable batteries may only be removable and replaceable by independent professionals, instead of end users. However, the Commission may do so only if the additional derogation is necessary to take into account technical and market developments and there are scientifically grounded concerns over the safety of end users removing or replacing the portable batteries, or such removability or replaceability by end users risks being in violation of other EU product safety rules.
The SBR does not define "independent professionals." However, such category of professionals also includes those that are not dealers authorized by the manufacturers of the devices. The Commission's guidelines may have to provide criteria on the qualifications that such professionals must meet in order to ensure the safety of end users and the devices.
LMT Batteries
The SBR defines LMT batteries as those that are sealed and weigh below or equal to 25 kg, are designed to provide electric power for the traction to wheeled vehicles that can be powered by an electric motor alone or by combination of motor and human power, including type-approved vehicles of category L under Regulation 168/2013, and are not electric vehicle batteries (e.g., batteries for electric bicycles). As from 42 months from the entry into force of the Regulation, producers marketing devices incorporating LMT batteries in the EU/EEA must ensure that the batteries are readily removable and replaceable "at any time during the lifetime" of the device.
However, in contrast with the requirements for portable batteries, the LMT must be removable and replaceable by "independent professionals," and not end users. Moreover, in the case of LMT batteries, the removability and replaceability requirements also apply to the battery cells included in the battery pack.
Replaceability Requirements
At the last moment of the EU's legislative negotiations, the European Parliament and Council introduced a confusing second subparagraph to Article 11(5) that seems intended to define the "replaceability" requirements for both portable batteries and LMT batteries. This is despite the fact that the first subparagraph of Article 11(5) regulates the removability and replaceability of only LMT by professional users.
In particular, as currently drafted, the second subparagraph of Article 11(5) states that a portable and LMT battery is "readily replaceable" if after its removal from an appliance or light means of transport, "it can be substituted by a similar battery, without affecting the functioning or the performance or safety of that appliance or light mean of transport." While unclear, the Commission and Member State authorities could take the view that the obligation to ensure that the battery can be substituted by a "similar" battery, "without affecting the functioning or the performance of the appliance or light mean of transport" also applies when an end user, and not only an independent professional, removes and replaces the portable battery from the device.This view could be supported by the fact that the subparagraph also contains a requirement on producers to ensure that portable and LMT "batteries be available as spare parts of the equipment they power for a minimum of five years after placing the last unit of the model on the market, with a reasonable and non-discriminatory price for independent professionals and end users" (emphasis added).
The guidelines that the Commission is expected to adopt, will also have to clarify this second subparagraph of Article 11(5). Among other things, we anticipate that the guidelines will have to take into account the Sale of Goods Directive when interpreting the subarapgraph's removability requirements. In any event, the use of the term "similar" suggests that producers must ensure that portable and LMT batteries in appliances can be replaced by batteries that are not identical, and therefore arguably can also be competing batteries, as long as they do not affect the performance or safety of the appliance.
It is also possible that this subparagraph to Article 11(5) may be slightly edited (e.g., it may be converted into a separate paragraph) before the SBR is published.
Removability and Replaceability Requirements for Electric Vehicle Batteries and SLI Batteries
In the end, the European Parliament and Council decided to drop the specific removability and replaceability requirements for automotive batteries, industrial batteries and electric vehicle batteries that the European Parliament had proposed. Instead, a recital to the SBR states that "SLI batteries and electric vehicle batteries incorporated in motor vehicles should be removable and replaceable by independent operators." The same recital adds that for the purpose of the design, manufacturing and the repair of SLI batteries and electric vehicle batteries, "manufacturers should provide the relevant vehicle on-board diagnostic information and vehicle repair and maintenance information on a non-discriminatory basis to any interested manufacturer, installer or repairer of equipment for [category M, N, and O] vehicles." The SBR defines a SLI battery as a battery "designed to supply electric power for starter, lighting, or ignition and [that] may also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery."
Thus, the recital calls for an opening up of the market of SLI and electric vehicle batteries. This is in line with the obligations that the Regulation on the Type Approval of Vehicles imposes on vehicle manufactures to provide independent operators with OBD information and vehicle repair and maintenance information. However, it is unclear how this will work in practice taking into account the warranty terms of electric vehicle manufacturers.
The recital also indicates the willingness of the Council and Parliament that a future amendment of the End of Life Vehicles Directive include provision on joining, fastening and sealing elements to ensure that the SLI batteries and electric vehicle batteries can be removed, replaced and disassembled.
Next Steps
The SBR's new removability and replaceability requirements will apply to portable and LTM batteries and devices and means of transport containing them that are marketed as of (around) the second half of 2026. Nevertheless, businesses and their trade associations should already assess the impact of the new requirements on their products and batteries. They should also try to contribute to the Commission's adopting of interpretative guidelines and the possible introduction of additional exceptions to the obligation to ensure that portable batteries be readily removable and replaceable by end users. We expect that during the next two years the Commission will hold one or more public consultations before issuing the guidelines and exceptions.
Grid-scale energy storage could help avoid such outages. Moreover, the transition to greater reliance upon renewable energy resources to combat climate change amplifies the need for grid-scale storage. While some renewable energy resources have consistent output, like geothermal or hydroelectric, other sources, like wind and solar power, generate intermittently.
Biden's AJP proposes to promote energy storage by making standalone storage projects eligible for the federal investment tax credit. As it currently stands, energy storage only receives tax credits if it is integrated with renewable generation sources that are already eligible for the tax credit.Additionally, the AJP includes utility-scale energy storage in a list of investments eligible for fifteen billion dollars of support.
The AJP's investments in energy storage as a vehicle for job creation align with the Administration's recent announcement of its intention to develop a "10-year, whole-of-government plan to urgently develop a domestic lithium battery supply chain that combats the climate crisis by creating good-paying clean energy jobs across America." That plan, like the AJP, is intended to reduce the U.S.'s reliance upon China for the vast majority of the world's lithium-ion battery cell manufacturing and raw material refining.
Storage Investment Tax Credit
Despite being essential to the scalable adoption of clean renewable energy sources, energy storage on a standalone basis does not at this time qualify for a federal investment tax credit .hrefs/blogs/Investing-Energy-service-service-business-ace-a/a/a/on the way, the falling water passes through a turbine and produces electricity that it supplied to the grid. But the physical land and water demands of a pumped hydro project make it an option that is not universally available.
Other more advanced forms of long-duration energy storage involve cooling ambient air to supercritical temperatures when electricity is in surplus or cheaper, storing it in low-pressure vessels, and then allowing the rapid expansion of the gas to drive a turbine and create electricity without combustion at times when energy demand increases. These more advanced options can provide a 50 megawatt (MW) facility, with five to eight hours of storage on an acre of land.
Green hydrogen also holds promise as a means of storing intermittent renewable energy, as we described in a prior post in this series.
But, by far, the most common form of energy storage being deployed today is through lithium-ion batteries.举个例子,Tesla目前正在加利福尼亚州前化石生成设施网站委托使用 < ahrfss/arielcohen/2020/08/13/tefs-bgins建设-worldstWoodMackenzie和美国能源存储协会2千多兆瓦新能源存储系统s//s/swoodmac.com/research/products/power-and-reservers/us-energy-serve-monitor/This is an increase of 182% from the previous quarter, and marked a new record quarter for U.S.storage.
The President's proposed tax credit could assist in encouraging that growth. The solar energy industry has cited the tax credit as one of the most critical mechanisms supporting its meteoric growth of approximately 10,000% since 2006.
More than 150 groups, including the Environmental Defense Fund, NRDC, Solar Energy Industries Association, American Clean Power Association, signed on to letters to House and Senate leadership, urging the legislature to make energy storage technologies eligible for these tax credits. Specifically, they argued that such a reform would allow energy storage to compete with other green technologies.
Clean energy industry leaders stand behind the policy. According to Gregory Wetstone, president and CEO of the American Council on Renewable Energy (ACORE), "[a] federal tax credit for energy storage would have a transformative impact, promoting private sector investment and helping monetize the value of energy storage technology." The energy tax credit also enjoys bipartisan support.
Additional Funding for Utility-Scale Energy Storage
One of the major goals of the AJP is to establish the United States as a leader in climate science, innovation and R&D. Specifically, the AJP would invest $15 billion in demonstration projects for climate R&D priorities, including utility-scale energy storage, among a number of other technologies. So, in addition to the extension of eligibility for the investment tax credit, the AJP could provide financial assistance to utility-scale energy storage projects at the cutting edge.
A Secure Domestic Supply Chain for Energy Storage
Despite the paucity of federal support available to-date, cost effective energy storage has been described as the "holy grail" that could unlock possibilities for the deployment of intermittent renewables at the scale needed to achieve the President's target of a zero-carbon electricity sector by 2035. The AJP's and Congress's plans to reward storage with tax benefits would be an important first step in mobilizing the private capital needed to realize storage's potential.
Additionally, as a result of the Administration's assessment of critical supply chains, which was conducted pursuant to Executive Order (E.O.) 14017, the Administration, just last week, announced an even broader effort to secure a domestic supply chain for high-capacity batteries.
The recommendations resulting from the Administration's supply chain assessment include the following (among others):
- Developing a National Blueprint for Lithium Batteries – a 10-year plan to onshore the entire supply chain for batteries, from the critical minerals that go into them, to recycling at their end-of-life;
- Investing in development of next-generation batteries that will reduce critical mineral requirements for grid storage!并
- Launching支持联邦机构通过能源部联邦能源管理程序部署能源项目。
离散能源链创举反映了政府的观点,即投资清洁能源技术不仅对解决气候变化问题是必要的,而且对确保美国21世纪全球领导权也是必要的。
The value of storage resources to the grid
The reliable operation of the North American alternating current (AC) grid depends on maintaining a frequency near 60 Hertz (Hz). If frequency deviates too far from 60 Hz, the grid can become unreliable. Batteries' and flywheels' unique ability to quickly absorb and discharge electricity provides them with significant operational flexibility to help keep the bulk power system in balance.Importantly, these electric storage devices can also provide a variety of additional services in bulk power markets.
The complaint and the Order
Indianapolis Power & Light (IPL) owns a grid-scale lithium ion battery-based energy storage system that, it claims, is capable of providing a variety of grid support services to the Midcontinent ISO (MISO). In its complaint, IPL argued that the MISO tariff limits storage resources to providing only one type of service (regulation service) but subject to a dispatch protocol developed for flywheels that is not appropriate for lithium ion batteries and other fast resources. More importantly, IPL's battery facility is technically capable of providing services in addition to regulation. For example, the facility can act like a demand response resource and supply energy and other services in MISO's markets. IPL asserted the tariff should allow any resource to provide the services it is technically capable of providing.
FERC agreed with IPL, finding that MISO's tariff unnecessarily restricts competition by preventing storage resources from providing all the services they are technically capable of providing, which could lead to unjust and unreasonable rates. The Order says that "electric storage resources…should not be required to participate in MISO's markets by using rules that were designed for other types of resources….because those participation models do not accommodate the unique features of electric storage technologies" and that "failure to recognize the unique physical and operational characteristics of electric storage resources could unnecessarily restrict competition by preventing electric storage resources from providing all the services that they are technically capable of providing, which could lead to unjust and unreasonable rates."
The Order finds that IPL has met its burden to show that the MISO Tariff is unjust, unreasonable, and unduly discriminatory or preferential. Accordingly, FERC orders MISO "to remedy its unjust and unreasonable Tariff to provide Indianapolis Power with relief" and make a compliance filing within 60 days. The Order notes, however, that the Commission has not made any final determinations in its Storage NOPR proceeding, which proposes to require the RTOs to establish rules that recognize the physical and operational characteristics of storage resources and accommodate their participation in all markets in which they are technically capable of participating.
FERC rejected several parts of the complaint in which IPL alleged that certain MISO tariff provisions regarding compensation and dispatch protocols adversely affect storage resources. These issues are likely to be addressed again in the context of the tariff provisions MISO files in compliance with the Order.
A spokesperson for IPL said that "(t)echnological advances in this field happen rapidly [and] understanding benefits and the regulatory changes needed to realize all these benefits can take years."
Hence the potential significance of distributed generation. By day, a home battery can be charged on renewable sources!by night, it will continue to provide power despite the setting sun or calming winds. Most manufacturers of decentralized storage appear to provide scalable batteries—one battery could power a home or small business, and many batteries could power a town. Home battery costs have decreased 14% since 2007, as many manufacturers currently list their home batteries at around $3,000. Moreover, costs to consumers will likely continue declining because of the many manufacturers competing in the marketplace and Tesla's promise to place its home battery specifications in the public domain.
When Tesla CEO Elon Musk unveiled his company's home battery on April 30, 2015, he noted its potential value for Africa. The alternative—installing and upgrading traditional grid infrastructure on the continent—is highly expensive. For instance, South Africa's government-owned utility company estimated it would cost $22 billion to improve the grid enough to meet current demand. Decentralized energy storage that is affordable will increase the feasibility of on-site energy generation and reduce the need for a fully-developed transmission grid.Analysts project the market for microgrids reaching $20 billion in 2020, and on-site generation of solar power becoming comparable to or cheaper than grid-supplied power. Just like how cell phones enabled access to the internet and microfinancing, distributed generation and on-site storage could light up homes, increase technological innovation, and change the look of the African economy.
Whether a home battery built by Tesla, General Electric, Samsung, LG Chem, or another company becomes the premiere energy storage solution in Africa, distributed generation has the potential to revolutionize electricity and power throughout the continent.
Calvin Cohen is a summer associate in Covington's Washington D.C.Vanderbilt大学法学院办公和学生
Technological advances in distributed generation and battery storage and their consequent falling costs have the potential to significantly change the electric utility business model and regulatory policies. While change seems likely, there are varying views on its scope, probability and timing. Two are presented here.
One perspective is that fundamental changes in the way electricity is produced and delivered are unavoidable. They are coming soon, and new regulatory policies and business models are needed. These are the implications of a new report by the Rocky Mountain Institute (The Economics of Load Defection) that describes the findings of research evaluating the relative economics of taking service from the grid compared to customer-installed resources.
With increasing retail electricity prices and decreasing solar and battery costs, the report finds that the most economic scenario for electricity customers is to install combination solar-plus-battery systems and remain on the grid.最终效果取决于客户对变化经济学和安装设施快速行动,但根据报告,太阳能+电池系统最终提供客户电量大都。 2030年,离现在仅15年之久,美国东北部电网销售流失could be as high as 50% for residential customers and 60% for commercial customers.
Utilities are concerned about this potential revenue erosion and are proposing policies to address it. One concern is that part of their declining sales revenue pays for the grid. So one suggested policy is to abolish net metering, under which customers receive a retail rate billing credit for electricity produced by their facilities above what is consumed and thus put on the grid. Another policy is to impose a fixed charge on customers that have on-site generation to help pay for the grid. According to the report, however, both policies will only delay the eventual loss of revenue.
The report observes that customers with solar-plus-battery systems should be able to bring value to the distribution grid by deferring upgrades and providing ancillary services and congestion relief, but realizing these benefits will require reforms on three fronts:
- New pricing and rate structures that are locational (allowing congestion pricing or other incentives), temporal (time-of-use and real-time pricing) and attribute-based (breaking apart energy, capacity, ancillary and other service components).
- New business models based on grid-connected customers with distributed resources (like solar and batteries) and a two-way flow of electricity on the grid (not one way from grid generators to customers).
- New regulatory models that (1) provide fair and equal customer access to distributed resources, (2) recognize, quantify and monetize the benefits and costs of distributed resources, and (3) treat all customer equitably.
In an interview with greentechmedia, Leia Guccione, a co-author of the report, said "there is a real cost to doing nothing....缺少更多客户选择时,客户将自行处理事务网格变换-过度投资-未充分利用资本中将产生最优结果。 国家监管研究院(NRRI)
KenCostello提供最近一篇文章中略微不同的视角,即公共事业双周刊( 表示,Costello表示,“变化似乎不可避免,但对电产业的影响仍然在通量和未知中 。不可避免激进产业变换和`无大变换'的视觉都似乎极端化。”
On the deployment front, energy storage is reportedly poised for significant growth in the U.S.Storage is an important complement to variable generators such as solar and wind because it provides energy when those resources cannot. According to a report by the Energy Storage Association and GTM Research, the storage capacity forecasted to be deployed in 2015 (220 megawatts) is more than three times the 2014 total, and by 2019 annual additions are expected to be almost four times the 2015 level (860 megawatts). Perhaps more important, 90% of storage capacity added in 2014 was on the utility side of the meter but by 2019, 45% of new storage is expected to be on the customer side of the meter. Increased deployment of customer-side storage will mean customers can lower their demand at peak times and perhaps rely on their own renewable power resources. Either means less need for utility income-producing investment in generation capacity.
And on the regulatory front, the New York Public Service Commission adopted a comprehensive policy framework for a reformed retail electric industry that is aimed at increasing distributed energy resources and dramatically changing the role of utilities. Distributed energy resources "will become integral tools in the planning, management and operation of the electric system," placing them "on a competitive par with centralized options." The current retail utilities will serve as a platform to provide uniform market access to customers, distributed resources and aggregators. In a press release, Commission Chair Audrey Zibelman said the new policy "will reorient both the electric industry and the ratemaking process toward a consumer-centered approach that harnesses new technologies and markets." Each New York utility must file an implementation plan by December 15, 2015.
These developments — advances in fuel cells and storage, and a new regulatory policy in a key state that significantly elevates the role of distributed resources to meet customer needs — are but the most recent indicators that new technologies are making steady inroads toward transforming the traditional role of electric utilities.
Half of the new electricity generation plants added in 2013 are fired by natural gas and almost 30% of new generation is powered by solar and wind energy, according to an April 8 report from the Energy Information Administration. This combination is likely to mean even more demands on the already-strained natural gas delivery infrastructure.
A need for more pipeline capacity is an obvious impact of adding more gas-fired generators. However, substantial additions of renewable generation also add demands on pipelines. As reported in a recent edition of the trade publication Megawatt Daily,[1] Frank Brock with ICF International points out that when renewables are not running, such as when the sun goes down and the wind stops blowing, "you have a big surge in the need for replacement generation — and that's coming from natural gas." This demand for more gas deliverability is weather dependent, and, according to Brock, there will not be a lot of investment in new pipeline capacity unless the demand is "solid and steady."
This impact will be especially felt in California. According to the EIA report, nearly 60% of the natural gas generation capacity and 75% of solar resources added in 2013 are in California. The state needs generation just to meet load, and also needs flexible generation resources like gas to complement the renewable resources being added to meet an ambitious renewable resource requirement. Deliverability constraints will also be felt in New England, according to Brock, as a result of the shale gas boom in the region.
Part of a solution may be additional gas storage.This could come from distant traditional storage facilities or close-in LNG peak-shavers. Brock says no one is really thinking about storage now, but a probabilistic analysis based on expected weather over the next 10 years would likely show "a huge need for high-deliverability storage."
The Federal Energy Regulatory Commission (FERC) encourages new storage facilities by allowing storage providers to charge negotiated, market-based rates. FERC allows market-based rates if the seller shows it has no market power. However, for storage and storage-related services related to a facility placed in service after August 8, 2005, market-based rates are allowed without such a showing if FERC determines that: (1) market-based rates are in the public interest and necessary to encourage the construction of the storage capacity in an area needing storage services!servits/Wangp/AppData/Lible/Microsoft/Windows/Temory%20Files/Content.OptLook/NUCWH2M/Gas%20storage%20une
FERC recently revised its rules for interconnecting small generation facilities (no more than 20 MW) to the grid. Among other things, the new rules provide increased flexibility in qualifying for a "fast track" interconnection process, especially for solar and energy storage resources.
Under FERC's small generator interconnection procedures, a generator makes an interconnection request and the transmission provider then evaluates whether the generator can be interconnected to the grid safely and reliably. One procedure for evaluating an interconnection request is the Study Process, which normally requires three studies to identify adverse system impacts and any system modifications required to accommodate the interconnection. There is also a Fast Track procedure available to facilities no larger than 2 MW that employs technical screens to quickly identify any safety or reliability issues associated with a proposed interconnection. If the screens are passed, the interconnection moves forward without further study.
FERC found that, due to the increasing number of small generator interconnection requests driven by state renewable portfolio standards and growth in solar PV installations, reforms were needed to avoid inefficient interconnection queue backlogs and facilities undergoing the more costly Study Process when they could be interconnected under the Fast Track Process safely and reliably.
The most significant reform FERC adopted was to revise the Fast Track eligibility threshold for inverter-based machines. An inverter is a device that converts the direct current (DC) output of a DC generator to alternating voltage (AC) so that it can be interconnected with the AC electric system.The output of a solar panel is DC. With the new rules, under certain conditions (generator capacity and interconnection voltage and location) inverter-based facilities up to 5 MW will be eligible for the Fast Track process. That's more than double the existing 2 MW threshold, which remains for other machines. Accordingly, this change should allow more solar facilities to use the Fast Track Process. In fact, FERC's rulemaking process for these reforms was started in response to a petition by the solar industry requesting significant improvements to federal interconnection rules for solar wholesale distributed generation.
Other reforms adopted by FERC include:
- Energy storage devices are explicitly included in the definition of Small Generating Facility.
- Interconnection customers may request from the transmission provider a pre-application report that provides readily available information about system conditions at any possible interconnection point. These reports are expected to help a customer select the best site for its facility, reduce developer costs, and diminish the practice of multiple interconnection requests for a single project.