Outline

1. Standards Testing Protocols, Opportunity for Round-Robin Testing and Inter-Laboratory Conformity Assessments • T. Basso, NREL*; IEEE SCC21 Secretary; and USA IEC TC8/TAG Technical Advisor and Administrator • 2nd IRDER Conference Workshop • December 4, 2006; Napa California • ---------------- ---------------------------------------------------- -------------------- • * National Renewable Energy Laboratory (NREL), • Distributed Energy & Electricity Reliability Program; funded by US DOE Office of Electricity Delivery and Energy Reliability (OE)

2. Background: standards/protocols/programs for testing and conformity assessment, e.g., development, maintenance, updating; approach; etc. • Sample Case Studies: 1) Photovoltaics – performance criteria and test methods; standards development; laboratory accreditation and equipment certification; implementation of a conformity assessment program (e.g., PowerMark Corporation); … 2) DER Interconnection –interconnection requirements and testing requirements; ANSI/IEEE 1547 standards; 2005 Energy Policy Act (EPACT); implementation of best practices (PJM, MADRI, states models); Nationally Recognized Testing Labs; … • Opportunities/Discussion: multiple programs, consistency, quality, transparency, reciprocity,... Where to from here? Outline

3. Definitions and Terms accreditation – an authoritative body establishes formal recognition via formal processes that an entity is competent to perform specified tasks. certification - compliance to standards or specifications. Certification is established via conformity assessment. conformity assessment - official valuation activities (i.e., programs, protocols or schemes) concerned with determining that requirements are fulfilled; conducted by some organization or “party.” Program type often defined in regards to who is the responsible party: First party (self assessment) - by a supplier(s); Second party - by a buyer(s); Third party - by an entity independent of both seller and buyer. Programs in USA often are not centrally organized. Program activities are often a mix of government or regulatory mandates, and private sector (market based). Various national and international programs generally exist, but not formalized for interconnection; critical to have quality, transparency, and reciprocity. Nationally Recognized Testing Laboratory (NRTL)requirements for are in OSHA 1910.7 and Appendix A.

4. Standards and Conformity Assessment Benefits • Accelerates engineering advances & implementation, interoperability, and installation • Assists increased quality and reliability achievement • Simplifies compliance to needs, permitting, & rules • Promotes advanced communications; software platforms interchangeability • Enables enhanced DR systems and grid intelligence • Lower cost and quicker deployment for projects. • Safeguards against hazards • Fosters quality design and manufacture • Increases competitiveness in industry • Creates and expands markets • Facilitates Trade and Commerce • Assurance is provided when products meet quality standards, then users need not be concerned with redundant testing or evaluation of the product

5. Technical Standards Testing & Certification Implementation: Rules & Agreements Standards, Testing, Implementation Putting the Pieces Together(NREL approach) Stds, protocols/programs:established by stakeholders; satisfy mandates; quality; recognized/accepted; not stagnant. Consensus driven. Defined scope & purpose. Proven/validated. Maintained/updated. Controlled/quality: processes, facilities, equipment personnel. Lab accreditation. Manufacturer quality. Test @ cradle-to-grave. Goals/purposes. Which standards & programs? Authority having jurisdiction. Dispute resolution.

6. Approach • R & D, interim performance criteria & test methods development • Round-robin testing and evaluation trials • National consensus standards established via industry driven partnerships; balanced stakeholder participation. • Implementation approaches instituted (standards adoption, rules of engagement, agreements, etc.). • Harmonizationof national and international standards, codes, and certification/laboratory accreditation, e.g., • - IEC/IEEE dual-logo standards. • - USA Technical Advisory Group IEC/TC8 System Aspects of Electrical Energy Supply (T. Basso Co-Technical Advisor with J. Koepfinger –who is also IEC Standards Management Board member; TC8 draft white papers). • IEC/TC82 Photovoltaics (USA is Secretariat) • IEC additional participation: IEC/JCG Distributed Renewable Energy Systems, IEC/TC 88 Wind, IEC 61850 standards (communications), etc.

7. Approach • IEEE: Standards Board • Approves all IEEE standards projects and standards for publication. • Established IEEE liaison to DOE (R. DeBlasio, Chair SCC21) • - Establishes Standards Coordinating Committees (SCC) that report directly to Board, e.g., IEEE SCC21 (Photovoltaics, fuel cells, energy storage and dispersed generation, i.e., 1547 series of interconnection standards). • IEEE standards: developed as American National Standards (ANSI/IEEE); recognized worldwide. • Additional Standards & Codes Interactions, e.g., -National Electric Code, building codes, state Public Utility Commissions, other technology specific standards/codes/processes. • Formalization of certification & conformity assessment.

8. Stakeholders and Resources (examples) • IEEE • ISO • NAVLAP • NEC • OSHA, e.g., NRTL • PMC • PV GAP • UL • A2LA • ANSI • ASQC • ASTM • ASU/PTL • FSEC • IEC • Consumers, owners, and operators • Manufacturers and system integrators • Utilities and Independent System Operators/RTO • Authorities having jurisdiction • Regulations, legislation, DER incentive programs. • Technical professionals, Test Labs (& Nat’l Labs - impartiality)

9. Background: standards/protocols/programs for testing and conformity assessment, e.g., development, maintenance, updating; approach; etc. • Sample Case Studies: 1) Photovoltaics – performance criteria and test methods; standards development; laboratory accreditation and equipment certification; implementation of a conformity assessment program (e.g., PowerMark Corporation); … 2) DER Interconnection –interconnection requirements and testing requirements; ANSI/IEEE 1547 standards; 2005 Energy Policy Act (EPACT); implementation of best practices (PJM, MADRI, states models); Nationally Recognized Testing Labs; … • Opportunities/Discussion: multiple programs, consistency, quality, transparency, reciprocity,... Where to from here? Outline

10. Case Study: Photovoltaics (PV) 1970’s: PV for space: no consensus standards, testing protocols or conformity assessment for terrestrial PV. Late 1970’s – early 1980’s: DOE/National Labs establish Interim PV Performance Criteria & Test Methods(NREL reports): criteria, requirements, evaluation - precursor to standards; NREL led round-robin testing trials during and after preceding. Early to late 1980’s: IEEE SCC21 established; Standards and Codes Forumsinitiated (IEEE, ASTM, NEC, etc.); first consensus PV standards published – round-robin testing to “test the tests and the requirements”(IEEE, ASTM); NEC Article 690 Photovoltaics written; IEC/TC82 (PV Systems) established (USA Chair and Secretariat) –IEC uses SCC21 draft IEEE American National Standards for PV in TC82.

11. ISO/IEC, ANSI, ASQC (guides; accreditation; quality system) Test method selection Lab Accreditation Body(e.g., A2LA, NVLAP, ICBO …) Product Certification Body(e.g., SRCC, ARI, …) Test Lab, or Product Certification Lab Manufacturer (quality approved) ·Design · Production ·Test & inspection Quality Products Case Study: PV (& Certification/Accreditation) Early-mid-1990’s. DOE/NREL establish stakeholder group; published PV Module Certification/Laboratory Accreditation Criteria Developmentand …Implementation Handbook (NREL TP-412-7680; & 21291) (NREL 7680): Figure 3.1 Hierarchy of QA Regimens(International Standards Organization –ISO and International Electrotechnical Commission - IEC

12. Case Study: PV & Certification/Accreditation 1996 PowerMark Corporation (PMC) incorporated based on preceding documents – PMC develops & manages PV product certification processes e.g., (also see next viewgraphs), [PV-X] are pro-forma/type required documents (from NREL-TP-412-7680): [PV-1] Criteria for Model Quality System for laboratories Engaged in Testing PV Modules [PV-2] Model for Third-Party Certification and Labeling Program for PV Modules [PV-3] Testing Requirements - Certification & Labeling Program for PV Modules. Late 1990’s – Early 2000’s. IEC & PV Global Assistance Program pursue conformity assessment for photovoltaics; PMC activities: i) PMC selected as USA Licensee for PV GAP; ii) PMC established PV lab accreditation procedures; iii) PMC established a procedure for certification of PV module manufacturers originally to (SCC21) IEEE 1262 now IEC 61215 or IEC 61646; iv) PMC lab accreditation to ASU/PTL (PV Testing Lab); v) PMC worked with the international community – reciprocity - to accept ASU/PTL accreditation worldwide.

13. Figure 3-2 Certification Body Assessment Option ISO/IEC, ANSI, ASQC, ASTM (guides; accreditation; quality system, etc.) Operates on Pays for service Certification Body (Assessors) Assesses and accredits laboratory [PV-2] Accepts manufacturer, and certifies and labels product Manufacturer Test Laboratory Tests manufacturer’s product [PV-1] [PV-3] Note [PV-X] are required documents. Case Study: PV & Certification/Accreditation: Third Party Model (NREL-TP-412-7680)

14. Figure 3-3 Independent Assessment Option ISO/IEC, ANSI, ASQC ASTM (guides; accreditation; quality system, etc.) Accreditation Body Operates on Pays for service Liaison Certification Body [PV-2] Accepts manufacturer, and certifies and labels product Assessor Assesses Laboratory Manufacturer Test Laboratory Tests manufacturer’s product [PV-1] [PV-3] Note [PV-X] are required documents. Case Study: PV & Certification/Lab Accreditation: Third Party Model (NREL-TP-412-7680)

15. Case Study: PV & Certification/Accreditation Early 2000’s to present. Nations, states, & incentive programs for solar PV technology systems cite/mandate PV certification and conformity assessment (peak power or performance based). NREL Cell & Module Performance Laboratory (“Trust But Verify”) achieves accreditation to ISO 17025 (testing & calibration) standard. PMC activities: i) PMC interfaces/coordinates w/state PUCs in relation to certification and solar rebates; ii) PMC lab accreditation to Florida Solar Energy Center (FSEC) for PV testing and reciprocity; iii) PMC established a procedure for certification of PV charge controller manufacturers - no charge controller manufacturers have been interested in becoming certified; iv) Solarex & USSC PV modules now certified (listed and labeled) per PMC.

16. How many national and state PV certification/labels • might we have to deal with? • number of United Nations • member states………. 191 • number of US States.... 50 • 241 Where to from here? • Incomplete set of stds/guides. • Satisfy stakeholders, e.g., certify per power or energy performance? • Accommodating modern technology, establishing, updating, and proving requirements, tests, standards, and protocols. • Lack of standards coordination and harmonization. • Lack of transparent and consistent implementation rules, procedures and agreements. • Misunderstanding/misapplication (limited experience/knowledge). • User/stakeholder disagreement.

17. Outline • Background: standards/protocols/programs for testing and conformity assessment, e.g., development, maintenance, updating; approach; etc. • Sample Case Studies: 1) Photovoltaics – performance criteria and test methods; standards development; laboratory accreditation and equipment certification; implementation of a conformity assessment program (e.g., PowerMark Corporation); … 2) DER Interconnection – interconnection requirements and testing requirements; ANSI/IEEE 1547 standards; 2005 Energy Policy Act (EPACT); implementation of best practices (PJM, MADRI, states models); Nationally Recognized Testing Labs; … • Opportunities/Discussion: multiple programs, consistency, quality, transparency, reciprocity,...Where to from here?

18. Case Study: Interconnection (IC) 1978. USA federal act (for non-utility generators): PURPA – but no consensus standards or uniform approachfor requirements, testing or conformity assessment for interconnecting small generators with utilities. Each utility has their own standards, testing and conformity assessment practices. 1988. IEEE Std 1001 Guide for Interfacing Dispersed Storage and Generation Facilities with Electric Utility Systemspublished. 1990’s. SCC21 IEEE Std 929 Recommended Practice for Utility Interface of PV Systems published; in 1999 IEEE establishes SCC21 1547 interconnection standards development project.

19. Case Study: Interconnection (IC) Early 2000’s. First national consensus interconnection standards published: SCC21 IEEE Std 1547 (2003) - requirements for interconnection and its tests, and SCC21 IEEE Std 1547.1 (2005) - test procedures for conformance to 1547; IEC TC8 System Aspects of Electrical Energy Supply revises scope to address T&D, DER interconnection, reliability, etc.; PJM Interconnect, Inc. gets Federal Energy Regulatory Commission (FERC) approval (in 2005) “Std for Small Gen (≤2MW) Interconnection;” In 2006 PJM approves “Std for Small Gen (≤10 MW) Interconnection” and “Std for Small Gen (>10-to-20 MW) Interconnection;” sent to FERC for approval. Mid-Atlantic Distributed Resources Initiative (MADRI) group establishes Model Interconnection Procedures for States to use as a starting point for their own implementation rule.

20. Case Study: Interconnection (IC) • Early 2000’s • Federal 2005 EPACT Section 1254 Interconnection – • PURPA (1978) is amended as follows (paraphrased) • - Utility shall make available interconnection service to its customers (on-site generation connected to distribution facilities). • - Interconnection services shall be offered based upon the IEEE standards 1547 as they may be amended from time to time. • - Agreements and procedures shall be established, promoting current best practices of interconnection for DG, including practices stipulated in state regulatorymodel codes (all such agreements and procedures shall be just and reasonable, and not unduly discriminatory or preferential). • FERC small gen IC rules:mandate establishment of Small Gen Interconnection Agreement (SGIA) and Small Gen Interconnection Procedures (SGIP). • Note: above interconnection implementation details are left to the individual authorities having jurisdiction - AHJs.

21. Case Study: IC To Date 1547 Clause 5.1 Design test - footnote 14: The design test of 5.1 may be adopted as the basis for certification of interconnection systems. 1547.1 Conformance test procedures for interconnecting DR. UL 1741 Safety for standard: supplements and is to be used in conjunction with 1547 and 1547.1 for utility connected systems. PJM small generator stds allow certification (but not mandated); via nationally recognized test lab – NRTL (per OSHA). MADRI interconnection rule provides expedited process for certified equipment; certification via NRTL. Some states establish or recognize certification (e.g., California Air Resources Board). NEC (2008 draft) Article 705-xx Interconnection(new) requires interconnection systems shall be suitable for their intended purpose (per standard UL1741/1547/1547.1).

22. IC Example: MADRI Model Interconnection Procedures (published Nov’05 - Mid-Atlantic Distributed Resources Initiative) • Objective: foster regional consistency among states’ small generator interconnection procedures across Mid-Atlantic region (started with FERC, PJM, and states rules). • Two key considerations • Technical Standards - establish common requirements for DG interconnection (based on 1547/1547.1/PJM standards) • Implementation Procedures - establish common rules and agreements for DG interconnection • Additional considerations: Certification identified – but formal details are left to each user adopting the procedures. • Implementation. Model procedures are a starting point for each authority having jurisdiction to complete the details and interpret or address technical queries on their own.

23. IC Example: PJM* Interconnect, Inc. Small Generator Interconnection Request Scoping Meeting to discuss Request Small Generator Interconnection Study Determine Interconnection Requirements per PJM “Applicable Technical Requirements and Standards for 20 MW and Less” IEEE 1547 Design Tests (Pre-certification Optional) IEEE 1547 & Other Technical Requirements Issue Interconnection Study Report and Tender ISA Execute Agreements Ÿ Interconnection Service Agreement Ÿ Construction Services Agreement (If Required) Verify Interconnection System Satisfies Test Requirements Ÿ Production Test Ÿ Installation Evaluation Ÿ Commissioning Tests Design Test (If not pre-certified) Construction & Commercial Operation • PJM purposeof adopting PJM-wide technical standards based on 1547: • Limit barriers to interconnection • Provide transparency • Allow precertification & other means to expedite interconnection process. • *PJM is a regional transmission organization with over 140 GW load; 165 GW generating capacity.

24. NREL 1547 Certification Model UL 1741 Standard

25. NREL Model 1547 Interconnection Certification

26. NREL 1547 Certification Model UL 1741 Standard

27. NREL 1547 Certification Model UL 1741 Standard

28. IC Needs and Observations • Interconnection implementation details left to individual authorities having jurisdiction, e.g., to complete the details for requirements, testing protocols, conformity assessment; to interpret and address technical queries; fill the gaps (NRTL is for labs, not the overall certification/accreditation program). • Where to go for listing/database of accredited labs and certified or qualified interconnection equipment? Is the lab accreditation and certified equipment universally accepted? (Who decides? How?). • Who to contact to get clarifications, submit a formal query or dispute, or to pursue study and get resolution of issues (both technical and otherwise)? • How to address accommodation of technology evolution and grid modernization, e.g., grid-DER interactions, impacts, reliability, operations, information exchange? • How to expedite national/international harmonization and reciprocity for testing, certification and conformity assessment.

29. Outline • Background: standards/protocols/programs for testing and conformity assessment, e.g., development, maintenance, updating; approach; etc. • Sample Case Studies: 1) Photovoltaics – performance criteria and test methods; standards development; laboratory accreditation and equipment certification; implementation of a conformity assessment program (e.g., PowerMark Corporation); … 2) DER Interconnection –interconnection requirements and testing requirements; ANSI/IEEE 1547 standards; 2005 Energy Policy Act (EPACT); implementation of best practices (PJM, MADRI, states models); Nationally Recognized Testing Labs; … • Opportunities/Discussion: multiple programs, consistency, quality, transparency, reciprocity,... Where to from here?

30. Opportunities/Discussion Summary Remarks • Value added: satisfy the needs through involvement of all stakeholders, (e.g., consumers, owners, operators, manufacturers, system integrators,utilities, ISOs/RTOs, authority having jurisdiction, test labs, National Labs, regulations, legislation and incentive programsetc.). • Test the tests and the requirements. • Pilot implementation plan should be developed to test the approval process with NREL providing technical expertise and testing support on a case by case basis (WFO), leading development of test methods and standards and conducting round-robin testing to verify every testing entity is conducting the tests as prescribed in 1547 and 1547.1. • Support expanded programs (independent, 3rd Party management and oversight) – appropriately tailor to states’ or nations’ mandates; coordinate product and performance programs with state, national, and international incentive or rebate programs; fill the technology gaps (new technology and updated or missing pieces of programs).

31. Opportunities/Discussion Summary Remarks • Continually update accreditation of test labs. • Promulgate certification reciprocity; provide coordination. • Provide oversight and technical inputs to standards development. • Support interconnection implementation details: • EPACT and FERC leave details to the individual authorities having jurisdiction - AHJs. • MADRI Model Procedures offer a starting point to AHJs and certification is identified – but completing the details and interpreting or addressing technical and other queries are left to the AHJs on their own. • The designation of using nationally recognized test labs (NRTL per OSHA) for interconnection is identified but NRTL is specific to laboratories - not to an overall program – programs are not wholly formalized.

32. Opportunities/Discussion – Where To From Here? NREL DER Test Facility “Test the Tests and the Requirements”

33. Contact Information • Dick DeBlasio, NREL Technology Manager • NREL Distributed Energy & Electricity Reliability (DEER) Program • Chair IEEE SCC21, 1547; IEEE Standards Board Liaison to DOE • email: Dick_DeBlasio@nrel.gov voice: (303) 275 – 4333 • Thomas Basso* NREL • Sec’ty IEEE SCC21 & P1547.2.3.4.6 • email: thomas_basso@nrel.gov • voice: (303) 275 - 3753 • * NREL DEER Distribution & Interconnection R&D • NREL http://www.nrel.gov • 1617 Cole Blvd. MS-1614 Golden, CO 80401-3393 • IEEE SCC21 -- IEEE Standards Coordinating Committee 21 on Fuel Cells, Photovoltaics, Dispersed Generation, & Energy Storage http://grouper.ieee.org/groups/scc21/ • IEEE Std 1547TM series of standards http://grouper.ieee.org/groups/scc21/dr_shared/ • Ben Kroposki* NREL • Sec’ty 1547.1 & Chair P1547.4 • email: benjamin_kroposki@nrel.gov • voice: (303) 275 – 2979