in-20250723-IR-170250368RAA: _________________________

TITLE 170 INDIANA UTILITY REGULATORY COMMISSION Regulatory Analysis LSA Document #25-368 I. Description of Rule  II. Fiscal Impact Analysis  III. Impacted Parties IV. Changes in Proposed Rule  V. Benefit Analysis VI. Cost Analysis Change Citation  Costs The definition of “customer facility” is modified to explicitly include energy storage systems or technologies, such as batteries, in the definition, thereby subjecting batteries and other energy storage systems to the same interconnection process as solar panels and other customer owned generation. The term “customer facility” replaces “customer generation facility” throughout the rule. Proposed 4-4.3-1 and throughout Minimal to no costs are imposed on regulated entities based on the change to allow new and additional customer facilities to interconnect. The regulated utilities may see limited additional applications for interconnection for the new types of customer facilities, but electric utilities already have methods in place to process interconnection applications. The incorporated standards for IEEE 1547 and UL 1741 are updated to more recent version of those standards, to the 2018 version of IEEE 1547 and the 2021 version of UL 1741, thereby incorporating updated reliability and safety standards that will apply to new customer facilities. Proposed 170 IAC 4-4.3-5 The updated performance and safety standards mean that Customers will only be able to interconnect compliant electronics and facilities. In some cases, non-compliant electronics, such as inverters, battery controllers, etc. may be less expensive, but safety and reliability considerations outweigh any increase in cost for the licensed and compliant electronics. IURC staff expects that most if not all systems and electronics for purchase by customers in the United States will be compliant with the updated standards as more states implement these standards in their own rules.7 However, at this time there remain non-compliant electronics and facilities in commerce, which is why it is imperative to establish these standards in Indiana. Pricing for non-compliant inverters is comparable to pricing for compliant inverters. Customers with existing facilities that are already interconnected are not affected by this rule.8 The threshold for customer facilities for Level 1 interconnections with no charge is increased from 10 kilowatts to 25 kilowatts, thereby allowing larger customer facilities to interconnect with no charge and with a simplified interconnection process. Proposed 170 IAC 4-4.3-6 This change is a cost savings to customers, as a customer may apply through the essentially free Level 1 application process instead of the more costly Level 2 process for customer facilities below the threshold. The Level 2 application and interconnection review fee is capped in 170 IAC 4-4.3-4(e)(2) at fifty dollars plus one dollar for each additional kilowatt. There may be relatively minimal costs to electric utilities who will not be able to collect the Level 2 interconnection fee for those customers. Only one utility commented on the possible loss of Level 2 interconnect fee revenues. One regulated utility provided information showing total application fees it estimates it would lose with this revision. For the period 2020-2024, the lost revenue vs. received revenue for the applications which would now be Level 1 vs. Level 2 was $20,648. IURC staff opined that this cost is offset by equal savings afforded to customers. And IURC staff estimated that the loss of a few thousand dollars per year will in no way impact electric utilities or their profitability.

VIII. Regulatory Analysis

In the aggregate, the proposed rule by avoiding even one blackout because of the increased reliability of the system due to the rule changes could have benefits in the hundreds of thousands of dollars. That is contrasted with costs which, if they occur at all, are estimated to be less than $10,000 annually for all utilities. Therefore, the potential benefits exceed the relatively minimal and unlikely costs.

IX. Contact Information of Staff to Answer Substantive Questions

_________________________ 2 IC 8-1-40.1-4. 3 Information about Indiana’s stakeholder process can be found on our website at: https://www.in.gov/iurc/home/implementation-re-ferc-order-2222/ 4All comments submitted throughout this stakeholder process, as well as presentations, notes, and other materials are posted and available for viewing at: https://www.in.gov/iurc/home/implementation-re-ferc-order-2222/ 5 https://www.in.gov/iurc/home/implementation-re-ferc-order-2222/ 6 See Comments of Advanced Energy United, submitted 1/17/25, at https://www.in.gov/iurc/files/2025.01.17-IURC-RM-24-01-United-Strawman-Proposal-Comments-Final.pdf 7 See e.g. https://irecusa.org/resources/ieee-1547-2018-adoption-tracker/ https://sagroups.ieee.org/scc21/standards/1547rev/#:~:text=This%20standard%20establishes%20criteria%20and,the%20IEEE%20Standards%20Reading%20Room. https://solarbuildermag.com/inverters/smart-pv-inverter-overview-ieee-1547-2018-and-ul-1741-explained/ “Not all states have announced their plans for adopting the IEEE 1547-2018 Standard, but many of the biggest markets for solar PV (e.g., California, Texas, New York) either already have established dates or intend to by the end of 2023. Grid Independent System Operators (ISOs) may also choose to adopt the IEEE 1547-2018 standard. ISOs in the Midwest and Northeast have already introduced guidelines or have plans to do so soon.” 8 See e.g. https://www.amazon.com/Inverter-AC110V-Output-DC26-46V-Suitable/dp/B0CY4VDB8T/ref=sr_1_7_sspa?crid=3M0DBJII3T1W0&dib=eyJ2IjoiMSJ9.n1jr-sGk-hk098PCoH2Wq9OPaL--EfymUqq-BUrgfz1vscYi2SLyeinKC63X6wbD5zIfiw5BBinGgZdWvqXRduc66Wh1nlPHDiTqwMr9BzB3Vu9PQGNVeTmwNMZ88ZtKtS38sGq-IROTdiPLhAVzJKvx395W0lNsjMzlgOoV7eqVYQu7s2oAXAeoLZuB1EGRKkWXGTGKDd5nbUShad2aqlIoeRIAJ78Jrg9HSoI50UQ.YBaOTl8GaMEi_aPLdEQmWXQEYc2RxS9LRanGj20BEoY&dib_tag=se&keywords=residential%2Bsolar%2Bpanel%2Bmicro%2Binverter&qid=1747835842&sprefix=residential%2Bsolar%2Bpanel%2Bmicro%2Binverter%2Caps%2C60&sr=8-7-spons&sp_csd=d2lkZ2V0TmFtZT1zcF9tdGY&th=1 9 Seehttps://www.energysage.com/solar/best-solar-inverters/ 10 Compare https://enphase.com/store/microinverters/iq7-series/iq7pd-72-microinverter to https://enphase.com/store/microinverters/iq8-series/iq8h-microinverter?sku=IQ8H-240-72-2-US 11 See also https://enphase.com/installers/resources/ieee-1547-2018#:~:text=Note:%20*%20Three%2Dphase%20implementations%20using%20IQ7%20and,be%20used%20to%20install%201547%2D2018%20compliant%20systems. 12 See e.g. https://www.amazon.com/Inverter-AC110V-Output-DC26-46V-Suitable/dp/B0CY4VDB8T/ref=sr_1_7_sspa?crid=3M0DBJII3T1W0&dib=eyJ2IjoiMSJ9.n1jr-sGk-hk098PCoH2Wq9OPaL--EfymUqq-BUrgfz1vscYi2SLyeinKC63X6wbD5zIfiw5BBinGgZdWvqXRduc66Wh1nlPHDiTqwMr9BzB3Vu9PQGNVeTmwNMZ88ZtKtS38sGq-IROTdiPLhAVzJKvx395W0lNsjMzlgOoV7eqVYQu7s2oAXAeoLZuB1EGRKkWXGTGKDd5nbUShad2aqlIoeRIAJ78Jrg9HSoI50UQ.YBaOTl8GaMEi_aPLdEQmWXQEYc2RxS9LRanGj20BEoY&dib_tag=se&keywords=residential%2Bsolar%2Bpanel%2Bmicro%2Binverter&qid=1747835842&sprefix=residential%2Bsolar%2Bpanel%2Bmicro%2Binverter%2Caps%2C60&sr=8-7-spons&sp_csd=d2lkZ2V0TmFtZT1zcF9tdGY&th=1 Notice of First Public Comment Period: 20250723-IR-170250368FNA Notice of Determination Received: June 3, 2025