Microgrid regulations

The PR Energy Commission last week issued their proposed regulations on microgrid development. I read it over the weekend and recommend everyone interested in energy do so. Don't get scared thinking it will be like most regulations with dense, unreadable, legalese. I think anyone, even someone who knows very little about energy beyond how to turn on a light switch, will be able to understand it. 

One of the things I learned is what I pioneer I am in PR energy development. I developed a microgrid back more than 30 years ago!

Without going into a lot of detail here, what it mainly does is allows individuals, companies, consumers, third parties, municipalities and pretty much anyone else to develop small scale power projects. These might serve a single plant or building or an area as large as a municipality. 
 
Most importantly, it recognizes the right of third parties to sell electricity at retail under certain conditions. (This stems from the Alcon case discussed previously here http://darkislandpr.blogspot.com/2017/12/alcon-v-prepa.html) Microgrid operators can sell power to PREPA , to members (if a co-op), to themselves or to customers connected to the grid.

The goal, highly worthy in my view, is to get away from the entire island being dependent on a few distant central plants in Penuelas and Guayama and get power generation distributed closer to point of use. 

It tries to encourage the use of renewables, not limited to wind and solar, but permits all types of energy generation for microgrids. It specifically mentions cogeneration, or "Combined Heat and Power" (CHP) as it calls it. I think this, combined in some applications with batteries, is the best way to go. 

I really only have three comments, which I will be submitting, about the proposed regulation:

1) I think small scale (>10MW) packaged nuclear plants will become practical and available in the next 5-10 years. Nuclear is the ultimate renewable energy and should be included in the regulation. 

2) CHP generally involves using a gas turbine or diesel engine to generate electricity then recovering the waste heat and using it for steam, chilled water or some other purpose. This boosts the system efficiency from @40% for electric only to 60-80%. Combined cycle is a form of cogeneration that uses the waste heat from the gas turbine to power a secondary steam turbine generator. Eco-Electrica and AES Guayama are both combined cycle cogenerators. 

It is unclear in the regulation whether combined cycle will be permitted. I believe it should be permitted and the regulation should explicitly do so.

3) Microgrids can sell power only to those connected to the microgrid or to PREPA. I would like to see provisions for PREPA to wheel power between microgrids. A microgrid in Mayaguez may have excess capacity at certain times that could be used by another microgrid in Humacao. They should be able to inject the power into the PREPA grid in Mayaguez and sell it to the microgrid in Humacao. PREPA would receive a fee for use of their system for this transmission, of course. As I understand the current proposal, the Mayaguez plant would have to sell the excess to PREPA who would then sell it generally to their customers. 

I seem to recall that PURPA requires wheeling for "Qualified Facilities" but it has been many years and I may be misremembering it.

Read the whole thing here:

http://energia.pr.gov/wp-content/uploads/2018/01/Proposed-Regulation-on-Microgrid-Development-CEPR-MI-2018-0001-1.pdf

Comments can be submitted prior to Feb 4 to comentarios@energia.pr.gov