Within NARUC is the Center for Partnerships & Innovation (CPI). The role of CPI is to identify emerging challenges and connect state commissions with expertise and strategies to navigate complex decision-making. Over the years, CPI has created numerous documents for the benefit of the state Commissions and Commissioners on Critical Infrastructure protection and cybersecurity.

To access previous issued documents, manuals, NARUC maintains a resource library that lets you search by dates, departments, key words, etc. Visit https://pubs.naruc.org/resources/library/index.cfm.

(i.e., Presidential Executive Orders from Obama and Trump Administration establishing Coordinating Councils, their purpose, and responsibility.)

• On February 12, 2013, President Obama signed Presidential Policy Directive (PPD) 21, Critical Infrastructure Security and Resilience. The Executive Order establishes national policy on critical infrastructure security and resilience advancing a national unity of effort to strengthen and maintain secure, functioning, and resilient critical infrastructure.
• Also on February 12, 2013, President Obama signed Executive Order 13636, Improving Critical Infrastructure Cybersecurity. The Executive Order was designed to increase the level of core capabilities for our critical infrastructure to manage cyber risk. It does this by focusing on three key areas: (1) information sharing, (2) privacy, and (3) the adoption of cybersecurity practices. The EO tasked the National Institute for Standards and Technology (NIST) to work with the private sector to identify existing voluntary consensus standards and industry best practices and build them into a Cybersecurity Framework.
• In February 2016, the Obama Administration announced a broad-based initiative, the Cybersecurity National Action Plan (CNAP), which included many of the efforts begun during the Sprint and CSIP as well as additional federal and private-sector projects. The CNAP announcement accompanied a $19 billion investment set forth in the FY2017 President’s Budget.39 The CNAP included a proposed $3.1 billion Information Technology Modernization Fund (ITMF); establishment of a federal Chief Information Security Officer (CISO); continued identification and review of highest value and most at-risk IT assets; an increase in government-wide shared services for IT and cybersecurity; expansion of DHS EINSTEIN and Continuous Diagnostics and Mitigation (CDM) programs; an increase in DHS federal civilian cyber defense teams to a total of 48; and an investment in cybersecurity workforce programs to support federal government needs.
• Issued by the Obama Administration on February 13, 2015, Executive Order 13691, Promoting Private Sector Cybersecurity Information Sharing, further acknowledged that organizations engaged in the sharing of information related to cybersecurity risks and incidents play an invaluable role in the collective cybersecurity of the United States. This Executive Order encouraged the formation of such information sharing organizations, establishes mechanisms to improve their capabilities, and enables them to better partner with the Federal Government on a voluntary basis.
• In May 2017, President Trump signed an Executive Order 13800 on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure. The intent of the EO was to improve the Nation’s cyber posture and capabilities in the face of intensifying cybersecurity threats. EO 13800 focuses federal efforts on modernizing federal information technology infrastructure, working with state and local government and private-sector partners to more fully secure critical infrastructure, and collaborating with foreign allies.
• On July 28, 2021, President Biden signed a National Security Memorandum (NSM) on “Improving Cybersecurity for Critical Infrastructure Control Systems.” The memorandum looks to develop cybersecurity performance goals for critical infrastructure and establish the President’s Industrial Control System Cybersecurity (ICS) Initiative. The voluntary initiative facilitates the deployment of technology and systems that provide threat visibility, indicators, detections, and warnings. ⁵⁸

^58. https://www.whitehouse.gov/briefing-room/statements-releases/2021/07/28/fact-sheet-biden-administration-announces-further-actions-to-protect-u-s-critical-infrastructure/

More recent publications from NARUC and the partnerships that have been entered into with:

• A Guide for Public Utility Commissions: Recruiting and Retaining a Cybersecurity Workforce (Feb. 2021)
• Public Utility Commission Stakeholder Engagement: A Decision-Making Framework (Jan. 2021)
• Private, State, and Federal Funding and Financing Options to Enable Resilient, Affordable, and Clean Microgrids (Jan. 2021);
• User Objectives and Design Options for Microgrids to Deliver Reliability, Resilience, Clean Energy, Energy Savings, and Other Priorities (Jan. 2021);
• Understanding Cybersecurity for the Smart Grid: Questions for Utilities (Dec. 2020);
• Artificial Intelligence for Natural Gas Utilities: A Primer (Oct. 2020);
• Cybersecurity Tabletop Exercise Guide (Oct. 2020);
• Public Utility Commission Participation in GridEx V: A Case Study (Oct. 2020);
• Battery Energy Storage Technology Adoption & Utility Structure (Oct. 2020).⁵⁹

NARUC collaborates with the National Association of State Energy Officials (NASEO) and the National Governors Association (NSA) and others on critical infrastructure and cybersecurity related topics. In October of 2020, NARUC and NASEO authored a mini guide that details ways in which public utility commissions and state energy offices interact, how these relationships can be strengthened and how governors’ state energy office directors and commissioners, as well as staff, can look to further engage with their counterparts.⁶⁰

In June 2020, NARUC and NASEO launched a new partnership to mitigate cybersecurity risks and consequences in solar energy developments. With support from the United States Department of Energy Solar Energy Technologies Office, the project will leverage state, federal, and private-sector expertise on cybersecurity, grid, and photovoltaic to identify model solar-cybersecurity programs and actions for states to take in partnership with utilities and the solar industry.⁶¹

^59. https://pubs.naruc.org/pub/61F4BF9B-155D-0A36-31E7-7DD96F8F99D2

^60. https://www.naruc.org/about-naruc/press-releases/new-naruc-naseo-mini-guide-on-state-commission-and-state-energy-office-engagement-released-by-ncep/

^61. https://www.naruc.org/about-naruc/press-releases/naseo-and-naruc-announce-initiative-on-cybersecurity-in-solar-projects-cybersecurity-advisory-team-for-state-solar-catss/

In the event of a cybersecurity emergency, the rule for federal partners is: “A call to one is a call to all!”

• Department of Energy
• Department of Homeland Security (CISA, FEMA)
• Federal Energy Regulatory Commission
• Department of Defense
• National Security Agency
• Department of Justice (FBI)
• National Institute of Standards and Technology (NIST)

https://nvlpubs.nist.gov/nistpubs/ir/2013/NIST.IR.7298r2.pdf 

https://www.naruc.org/cpi-1/critical-infrastructure-cybersecurity-and-resilience/cybersecurity/cybersecurity-manual/

States have put an emphasis on areas of emergency preparedness and protection of vital critical infrastructure through partnership with federal and other state agencies. State emergency management agencies have partnered with state and federal agencies updating their state’s Continuity of Operations Plans, most of which includes participation by their energy offices and state utility commissions. Other activities within states includes that of their State Homeland Agencies and their Fusion Centers. Many states have benefited from partnering with their state’s National Guard.

Fusion centers are information centers that enable intelligence sharing between local, state, tribal, territorial, and federal agencies. They are actual physical locations that house equipment and staff who analyze and share intelligence. Nationwide, there are 78 recognized fusion centers listed on the Department of Homeland Security (DHS) website.

Fusion centers are staffed by local law enforcement and other local government employees as well as Department of Homeland Security personnel. Staffing agreements vary from place to place. Fusion centers are often also co-located with FBI Joint Terrorism Task Forces.

Fusion centers enable unprecedented levels of bi-directional information sharing between state, local, tribal, and territorial agencies and the federal intelligence community. Bi-directional means that fusion centers allow local law enforcement to share information with the larger federal intelligence community, while enabling the intelligence community to share information with local law enforcement. Fusion centers allow local law enforcement to get—and act upon—information from agencies like the FBI.⁶² 

https://www.dhs.gov/fusion-center-locations-and-contact-information

^62. https://www.eff.org/deeplinks/2014/04/why-fusion-centers-matter-faq#:~:text=There%20are%2078%20recognized%20fusion,Department%20of%20Homeland%20Security%20personnel.

In 2020, NARUC, in partnership with United States Agency for International Development (USAID), created guidelines that assist regulators in determining if cybersecurity investments are reasonable, prudent, and effective. These guidelines are intended to assist regulators in defining tariffs by establishing a regulatory approach to enhance the cybersecurity stance of their power systems and are based on literature and current practices. The guidelines help regulators answer the following questions:

• Which regulatory frameworks are best suited to evaluate the prudency of cybersecurity expenditures?
• How can regulators identify and benchmark cybersecurity costs?
• How can regulators identify good countermeasures for cybersecurity?
• How can regulators assess the reasonableness of the costs associated with these countermeasures?
• Is it possible to evaluate the effectiveness of cybersecurity investments?
• Who should identify, benchmark, measure, and evaluate the countermeasures in different regulatory frameworks?

The document can be downloaded at: https://pubs.naruc.org/pub.cfm?id=9865ECB8-155D-0A36-311A-9FEFE6DBD077

Emergency Preparedness and Preparation has evolved over the years, and more so with the emphasis on moving out of our individual silos, recognizing interdependency in any emergency. The need for stakeholders to come together is an emphasis we find with many federal and state agencies. Examples of these type of partnerships is below:

Sector-based Information Sharing and Analysis Centers (ISACs) collaborate and coordinate with each other via the National Council of ISACs (NCI). Formed in 2003, the NCI today comprises 25 organizations designated by their sectors as their information sharing and operational arms. The NCI is a true cross-sector partnership, providing a forum for sharing cyber and physical threats and mitigation strategies among ISACs and with government and private sector partners during both steady-state conditions and incidents requiring cross-sector response.

Sharing and coordination is accomplished through daily and weekly calls between ISAC operations centers, daily reports, requests-for-information, monthly meetings, exercises, and other activities as situations require. The NCI also organizes its own drills and exercises and participates in national exercises. More information about the NCI and what it can do for you can be located at: https://www.nationalisacs.org/

The Electricity Subsector Coordinating Council serves as a liaison between electric utilities and the federal government in responding to threats and emergencies; the Council has developed a Cyber Mutual Assistance program that is now operational and has been expanded to include natural gas pipelines.⁶³

⁶³ https://www.electricitysubsector.org/CMA/

1. 1. Cybersecurity Exercises/Tabletops
      1. Black Sky Events – EIS conducts Black Sky Training sessions to practice recovery under regional outage of multiple critical infrastructures. In addition, there are a number of tabletop exercises that are available to state commission to download and use.: (insert link here):
      2. GridEx – Every other November, the North American Electric Reliability Corporation (NERC) conducts a grid security exercise known as GridEx. NERC has developed Critical Infrastructure Protection standards to ensure a baseline of cybersecurity for the bulk power system.
      3. Liberty Eclipse Series – A national biennial cybersecurity exercise conducted by the U.S. Department of Energy, many commissions participate in this tabletop exercise.
      4. ClearPath Series – An annual regional exercise focused on various threats to the national energy systems. Commissions are key players in these exercises.
      5. CyberStorms – A congressionally mandated cybersecurity exercise series, Cyberstorm aims to secure cyberspace by strengthening cyber preparedness in the public and private sectors.
   2. Training Assistance for State Commissions - in NARUC’s Center for Partnerships & Innovation - Virtual Cybersecurity Training events held in September of 2020 and in February of 2021.

1. Customers - protection, privacy, and security
   • The key question utilities and regulators often ask is: How to empower the customers? Customer data needs to be handled in a safe and secure manner so that the AI technology can be adequately applied for consumer research and, at the same time, customer data can be protected and processed in a mutually agreeable fashion. With AMI, Green Button Download my data and Green Button Connect my data⁶⁴ to achieve those goals.
2. Ownership - Utility ownership of DERs (energy storage and microgrid)
   • Some states allow utility DER ownership and some do not. Regulations will affect incentives in adopting new technologies such as storage and microgrid. For example, New York is not allowing utility ownership of storage, instead attempting to create third-party interest by stimulating markets and creating transparent, fair rules that fully unlock the value of storage
3. Aging Infrastructure
   • Many transmission and distribution systems⁶⁵ are over 30 years old and replacement of aging infrastructure has been a common driver for the need of utility rate increases. When considering transmission and distribution wires solutions, regulators should also consider the Non-Wires Alternatives (distribution side) or Non-Transmission Alternatives (transmission side) to make sure a wide spectrum of possibilities are considered in the final decision making.
4. Legal and regulatory policies
   i) Costs
   ii) Collaboration
   iii) Connection
   • In grid modernization, the objectives of affordability, reliability and sustainability should all be achieved⁶⁶. The question is how to get the best bang for the buck. For the states with clean energy goals, sustainability needs to be achieved in a least-cost and reliable fashion. Short-term and long-term climate action plans need to be developed considering all these objectives and scenario selection to achieve the three objectives with least cost. This needs to be targeted through collaboration, coordination and stakeholder inputs.
5. New technologies
   i) Electric vehicles
   • Currently, electric vehicles can meet most individuals’ daily driving needs, with increasing driving ranges on battery life. The Utility need to provide energy whenever drivers want it, it is crucial for power companies to understand the number of miles EV owners drive, how many kilowatt-hours they consume, time of EVs charging and customer willingness to charge at off-peak times.

ii) Energy Storage and hybrid systems⁶⁷

• • Energy Storage: A resource capable of absorbing electric energy from the grid, from a behind-the-meter generator, or other DER, storing it for a period of time and thereafter dispatching the energy for use on-site or back to the grid, regardless of where the resource is located on the electric distribution system. These resources include all types of energy storage medium (e.g., batteries, flywheels, electric vehicles, compressed air.)
  • Energy Storage legislation and incentives examples from other states: Even though costs are declining, storage is still a high upfront investment that needs value stacking in order to make it a good investment for developers. Cost and value of storage depends on technology, system size, location (in front of or behind the meter), and applications – not all of which are monetizable⁶⁸.
  • States have used incentives such as investment tax credit for storage (Maryland). The New York State Energy Research and Development Agency (NYSERDA) issued an energy storage roadmap for the PSC in June 2018. States like CA and VT also have good application examples.
  • Hybrid systems facilitate energy arbitrage, storing energy when wholesale market prices are low and selling it when prices are high. High production from variable generation can lead to congestion or even overruns of line capacity, while hybrid systems can allow batteries to charge during those busy periods and store it until prices go up again.

iii) Microgrids⁶⁹

• Definition of Microgrid: A collection of interconnected loads, generation assets, and advanced control equipment, installed across a limited geographic area and within a defined electrical boundary that is capable of disconnecting from the larger electric distribution system, or running in an island mode.
  • A microgrid involves four distinct components⁷⁰:
  1. Load(s): The consumer(s) of electricity.
  2. Distributed energy resources (DERs): The supply of electricity. DERs are generation, storage, and load control (i.e., energy efficiency or demand response) technologies located at the distribution system. DERs can be powered by a range of fuels including diesel, natural gas, and solar power.
  3. Controls: The management system of the microgrid. A microgrid controller performs multiple functions, including:
     
     1. identifying when and how to connect and disconnect from the grid;
     2. maintaining real and reactive power balance when the microgrid is disconnected and operating in islanded mode, and
     3. dispatching DERs to support load.
  4. Interconnection/point of common coupling (PCC): The point at which the microgrid connects to the distribution network. It is at this point that the microgrid controller connects to and disconnects from the larger grid.
     • There are three types of microgrid⁷¹:
     • Level 1 microgrid includes single customer and single facility such as a hospital building with on site microgrid. Level 2 microgrid includes single customer, multiple facilities, such as a University campus with microgrid powering multiple buildings and Level 3 is multiple customers, with multiple facilities, such as a town center microgrid powering multiple buildings on separate utility meters.
• • Regulatory policies about microgrid:
    • Many of the regulatory and policy barriers to microgrid development are complex and have no one-size-fits-all solution. Uncertainty over the regulatory treatment of microgrids, risk of added costs and delays from interconnection queues, lack of valuation methodologies for the full range of benefits provided by microgrids, and challenges associated with stakeholder communication and collaboration all present barriers to microgrids.
    • California, Maine, and New York have taken recent legislative and/or regulatory actions to clarify the regulatory treatment of multi-customer microgrids. Creating a distinct microgrid operator entity, separate from a public utility, is one of several options states are considering as part of regulatory frameworks to address barriers to microgrid development72

iv) Artificial Intelligence
• With the implementation of AMI and availability of large-scale interval data, AI can be used to fully explore the benefits of such consumption data.
• AI can find what the customer will value and improve customer satisfaction. Customer would appreciate a mid-cycle alerts for their projected bill increase for example.
• AI can alert a utility that a home has an EV using a level 1 charger that typically begins charging a battery at 6 pm each night. The Utility can advise the customer that charging at midnight would be cheaper by simply using a timer on the charger. Or such a customer can be a good level 2 charger candidate at a discount and the utility can provide price signal to the customer or control the charger with changing speed.
• EPRI is looking into using drones and AI to improve the inspection of transmission and distribution assets. Such an approach may be safer and faster than manual inspections.
• More advanced utility Internet of Things (IoT) analytics solutions using cloud computing and machine learning, and AI can be used to unlock valuable insights and drive operational efficiencies.

v) Smart Inverters
• Definition about smart inverters
  • Inverters augmented with advanced grid-support functions. Smart inverters include any inverter-based generation where DC is covered into AC and provided to the grid. This includes solar, energy storage, wind, and electric vehicles⁷⁴.
  • EPRI Senior Technical Executive Tom Key emphasizes that traditional inverters already provide an important service. “Grid-connected inverters are relatively sophisticated power electronic devices designed to make the handshake between a variable PV array and the electric power grid,” he said. “They shape the solar DC output to utility-quality AC power, synchronizing with the grid and managing energy flow. With smart inverters, we are trying to extend inverter functionality for a more integrated grid.”
• What do smart inverters do and why do we need smart inverters?
  • With the increasing presence of PV in power systems around the world, situations now exist where PV power is flowing both upstream and downstream on distribution systems designed for one-way power flow. In some locations, there simply is not enough infrastructure, or grid capacity, to support interconnection of PV without costly upgrades (such as larger conductors or bigger transformers).
  • Typically, the first sign of incompatibility is an increase in the voltage experienced by nearby customers. In the face of rising grid penetration of variable distributed energy resources, voltage regulation, protection, and capacity requirements all will need to be carefully managed by utilities in order to meet their electric service obligations.
  • “Smart” inverters can actively support local grid voltage, help operators more easily balance supply and demand, and better manage their own output.
• Functions and applications
  • Among the technology’s core benefits are its ability to⁷⁵: Provide local voltage support – To help maintain voltage quality—for example in end-of-feeder grid locations where additional generation could result in voltage violations— a Smart inverter of PV can curtail power to control voltage.
    Ride-through grid disturbances – During periods of (sometimes extreme) deviations in grid voltage and/or frequency, smart inverters are designed to remain connected to the grid and adjust their output to act as a counterbalance to frequency or voltage changes.
• Issues involved in smart inverters
  • States have included smart inverter deployment into their updated interconnection rules (DC, MD, HI, CA). Smart inverters meeting IEEE 1547-2018 standards are supposed to be available sometime in 2022.

⁶⁴ The Green Button initiative is an industry-wide effort to provide electricity customers with easy access to their energy usage data in a standardized, consumer-friendly, and computer-friendly format. With Green Button Connect My Data, consumers can choose which service providers to share their data with automatically. (See DCPSC website www.dcpsc.org, Order No 20717, footnote 5)
⁶⁵ Distribution Systems Primer. https://pubs.naruc.org/pub/C0B3BA7C-0CBB-CB2A-E2B1-00A3756340BA
⁶⁶ Electric Grid Resilience and Reliability for Grid Architecture. https://gridarchitecture.pnnl.gov/media/advanced/Electric_Grid_Resilience_and_Reliability.pdf; Resilience Framework, Metrics, and Methods for the Electricity Sector. https://resourcecenter.ieee-pes.org/publications/technical-reports/PES_TP_TR83_ITSLC_102920.html; ERPI Research on Resource Adequacy and Resilience. https://www.powermag.com/wp-content/uploads/2021/02/epri-report.pdf
⁶⁷ The Role of Energy Storage with Renewable Electricity Generation. https://pubs.naruc.org/pub.cfm?id=4AB4516E-2354-D714-519D-0D30DD95D9AF; Emerging Possibilities for Energy Storage. https://pubs.naruc.org/pub/3E31F705-155D-0A36-3180-C17693D98CCF
⁶⁸ Energy surge and storage NARUC; examples from Maryland, New York, and Vermont. https://www.naruc.org/default/assets/File/storage_surge_summary(1).pdf
⁶⁹ NARUC User Objectives and Design Approaches for Microgrids: Options for Delivering Reliability and Resilience, Clean Energy, Energy Savings, and Other Priorities. https://pubs.naruc.org/pub/E1F332D4-155D-0A36-31CB-889ABED753D5
⁷⁰ https://pubs.naruc.org/pub/E2004045-155D-0A36-3147-D7D1639A0458
⁷¹ Notes from Denver NARUC Summer meetings, Microgrid panel, referring to New Jersey PSC definitions. July 2021. Also see https://sustainablesolutions.duke-energy.com/resources/three-types-of-microgrids/
⁷² Paul de Martini et al., Smart Electric Power Alliance and Pacific Energy Institute, “How to Design Multi-User Microgrid Tariffs,” August 2020, https://pacificenergyinstitute.org/wp-content/uploads/2020/08/SEPA-PEI-How-to-Design-Multi-User-Microgrid-Tariffs.pdf. See p. 20. And https://pubs.naruc.org/pub/E1F332D4-155D-0A36-31CB-889ABED753D5 pg. 13
⁷³ Please see this publication March 2019 published by DOE for examples. Voices of Experience – Leveraging AMI Networks and Data -- https://www.smartgrid.gov/files/VOEAMI_2019.pdf
⁷⁴ EPRI Common Functions for Smart Inverters from https://www.epri.com/research/products/000000003002008217
⁷⁵ https://www.epri.com/research/products/000000003002005781</

The rapid increase of AMI technology has given utilities unprecedent insights into the performance of their structures. A number of factors have impacted the current push for advances in broadband networks⁷⁶:

• Smart Grid – backhaul communications necessary to support the data
• Cybersecurity – older technologies do not have the encryptions and firewalls necessary to protect data in transit over lines.
• Data usage – new applications, particularly video-enabled monitoring, require high bandwidths to leverage their full potential
• Distribution Reliability – real-time monitoring of critical equipment can identify failures before they occur, allowing for replacement and circumventing a potential outage
• Available of current telecommunications services – third party carriers and providers are discontinuing older technologies as they transition to digital networks.

⁷⁶ The Value of Broadband Backbone for America’s Electric Cooperatives: A Benefit Assessment Study, https://www.cooperative.com/topics/telecommunications-broadband/Documents/The%20Value%20of%20a%20Broadband%20Backbone.pdf

• This section will provide an entry-level overview of laws and programs related to the environmental impacts of electricity and natural gas consumption.
• This section will not address environmental issues related to water, wastewater, telecommunications, or other regulated sectors.

• Greenhouse gas (GHG) emissions from electricity and natural gas consumption
• Non-GHG air pollution from electricity and natural gas consumption
• Land & water impacts from power delivery and pipelines

The ERE committee serves as a venue for state regulators to discuss ways to provide utility customers with environmentally sustainable and affordable energy services. Particularly, the Committee focuses on energy efficiency, environmental protection, renewable and distributed resources, consumer protection, low income weatherization and assistance, and public interest research and development.

• Renewable portfolio standard (RPS) or renewable electricity standard (RES): Policies designed to increase the use of renewable energy sources for electricity generation.
  
  1. Renewable Energy Certificate: A renewable energy certificate (REC) is a market-based instrument that represents the property rights to the environmental attributes of renewable electricity generation. RECs are issued when one megawatt hour (MWh) of electricity is generated and delivered to the power system from a renewable energy resource.
  2. Solar Renewable Energy Certificates: Solar RECs (SRECs) are created for each megawatt-hour (MWh) of electricity generated from solar energy systems. Some states create SREC markets to spur the development of solar by requiring electricity suppliers to purchase SRECs produced by in-state solar systems as part of their obligation under the state’s Renewable Portfolio Standard. Sometimes this requirement is referred to as a “solar carve out.”
• Net Energy Metering: An electricity billing mechanism that credits renewable energy system owners for electricity they add to the power system.
• Virtual Net Metering (or Community Net Metering): In some jurisdictions, the proposed or adopted changes affect all residential and small commercial customers, whereas in others the changes apply only to NEM customers. In some jurisdictions, NEM or successor rate designs also apply to customers participating in variations of aggregated, neighborhood, or virtual net metering, which often also includes participants in community-solar projects. The rates for community solar participants are often somewhat different from customers with on-site DG, but they are sometimes considered part of the same overall tariff.

  Virtual Net Metering allows eligible customers to connect their electric load with renewable resources through subscription even the renewable system is not located on the customers properties. The subscribers will get rate credits from utilities and will pay a subscription fee. States, in general, have a maximum size for virtual net metering or community net metering facilities. For example, in D.C. it is limited to 5 MWs per project site. Twenty states have taken legislative or regulatory actions to enable community solar projects, and many additional states have approved specific utility-run community solar projects.⁷⁷

• Public Utility Regulatory Policies Act (PURPA): PURPA was enacted following the energy crisis of the 1970s to encourage co-generation and renewable resources and promote competition for electric generation. The statute imposes mandatory purchase obligations on electric utilities for power generated by co-generation facilities and small power production facilities of 80 MW or less in size at a rate that does not exceed the avoided cost.
• Feed-in Tariff: Policy mechanism to guarantee customers who own an eligible renewable electricity generation facility will receive a set price from their utility for all the electricity they generate and provide to the power system.
• Power Purchase Agreement: A contract between a seller who generates electricity and a purchaser of the electricity. The agreement defines all the commercial terms for the sale of electricity between the two parties, including date of commercial operation, schedule for delivery of electricity, penalties for under-delivery, payment terms, and termination. A power purchase agreement is a principle agreement that defines the revenue and credit quality of a generating project and therefore is a key instrument of project finance.
• Community Choice or Municipal Aggregation: Allows local governments to procure power on behalf of their residents, businesses, and municipal accounts from an alternative supplier while still receiving transmission and distribution service from their existing utility provider.
• Federal Renewable Energy Tax Credits: The investment tax credit (ITC) is claimed against the business tax liability of the company that develops, installs, and finances a renewable energy project. The production tax credit (PTC) is a per kilowatt-hour tax credit for the project owner over a 10-year period, with eligibility based on when the project commences construction and the 10-year timeline starting from the time the project is placed in service. The ITC and PTC include safe harbor provisions that make the project eligible for the credit if at least 5 percent of the project’s capital costs have been incurred by the end of the deadline year or if physical work has begun on the project by that time.
• Energy Efficiency Resource Standard (EERS): A quantitative, long-term energy savings target for utilities. Under direction from this policy, utilities must procure a percentage of their future electricity and natural gas needs using energy efficiency measures, typically equal to a specific percentage of their load or projected load growth.
• Demand Response is the reduction in consumption of electricity by customers from their expected consumption levels, in response to either reliability or price signals. For example, D.C. has an air-conditioner program that can cycle customers’ air-conditioners on and off during extreme hot summer peak days, customers will receive credits through participating into such demand response programs. Such programs can also bid into PJM capacity market to receive capacity earnings which will reduce program costs for consumers.
• Fuel Mix: Refers to generation mix; the percentage of coal, nuclear, natural gas, and renewable resources vary from time to time within an RTO.
• Least Cost Procurement: The goal of least cost planning and procurement is to minimize the cost to ratepayers of meeting the demand for electric energy services. Least cost planning and procurement generally requires utilities to consider investments, alternative solutions, and energy efficiency, conservation, and demand-side management.⁷⁸
• Integrated Resource Planning or Integrated Distribution Planning: An integrated resource plan is a utility plan for meeting forecasted annual peak and energy demand, plus some established reserve margin, through a combination of supply-side and demand-side resources over a specified future period.⁷⁹ Integrated distribution planning (IDP) consists of six key elements that can be grouped into two classifications. 1) Core IDP Elements (i.e., generally integration of internal elements and processes within the utility to enhance distribution planning), which include forecasting, sourcing solutions for grid needs, and transmission, distribution, and generation integration, and 2) Additional IDP Elements (i.e., associated with varying priorities depending on objectives, goals, and other circumstances unique to each utility), which typically include interconnection data integration, hosting capacity analysis, and stakeholder engagement.⁸⁰
• Energy Storage Targets: Mandates for electric utilities to procure quantities of energy storage across the transmission, distribution, and/or customer levels.
• Clean Peak Standard: Policy mechanism designed to meet peak demand with clean sources of energy, either by increasing the supply of clean energy during peak demand events or decreasing total demand during peak events.
• Interconnection Standards: Interconnection standards dictate how renewable energy systems can be legally connected to the electricity grid. They are a set of requirements and procedures for both utilities and customers. Typically, interconnection standards outline a multi-step process. In some jurisdictions, simple systems can be eligible for simplified, or fast-tracked, interconnection approval processes. For more complex systems, or in jurisdictions where simplified interconnection is not available, interconnection is generally a two-stage process.
• Value of Solar Tariff: Utility customers with distributed solar panels can provide power to and take power from the grid. A value of solar tariff clarifies how much energy is sold in each direction and at what rate the energy is valued. A value of solar tariff is a policy alternative to net energy metering, which is the most common form of valuing distributed generation interactions with and contributions to the electricity grid.
• System Benefit Charges: System benefit charges are assessed on all electric and/or gas customers to fund public benefits related to the provision of electricity or natural gas. System benefit charges are often used to fund energy efficiency programs.⁸¹
• Decoupling: Decoupling refers to the disassociation of a utility’s profits from its sales of the energy commodity to reduce the utility’s incentive to sell more energy.
• Non-wires alternatives: Non-wires alternatives use distributed energy resources to defer or replace the installation of more traditional utility infrastructure.

⁷⁷ See NRRI 19-01, NEM by Tom Staton https://www.naruc.org/nrri/nrri-library/research-papers/
⁷⁸ https://betterbuildingssolutioncenter.energy.gov/implementation-models/state-rhode-island%E2%80%99s-least-cost-procurement-strategy-energy-efficiency
⁷⁹ https://www.raponline.org/wp-content/uploads/2016/05/rapsynapse-wilsonbiewald-bestpracticesinirp-2013-jun-21.pdf
⁸⁰ https://www.raponline.org/wp-content/uploads/2019/12/rap_shenot_dsp_dsm_sweep_2019_nov_07.pdf https://sepapower.org/knowledge/integrated-distribution-planning-idp-what-is-it-and-how-do-we-achieve-it/
⁸¹ https://www.nrel.gov/docs/legosti/old/22852.pdf