In order to better manage the queue of power generating projects in a very active California power development market, the California ISO on Sept. 30 filed with the Federal Energy Regulatory Commission a series of proposed changes to the queue process.
“Identifying ways to better administer its generation interconnection queue has become increasingly important to the ISO and its customers in light of the significant increase in the number of new generation projects stimulated by California’s ambitious renewable portfolio standard,” said the CAISO filing. “The large number of projects and the different project configurations, along with the need for project modification, presents significant administrative challenges and costs for the ISO.”
CAISO said it has addressed these challenges in part by dedicating additional resources to administering its interconnection queue. The ISO has also identified six modifications which have been approved by the ISO Governing Board to its interconnection procedures and agreements that would help to improve the efficiency of the interconnection process and to help ensure that generation projects move through the interconnection process more efficiently.
These six queue management proposals represent the first of three tariff amendments that CAISO anticipates filing under its 2013 IPE initiative, which was launched in April 2013 to improve various aspects of the generator interconnection process. CAISO said it is committed to continuous improvement in this area to reflect changes in the industry and to better accommodate the needs of interconnection customers. The IPE initiative is the most recent in a series of stakeholder processes that the ISO has conducted over the past several years in order to meet this commitment.
The ISO launched the IPE initiative by publishing a scoping proposal on April 8. Instead of following its usual practice of beginning a stakeholder initiative with an issue paper, the ISO identified the development of this scoping proposal as a necessary first step in the IPE initiative. The scoping proposal had two purposes.
- First, it assembled a comprehensive list of potential topics in one place from a number of sources that included last year’s generator interconnection stakeholder process, commitments made by ISO management to consider certain specific issues raised by stakeholders, other topics suggested by stakeholders over the course of the last year, and issues identified by the ISO pursuant to an internal review aimed at improving the ISO’s ability to administer the queue.
- Second, the scoping proposal selected a set of potential topics from a comprehensive list of topics for proposed inclusion in the scope of the IPE initiative. This was necessary because the comprehensive list of topics (nearly fifty total) represented a far larger set of topics than could be reasonably addressed within the scope of this initiative, CAISO noted. To develop a set of topics representing a more reasonable workload to include in-scope, the organixation took into consideration the estimated level of effort and relative priority associated with each topic as well as its potential contribution to queue management efforts. This resulted in twelve topics that the ISO proposed in the April 8 scoping proposal for inclusion in-scope. Based on stakeholder feedback received following the release of the scoping proposal, the ISO expanded the scope of the IPE initiative by three topics and posted an issue paper on June 3 that addresses the resulting scope of fifteen topics.
CAISO proposes tariff changes to cover new requirements
The Sept. 30 filing with FERC is a tariff amendment which proposes modifications to improve the ability of the ISO to administer the generator interconnection queue and to address miscellaneous non-substantive tariff issues. With respect to the queue management-related modifications, the ISO proposes to revise its tariff as follows:
- requiring interconnection customers to pay for the actual costs incurred by the ISO and participating transmission owners for evaluating their requests for modifications to their projects;
- extending to small generator projects the existing tariff provisions for large generators regarding commercial operation date extensions and other modifications to their projects;
- applying to small generator projects the existing tariff provisions for large generators regarding the maximum length of time a project is allowed to remain in the interconnection queue;
- clarifying that the participating transmission owner tenders the draft generator interconnection agreement (GIA) to the interconnection customer;
- changing the triggering event for tendering the draft GIA from the provision of the Phase II interconnection study report to the study results meeting, unless agreed otherwise by the parties; and
- reducing the time for the ISO to provide a final GIA to interconnection customers once negotiation of the GIA is completed.
With respect to the miscellaneous revisions proposed in the Sept. 30 filing, these modifications are not intended to materially change established policies or the rights and obligations of the ISO or its market participants. Instead, these revisions are intended to add additional detail to clarify the meaning of tariff provisions, ensure consistency throughout the tariff as well as between the tariff and applicable business practices, and correct typographical and other inadvertent errors, CAISO said.
CAISO requests that the commission accept the tariff revisions contained in this filing to be effective as of Dec. 3, 64 days from the date of this filing to ensure that the changes apply to cluster 5 projects which are scheduled to receive their phase II study results on Dec. 3.