Several parties on Sept. 8 filed notices of intervention with the Federal Energy Regulatory Commission in a case involving an American Wind Energy Association request that changes be ordered in the interconnection procedures at various regional organizations to allow a faster, smoother interconnection review process.
Several parties simply filed notices of intervention, with no actual comments offered.
One party filing comments was SunEdison Utility Holdings Inc., which submitted its comments “in whole-hearted support of the American Wind Energy Association’s (‘AWEA’) June 19, 2015 petition for rulemaking to revise generator interconnection rules and procedures (the ‘AWEA Petition’). SunEdison looks forward to participating in the rulemaking and to addressing the comprehensive changes that the Commission will propose.
“In these initial comments, though, SunEdison focuses only on one aspect of the Commission’s current standard interconnection procedures that significantly impedes timely and efficient interconnections: the serial, queue-order processing rules that still exist in some regional transmission organizations (‘RTOs’) and independent system operators (‘ISOs’). Presently, the interconnection study and restudy process is susceptible to significant delays. In order to ensure a more efficient and predictable process, the Commission should allow for the increased use of group studies and a ‘first-ready, first-served’ approach to queue processing. SunEdison, therefore, requests that the Commission initiate AWEA’s proposed rulemaking and add this critical proposed requirement that ISOs and RTOs adopt group study procedures and a first-ready, first serve approach to queue processing.”
SunEdison added: “Since 2008, while some RTOs/ISOs have developed new procedures that reduce, if not eliminate, some of their respective queue backlogs, others continue to experience lengthy delays in processing interconnection requests, which delays present significant barriers to project development. Indeed, in some RTOs/ISOs, an interconnection customer, after submitting an interconnection request, may have to wait through several rounds of studies and restudies, a process almost invariably measured in years, not months. As the nation’s generation mix continues to change and the industry is primed for significant new generation development, facilitating timely and efficient generator interconnection will be ever more critical.
“The Commission, developers and transmission providers now have years of experience under the current interconnection procedures to inform their judgments as to the refinements necessary to facilitate this expected increase in new generation development. The time is right for the Commission to institute a rulemaking to further improve interconnection procedures. Accordingly, SunEdison strongly supports the AWEA Petition and urges the Commission to take this opportunity to examine anew and further refine its generator interconnection procedures.”
Public power groups offer their perspective
The American Public Power Association (APPA), the Large Public Power Council (LPPC) and the National Rural Electric Cooperative Association (NRECA) (collectively called “the Trade Associations”), said in their joint Sept. 8 comments that AWEA proposes a wide-ranging suite of changes to the pro forma Large Generator Interconnection Procedure (LGIP) and Large Generator Interconnection Agreement (LGIA) addressing four broad areas, including those related to:
- certainty in the study/restudy process;
- transparency in the interconnection process;
- certainty of network upgrade costs; and
- accountability in the interconnection process.
The requested changes are designed to apply in RTO and non-RTO settings, although AWEA acknowledges that RTO procedures have diverged substantially from those included in non- RTO utility tariffs, which continue to reflect the basic format directed by the commission in Order Nos. 2003, et al, the associations said.
“The Trade Associations support an open discussion with AWEA, other interested stakeholders and the Commission of recommended changes to the LGIP and LGIA,” they added. “There is merit in evaluating the industry’s experience under these procedures and options for improvement that do not compromise system reliability or shift costs unjustifiably. A technical conference sponsored by the Commission, accompanied by ancillary discussions with interested parties, would be the best means of advancing the issues at this stage.
“Among other things, an initial exploratory conference should focus on the support for the requested changes, and whether certain recommendations are more appropriately addressed in a regional setting or limited to specific types of generation. The Commission has employed technical conferences and other preliminary procedures in connection with the development of the rules promulgated with Order Nos. 2003 and 890. These processes will well serve the parties here, where the specific reforms are not fully supported or formed, and industry consensus has yet to emerge. AWEA has indicated its support for a technical conference if the Commission deems it necessary.”
New York groups oppose the AWEA effort
Central Hudson Gas & Electric Corp., Consolidated Edison Co. of New York, Power Supply Long Island, New York Power Authority, Niagara Mohawk Power Corp. d/b/a National Grid, and Orange and Rockland Utilities (calling themselves the “Indicated New York Transmission Owners”) said in a joint Sept. 8 filing that they share AWEA’s desire to improve the interconnection process to the extent necessary and appropriate. “However, a uniform, one-size-fits-all national rulemaking conflicts with the Commission’s policy to allow regions to tailor their interconnection procedures to fit the regions’ unique circumstances,” they added.
“In Order No. 2003, the Commission provided Independent System Operators (‘ISOs’) and Regional Transmission Organizations (‘RTOs’) with the flexibility to account for regional differences by seeking independent entity variations from the pro forma GIP and GIA. In complying with Order No. 2003, the New York Independent System Operator, Inc. (‘NYISO’) sought and received approval for independent entity variations that allowed its interconnection procedures to be tailored to the specific circumstances in the region including the NYISO Open Access Transmission Tariff (‘OATT’).
“After Order No. 2003, the NYISO has worked with stakeholders to implement improvements to the interconnection requirements in Attachments S, X, and Z of its OATT and some such changes have recently gone into effect. As a result, the NYISO’s Standard Large Facility Interconnection Procedures, which administers the proposed interconnection of a Large Facility greater than 20 MW to the New York State Transmission System or Distribution System, include a number of Commission-approved independent entity variations that are specific to the circumstances in New York. These improvements to the interconnection process were identified and adopted by the NYISO after extensive stakeholder input.
“While the NYISO encouraged all interested parties to express their views in the stakeholder processes, AWEA and its members have not actively participated nor raised the concerns now articulated in its petition. AWEA fails to recognize that any solution to issues it raises involve a balancing of conflicting goals of flexibility, finality and speed that cannot be performed in a vacuum but rather must be viewed in the context of the regional tariff.
“Importantly, AWEA has not alleged nor identified any unjust, unreasonable, or unduly discriminatory interconnection practices that are specific to the NYISO. In fact, many of AWEA’s proposed reforms have either already been addressed by the NYISO or are not applicable to the NYISO process.
“For example, the NYISO’s interconnection process is different than those in other ISOs and RTOs because it has a unique Class Year Study that does not include the type of re-studies that affect the upgrades required for projects based on changes to higher-queued projects or system conditions. To the extent practicable, the NYISO evaluates interconnection requests in parallel, not sequentially. In this regard, the NYISO Class Year study process is actually superior to that being recommended by AWEA and its continued use has been supported by its stakeholders.
“AWEA’s concerns regarding ‘contingent facilities’ are also not relevant to the NYISO because the NYISO studies a cluster of projects in its Class Year Study. The study results are final only when all the developers remaining in the Class Year have accepted their cost allocation required for the System Upgrade Facilities necessary for the remaining projects to interconnect. If one or more developers do not accept their cost allocation, the NYISO updates the study results without their projects, and the remaining developers again elect whether to proceed with the updated cost amounts. In New York, the Connecting Transmission Owners are heavily involved in the performance of the interconnection studies and work closely with the NYISO to provide significant technical and cost related support. Therefore, AWEA’s assertion that the relevant Transmission Owners should have increased involvement in the System Reliability Impact Study stage of the interconnection process is simply not relevant to the NYISO.”
Put the TVA in the opposing category, as well
Said the Tennessee Valley Authority in its Sept. 8 comments: “Based on its experience interconnecting independently-owned generation over the past three decades, TVA believes that AWEA’s proposed changes to the Commission interconnection practices, model agreements, and procedures are largely unjust, unreasonable, and unduly discriminatory in favor of new independent generation developers at the expense of transmission providers and other transmission system users.
“Rather than reducing total costs for consumers such as AWEA asserts, TVA believes that several of AWEA’s proposed changes would simply shift costs to existing transmission system users for the benefit of new generation developers, and at times would increase study costs for the interconnection customer or would increase the net costs to consumers. In these comments, TVA has not attempted to address all of AWEA’s proposed changes, but only those that in TVA’s estimation are the most problematic.”
One of TVA’s problem spots is that AWEA proposes capping the generation developer’s responsibility for the costs of interconnection facilities and network upgrades at the amounts estimated early in the study process, prior to execution of an agreement, absent “extraordinary circumstances beyond the transmission provider’s control.”
Wrote TVA on that point: “This proposal is based on the mistaken premise that the transmission provider normally has full control over the study schedule. This ignores the effects of affected systems that must collaborate in the study process, as well as the impact of higher-queued interconnection requesters that may choose to withdraw from the queue.
“Additionally, upgrade cost estimates can change between the time the transmission provider gives the estimate and the time that the generation developer decides to proceed with the work due to unexpected changes in prices for commodities such as steel, copper, and aluminum. All of these things are outside the control of the transmission provider and so should not affect the transmission provider’s cost responsibility, yet they clearly do not satisfy AWEA’s ‘extraordinary circumstances’ requirement. TVA suggests that AWEA’s proposal in this regard should be rejected as unjust, unreasonable, and unduly discriminatory.”
GE wants interconnect deals to be more flexible in terms of technology changes
General Electric‘s (NYSE: GE) GE Power & Water and GE Energy Consulting filed Sept. 8 comments that were brief and centered on how wind projects can change during the lengthy interconnection review process due to the constant evolution of power plant technologies.
“GE suggests that the Commission modify its pro-forma GIP and GIA to specify the exact location that the real power in MW is measured and that that location be the point of interconnection (‘POI’), which is normally at the same location as the revenue meter,” GE wrote. “This is the Net Maximum Capacity (‘NMC’) of the wind facility. The wind facility can be modeled as a single large generator rather than a collection of wind turbines. The wind facility control system can monitor and control the electrical condition at the POI to remain within limits set by the GIA.
“Many GIA’s now consider the Group Installed Capacity (‘GIC’), which is simply the sum total of the MW ratings of all the individual wind turbines. The GIC always exceeds the NMC due to balance of plant real power losses between the wind turbines and the POI. GE refers the Commission to the attached peer-reviewed paper, ‘Planning for Interconnection of Wind Plants based on Net Maximum Capacity’, which concludes in most cases, upgrades to individual turbines can be made before and after interconnection that improve the performance of the wind facility without affecting the dynamic response or short circuit characteristics of the wind facility as measured at the POI. For these reasons, GE suggests that the pro forma GIA specify the NMC at the POI and not the GIC.”