SunEdison Utility Holdings told the Federal Energy Regulatory Commission on Oct. 16 that something needs to be done to fix an ISO New England project queue system that is supposed to take ten months to get through, but is instead taking about four years when it comes to projects in parts of Maine.
On Sept. 8, SunEdison had filed comments with FERC in support of the American Wind Energy Association’s (AWEA) June 19 petition for a rulemaking to revise generator interconnection rules and procedures on a nationwide basis. In its Oct. 16 filing, SunEdison offered a limited reply in response to other commenters.
SunEdison focused its initial comments on only 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). SunEdison recommended that, in order to ensure a more efficient and predictable process, FERC should allow for the increased use of group studies and a “first-ready, first-served” approach to queue processing.
SunEdison’s Oct. 16 reply comments address one of the points raised by ISO New England (ISO-NE), a region in which SunEdison has developed, and is continuing to develop, a number of renewable energy projects. ISO-NE asserts that its current processes are working well with the exception of requests to interconnect in the Northern and Western Maine portions of the system.
ISO-NE contends that the significant backlog in Western and Northern Maine results from the characteristics of the Maine transmission system; the large number of interconnection requests (3,600 MW) which ISO-NE labels an “oversubscription”; and the nature of the generator technologies (mainly wind). ISO-NE adds that other delays are introduced by actions and inactions of individual customers (e.g., frequent project modifications, failure to provide functional models in a timely manner, and challenges to study/upgrade findings), SunEdison wrote.
ISO-NE also states that it will be unable to integrate existing and incremental generation into the Western and Northern Maine region without significant transmission expansion. ISO-NE concludes that a nationwide rulemaking is unnecessary and a less efficient approach to address interconnection reform, “particularly those related to a queue backlog in the Maine areas of the system.”
SunEdison wants targeted reforms at ISO-NE before nationwide process can run its course
SunEdison said it supports AWEA’s suggested technical conference with respect to a nationwide rulemaking, but the Maine interconnection issues are not readily resolved through a nationwide rulemaking, and immediate targeted changes to ISO-NE’s processing of interconnection requests in Maine are needed. The nationwide rulemaking process should not prevent or delay more targeted solutions for areas such as Northern and Western Maine, where the interconnection backlog is particularly acute, SunEdison said.
SunEdison said that, while the extensive summary of its work offered by ISO-NE seems to suggest that ISO-NE is applying resources to address interconnection issues in Maine, these efforts have not resulted in any initiatives that directly target the Maine backlog – a backlog which currently provides estimated system study start dates some four years after the interconnection request is submitted. The ISO-NE Tariff contemplates that the interconnection study process will take approximately 10 months.
“Despite ISO-NE claims that its queue backlog does not arise from a flawed interconnection process or ISO-NE’s failings in implementing its processes, the mere fact that the backlog in Northern Maine is approximately four years evidences a clear and pressing problem,” SunEdison argued. “Moreover, ISO-NE’s description of modest improvements – as currently proposed in the stakeholder process – does not hold any credible promise of reducing the four year backlog for Maine-focused system impact studies.
“SunEdison fully agrees with ISO-NE that Northern and Western Maine present a special case that will not be resolved efficiently or on a timely basis by waiting for the completion of a rulemaking, but it also will not be resolved with the efforts summarized by ISO-NE in its comments. SunEdison does not disagree that ISO-NE faces additional challenges in Northern and Western Maine, but this is not a reason to live with unacceptable results. Rather it is the reason to step-up efforts to identify solutions beyond those that might arise from a rulemaking or a stakeholder process addressing general interconnection processes.
“Because the challenges of interconnecting generation in Northern and Western Maine are significant and unique, a solution must be designed to directly address these challenges so that interconnection studies can be completed in a timeframe more on par with the tariff requirements. As SunEdison explained in its initial comments, backlogs can be reduced though group studies and a first ready, first served process. Given that ISO-NE has identified as one of the reasons for delay in Maine studies the fact that projects are not ready to move forward on schedule or make frequent changes, these factors, at least, can be addressed by moving to a first-ready, first-served approach. Moreover, ISO-NE could adopt this approach selectively for Northern and Western Maine, even if only on a temporary basis, and use a group study of all projects that are ready within a certain timeframe to clear out the current significant backlog. Projects that are ready could be studied together rather than standing idle in the backlog waiting for other projects that are not ready to move forward to delay the already slow serial study process or cause repetitive restudies.”
ISO-NE cites various factors for queue backlog, including system reliability issues
ISO-NE said in Sept. 8 comments in this case that its interconnection processes are working well overall, with studies and interconnection generally occurring in expected timeframes. With the exception of the Interconnection Requests for projects seeking to interconnect in the northern and western portions of the transmission system, substantially all the generator Interconnection Requests made through 2014 have completed the SIS phase or have moved to the Interconnection Agreement and commercialization phases of the interconnection process. As a result, the region has added approximately 90 new (including incremental additions to existing) generating units (representing total capacity of approximately 2,800 MW), including wind and other inverter-based technology projects, during the period from 2009 to the present.
“While interconnection queue processing is generally working smoothly in non-Maine areas of the system, a significant queue backlog has emerged due to Interconnection Requests for more than 3,600 MW of new generation, mostly wind resources, seeking to interconnect in Northern and Western Maine, which has been exacerbated by a steady stream of additional Interconnection Requests,” wrote ISO-NE. “The sources of the Maine interconnection backlog are threefold. The first source is the underlying nature of the Maine transmission system. The second source is the extent of oversubscription of requests to interconnect in Maine, and the third source stems from the nature of the generator technology being proposed.
“Over the past several years, the addition of generation in Maine, in combination with the area’s limited transfer capability, has increased the likelihood of many northern New England interfaces operating near their limits, creating ever-greater restrictions on northern New England resources. Because these interface limits depend on generation dispatch, the operation of the system becomes more complex. Additional concerns in northern New England include limited system flexibility to accommodate maintenance outages, limited dynamic reactive-power resources, and high real- and reactive-power losses. The existing system still includes three complicated special protection systems, which interact with each other in the management of North-to-South flows following system contingencies, thus compounding the complexity of reliable system operation.
“A significant number of new wind generation projects have already interconnected, pursuant to the Network Capability Interconnection Standard (previously, MIS), to the northern portions of the New England transmission system. … These portions of the system are remote from the region’s load centers and are susceptible to poor voltage performance. These same locations have also already experienced congestion in system operations, especially during transmission system maintenance periods. Such congestion, which is consistent with the proper functioning of the New England markets in the case of surplus minimally interconnected generation, is expected to continue in the absence of significant transmission expansion.
“The pending Interconnection Requests in the Maine area would be far beyond the existing inherent capability of the Maine transmission system. Simply stated, the Maine area is oversubscribed from a basic generation interconnection perspective and especially from a cumulative generation integration standpoint. Maine is already a heavy export area. Its forecast 2015 summer peak load is approximately 2,300 MW (net). Maine export capability is 1,900 MW, so the total load plus export capability is 4,200 MW. Existing generating capacity in Maine as of summer 2015 is approximately 3,100 MW, New Brunswick import capability is 1,000 MW, and new wind proposals as of September 2015 total 3,400 MW and new non-wind proposals total 200 MW. Thus, the potential resource total would be 7,700 MW. Proposals for new interconnections in the Maine area, if they materialize, will add to the significant oversupply of resources coming through Maine to the rest of New England.”