[Federal Register Volume 83, Number 81 (Thursday, April 26, 2018)]
[Notices]
[Pages 18285-18288]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-08722]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket No. AD18-8-000; Docket No. EL18-26-000]
Reform of Affected System Coordination in the Generator
Interconnection Process, EDF Renewable Energy, Inc. v. Midcontinent
Independent System Operator, Inc., Southwest Power Pool, Inc., and PJM
Interconnection, L.L.C.; Notice Inviting Post-Technical Conference
Comments
On April 3 and April 4, 2018, Federal Energy Regulatory Commission
(Commission) staff conducted a technical conference to discuss issues
related to affected systems that have been raised in the complaint
filed by EDF Renewable Energy, Inc. against Midcontinent Independent
System Operator, Inc., Southwest Power Pool, Inc., and PJM
Interconnection, L.L.C. in Docket No. EL18-26-000 and in the
Commission's Notice of Proposed Rulemaking (Generator Interconnection
NOPR) on the interconnection process in Docket No. RM17-8-000.
All interested persons are invited to file initial and reply post-
technical conference comments on the questions listed in the
Supplemental Notice of Technical Conference issued in this proceeding
on March 26, 2018 and the questions listed in the attachment to this
notice. Commenters need not respond to all topics or questions asked.
Commenters may reference material previously filed in this docket but
are encouraged to submit new or additional information rather than
reiterate information that is already in the record.
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In particular, commenters are encouraged, when possible, to provide
examples in support of their answers. Initial and reply comments are
due within 30 days and 45 days, respectively, from the date of this
notice.
For more information about this notice, please contact:
Myra Sinnott (Technical Information), Office of Energy Policy and
Innovation, (202) 502-6033, [email protected].
Kathleen Ratcliff (Technical Information), Office of Energy Market
Regulation, (202) 502-8018, [email protected].
Lina Naik (Legal Information), Office of the General Counsel, (202)
502-8882, [email protected].
Dated: April 19, 2018.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
Post-Technical Conference Questions for Comment
For any of the following questions, please also describe any issues
presented when an affected system is a non-public utility transmission
provider.
General Affected Systems Coordination Processes
1. Please describe any affected system coordination processes and
guidance available for your market or balancing authority area,
including, but not limited to, tariff provisions, joint operating
agreements (JOA), and business practice manuals (BPM).
2. Please explain the role of the host transmission provider in
managing the coordination and communication between an interconnection
customer and an affected system during the course of an interconnection
request process. If the interconnection customer has primary
responsibility to coordinate and communicate with the affected system,
please explain how the host transmission provider ensures that affected
system matters are addressed before proceeding with an interconnection
for which affected system impacts have been raised.
3. With respect to Midcontinent Independent System Operator, Inc.
(MISO), Southwest Power Pool, Inc. (SPP), and PJM Interconnection,
L.L.C. (PJM) specifically, once the need for an affected system study
is determined, please describe how each RTO then coordinates with the
other RTO to consider the affected system impacts due to an
interconnection request on the host system. Please include the steps in
the process and any timelines and other procedural matters, and
reference any tariff, JOA, BPM, and/or other provisions that describe
the process for such coordination.
4. Should there be a pro forma affected system study agreement that
provides for firm timelines for the affected system to provide the
relevant studies? If so, what terms and conditions should it contain,
and what entities should be parties to the affected system study
agreement (e.g., host transmission provider, host transmission owner,
affected system, interconnection customer)? What modifications would
need to be made to such a study agreement to accommodate a non-public
utility affected system?
5. Regardless of whether the Commission proceeds with development
of a pro forma affected systems study agreement, should MISO, SPP, and
PJM develop a common affected systems study agreement? If so, what
terms and conditions should this agreement contain, and what entities
should be parties to the agreement (e.g., host transmission provider,
host transmission owner, affected system, interconnection customer)? If
possible, please provide a sample of a commonly used affected systems
study agreement.
6. As part of the affected systems study agreement, if affected
systems were allowed to charge interconnection customers an
administrative fee for conducting affected system studies, in addition
to receiving reimbursement for the actual costs of conducting affected
system studies, would such a fee motivate affected systems that lack
resources, such as full-time employees, to conduct affected system
studies in a more timely manner? If so, how should the fee be
determined and what milestones of the affected system should be tied to
the fee? Should such an administrative fee be tied to the affected
system providing its study results by a certain date?
7. Describe any planned or in-process affected system coordination
improvement efforts taking place in your market or balancing authority
area (through a stakeholder process, etc.). Please provide links or
directions to any publicly available materials related to these
improvement efforts.
Modeling and Study Procedures Used for Affected Systems Information
1. Please explain how Network Resource Interconnection Service
(NRIS) and Energy Resource Interconnection Service (ERIS) are modeled
both when conducting studies on your system and when conducting studies
as an affected system, and provide a reference to where that
information is located in your tariff. Are the standards (e.g. shift
factors, contingency lists) for modeling NRIS and ERIS available to
customers, and if so, where is this information located?
2. Explain the reasons an affected system would study an
interconnection request made in a host system using NRIS criteria when
the interconnection customer is only requesting NRIS in the host
system. What are the benefits and drawbacks to studying and also
requiring an interconnection customer seeking NRIS in the host system
to be responsible for network upgrade costs in an affected system in
the same manner as an interconnection customer who requests NRIS in the
affected system?
3. Explain the reasons an affected system could or should study an
interconnection request using ERIS criteria when the interconnection
customer is requesting NRIS in the host system. If you believe affected
system transmission providers should study NRIS requests as ERIS,
please include an explanation of how ERIS criteria address reliability
concerns associated with an NRIS interconnection request in both the
host and affected systems.
4. Should there be a standard approach to determine if an
interconnection customer requesting NRIS in the host system is studied
as NRIS or ERIS on an affected system? If so, what should the standard
be and why?
5. If there is no generic reform that dictates how affected systems
study interconnection customers who request NRIS on the host system,
should MISO, SPP, and PJM develop a standard approach to determining
whether such an interconnection customer should be studied as NRIS or
ERIS on the affected system(s) during the modeling process? If so, what
should the standard be and why?
6. Please explain the process used to calculate generation shift
factors, including how and where the reference bus is selected, when
conducting an affected system study for interconnection requests made
in a host system.
7. What are the dispatch assumptions used in affected systems
studies? Are the dispatch assumptions the same for already
interconnected resources on the host system that affect flows on the
affected system and resources already interconnected in the affected
system? Are these dispatch assumptions consistent with the assumptions
an affected system uses when it performs an interconnection request
within its footprint? Are the dispatch assumptions an affected system
uses in affected system studies provided to
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interconnection customers? To the extent already interconnected
resources on the host system are assumed to be dispatched at full
output, what is the rationale for that assumption?
8. What criteria do transmission providers use to determine whether
an interconnection request on the host system requires an affected
system study on an affected system? Please provide references to
tariff, JOA, BPM, and any other provisions that include this criteria.
If the determination is based on ``engineering judgment,'' is this
judgment adequately explained to the interconnection customer? If so,
in what form does the interconnection customer receive that
information? If there is a disagreement regarding this determination,
is there a process for the customer to challenge it? If so, please
provide a detailed description of that process.
9. Should MISO, SPP, and PJM be required to use the same criteria
to determine whether an interconnection request on the host system
requires an affected system study on an affected system?
10. Please comment on the possibility of implementing jointly
developed interconnection-wide transmission models between transmission
providers in affected system studies to detect topology changes to a
transmission provider's region that might not be visible by the
affected systems until the next interconnection-wide model update.
11. When an affected system studies an interconnection request,
should it model its entire footprint or a sub-region(s) of its system?
If a sub-region(s) would be sufficient, please explain what criteria
would be used to determine the sub-region(s) in an affected system that
are impacted by an interconnection request in a host system.
12. What are the benefits and drawbacks for the interconnection
customer, the host transmission provider and the affected system to an
affected system studying all interconnection requests in a host system
study cluster or queue to determine affected system impacts? Is there a
way the host system could employ some type of pre-screening process to
limit affected systems analysis to only those requests that may impact
an affected system? What criteria should be used in such a pre-
screening process?
13. At what point in the interconnection process should
interconnection customers be required to provide relevant modeling data
to best avoid delays in both the host interconnection and affected
system study processes?
Timing of Affected System Coordination
1. Does the host system's interconnection process include an
opportunity for the host system and interconnection customer to review
an affected system study and discuss the results with the host system
or affected system, as necessary, before the interconnection process
either requires a financial milestone payment or execution of an
interconnection agreement? If so, please provide references to the
relevant tariff or manual descriptions of this opportunity. Is this
opportunity to review included in the host system's interconnection
queue timeline? If so, how much time is allowed?
2. Should all host system transmission providers be required to
align their interconnection study process schedules with any relevant
affected systems in order to allow for both host system and affected
system studies to occur on the same timeline? Would such alignment
improve the timing at which an interconnection customer receives
affected system study results? What actions could the host system,
affected system, and interconnection customer take to better align the
completion of affected system study results? Should the Commission
require that an interconnection customer receive affected system study
results at the same time it receives a host system's system impact
study results? If so, would there be any concerns with that approach?
3. Should MISO, SPP, and PJM be required to adopt a common timeline
for conducting affected systems studies and providing results to
interconnection customers and/or the host transmission provider? If
not, why not? If so, please explain how this common timeline could be
implemented. For example, would each RTO begin affected system studies
at certain set dates throughout the year and commit to providing
results by certain set dates, or are there other ways of implementing a
common timeline? Please also provide an example of how this common
timeline could be developed--that is, by providing sample tariff, JOA,
BPM, or other language.
4. Should affected systems be required to adhere to a time limit or
point in the host system's interconnection process (such as when a
generator interconnection agreement (GIA) is tendered or system impact
study data is provided by the host system to the interconnection
customer) by which the affected system should notify the
interconnection customer and/or host transmission provider of network
upgrade costs?
5. Should affected system study results be aligned with the host
system's system impact study results to allow interconnection customers
to have an estimate of all of their potential network upgrade costs
prior to proceeding in the queue with an at-risk financial payment?
Alternatively, if an interconnection customer is required to proceed
with an at-risk financial payment or move forward with an
interconnection agreement without having the affected system study
results, should the affected system or host system be required to
provide the interconnection customer with an option for a refund of its
payment if it withdraws due to late-received affected system study
results?
6. Please comment on the potential for an alternative affected
system study process in which the host system obtains the model from
the affected system and performs the impact analysis on the affected
system for interconnection customers itself, with the host system
following up with the affected system to verify results. Would such an
approach be beneficial or practicable? Would the additional analysis
and verification add time to the interconnection process? Should the
host system be compensated for performing the impact analysis?
7. Should the Commission require that time be allowed to
potentially identify and consider either alternatives to the dispatch
assumptions or adjustments to the interconnection request that could
mitigate the cost of a network upgrade on an affected system? If so,
what duration of time would be sufficient?
8. With respect to MISO, SPP, and PJM specifically, should the
Commission require that time be allowed to potentially identify and
consider either alternatives to the dispatch assumptions or adjustments
to the interconnection request that could mitigate the cost of a
network upgrade on an affected system? If so, what duration of time
would be sufficient? Even if a common timeline is not required by the
Commission, should MISO, SPP, and PJM nevertheless be required to build
time into their own interconnection processes to allow for further
consideration of affected system study results and potential mitigation
measures as an alternative to the network upgrades included in an
affected system study? For example, should interconnection customers in
MISO be allowed more than 15 days
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after receipt of affected system study results to decide to proceed to
the next phase of the definitive planning phase (DPP)?
9. Should MISO perform fewer affected systems studies than the
three studies currently required as part of the three-phase DPP
process? If so, which phase(s) in the DPP is most important to the
analysis of potential impacts on affected systems? Should an
interconnection customer in MISO be permitted to proceed to the next
DPP phase even if an affected system study is not ready and therefore
not included in the system impact study of the prior phase?
Allocation of Affected System Costs
1. Are there improvements that could be made to transmission
planning processes to better identify transmission projects that
benefit host systems and/or affected systems but that are currently
identified only in interconnection studies and affected system studies?
If so, please explain how such improvements should be made? What are
the benefits and drawbacks of such an approach?
2. If study results from affected systems are significantly
delayed, and the interconnection customer is required to proceed in the
process without affected system study results, should the customer
still be responsible for the full cost of an affected system upgrade?
Should there be a time after which the affected system has ``lost its
chance'' to have the interconnection customer be responsible for the
network upgrade? If so, how would the affected system then address the
need for the network upgrade?
3. How should costs be allocated among affected system and host
system interconnection customers in instances where a major network
upgrade on a transmission provider's system is only identified through
an affected system study and not identified in the host system studies?
Should host system interconnection customers be responsible for any
portion of those network upgrade costs? Should an interconnection
customer needing such an affected system upgrade have the ability to
challenge the assignment of network upgrade costs? Please also discuss
this issue specifically in the context of the Cooper South constraint
in SPP.
4. Should the host system and affected system be required to
conduct a ``least-cost alternative'' analysis for identified affected
system upgrades? If so, please explain how that will improve the issues
with affected systems.
5. If the same network upgrade is required by interconnection
requests on both a host system and an affected system, is there cost
sharing among the interconnection customers? Does this cost sharing
extend to lower-queued customers, whether they are host system
customers or affected system customers?
6. How are interconnection requests made on an affected system
aligned with host system interconnection requests for the purpose of
determining queue order and cost responsibility? For instance, where
the affected system uses a cluster study approach, are interconnection
requests external to the affected system integrated into the affected
system's current cluster study with queue priority and cost
responsibility equivalent to the other interconnection requests in the
cluster?
7. Should MISO, SPP, and PJM be required to develop a network
upgrade construct that avoids a ``higher-queued'' penalty, whereby
network upgrade costs are assigned to higher-queued projects (earlier
in time) rather than to lower-queued projects (later in time)? How do
MISO, SPP, and PJM determine whether affected system interconnection
customers or host system interconnection customers are responsible for
the cost of a specific network upgrade? Please list the tariff, JOA, or
BPM provisions that may govern this process.
8. With respect to MISO, SPP, and PJM specifically, should they be
required to develop a unified approach to determine queue priority in
affected systems analysis to determine cost responsibility for network
upgrade costs?
9. Please describe whether interconnection customers that fund
network upgrades on an affected system and pursuant to an affected
system study receive transmission credits, transmission rights, or any
other consideration for funding those network upgrades on the affected
system. Please provide any tariff or other provisions that govern this
issue.
10. Please describe whether interconnection customers that fund
network upgrades on an affected system and pursuant to an affected
system study in MISO, SPP, or PJM receive transmission credits,
transmission rights, or any other consideration for funding those
network upgrades on the affected system. Please provide any tariff,
JOA, BPM or other provisions that govern this issue. Does any disparity
in approaches between MISO, SPP, and PJM impact the interconnection
customers and/or affected system study process? If so, how?
[FR Doc. 2018-08722 Filed 4-25-18; 8:45 am]
BILLING CODE 6717-01-P