Transcript Proposed Revisions to Large Generator Interconnection

Large Generator
Interconnection Procedures
Reform
2nd Stakeholder Meeting
May 5, 2009
Agenda
• Background
• Review of Overall Process and
Discussion of Comments
• Proposed Schedule
May 5, 2009
2
February Proposal
• Most of the changes adopted in January 2009
were retained.
• Interconnection process based on Load and
Resource Study and related Transmission
Study.
• New options for determining Network
Upgrades.
• Biannual Interconnection Request Windows.
May 5, 2009
3
February Proposal
• Queue Management:
– First Come-First Served through the System
Impact Study;
– First Ready-First Served after the System
Impact Study.
• Multiple Customer options for proceeding
to Facilities Study.
May 5, 2009
4
$250,000 Study Deposit for >75 MW Projects
OR,
$125,000 Study Deposit for ≤ 75 MW Projects
Customer
LGIA
Defer up to
1 year
(Includes $25,000 non-refundable for both
generation levels)
SIS
Review
Proof of 50% site control at time of application
Review
Published
Load &
Resource
Transmission
Study
100% Site
Control
Required
Attend
Information
Session at
Beginning
of IR
Application
Window
A
SIS Scoping
Meeting
Submit IR
B
Customer will
have access
to Base Case
Data and may
perform own
Optional
Feasibility
Studies
Two month
windows to
submit
application.
IR Applications
reviewed on
semi-annual
basis.
Three levels of
generation allowed
and specified for
study at time of
meeting
C
SIS
After power
flow portion
of SIS,
customer is
must select
one
generation
level
IC Facilities
& Unit
Specific
Network
Upgrades
(with cost
estimates)
and
FS
Scoping
Meeting
Verify
50% of
Site
Control
Customer
Shows
Designation
as Network
Resource &
submits
deposit
D
At Risk
Path
Customer submits
deposit & TSR or
proceeds at own
risk
TSR
Path
Network
Upgrade
Studies
Facilities
Study
Customer
Review Published
Load & Resource
Transmission Study
A
Attend Information
Session at beginning
of IR Application
Window
Customer will have access to
Base Case Data and may
perform Optional Feasibility
Studies
$250,000 Study Deposit for >75 MW Projects
OR,
$125,000 Study Deposit for ≤ 75 MW Projects
(Includes $25,000 non-refundable for both generation levels)
Proof of 50% site control at time of application
Submit IR
Two-month windows to submit application
IR Applications reviewed on semi-annual basis.
B
SIS Scoping
Meeting
Three levels of generation
allowed and specified for
study at time of meeting
SIS
After power flow portion
of SIS, customer is
asked to select one
generation level
IC Facilities and
Unit-Specific
Network
Upgrades
C
LGIA
Defer up to 1 year
SIS Review (with cost
estimates) and
FS Scoping Meeting
Verify
50% of Site Control
Customer deposits 50% of
IC Facilities and unit-specific
Network Upgrades money
and submits TSR or
proceeds at own risk
D
Customer shows
designation as Network
Resource & deposits
50% of IC Facilities &
unit-specific Network
Upgrades money
At Risk
Path
Network
Upgrade
Studies
TSR
Path
Facilities
Study
Network Resource Path
• Network Customers submit Annual Load and
Resource Plan.
• Tri-State prepares Load and Resource Plan and
related Transmission Plan.
– Resource Zones identified
– Network Upgrades identified
– Tri-State funds the cost of Network Upgrades
• Customer demonstrates that it is a planned
Network Resource within Resource Zone.
May 5, 2009
10
Network Resource Path
• Facilities Study includes:
– Interconnection Facilities
– Unit-specific Network Upgrades required to interconnect
the facility
• Example: Ring Bus at Interconnection Substation is considered a
Network Upgrade
• Interconnection Customer will fund Interconnection
Facilities and unit-specific Network Upgrades.
• Interconnection Customer will receive transmission
credits for Network Upgrades.
May 5, 2009
11
LGIA
Defer up to 1 year
SIS Review (with cost
estimates) and
FS Scoping Meeting
Verify
50% of Site Control
Customer deposits 50% of
IC Facilities and unit-specific
Network Upgrades money
and submits TSR or
proceeds at own risk
D
Customer shows
designation as Network
Resource & deposits
50% of IC Facilities &
unit-specific Network
Upgrades money
At Risk
Path
Network
Upgrade
Studies
TSR
Path
Facilities
Study
Transmission Reservation Path
• Customer’s Generating facility is not a
Network Resource within a Resource Zone.
• Customer requests transmission under TriState’s Open Access Transmission Tariff.
• Tri-State performs Transmission System
Impact Study.
– Identifies Network Upgrades required to deliver
power across the system, not unit-specific
Network Upgrades.
May 5, 2009
13
Transmission Reservation Path
• Interconnection Facilities Study:
– Studies Interconnection Facilities and unit-specific
Network Upgrades.
– Incorporates results of Transmission System Impact
Study Interconnection Customer funds Network
Upgrades.
• Interconnection Customer will fund
Interconnection Facilities and unit-specific
Network Upgrades.
• Interconnection Customer will receive
transmission credits for Network Upgrades.
May 5, 2009
14
LGIA
Defer up to 1 year
SIS Review (with cost
estimates) and
FS Scoping Meeting
Verify
50% of Site Control
Customer deposits 50% of
IC Facilities and unit-specific
Network Upgrades money
and submits TSR or
proceeds at own risk
D
Customer shows
designation as Network
Resource & deposits
50% of IC Facilities &
unit-specific Network
Upgrades money
At Risk
Path
Network
Upgrade
Studies
TSR
Path
Facilities
Study
At-Risk Path
• Customer’s Generating facility is not a Network
Resource within a Resource Zone.
• Customer chooses not to request transmission.
• Interconnection Facilities Study:
– Studies Interconnection Facilities and unit-specific
Network Upgrades
• Interconnection Customer will fund Interconnection
Facilities and unit-specific Network Upgrades.
• Interconnection Customer will receive transmission
credits for Network Upgrades.
• Customer may use transmission system on an as-is
basis, at its own risk for deliverability.
May 5, 2009
16
Facilities Study Deferral
• If Customer has not met all Facilities Study
requirements, it may request one-time delay of up to
1 year.
• When Customer is ready for Facilities Study, it is
scheduled behind any other request that has
previously met Facilities Study milestones.
– First Ready First Served
• Tri-State will use the original System Impact Study
but may be required to update the study to reflect
system changes during the deferral period.
May 5, 2009
17
$250,000 Study Deposit for >75 MW Projects
OR,
$125,000 Study Deposit for ≤ 75 MW Projects
Customer
LGIA
Defer up to
1 year
(Includes $25,000 non-refundable for both
generation levels)
SIS
Review
Proof of 50% site control at time of application
Review
Published
Load &
Resource
Transmission
Study
100% Site
Control
Required
Attend
Information
Session at
Beginning
of IR
Application
Window
A
SIS Scoping
Meeting
Submit IR
B
Customer will
have access
to Base Case
Data and may
perform own
Optional
Feasibility
Studies
Two month
windows to
submit
application.
IR Applications
reviewed on
semi-annual
basis.
Three levels of
generation allowed
and specified for
study at time of
meeting
C
SIS
After power
flow portion
of SIS,
customer is
must select
one
generation
level
IC Facilities
& Unit
Specific
Network
Upgrades
(with cost
estimates)
and
FS
Scoping
Meeting
Verify
50% of
Site
Control
Customer
Shows
Designation
as Network
Resource &
submits
deposit
D
At Risk
Path
Customer submits
deposit & TSR or
proceeds at own
risk
TSR
Path
Network
Upgrade
Studies
Facilities
Study
Proposed Schedule
• May 15th—Tri-State will post draft LGIP.
• June 12th —Comments due on draft LGIP.
• 30 days prior to Effective Date—post final LGIP
on OASIS.
• Late Summer 2009—LGIP is effective.
• 30 days after Effective Date—publish Load and
Resource Transmission Study.
May 5, 2009
19
Addendum
• Summary of Comments and Tri-State
responses
May 5, 2009
20
Key Comments and Responses
• Feasibility Studies—elimination of Feasibility
Study has negative impact on applicants —
Establish Pre-Application Queue process and
make Feasibility Study optional.
• Experience for Tri-State is that Feasibility
Studies provide little value.
• Encourage applicants to conduct own screening
studies using available WECC base-case data.
May 5, 2009
21
Key Comments and Responses
• Deposits—request for reduced, staged deposits:
$40,000 to $90,000
• Tri-State deposits are intended to cover the estimated
cost of Interconnection Studies and administration
costs.
– The suggested deposits will not cover study costs.
– $25,000 will be non-refundable
• The deposits will be used for study costs plus cost of
administering requests.
May 5, 2009
22
Key Comments and Responses
• Site Control—requirements are too burdensome
and too soon in the process.
• Site Control is key to assessing the validity of
interconnection requests.
– Retain existing requirement for 50% of site control at
application.
– Delay 100% site control until execution of LGIA.
• Strict site control requirements benefit both TriState and Interconnection Customers by helping to
identify valid projects.
May 5, 2009
23
Key Comments and Responses
• Site Control—continued
Tri-State expectations: At application Tri-State
expects the application to include documentation
of lease or ownership rights as along with a GIS
map of the entire site with the areas under
contract or option highlighted on the map.
Documentation would typically include copies of
leases, deeds, or option agreements, which TriState will treat as confidential information.
May 5, 2009
24
Key Comments and Responses
• Cluster Studies will be more effective than standalone studies proposed by Tri-State.
• Tri-State does not agree that cluster studies will be
more effective way of studying Interconnection
Requests.
• However, Tri-State has retained the right to use
cluster studies where it determines that they may
be a more efficient way of studying
Interconnection Requests.
• Tri-State is prepared to discuss this issue as part of
the stakeholder process.
May 5, 2009
25
Key Comments and Responses
• Interconnection Studies should be linked to LongRange Transmission Planning.
• Tri-State will continue to use WECC base-cases
modified to meet the needs of the Interconnection
process.
– Facilities identified in long range plans are often
scheduled after the generators’ in service date.
– Long-Range projects do not have CPCNs and can not
be counted out for planning Network Upgrades.
May 5, 2009
26
Key Comments and Responses
• Suspension—Tri-State should expand ability to
suspend construction—developers need more
flexibility.
• Suspension undermines certainty of planning process.
• Customer has the ability to delay in-service date up to
5 years, but construction will proceed if it affects other
requests.
• Option to delay Facilities Study for up to one year.
May 5, 2009
27
Key Comments and Responses
• Proposal is discriminatory and may violate FERC
Order 2003
• Tri-State, as a non-jurisdictional, is subject to
limited FERC jurisdiction
– Tri-State must meet FERC’s comparability and nondiscrimination requirements
– Tri-State’s proposal meets those thresholds
• Tri-State proposes 3 paths for interconnection.
– The paths are not intended to be equivalent but to
provide customers options to interconnect
May 5, 2009
28