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ISO-NE PUBLIC
J U L Y 2 4 , 2 0 1 8 | W E S T B O R O U G H , M A
Al McBride
Reform of Generator Interconnection Procedures and Agreements
FERC Order No. 845 Compliance
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D I R E C T O R , T R A N S M I S S I O N S T R A T E G Y & S E R V I C E S
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• On April 19, 2018, the Federal Energy Regulatory Commission (“Commission”) issued Order No. 845, its Final Rule on Reform of Generator Interconnection Procedures and Agreements – Compliance filings directed in Order No. 845 are due on or before
November 5, 2018
• At the May 24, 2018 and June 19, 2018 Transmission Committee (TC) meetings, ISO-NE discussed the background on Order No. 845, the compliance requirements associated with the Order, and how ISO-NE proposes to comply with the Order
• At this meeting, ISO-NE will present the first draft of the Tariff redlines that are proposed to comply with the Order
FERC Order No. 845 Compliance: Generator Interconnection
Proposed Effective Date: Upon FERC approval of ISO New England’s Compliance Filing (Compliance Filing is required by November 5, 2018)
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Summary of Order No. 845 Reforms Improving certainty in the interconnection process
• To improve certainty in the interconnection process, the Final Rule: 1. Removes the limitation that interconnection customers may only exercise the
option to build a transmission provider’s interconnection facilities and stand-alone network upgrades in instances when the transmission provider cannot meet the dates proposed by the interconnection customer; and
2. Requires that transmission providers establish interconnection dispute resolution procedures that allow a disputing party to unilaterally seek non-binding dispute resolution.
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Summary of Order No. 845 Reforms Promoting more informed interconnection decisions
• To promote more informed interconnection decisions, the Final Rule:
3. Requires transmission providers to outline and make public a method for determining contingent facilities;
4. Requires transmission providers to list the specific study processes and assumptions for forming the network models used for interconnection studies;
5. Revises the definition of “Generating Facility” to explicitly include electric storage resources; and
6. Establishes reporting requirements for aggregate interconnection study performance.
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Summary of Order No. 845 Reforms Enhancing the interconnection process
• To enhance the interconnection process, the Final Rule: 7. Allows interconnection customers to request a level of interconnection
service that is lower than their generating facility capability; 8. Requires transmission providers to allow for provisional interconnection
agreements that provide for limited operation of a generating facility prior to completion of the full interconnection process;
9. Requires transmission providers to create a process for interconnection customers to use surplus interconnection service at existing points of interconnection; and
10. Requires transmission providers to set forth a procedure to allow transmission providers to assess and, if necessary, study an interconnection customer’s technology changes without affecting the interconnection customer’s queue position.
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Roadmap of Affected Tariff Provisions 1. Option to Build:
– LGIA Art. 5 and Appendix B
2. Dispute Resolution: – LGIP § 13.5
3. Contingent Facilities: – LGIP §§1 and 3.8 – LGIA Art. 1 and Appendix A
4. Study Processes and Assumptions: – LGIP § 2.3
5. Generating Facility Definition: – LGIP § 1 and Appendix 1 (IR Form) – LGIA Art. 1
6. Reporting Requirements for Aggregate Study Performance: – LGIP §§ 3.5, 3.6, 6.1, 7.2, and 8.1
7. Interconnection Service below Generating Facility Capability: – LGIP §§ 3.1, 4.4.1, 6.3, 7.3, 8.2, and Appendix 1 (IR Form)
8. Provisional Service: – LGIP § 1 – LGIA Art. 1 and 5.9
9. Surplus Interconnection Service: – LGIP § 1, 3.3, and Attachment C to Appendix 1 (IR Form) – LGIA Art. 1
• Additional revisions have been made in LGIP § 5.1 and 5.2 to reflect Effective Date and Transition
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REFORM #1 – OPTION TO BUILD Tariff Language
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LGIA Section 5.1 & 5.2 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #2 – DISPUTE RESOLUTION Tariff Language
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #3 – CONTINGENT FACILITIES Tariff Language
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Definition Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.8 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.8, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #4 – STUDY PROCESSES AND ASSUMPTIONS Tariff Language
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LGIP Section 2.3 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 2.3, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #5 – GENERATING FACILITY DEFINITION TO INCLUDE STORAGE Tariff Language
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Definition Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Appendix 1 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
Will the Generating Facility include electric storage capacity? Yes ___ No ___
If yes, describe the electric storage device and specifications:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
Provide the maximum output of each generator including each electric storage device: __
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REFORM #6 – REPORTING REQUIREMENTS FOR AGGREGATE STUDY PERFORMANCE Tariff Language
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LGIP Section 3.5.2 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
3.4.4
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.5.2, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 6.1, 7.2, and 8.1 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #7 – INTERCONNECTION SERVICE BELOW GENERATING FACILITY CAPABILITY Tariff Language
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LGIP Section 3.1 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.1, continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 4.4.1 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 7.3 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section Appendix 1 (IR Form) Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #8 – PROVISIONAL INTERCONNECTION SERVICE Tariff Language
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Definitions Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIA Section 5.9.2 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #9 – SURPLUS INTERCONNECTION SERVICE Tariff Language
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Definitions Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.3 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.3 continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.3 continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.3 continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Section 3.3 continued Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Attachment C to Appendix 1 Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Attachment C to Appendix 1, continued
Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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LGIP Attachment C to Appendix 1, continued
Yellow highlighted text denotes deviation from FERC Pro Forma, where FERC has prescribed the language to be adopted
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REFORM #10 – EVALUATION OF TECHNOLOGY CHANGES Tariff Language
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No Tariff Change Proposed
• The ISO-NE interconnection process already allows for the evaluation of technology changes through the pre-System Impact Study true-up process and the 10 day material modification review window
• These provisions were developed in the 2016 New England interconnection reforms and allow the same or more flexibility in accommodating technology changes as the reform proposed by the Commission
• ISO-NE will propose that the ISO-NE procedures already meet or exceed the requirements of Order No. 845
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Next Step
• Second Tariff language review at the September 18, 2018 Transmission Committee meeting
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Stakeholder Schedule
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Stakeholder Committee and Date Scheduled Project Milestone
Transmission Committee May 24, 2018
Initial discussion
Transmission Committee June 19, 2018
Additional discussion
Transmission Committee July 24, 2018
First review of proposed Tariff language
Transmission Committee September 18, 2018
Second review of proposed Tariff language
Transmission Committee October 23, 2018
Additional discussion of Tariff language and vote
Participants Committee November 2, 2018
Vote
Compliance filing will be submitted in time to meet the compliance filing deadline of November 5, 2018
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