Responding to a complaint filed by EDF Renewable Energy Inc., the Federal Energy Regulatory Commission on Feb. 2 said that it will hold a technical conference to examine interconnection coordination issues involving the Midcontinent Independent System Operator, the PJM Interconnection and the Southwest Power Pool.
In October 2017, EDF Renewable Energy filed a complaint at FERC (Docket No. EL18-26) against MISO, SPP and PJM.
EDF is engaged in the development, ownership, and operation of large scale wind, biomass, solar, and biogas generation and distributed energy and energy storage systems. It has proposed generation pending in the interconnection queues of MISO, SPP, PJM, and other regional transmission organizations.
In its complaint, EDF asked FERC to order MISO, SPP and PJM to file revisions to their respective open access transmission tariffs and joint operating agreements in order to reform their interconnection coordination procedures with “Affected Systems” that are also RTOs.
In its Feb. 2 order, FERC notes that an Affected System is an electric system other than the transmission provider’s transmission system that may be affected by a proposed interconnection. If a generator seeks to interconnect to the grid in the MISO region, for example, PJM might be an Affected System.
FERC Orders 2003, 2003-A
In Order No. 2003, FERC required utilities that own, control or operate facilities used for transmitting electric energy in interstate commerce to amend their tariffs to include interconnection procedures and an interconnection agreement for electric generating facilities having a capacity of more than 20 megawatts. Order No. 2003 requires the transmission provider to coordinate interconnection studies and planning meetings with Affected Systems.
The commission found that, although the owner or operator of an Affected System is not bound by the provisions of another transmission provider’s Large Generator Interconnection Procedures (LGIP) or Large Generator Interconnection Agreement (LGIA) adopted in Order 2003, a transmission provider evaluating a proposed generator interconnection must allow any Affected System to participate in the process when conducting the interconnection studies and incorporate the legitimate safety and reliability needs of the Affected System.
In Order No. 2003-A, the commission further held that the results of any study of the effect of an interconnection on any Affected System must be included in the interconnection study “if available,” which allows the interconnection process to proceed even in the face of delays or non-response by the Affected System.
MISO, PJM and SPP coordination
MISO, SPP, and PJM are Commission-approved RTOs and transmission providers under Order No. 2003. Each RTO’s tariff identifies the requirement for the host RTO to coordinate with neighboring RTOs that are Affected Systems. MISO and PJM business practice manuals include additional information on coordination with Affected Systems.
The RTOs have also entered into Joint Operating Agreements (JOAs) that outline the coordination and exchange of data and information between the RTOs.
For example, the MISO-PJM JOA and the MISO-SPP JOA state that each party will coordinate with the other the conduct of any studies required in determining the impact of a request for generator or merchant transmission interconnection and further require the RTOs to “coordinate and mutually agree on [the] nature of studies to be performed to test the impacts of the interconnection on the potentially impacted [p]arty.”
EDF cites lack of detail
In its complaint, EDF argued that there is a lack of adequate detail in the MISO, SPP, and PJM tariffs, MISO-SPP JOA, and MISO-PJM JOA regarding:
- The timing for RTOs to complete Affected Systems analyses;
- The standard the Affected System applies to determine impacts from proposed generation interconnecting in the host RTO; and
- How network upgrade costs are assigned between proposed generation connecting in the host RTO versus the Affected System RTO.
EDF said that this lack of clarity impedes the ability of a proposed generation developer to assess the commercial viability of its project, which EDF contends is contrary to the Commission’s requirement that a transmission provider apply transparent open access interconnection service procedures and FERC’s purpose for establishing pro forma generation interconnection processes.
FERC noted in its order that EDF provided examples mainly from its experience with MISO and SPP to illustrate alleged deficiencies common among MISO, SPP and PJM. EDF said that there are similar examples from recent MISO and PJM studies. Specifically, EDF asserted that some interconnection customers have encountered problems because of MISO Affected System data that were provided late to generation being studied in the PJM queue.
EDF said that Affected Systems information sent to MISO from SPP erroneously included a $38 million Affected System network upgrade to be assessed to generation projects in a MISO February 2016 West study group, even though the line SPP had listed was a transmission project that SPP had already designated as part of its Integrated Transmission Plan.
EDF argued that, although the line was removed when the issue was brought to MISO’s attention, the system impact study would have included this $38 million cost had EDF not been provided with an advance opportunity to review the Affected Systems information.
In addition, the company said it is unclear whether MISO and SPP are using the same base case models for their respective studies. EDF argues that the Affected System RTO and the host RTO should be obligated to use a consistent and up-to-date base case model and should further allow for interconnection customer involvement at an early stage.
EDF also asserted that there is no clear process by which MISO, SPP, and PJM assign network upgrade costs for interconnection projects located near the RTO seams.
Moreover, the company said that the MISO, SPP, and PJM tariffs, business practice manuals and JOAs do not disclose the modeling standard the RTOs use to determine Affected System impacts and that each RTO apparently uses a different standard.
MISO, PJM, and SPP all urged FERC to reject EDF’s complaint, arguing that EDF had not shown that the RTOs’ tariffs or rules were inconsistent with any FERC requirements addressing coordination with Affected Systems. The RTOs also argued that the issues raised by EDF should be addressed in the Commission’s pending notice of proposed rulemaking (NOPR) proceeding on generator interconnection issues (RM17-8).
FERC sets technical conference
Rejecting the RTOs’ calls to dismiss the complaint, FERC found that EDF raised a number of issues related to the Affected Systems coordination between MISO, SPP, and PJM that warrant further examination.
“The record developed thus far suggests that such issues, and the underlying need to ensure that transmission providers offer all generators interconnection service pursuant to just and reasonable terms and conditions, may warrant further clarity in the Affected Systems coordination between MISO, SPP, and PJM,” the commission said.
“We find that a technical conference is an appropriate vehicle to develop a more complete record concerning these issues and the specific reforms proposed by EDF in the complaint. Therefore, we direct Commission staff to establish a technical conference to explore these issues.”
The Commission acknowledged that the Affected System coordination issues raised in EDF’s complaint were related to issues under generic consideration in the generation interconnection NOPR proceeding. Rather than deny the complaint pending the outcome of the NOPR, however, FERC noted that commission staff at the technical conference will also consider issues related to Affected Systems coordination that were raised in response to the generation interconnection NOPR in Docket No. RM17-8.
“We find that holding a joint technical conference on Affected Systems issues identified both in this Complaint and in the Generator Interconnection NOPR will offer the Commission and interested parties the opportunity to consider specific reforms in MISO, SPP, and PJM at the same time as more generic reforms,” FERC said in the order.
In a separate notice issued by the Commission (Docket No. AD18-8), FERC said the conference will be held at Commission headquarters in Washington, D.C., on April 3-4.