FERC Filings
Request of EPSA for Clarification and Rehearing of Order No. 2003-A re: Standardization of Generator Interconnection Agreements and Procedures
Studies associated with Network Resource Interconnection Service
In Order No. 2003-A at P 545, the Commission, unfortunately, introduces some uncertainty as to what additional studies or additional upgrades might be associated with NRIS when it states:
However, we note that this provision is not intended to prevent the Transmission Provider from performing any additional studies or constructing any additional upgrades when necessary. … Thus we are adding the following sentence to Article 4.1.2.2: “The provision of Network Integration Service or firm Point to Point Transmission service may require additional studies and the construction of additional upgrades.”
In Order No. 2003, the Commission adopted the defining element of NRIS that had been developed by transmission providers and transmission customers during the ANOPR process. Specifically, the Commission noted that “once an Interconnection Customer has obtained Network Resource Interconnection Service, any future transmission service request for delivery from the Generating Facility would not require additional studies or Network Upgrades.”
The Commission went on to clarify that since Interconnection Service conveys no right to flow the output of the Generating Facility onto the Transmission System, later requests for firm point-to-point delivery service may require additional Network Upgrades. However,
with Network Resource Interconnection Service, the Interconnection Customer would be eligible to obtain Network Service under the Transmission Provider’s OATT, or network access service under the Tariff or an RTO or ISO, without the need for additional Network Upgrades.
In Order No. 2003 at P 769, the Commission explained that NRIS does not “necessarily provide the Interconnection Customer with the capability to physically deliver” power to any particular load. The Generating Facility may need to participate in redispatch or other congestion management protocols.
Now, Order No. 2003-A introduces uncertainty with respect to the rights associated with NRIS and whether the defining element of NRIS is still consistent with the policies and procedures developed in Order No. 2003. Order No. 2003-A at P 545 notes only that additional “studies and upgrades would be associated with a request for delivery service under the OATT.” EPSA urges the Commission to clarify that any additional studies or upgrades referenced in this section apply only to optional upgrades requested by the Network Customer to reduce congestion or to customer-specific delivery issues unrelated to the Generation Facility’s designation as a Network Resource. EPSA fears that the ambiguity created by Order No. 2003-A may invite Transmission Providers to routinely require studies whenever requests are made to designate NRIS generators as Network Resources and may incent transmission owners to pay insufficient attention to the requirement that the transmission system be planned to maintain the ability of NRIS generators to be designated as Network Resources.
If the Commission does not clarify that the Interconnection Customer’s exposure to additional studies and upgrades are to be limited to the circumstances described above, EPSA requests rehearing on this issue. If the Interconnection Customer is subject to restudy and to funding additional Network Upgrades any time a Network Customer seeks to designate a NRIS generator as a Network Resource, the important benefits that the NRIS product was intended to provide will be lost. Indeed, there will be no distinction between Energy Resource Interconnection Service (ERIS) and NRIS, except that NRIS generators will likely be required to fund more Network Upgrades initially, while also being subject, like ERIS generators, to further study and upgrade costs if a later request is made to designate it as a Network Resource.
The importance of maintaining the integrity of the NRIS product cannot be overstated. The NRIS product was the centerpiece of the ANOPR process and transmission providers and interconnection customers worked hard to deal with the central issue of how to define the product. If the Commission unravels this essential product now, all the progress that has been achieved in the almost three years since the Commission directed the parties to develop an NRIS product with these very same elements will be undone. In the ANOPR Best Practices, Transmission Providers were required to offer generators multiple interconnection products. Specifically, the generator was to be offered Capacity Resource, a forerunner to NRIS. The ANOPR noted:
The Transmission Provider must conduct the necessary studies and construct the network facilities needed to integrate the Generator’s facility in a manner comparable to that in which the Transmission Provider integrates its generating facilities to serve native load customers.
The Commission should also require Transmission Providers to include in their compliance filings the protocols and procedures they would use to determine when additional studies or upgrades are needed. The Commission expressly recognizes that not all Transmission Providers apply the same procedures or reliability criteria in their studies of NRIS. The Commission should require Transmission Providers to include in their compliance filings the protocols, procedures, criteria and assumptions to be used in their studies so that parties can evaluate whether those procedures are “consistent with or superior to” the requirements of the Order and the OATT and bring their concerns about flawed protocols and procedures to the Commission’s attention.