Is FERC s Generator Interconnection Policy really conducive to efficient generation development?

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1 By Steven S. Garwood PowerGrid Strategies, LLC March 24, 2010

2 Is FERC s Generator Interconnection Policy really conducive to efficient generation development? Critical environment for efficient generation development: Process should provide reasonable level of schedule certainty Process should provide reasonable level of cost certainty Process should be integrated with, but not be a substitute for, overall system reliability planning In many respects, FERC s implementation of its Interconnection Policy, including allowed variations in regions of the country, significantly fail to produce an environment of business certainty. energy market 2

3 FERC Orders Od 2003, 2006 and 661 In Order 2003 (LGIP >20MW) and 2006 (SGIP <20MW), FERC required jurisdictional utilities to implement so-called Standardized Generator Interconnection ti Procedures (GIP) and Interconnection ti Agreements (GIA). Order 661 came later to address technical limitations of wind turbine technology. FERC s stated goal was to prevent undue discrimination, preserve reliability, increase energy supply, and lower wholesale prices for customers by increasing the number and variety of new generation that will compete in the wholesale electricity market. Variations in the standard d were permitted in rare circumstances by non- RTO/ISO Transmission Providers based on demonstration that variations were superior to the pro forma standard. An enormous degree of deference was granted RTOs and ISOs with regard to implementing variations to the pro forma standards. The results implementation of not-so standard GIP throughout much of the country which pose risks to generator developers in the form of uncertainty as to schedule and cost thatt threatenst achieving i the very results FERC s socalled Standard GIP were suppose to promote. energy market 3

4 Pro Forma Standard GIP Highlights Application & Queue Processing First-Come, First-Served (FC-FS) $10, Deposit + Site Control or additional $10, In-Service Date within 7-10 yrs. of Application Date Tied to Planning Horizon of Transmission Provider (TP) TP Posts Request details on OASIS Generator Interconnection ti Queue masking identity of Interconnection Customer (IC) until GIA is executed or filed at FERC Queue position dictates t order of performing studies and responsibility for new or upgraded facilities costs Scoping Meeting held within 30-days to discuss alternate POI and details for Interconnection Studies energy market 4

5 Pro Forma Standard GIP Highlights Application & Queue Processing - continued Queue Position Maintained Provided: Deposits for Interconnection Studies are made timely Study Agreements are executed timely No Material Modifications are made to Project Suspension periods not to exceed 36 months cumulatively GIA is negotiated, executed or requested to be filed with FERC unexecuted on a timely basis energy market 5

6 Pro Forma Standard GIP Highlights Application & Queue Processing - continued Interconnection Service Types Energy Resource (ER) allows IC to deliver full output of generating facility using existing firm or non-firm transmission capacity on an asavailable basis. Network Capacity Resource (NR) allows IC to be interconnected and integrated comparable to TP s own generating facilities used to serve native load, or if in an RTO/ISO with market-based congestion management, on the same basis as all other Network Resources. energy market 6

7 Pro Forma Standard GIP Highlights Material Modifications Changes to proposed generating facility that result in new request and loss of existing queue position TP has discretion to determine if proposed changes are Material Modifications during interconnection studies Explicitly allowed changes deemed not Material Modifications Prior to executing System Impact Study (SIS) Agreement - Up to 60% decrease in capacity, changes to configuration, technical parameters and transformer impedance Prior to executing Facilities Study (FS) Agreement Up to an additional 15% decrease in capacity, changes to configuration, technical parameters and transformer impedance energy market 7

8 Pro Forma Standard GIP Highlights Interconnection Studies (Individually or Clustered) Feasibility Study (FEAS) IC pays $10,000 deposit / commits to pay actual study costs TP expected to complete study in 45-days rarely accomplished Study Scope includes power flow analysis looking at thermal, voltage and short-circuit impacts, taking into account existing and prior-queued generators System Impact Study (SIS) IC pays $50,000 deposit / commits to pay actual study costs TP expected to complete study in 90-days rarely accomplished Study Scope adds stability analysis to the FEAS Study; recognizes ER vs. NR Facilities Study (FS) IC pays $100,000 deposit / commits to pay actual study costs TP expected to perform 90-day or 180-day version at IC s request rarely accomplished Study Scope to include detailed design of Network Upgrades and TP Interconnection Facilities energy market 8

9 Pro Forma Standard GIP Highlights Responsibility for Cost of new/upgraded facilities Interconnection Facilities Developer elope pays 100% Network Upgrades Developer pays 100% of facilities that would not be built but-for the need to interconnect the developer s generating facility Developer receives a refund of amounts paid for network upgrades: Via transmission service payment credits for initial 5-yrs Balance refunded regardless of transmission service payments over a period not to exceed 20-yrs for COD Refunds to include interest on un-refunded balance energy market 9

10 It Interconnection ti Queue Backlog Spawns Reforms FERC Seeks Queue Reforms December 11, 2007 FERC held a technical ca conference e ce to hear interested parties take on problems with queuing practices; TP s not processing queue within tariff time lines; Complications / delays caused by re-studies when projects withdraw Volume of requests taxing queuing process in some locales; Large number of renewable projects with expedited development schedules not able to be accommodated Implementation of new Capacity Market Rules not accommodated well energy market 10

11 Interconnection Queue Backlog Spawns Reforms FERC Seeks Queue Reforms - continued March 20, 2008 FERC issued an Order in Docket No. AD stating: These backlogs not only deprive generation developers of needed business certainty, they also undermine other important public goals. over the long term, the improved transmission planning required under Order No. 890 result in a more robust transmission system and make it easier to interconnect with the transmission system. Required all RTO/ISO to file reports on the status of their queue management practices and reforms to mitigate the queue backlog. energy market 11

12 Interconnection Queue Backlog Spawns Reforms FERC Seeks Queue Reforms continued FERC encouraged consideration to the following when developing new GIP: Use of cluster studies and allocating cost of common upgrades Cluster groups based on other attributes other than timing of request Increasing staff to perform studies, including use of consultants Eliminating the Feasibility Study Alternative basis for prioritizing queue requests such as first-ready / first served instead of first-come / first served approach Increasing requirements to obtain and maintain a queue position Impact on small projects Impact on existing requests, especially late-stage existing requests vs. future new requests energy market 12

13 ISO NE Standard GIP Highlights Pre-Queue Reforms Queue Processing based on First-Come, First-Served (FC-FS) Studies performed individually/serially, not Clustered FEAS and FS - optional Study Deposits / Timing: FEAS = $10k of est. monthly study costs / 45-days SIS = $50k or est. monthly study costs / 90-days FS = $100k or est. monthly study costs / days N0 distinction between ER & NR all are NR Interconnection Studies based on Minimum Interconnection Standard (MIS ) per FERC Order energy market 13

14 ISO NE Standard GIP Highlights Pre-Queue Reforms Continued Generator pays 100% of all Transmission Upgrades + on-going O&M with no opportunity for any refund No transmission charges for wheeling output Same Material Modification and Suspension language as Pro Forma April 2008 Queue contained 104 interconnect t requests 13,400MW energy market 14

15 ISO NE Standard GIP Highlights Queue Reforms Filed Oct / Effective Feb. 1, 2009 Most reforms related to integration of Forward Capacity Market (FCM) Rules with GIP: Distinguishes ER vs. NR (referred to as NR vs. CNR in New England) First-Cleared / First-Served Queue Processing for CNR projects Additional group studies for CNR demonstrating interconnection possible by start of FCM Capability Commitment Period and intra-zonal deliverability Additional Non-refundable Deposits and new Milestone Requirements to obtain/maintain queue position as CNR Long-Lead Facility Treatment availability energy market 15

16 ISO NE Standard d GIP Highlights ht Queue Reforms continued Other Non-FCM Reforms -increased deposits / more stringent milestones: Deposits: Application = $50k + proof of site control or add l non-refundable $10k FEAS = 100% of estimated study costs paid at execution of study agreement SIS = >100% est. study cost or $250k; or < 100% est. study cost or $50k + proof of having all Major Permits and at least $250k of At-Risk expenditures FS = >25% est. study cost or $250k; or > 100% est. 1 st mo. study cost or $100k + proof of having all Major Permits and at least $250k of At-Risk expenditures or 25% of total study costs Milestone reforms more stringent site control; insurance; payment schedules March 2010 queue 93 generator interconnect requests 18,700MW Meaningful / Effective Improvements? Distinct process for recognizing CNR vs. NR energy market 16

17 PJM Standard GIP Highlights Pre-Queue Reforms Queue Processing based First-Come, First-Served (FC-FS) within biannual Queue Submittal Windows Studies may be performed in Clusters Study Deposits / Time (Study costs allocated among clustered projects) FEAS = $10k / days beginning as close of window,.i.e. 8-9 months SIS = $50k / days FS = >$100k or est. 3-months study costs / no specified time to complete Distinction between ER & NR by requiring demonstration of deliverability for NR energy market 17

18 PJM Standard GIP Highlights Pre-Queue Reforms Continued Generator pays 100% of all Transmission Upgrades + Interconnection Facilities (IF) and on-going IF-related O&M with no opportunity for any refund Upgrade Costs allocated on stand-alone basis based on Queue Position No transmission charges for wheeling output Material Modification similar to Pro Forma but allows up to > 20% or 50MW capacity decrease up to execution of interconnect agreement Suspension language same as Pro Forma Use of Interim Interconnection and Construction Services Agreements used to expedite process April 2008 queue 360 generator interconnect requests - 84,164MW energy market 18

19 PJM Standard GIP Highlights Queue Reforms Developed in response to the Dominion Settlement Agreement in Docket No. EL08-36 involving capacity rights of an existing Generating Facility Increased Queue Submittal Windows from 2 per year to 4 per year Increased Deposit Requirements: At Request / FEAS = Initial $100-$200/MW up to $100k + Base $10k-$30k non- refundable. Study to be completed 90-days after close of submittal window SIS = $50k non-refundable + >$100-$300/MW; less for <20MW; study to commence 6-months after close of submittal window and completed in 120-days. (Non-Refundable amounts become refundable if SIS 60-days late) FS = $100k refundable; less for <20MW. Est. time to complete = 180-days Mandatory Scoping Meetings explicitly waive, hold or be terminated Projects not ready to proceed may opt out and be studied in next Queue Window energy market 19

20 PJM Standard GIP Highlights Queue Reforms Continued Network Upgrade Cost Allocation: excluding stability-related upgrades, and upgrades <$5 million, allocated among all Clustered Projects based on distribution factors (DFAX) >$5 million based first on queue position, then on DFAX for stability determined in Facilities Study on individual project basis cost reallocation of prior queue-related upgrades limited it to upgrades > $5 million and not more than 5-yrs from date of ISA for project first identified Current queue 408 generator interconnect requests 94,315MW Meaningful improvements? Additional queue submittal windows Partial refund of study funds for late SIS completion Limit on new projects being allocated cost of prior upgrades energy market 20

21 SPP Standard GIP Highlights Pre-Queue Reforms Queue Processing based First-Come, First-Served (FC-FS) Studies performed individually/serially, not Clustered Application & Study Deposits / Time Application = $10k + proof of site control or add l $10k FEAS (Optional) = $10k / 45-days per tariff; actual experience is 5-7 months SIS = $50k / 90 days per tariff; actual experience 6 months or more FS = >$100k or est. monthly study costs / days Distinction between ER & NR by requiring demonstration of deliverability for NR energy market 21

22 SPP Standard GIP Highlights Pre-Queue Reforms Continued Generator pays 100% of all Transmission Upgrades + and Interconnection Facilities (IF) and on-going IF-related O&M Upgrade Costs allocated on stand-alone basis based on Queue Position Transmission Service (TS) required for delivery of output Network Upgrade costs reimbursed via TS Credits for initial 5-yrs with balance refunded regardless of TS Credits within 20-yrs. Material Modification and Suspension same as Pro Forma April 2008 queue 106 generator interconnect requests 26,811MW. 94 were wind projects totaling 24,473MW June 2009 queue 255 generator requests-57,000mw, 50,000MW of which were wind. energy market 22

23 SPP Standard GIP Highlights Queue Reforms Sept. 09 SPP implemented transitional MW Segment Cluster Studies to clear back log prior to implementation of other/permanent reforms Two 15,000MW Clusters Upgrade costs allocated pro rata within each cluster without regard to queue position Permanent Reforms filed June 1, 2009 include: Fast-track option for qualifying projects Stringent suspension provisions Increased Deposit Fees New 4-Tier Study Queue including a preliminary queue and non-binding technical analysis option for speculative projects Project Readiness Milestones required to enter final queue energy market 23

24 SPP Standard GIP Highlights Queue Reforms Continued Fast-Track Option First-Ready, First Served (FR-FS) FS) Suspensions limited to 18-months, significant financial security for construction of shared network upgrades without delaying construction Permanent Adoption of Cluster Studies as the norm 4-Tier Study Queue: Interconnection Feas Study Queue (IFS Queue) - Optional / 90-day submittal window /lowest priority queue / Queue Priority within IFS Queue based on FC/FS. No re-studies for withdrawal al Preliminary Interconnection SIS Queue (PISIS Queue) Optional / 180-day window submittal / Queue priority within PSIS Queue based on FR-FS; Priority > IFS < DISIS. No re-study for withdrawals Definitive Interconnection SIS Queue (DISI Queue) - mandatory milestones / superior queue priority to IFS or PISIS / FR-FS priority within DISIS Queue Definitive Interconnection FS (DIFS) same mandatory milestones and queue priority as DISIS energy market 24

25 SPP Standard d GIP Highlights ht Queue Reforms Continued Application & Study Deposits / Time: Application Request = $10k + proof of site control or move to IFS Queue IFS Queue = $10k / 90-days for requests submitted in same 90-day window PISIS = Proof of Site Control + $40k (<100MW); $60k (>100<800MW); $90k (>800MW). study to commence 6-months after close of submittal window and completed in 120-days. (Non-Refundable amounts become refundable if SIS 60-days late) DISIS = Proof of Site Control & Adequacy + $75k (<75MW) $150k (>75MW); Deposit set at 2X cost and non-refundable if withdrawn day submittal window and 120-day study period Facilities Study (FS) = Additional security covering cost of Network Upgrades; Est. time to complete: draft reports 90-days; final reports: 8- months Study cost allocation: 50% per project / 50% pro rata MWs energy market 25

26 SPP Standard d GIP Highlights ht Queue Reforms Continued Current Queue updated March 12, 2010 shows the Active Queue containing 232 requests totally more than 41.5 GW of which 189 are wind projects totaling 33.2 GW. Eliminating those that state they are in commercial operation, total t requests decline to about 182 requests and 30.1 GW energy market 26

27 And How About MISO MISO filed its proposed GIP Queue Reforms June 26, 2008 in Docket No. ER which FERC approved effective August 25, MISO s new GIP adopted many of FERC s suggested changes. Results to-date continuing uncertainty in terms of scheduling, network upgrades required, and cost responsibility. Case in point Group 5 transitional group 37 projects totaling over 2,765MW (originally a few have withdrawn) So-called FINAL SIS published Oct. 2007; many additional studies followed with last Facilities Study just recently completed No projects yet connected / none, if any, likely to for years to come Group 5 studies used for purpose of larger regional system planning Cost allocation changed mid-stream poses significant cost increases $700 million 220 mile 345kV line allocated to 19 generators at last minute No workable solution in sight. FERC yet to provide any useful, meaningful guidance. energy market 27

28 MISO Standard d GIP Highlights ht Queue Reforms MISO Queue reforms included: d First-ready / first served prioritization Increased requirements to obtain and maintain queue position, i.e. higher deposits (including significant non-refundable portions) and additional milestones which must be strictly adhered to Cluster Study groups no longer based solely on queue position timing/order. Qualitative Feasibility Studies for determining queue processing Possible Fast-Track based on Feasibility Study Results Introduction of Temporary Interconnection Agreement Refinements to Material Modification provisions Limited opportunity for Suspensions Eliminated distinction of Generators < / > 20MW energy market 28

29 MISO Standard d GIP Highlights ht Queue Reforms Continued MISO s GIP revised to include 4 new distinct t phases: 1. Pre-Queue Phase voluntary pre-application session with MISO to understand GIP, understand obligations, how to complete application. 2. Application Review Phase MISO determines whether application is complete; once complete initial queue position is established and initial screening-level Feasibility Study including up to 3 POIs, is scheduled. 3. System Planning & Analysis Phase (SPA) Initial System Impact Study is performed during this phase likely to be a Cluster Study. Depending on Feasibility Study results, projects could skip SPA Phase. 4. Definitive Planning Phase (DPP) Re-studies of System Impact Studies and Facilities Studies are performed during this phase. Optional Study available to developers prior to submitting a formal application. energy market 29

30 MISO Standard d GIP Highlights ht Queue Reforms Continued Queue Position Prioritization: iti Initial queue position based on time of completed application Determines order in which Feasibility Studies are performed After Feasibility Study, queue processing / prioritization is based on Feasibility Study Results and achievement of Milestones Cluster System Impact Studies (SIS): Initial i SIS performed during SPA Re-study of SIS performed during DPP Generators included based on relative electrical proximity and initial queue position Withdrawn generators may be replaced with other similar generators pending in the queue but not yet included in an SIS, with unspent deposit of withdrawn generator being used to off-set study costs energy market 30

31 MISO Standard d GIP Highlights ht Queue Reforms Continued New Deposit Requirements Two Deposits are now required; one at time of Application and another at the time of entering the DPP (prior procedures required 4-deposits) Deposits include significant non-refundable amounts and are based on maximum capacity of proposed generating project Application Deposit 0-5MW $15k 6-20MW $25k 21-50MW $35k MW $65k MW $95k > 1000MW $125k Incl. Non-Refundable $5k Application Fee Additional $100k required w/o site control DPP Deposit based on 2X Study Cost w/ excess forfeited upon withdrawal from queue, or used to support construction. DPP Deposit 0-5MW $55k 6-20MW $125k 21-50MW $185k MW $275k MW $325k MW $425k MW $535k > 1000MW $645k energy market 31

32 MISO Standard d GIP Highlights ht Queue Reforms Continued New Milestone Requirements new GIP includes new mandatory Milestones which must be achieved in order to advance through the various phases of the GIP. M1 Milestones during Application Phase M2 Milestones at fist stage of DPP M3 Milestones at second stage of DPP New Milestones include Technical, Non-Technical and Financial. Financial Milestones are in addition to Deposits. energy market 32

33 MISO Standard d GIP Highlights ht Queue Reforms Continued MI Milestones for Application to be complete, all of the following Technical Milestones must be achieved / satisfied: M1 Technical Milestones Generic Study Model Point of Interconnection (POI) Impedance from collector substation to POI Technical data to run studies One-line diagram Generator output (MW) Step-up transmission data Simplified stability model. Location of the POI in study model. Impedance of radial line from GSU to POI. Data to run studies, i.e. sequence impedance, generator reactance, saturation curve, etc. (as applicable). Diagram of Generating Facility showing Interconnection Facilities and POI. Seasonal Gross and Net MW output Specs. of the GSU energy market 33

34 MISO Standard GIP Highlights Queue Reforms Continued M2 Milestones Definitive Planning Entry Milestones. Customer must meet all of the technical milestones, plus any two of the non-technical milestones. M2 Technical Milestones Detailed Stability Model Definitive Point of Interconnection (POI) Definitive one-line diagram Actual stability model. Final opportunity to select final POI. Any subsequent material changes will resulting in withdrawal. Definitive Generator output (MW) Any subsequent material changes will resulting in withdrawal. energy market 34

35 MISO Standard GIP Highlights Queue Reforms Continued M2 Milestones Milestones needed for SPA and Definitive Planning Phase Entry. Customer must meet all of the technical milestones, plus any two of the non technical milestones. (Continued) M2 Non-Technical Milestones (meet any two or their substitutes at Definitive Planning Entry) Primary M2 Milestones Proof that Turbines are on order Proof of submission of all required permits Approval of State Regulatory Commission Board Approval or approval of highest level of approval authority per its governance M2 Deposit (D2) Substitute M2 Milestones Deposit or LOC = 1-month transmission charge due at SPA (Refundable upon M3 Milestones or Withdrawal Deposit or LOC = 1-month transmission charge due at SPA (Refundable upon M3 Milestones or Withdrawal Deposit or LOC = 1-month transmission charge due at SPA (Refundable upon M3 Milestones or Withdrawal Deposit or LOC = 1-month transmission charge due at SPA (Refundable upon M3 Milestones or Withdrawal NA energy market 35

36 MISO Standard d GIP Highlights ht Queue Reforms Continued M3 Milestones Milestones needed for continuing Definitive Planning Phase. Customer must initially meet one of the three non-technical milestones. There are no Technical Milestones in M3. M3 Non-Technical Milestones (meet any one at initial M3 submission). Financial Security Deposit or LOC = est. cost of Network Upgrades (Refundable upon execution of GIA) Executed PPA or Office Attestation Execution of PPA or statement of officer attesting that Generating Facility is included in state resource adequacy plan Turbine Order Demonstration that turbines have been ordered energy market 36

37 MISO Standard GIP Highlights Queue Reforms Continued Suspensions New GIP include limited opportunity for Suspensions Suspensions permitted for Force Majeure only Non-refundable deposit equal to greater of cost of Network Upgrades or $5M Network Upgrade engineering / construction will continue on schedule unless a regulatory order states otherwise energy market 37

38 MISO Standard GIP Highlights Queue Reforms Continued To deal with Common Use Upgrades (CUU) MISO introduces new Multi- Party Facility Construction Services Agreement (MPFCA) Contract for construction and payment of CUU Parties include MISO, TO responsible for construction of CUU and all generators deemed responsible for need and cost of CUU Generators must execute MPFCA or are terminated t Generators must provide financial security covering their respective total cost responsibility for CUU at least 30-days prior to TO s need for funds If Generators withdraw/terminate, costs shift to remaining generators Withdrawing/terminated generators lose deposit/financial security unless cause for withdrawal is due to cost increase > 25% energy market 38

39 MISO Standard d GIP Highlights ht And the Uncertainty / Unworkable continues July 2009 MISO filed interim i revised generator interconnection- ti related network upgrade cost allocation which FERC approved Oct Prior methodology allocated 50% of network upgrades to generators serving load in MISO, except for ATC/ITC network upgrades which were fully refunded; New methodology allocates generator interconnection-related network upgrades as follows: 90% for network upgrades > 345kV 100% for network upgrades < 345kV Interim method in effect until July 2010 when MISO is required to file new proposal for permanent methodology Premise of need for new method is threat of OTP and MDU withdrawing from MISO due to prior cost allocation method energy market 39

40 MISO Standard d GIP Highlights ht And the uncertainty / unworkable continues FERC approved interim solution without evidence to support that OTP s and MDU s costs would be reduced as stand-alone utilities MISO and several committees working to develop new methodology that goes beyond interconnection costs, and includes transmission service rate design Main themes/debates should generators pay on-going transmission charges and how to ensure the right load pays for costs allocated to load What facilities costs should be in a Regional / Sub-regional/Local rate MISO seems intent on proposing an Injection-Withdrawal methodology despite independent market report noting negative impacts to market efficiencies from proposal Generators favor Highway/Byway method under consideration in SPP energy market 40

41 SO Much for Standardization Conclusions: FERC s implementation of GIP in RTO/ISOs has resulted in not-so standard GIP Queue Reforms have not been very effective at meeting objectives Reforms appear to focus more on creating / increasing barriers to entry Some RTO/ISO GIP seem to work better than others There are some real challenges ahead for generation development in MISO due to business uncertainty and signs of potentially higher cost for transmission access FERC, State Commissions and ISO s need to understand that business certainty is critical to a vibrant and efficient market for generation development to occur energy market 41

42 For further information contact: Steven S. Garwood PowerGrid Strategies, LLC (207) or energy market 42