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Monica Gonzalez

Monica Gonzalez. Senior Regulatory Counsel. Order 792 Compliance Filing. April 22, 2014. NEPOOL Transmission Committee . Presentation Objectives. Provide overview of FERC Order 792

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Monica Gonzalez

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  1. Monica Gonzalez Senior Regulatory Counsel Order 792 Compliance Filing April 22, 2014 NEPOOL Transmission Committee

  2. Presentation Objectives • Provide overview of FERC Order 792 • Describe ISO New England’s (ISO-NE) efforts to develop the Order 792 compliance filing, including coordination with the PTOs • Describe Order 792 requirements and revisions to Schedule 23 of the ISO-NE Open Access Transmission Tariff (ISO-NE OATT) to reflect those requirements and any “independent entity variations” or regional differences. • Schedule 23 contains ISO-NE’s Small Generator Interconnection Procedures (SGIP) and Small Generator Interconnection Agreements (SGIA)

  3. Order 792 Overview • On November 22, 2013, FERC issued Order 792 requiring all public utility transmission providers (including, ISO-NE) to revise their pro forma Small Generator Interconnection Procedures (SGIP) and Small Generator Interconnection Agreement (SGIA) as specified in the order. • Order 792 revises the pro forma SGIP and SGIA to: • Provide an Interconnection Customer with the option of requesting a Pre-Application Report providing existing information about system conditions at a possible Point of Interconnection; • Revise the 2 MW eligibility threshold for the Fast Track Process • Revise the Fast Track screen/study process • Include energy storage devices as part of a Small Generating Facility • Clarify certain sections • Order 792 established two compliance requirements: • Submit filing indicating intent to request “Independent Entity Variation” – ISO-NE submitted filing on 2/3/2014 • Compliance filing of revisions to Schedule 23 to reflect the changes adopted in Order 792 plus any “Independent Entity Variations” or regional differences identified – Due 8/4/2014

  4. ISO Compliance Filing Efforts • Given the Order 792 requirements and the shared rights and obligations between the ISO-NE and the PTOs under Schedule 23, the ISO initiated discussions with the PTOs in February. • ISO-NE and PTO discussions focused on three areas: • Pre-Application Reports • Interconnection Requests • Fast Track Process eligibility/screens • These discussions informed the ISO-NE’s development of the revisions to Schedule 23 that are being presented to the Transmission Committee.

  5. New Pre-Application Report • Order 792 revises the pro forma SGIP to provide an Interconnection Customer the option to request a Pre-Application Report. • Order 792 sets the fee for the Pre-Application Report at $300, but provides flexibility for transmission provider to request a higher fee. • Based on ISO-NE analysis and input from the PTOs, the Schedule 23 revisions reflect a $500 fee. • Order 792 requires the Pre-Application Report be provided, but is limited to readily available information. • ISO-NE polled the PTOs and is comfortable that much of the data to be provided under the new provisions will be readily available.

  6. New Pre-Application Report (Continued) • Order 792 sets the due date for the Pre-Application Report at 20 Business Days • Order 792 specifies the information to be provided in a Pre-Application Report request • A Pre-Application Report Request Form has been developed and will be made available on the ISO-NE website.

  7. Revised Fast Track Process Eligibility Threshold • Order 792 revises the threshold for Fast Track Process eligibility: • Eligibility to the Fast Track Process raised up to 5 MW for inverter-based generation (wind, solar, etc.) • Eligibility to the Fast Track Process based on voltage at Point of Interconnection and distance from substation • Eligibility to the Fast Track Process left at 2 MW for synchronous and induction generators • Eligibility to the Fast Track Process will be at voltages up to 69 kV • The Schedule 23 revisions adopt the new Fast Track Process eligibility thresholds, but limit eligibility to projects connecting below 69 kV.

  8. Revised Fast Track Study Process • Order 792 revises the Fast Track study process: • Fast Track Process includes an initial review • Fast Track Process initial review includes an exclusion for stability constrained areas • If project passes the initial review, an executable Interconnection Agreement must be issued 5 days after that determination • If project does not pass the initial review, the Interconnection Customer must be notified in 5 days of that determination and be provided all data and analysis underlying the determination • If project does not pass the initial review, the Interconnection Customer must be offered a meeting within 10 days • The Schedule 23 revisions reflect these changes.

  9. Revised Fast Track Study Process (Continued) • If project does not pass the initial review, the Interconnection Customer must be offered an agreement for a supplemental study including a good faith estimate • The supplemental study must be completed in 30 Business Days • The supplemental study includes a minimum load screen, a voltage and power quality screen and a safety and reliability screen • If the project passes the supplemental process and no upgrades are required , an executable Interconnection Agreement must be issued 10 days after that determination • If the project passes the supplemental process and minor upgrades are required , an executable Interconnection Agreement must be issued 15 days after that determination

  10. Other Changes • Order 792 also: • Updated the definition of Small Generating Facility to include energy storage devices • Refined the definition of maximum capacity • Added the definition of Network Resource and Network Resource Interconnection System • The Schedule 23 revisions reflect the changes to the Small Generating Facility and maximum capacity, with corresponding variations proposed to include energy storage device in: • Interconnection Request and Material Modification • Interconnection Request Form • The Schedule 23 revisions do not reflect the changes to the definitions of Network Resource and Network Resource Interconnection Service because they are not consistent with the current Network Resource and Capacity Network Resource construct previously approved by FERC for New England.

  11. Next Steps • TC: • April meeting/discussion • May TC meeting/action • PC: • June PC meeting/action (no July meeting) • PTO AC action • Filing • August 4, 2014

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