Comments on PRR 745 and PRR 746
Submitted July 22, 2014
by Susan Schneider on behalf of Large Scale Solar Association
GIDAP BPM 1.4.2 – Highlighted Definitions Applicable to this GIDAP BPM, paragraph 2
GIP BPM 1.4.2 – Special Definitions for this GIP BPM, paragraph 2 / “Identified Affected System” shall mean an Affected System operator who either initially responded to the initial CAISO notification stating that it should be considered an Affected System or whose electric system has been identified by the CAISO as potentially adversely impacted by a generator interconnection through the study process as an Affected System.
LSA Comments:
This distinction is very helpful – a few clarifications suggested. / The ISO accepted this suggestion.
6.1.4.2 – Affected System Notification and Declaration / The CAISO will provide notice to all electric system operators whose systems are in electric proximity to the CAISO controlled grid at the beginning of the cluster or independent study process of each iInterconnection rRequest that may impact their systems within a sufficient time period so that each electric system operator has the opportunity to participate in sScoping mMeetings and obtain a better understanding of each project.This notification will include timeline information from the CAISO’s interconnection process, including possible study coordination dates during the CAISO’s Interconnection Study process that would facilitate timely resolution of any Identified Affected System issues
LSA Comments:
Why would the CAISO wait until the Phase I Results Meetings to provide this schedule information? It should be provided with the initial notification of the Interconnection Request, not months later. / The ISO accepted this suggestion. Interconnection Study was not capitalized because inadvertently the current tariff does not include GIDAP in the definition.
The sScoping mMeeting for each iInterconnection rRequest will take place within 60 calendar days from the close of the iInterconnection rRequest window. At the sScoping mMeeting, participants will discuss the project details and schedule for both the Interconnection Studiesstudy and the project. If, following notice from the CAISO, an electric system operator believes it will be impacted by the proposed interconnection project, the CAISO will expect such electric system operator to make every effort to conduct its system impactinterconnection studies in parallel with the CAISO’s GIDAP process. / The ISO accepted this suggestion. Interconnection Study was not capitalized because inadvertently the current tariff does not include GIDAP in the definition.
Starting with Cluster 87, the CAISO will request that an electric system operator, after receiving notice of the study process and scoping meetings, advise the CAISO in writing that either: 1) the CAISO should consider the electric system to be an Affected System (whether or not a system impact study has been conducted); or 2) the electric system is not an Affected System.
LSA Comments:
There is more than sufficient time to begin this process with Cluster 7. If the Scoping Meetings have already been help, then make the notice ASAP and follow the procedures here for the rest of the study process. / The scoping meeting for Cluster 7 has already taken place so the proposed process cannot start with Cluster 7.
If the electric system operator does not make this affirmative representation within 90 calendar days of the close of the interconnection request window, the CAISO will assume that the electric system is not an Affected System and will not permit the electric system operator to declare itself as an Affected System later in the process.
LSA Comments:
This clarification is very important. / The intent of the NERC Reliability Standards including FAC-002-1, FAC-002-2, TPL-001, TPL-002 and TPL-003, speak to mitigating reliability impacts on interconnected transmission systems and if there are impacts they have to be resolve. Therefore we can’t preclude an Affected Systems from identifying themselves later in the process. We understand the ICs concern and financial risk to the project but believe if the IC can resolve issues with Affected Systems early in the project life cycle process the risk is decreased. The ISO will make every effort possible to coordinate early with the neighboring electric systems.
Projects greater than or equal to 200 MW must be evaluated throughcomply withthe WECC Project Coordination and Path Rating ProcessesProgress Report Policies and Procedures, regardless of whether any electric system operators in electric proximity to the CAISO controlled grid haves identified themselves as Affected Systems.[1] That WECC process is described at:
Categorization Files/Guidelines/Project Coordination and Path Rating Processes.pdf. The CAISO, together with the PTOs, will facilitate and assist generator project sponsor efforts to comply with this reporting process. The CAISO will work with the Participating TOs, electric system operators, and the generation project sponsors to assess impacts on the potentially affected WECC paths if concerns are identified by operators of other systems.[1]
[1]If an Identified Affected System has concerns that the Acepted Rating of its WECC Path may be impacted, Tthe scope of this Path impact affected path study must be included in the study agreements between the Identified aAffected sSystems and generation project sponsors potentially causing the impacts.
LSA Comments:
LSA does not believe generators are subject to any requirements under this process beyond progress reporting, by the plain reading of the rules identified here. / The ISO accepted this suggestion.
The CAISO again will notify Identified Affected Systems when individual and group study results are available, and will invite them to attend each study phase results meetings for each project that may impact their electric systems.At the time of the Phase I results meetings, the CAISO also will provide Identified Affected System operators with the timeline information from the CAISO’s interconnection process, including possible study coordination dates during the CAISO’s Phase II study process that would facilitate timely resolution of any affected system issues. The CAISO will list the Identified Affected Systems in the Phase I and Phase II study reports.
LSA Comments:
Inserted this notice with initial notice of the Interconnection Request – no need to wait months more. / The ISO accepted this suggestion.
In each Interconnection Customer’s GIAFor each Interconnection Request, the CAISO shall establish a list of the Identified Affected Systems , which may change be reduced over timeand shall provide the list and any revisions to the Interconnection Customer as soon as practicable. Affected Systems wishing to become Identified Affected Systems shall notify the CAISO and the Interconnection Customer, and provide supporting studies or other documentation demonstrating adverse impacts from generator project interconnection with such notification, no later than the time when the GIA for the project is executed.
LSA Comments:
The list should be independent of the GIA, to remove the need to amend the GIA every time the list is changed.
This clarifies how/when an Affected System becomes an Identified Affected System. / The ISO accepted some of this suggestion. The ISO agrees with having the list of Affected Systems separate from the GIA. The ISO will be notifying the IC of the Affected System which can change over time and will not require an amendment to the GIA. The ISO does not agree that an Affected System that wants to identify itself should be required to produce studies to substantiate their identification. The intent of an Affected System to identify themselves early on is so that the IC can contract with the Affected System to do a study and determine the impact of the interconnection as soon as possible in the study process. In addition, as stated earlier, the ISO does not believe that the intent of the NERC Reliability Standards could require the Affected System to identify themselves prior to executing the GIA.
Once the GIA is executed, the list of Identified Affected Systems may be reduced over time. Notification of such changes will be in accordance with the process identified in the GIA. .The GIA will also direct the Interconnection Customer to affirmatively contact the Identified Affected Systems to address system impacts, if any. The CAISO will provide Interconnection Customer contact information to Identified Affected System operators and the CAISO will provide Identified Affected System operator contact information to the Interconnection Customer. Identified Affected System operators will be notified when study plans and base cases are posted on the CAISO secure website using the market participant portal.
LSA Comments:
Consent requirements should be clear by the time the GIA is executed and not be increased later in the process. There is more than enough time in the CAISO’s lengthy study process for an Affected System to conduct its own studies.
The process should provide for reduction of the list over time, e.g., as projects drop out. For example, CAISO should review the list of entities identified through its own studies in each Reassessment and remove those where it is clear that no impacts remain. / As stated earlier, the ISO does not believe that the intent of the NERC Reliability Standards could require the Affected System to identify themselves prior to executing the GIA. Moreover if the IC does not resolve Affected System issue expeditiously, there could be system changes that are not initially identified that could impact the reliability of the Affected System.
With respect to LSA’s comment that “The process should provide for reduction of the list over time, e.g., as projects drop out.”, the ISO has repeatedly explained that it does not have the information need to conduct studies on Affected Systems. Therefore it cannot determine on its own the impact to an Affected System. That is the purpose of this BPM section, i.e. to establish a process to determine the impact to Affected Systems as early as possible and mitigate the risk to project development.
The CAISO will provide the following assistance with Affected System contacts and coordination to pre-Cluster 8 7 interconnection customers:
1) For each Interconnection Customer with an executed GIA as of November 1, 2014, the CAISO will contact electric system operators in electric proximity to the generation project location on the CAISO controlled grid and ascertain whether the electric system is an Identified Affected System. The CAISO will provide a list to the Interconnection Customer of the Identified Affected System(s) and the Interconnection Customer must meet the documentation requirements set forth in Section 6.1.4.3 below.
2) For each Interconnection Customer who has not executed a GIA as of November 1, 2014, the CAISO will contact electric system operators in electric proximity to the generation project location on the CAISO controlled grid and ascertain whether the electric system is an Identified Affected System. The CAISO will incorporate into the GIA the list of Identified Affected Systems and the Interconnection Customer must meet the documentation requirements set forth in Section 6.1.4.3 below and in the GIA.
LSA Comments:
The language in both of these paragraphs is identical. / As discussed earlier the process cannot start with Cluster 7 because the Scoping Meetings have already been completed. The other suggestions were accepted. The ISO has rewritten this section and the two paragraphs have been combined.
6.1.4.3 Study Process and Affected System Contact Documentation / If the Interconnection Customer has been unsuccessful in resolving Identified Affected System issues at the time of the above demonstration, the documentation must provide sufficient details about all contacts and other attempts to work with the Identified Affected System and address system impacts. The CAISO will not allow generation projects to be energized on the CAISO controlled grid until Identified Affected System issues are resolved. If impacts cannot be mitigated within the CAISO controlled grid, the CAISO will advise the Interconnection Customer and the Identified Affected System operator that the interconnection cannot proceed. If an Interconnection Customer makes a unilateral decision that an affected system agreement is not necessary and does not reasonably attempt to address the issue with the Identified Affected System operator, the CAISO will advise the Interconnection Customer that the interconnection will not be allowed to move forward with synchronization and commercial operation unless the issue is resolved.
LSA Comments:
LSA continues to maintain that this sentence is gratuitous, i.e., that this is obvious from the rest of this paragraph and adds nothing to the substance of the rules here. / The ISO accepted this suggestion.
While the ISO understand that LSA believes the sentence is gratuitous, the ISO wants the sentence to remain because there are other ICs that do not understand this fundamental position.
However, if the Interconnection Customer’s reasonable coordination efforts with the Identified Affected System operator do not result in the Identified Affected System operator moving forward on a timely basis, and the CAISO determines that possible impacts on the Identified Affected System can be mitigated within the CAISO Controlled Grid on an interim or possibly permanent basis, the CAISO will advise the Identified Affected System operator and the Interconnection Customer that the interconnection can proceed without affirmative agreement by the Identified Affected System. If the Interconnection Customer and Identified Affected System disagree about the methodology used to determine the need for mitigation, upon request, the CAISO will confer with the parties in an attempt to resolve the differences. The CAISO will not withhold or delay interconnection if verifiable study results, in accordance with Good Utility Practice, do not provide justification to do so.
LSA Comments:
The addition of possible temporary mitigation is a very useful feature.
Ditto, assuming that the CAISO is willing to ever make this declaration over the objections of an Identified Affected System. / The ISO cannot accept this edit. The ISO needs the ability on a case-by-case basis to evaluate the concern of the Affected System.
6.1.5.1 Notifying the CAISO and Affected Participating TO(s); Study Process / Once an Interconnection Customer has entered the neighboring system operator’s interconnection process and if it appears that there could be reliability impacts on the CAISO cControlled gGrid, the CAISO and affected Participating TO(s) should be notified by the neighboring system operator so that study data can be exchanged and studies coordinated.
In addition, Interconnection Customers in the neighboring system, once apprised ofshould assess possible impacts on the CAISO or the interconnecting Participating TO,and should take reasonable steps to contact the CAISO and affected Participating TO(s) and enter into a study agreement with the Participating TO to identify reliability system impacts. During the study process, the CAISO and Participating TO will seek to work with the neighboring system and coordinate study schedules with the affected neighboring systems, if practicable, to which the generation project seeks to interconnect to evaluate cost effective and efficient mitigation solutions for reliability impacts on the CAISO cControlled gGrid. The CAISO will review and concur with impact studies prepared by the Participating TO. If requested by the generation project owner or the neighboring system operator, the CAISO will review impact studies prepared by the neighboring system operator.
LSA Comments:
Generation developers do not have the capability to assess transmission impacts. Notification by the neighboring system operator (per the paragraph above) should be sufficient. / The ISO accepted these suggestions.
6.1.5.2 Reimbursement for Reliability Mitigation Solutions on CAISO Controlled Grid / Funding and reimbursement for rReliability nNetwork uUpgrades on the CAISO controlled grid will be in accordance with the applicable provisions of the CAISO Tariff regarding generator interconnection. The CAISO will use the applicable tariff reimbursement scheme for rReliability Network uUpgrades to Participating TO systems in effect on the date on which the iInterconnection cCustomer entered into a study agreement with the affected Participating TO. / The ISO accepted these suggestions.
6.1.5.3 Facilities Construction Agreement / If reliability system impacts and mitigation solutions are identified in the Participating TO study process, the Interconnection Customer must enter into the CAISO’s fFacilities cConstruction aAgreement, which is a three-party agreement involving the Interconnection Customer, the CAISO and the affected Participating TO. The CAISO will notify the neighboring system operator that a fFacilities cConstruction aAgreement will be executed to address system impacts on the CAISO cControlled gGrid and will share the agreement with the neighboring system operator, upon request, once it has been developed and executed.
Prior to synchronization, the neighboring system operator should verify that the CAISO and potentially impacted Participating TO(s) have been contacted and that steps have been taken to address any reliability system impacts. / The ISO does not have a defined term “Facilities Construction Agreement” therefore it cannot be capitalized. The ISO agrees that Controlled Grid should be capitalized.
Comments on PRR 745 and PRR 746