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EDF Renewables implores FERC to take prompt action on affected systems studies

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EDF Renewables implores FERC to take prompt action on affected systems studies

EDF Renewables Inc. told the Federal Energy Regulatory Commission that bringing new generation projects online remains a serious challenge since the regulator sided with the developer 18 months ago on a complaint raising concerns about the nation's power grid interconnection procedures.

In a request for prompt commission action, EDF urged FERC to issue an order "as soon as possible" to address what it described as unjust practices plaguing affected systems coordination the process by which independent system operators and regional transmission organizations study and account for the potential impacts of new generation on neighboring grids. "The nation is in the midst of an overhaul in its generation fleet, but this new generation cannot be built because projects are stuck in RTO queues held captive by a lack of affected systems studies or are being assessed network upgrade costs on the affected system that are not just and reasonable," EDF said.

EDF develops, owns and operates renewable resources throughout the world, including more than 3.5 GW of generation in the U.S.

The issue dates back to October 2017, when EDF asked FERC to direct regional grid operators Midcontinent ISO, Southwest Power Pool and PJM Interconnection to provide more details on how and when an interconnecting project's impact on neighboring grid operators' systems is determined. According to EDF's original complaint, the grid operators' tariffs and joint operating agreements, or JOAs, merely "identify the requirement for the host and neighboring RTOs to coordinate" while interconnection customers in those three regions "have no idea what 'coordination' means."

FERC in issued an order in February 2018 stating that EDF had "raised legitimate issues specific to the MISO, SPP, and PJM tariffs and JOAs" that were not raised in a separate 2016 commission proposal to make major changes to the agency's large generator interconnection procedures and pro forma interconnection agreement. In doing so, FERC scheduled an April 2018 technical conference on the matter to gather input from a broad cross-section of stakeholders.

Following the conference, EDF submitted comments specifically recommending, among other things, that neighboring grid operators use the less stringent Energy Resource Interconnection Service, or ERIS, standard instead of the Network Resource Interconnection Services, or NRIS, standard in their affected systems studies. Adopting that reform would reduce the amount of money that project developers are required to put up in the form of financial milestones because the ERIS standard would not show the need for as many related upgrades on neighboring systems compared to the NRIS standard, EDF said.

Meanwhile, SPP argued in its own comments following the technical conference that using the less stringent ERIS standard in its affected system studies is not appropriate. Doing so "would expose SPP's members to negative impacts, could undermine reliability, and would result in inappropriate and discriminatory cost allocation to SPP interconnection customers that have requested a comparable level of service," the grid operator said.

EDF nevertheless noted in its Aug. 7 filing to FERC that SPP, using the NRIS standard, has claimed that $800 million in upgrades are needed to its system "to accommodate generation that will be sited within, and only deliver energy to, the MISO system." That $800 million "sent shock waves" to affected projects sited within MISO that could be asked to fund those upgrades, EDF said. Meanwhile, the company said information released upon further inquiry demonstrated that SPP's affected system results are "flawed in significant respects." The situation serves as "a clear and recent example why affected system coordination in this nation needs to be fixed."

"To use the NRIS standard in the affected systems, like SPP does, when you're not going to be delivering power there, is using too onerous of a standard, and so it's allowing SPP to gold-plate its system, which should not occur," Bruce Grabow, an attorney with Locke Lord LLP who submitted EDF's filing, said Aug. 8 in an interview.

Grabow said he is hopeful for commission action soon, noting that FERC has started to address major transmission and interconnection issues after working through a backlog following a nearly six-month stretch without a quorum. "FERC seems to be focused on tackling these broader policy issues now, so I think affected systems will be a part of that." (FERC dockets AD18-8, EL18-26)