The Federal Energy Regulatory Commission on Sept. 19 ordered the Midcontinent ISO, the Southwest Power Pool and the PJM Interconnection to provide more details on how and when an interconnecting project's impact on neighboring grid operators' systems is determined.
The order handed key wins to EDF Renewables Inc., a developer that FERC sided with nearly two years ago in concluding that the company had raised "legitimate issues" specific to the MISO, SPP and PJM tariffs and joint operating agreements, or JOAs, concerning affected system studies. Those high-stakes studies, which determine how much project developers must pay for related upgrades on adjacent grids, have become increasingly important as grid operators build out infrastructure to accommodate a wave of renewable generation.
EDF said in an October 2017 complaint that the problem is that the grid operators' 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." After considering EDF's claims, FERC issued an order in February 2018 concluding that the company had raised issues that warranted "further examination." The commission hosted a technical conference on the matter two months later.
The proceeding stalled after that, prompting EDF to warn the commission in August that "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."
In its Sept. 19 order, FERC sided with EDF on some of its most significant concerns. Notably, the commission agreed with EDF's assertion that a lack of transparency between MISO and SPP leaves interconnection customers wondering how network upgrade costs are being allocated.
EDF had said the lack of clarity inhibits generators from assessing the commercial viability of proposed projects, which runs contrary to FERC's requirement that transmission providers offer transparent open-access interconnection service. To address the issue, FERC directed the two grid operators, among other things, to forward each other interconnection requests and the information necessary to study the impact of those requests at least twice per year.
However, the commission stopped short of granting EDF's recommendation that the three grid operators use the less stringent Energy Resource Interconnection Service, or ERIS, standard instead of the Network Resource Interconnection Services, or NRIS, standard to model potential system impacts. Using the ERIS standard for affected system studies would reduce the amount of money that project developers are required to put up in the form of financial milestones because the less stringent standard would not show the need for as many related upgrades, EDF said in its post-technical conference comments.
FERC instead directed MISO, SPP and PJM to revise their JOAs to stipulate in their coordination documents where interconnection customers can find the modeling details they use when studying a project as ERIS or NRIS for interconnection requests on their own systems.
"The differences in the market structures across MISO, SPP, and PJM may justify each RTO using its own approach, such as an NRIS or ERIS modeling standard, to evaluate the impacts to it as an affected system regardless of the level of service that an interconnection customer is requesting in the host RTO," the commission said. (FERC dockets EL18-26, AD18-8)
