Order No Compliance Filing Related to Interconnection Issues Proposed Transmission Interconnection Process

Transcription

1 Order No Compliance Filing Related to Interconnection Issues Proposed Transmission Interconnection Process Thinh Nguyen Manager, Interconnection Projects New York Independent System Operator Joint ESPWG/TPAS February 5, New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY

2 Topics FERC Compliance Directive Current Interconnection & Transmission Expansion Rules Overview of Proposed Revisions to Existing Processes Types of Projects Subject to the Proposed Transmission Interconnection Process ( TIP ) Projects Remaining in the Transmission Expansion Process Controllable Transmission Seeking UDRs Threshold for Triggering the TIP TIP Overview TIP Detailed Process Description 2

3 FERC Compliance Directive FERC s 12/23/2015 Order on the NYISO s Fourth Order 1000 Compliance Filing directed NYISO to modify its existing interconnection processes Incumbent transmission projects and nonincumbent transmission projects that will seek recovery through NYISO Planning Processes must be subject to the same interconnection requirements The Commission s Order left open the option to propose a process other than the process in Attachments X and S for conducting the interconnection studies necessary for these types of projects 3

4 Current Interconnection & Transmission Expansion Rules All generation (proposed by both incumbent TOs and non-incumbents) with FERC jurisdictional interconnection points are subject to the NYISO s Interconnection Procedures Large Facility Interconnection Procedures in Attachment X (generators > 20 MW) Small Generator Interconnection Procedures in Attachment Z (generators 20 MW) Class Year Study procedures in Attachment S (applicable to all Large Facilities and certain Small Generating Facilities) 4

5 Current Interconnection & Transmission Expansion Rules All transmission projects proposed by entities that are not Transmission Owner signatories to the ISO-Related Agreements are subject to the Large Facility Interconnection Procedures in Attachment X and Attachment S Even if Developer intends to seek cost recovery through a NYISO Attachment Y Planning Process (the Reliability, Economic and Public Policy processes) Even if the project is AC transmission All proposed upgrades or additions to transmission facilities owned by the New York Transmission Owners are subject to the transmission expansion process in OATT 3.7 or OATT 4.5 Includes upgrades/reinforcements proposed by Eligible Customers to current TOs system Subject to a de minimis threshold, below which a project does not trigger the OATT study process 5

6 Considerations for Revisions to Existing Rules As the Commission indicated, the NYISO could propose to require all transmission to proceed through the Large Facility Interconnection Procedures in Attachments X and S of the OATT As the Commission recognized, there are potential drawbacks to that approach, suggesting the NYISO s ability to propose a new process for transmission projects NYISO s proposal seeks to optimize efficiency of existing processes and allow it to evaluate projects based on the proposed technology/ electrical characteristics vs. the characteristics of the proposing entity 6

7 Overview of Proposed Revisions to Existing Rules Develop a new Transmission Interconnection Process ( TIP ) A hybrid of the current Transmission Expansion Process and the Interconnection Process Retain existing Small Generator Interconnection Procedures Retain existing Large Facility Interconnection Procedures in Attachments X and S for all Large Generating Facilities and controllable transmission seeking UDRs (if eligible to seek UDRs) Existing transmission expansion process from OATT 3.7 and 4.5 will apply only to requests not subject to the new TIP 7

8 Types of Projects Subject to the Proposed TIP Overview Proposed TIP would apply to a transmission project, regardless of the entity that proposes it and regardless of the project s intended cost recovery mechanism Two exceptions: Project with de minimis impact will not be required to go through the TIP Controllable transmission that seeks UDRs must go through Attachments X and S 8

9 Types of Projects Subject to the Proposed TIP Specifically, unless below the de minimis threshold, the following would be subject to the TIP: 1) Transmission projects proposed by incumbent NYTOs and non-incumbents in (or that anticipate entering) a NYISO Planning Process 2) Transmission projects proposed by NYTOs triggered by their local planning process 3) Transmission projects proposed by other Eligible Customers that request to pursue expansions of the transmission facilities owned by NYTOs 4) Transmission projects proposed by non-incumbents outside the NYISO Planning Process (i.e., merchant projects), including HVDC and hybrid AC/DC transmission (unless controllable transmission seeking UDRs) 5) Transmission projects from TOs in neighboring regions (e.g., RTEP projects) 9

10 Controllable Transmission Seeking UDRs Controllable transmission lines for which the proposing entity seeks UDRs must proceed through the Large Facility Interconnection Procedures Even if they are seeking cost recovery under the NYISO s Planning Process Both incumbent TOs and non-incumbents can seek UDRs (if eligible for UDRs) by proceeding through Attachment X and Attachment S 10

11 Threshold for Triggering the TIP Currently, an SIS in the Transmission Expansion Process under the OATT 3.7 or is 4.5 is required for transmission projects that have the following potential impacts: Reduction in the transfer capability of a NYISO interface by greater than 10 MW or Increase in the transfer capability of a NYISO interface by greater than 25 MW 11

12 Threshold for Triggering the TIP Proposed de minimis threshold for the new TIP: If the project is connecting to facilities it owns, it will trigger the TIP if: It reduces the transfer capability of a NYISO interface by greater than 10 MW or increases the transfer capability of a NYISO interface by greater than 25 MW; or the proposal has the potential to convert other facilities into NPCC or BPS facilities If the project connects to facilities other than its own facilities, it will trigger the Transmission Interconnection Process, regardless of the MW impact 12

13 TIP Overview Transmission Interconnection Application Scoping Meeting Optional Feasibility Study System Impact Study Facilities Study Cost Responsibility for Network Upgrades Interconnection Agreement 13

14 TIP Application Requirements Transmission Interconnection Application Non-refundable $10,000 application fee NYISO to identify deficiencies within five (5) business days Deficiencies to be addressed within ten (10) business days. Failure to address application deficiencies will result in withdrawal. TIP will include a formal withdrawal provision, providing the ability to cure deficiencies that trigger withdrawal See Transmission Interconnection Application form posted with meeting materials 14

15 TIP Scoping Meeting Scoping Meeting among proposing entity, NYISO and Connecting Transmission Owner(s) To occur no later than thirty (30) calendar days from receipt of a valid application unless otherwise mutually agreed to by the parties To discuss at the Scoping Meeting: Discuss whether Project elects to pursue a Feasibility Study or proceed to a System Impact Study and discuss the scope of such study. Discuss which of the following options Project elects to use to determine interconnection design: Proposing entity to provide proposed interconnection design Proposing entity to request a Feasibility Study to develop and evaluate the proposed interconnection design Parties to include development of the proposed interconnection design as an upfront step of the System Impact Study 15

16 TIP Feasibility Study Optional Feasibility Study available at the proposing entity s option Study deposit of $60,000 Two-party study agreement between NYISO and the proposing entity Study schedule will depend on options elected by proposing entity 16

17 TIP Feasibility Study Feasibility scope may include any of the following, at the option of the proposing entity: Development of conceptual breaker-level one-line diagram of existing system where project proposes to interconnect (i.e., how to integrate the project into the existing system) Review of feasibility/constructability of conceptual breakerlevel one-line diagram of the proposed interconnection (e.g., space for additional breaker bay in existing substation or identification of cable routing concerns inside existing substation) Preliminary review of local protection, communication, grounding issues associated with the proposed interconnection Power flow analyses Short circuit analyses Bus flow analyses Identification of Network Upgrades with non-binding good faith estimate of cost responsibility and non-binding good faith estimated time to construct 17

18 TIP System Impact Study Study deposit of $120,000 Two-party study agreement Schedule dependent on study scope System Impact Study scope and report subject to TPAS review and OC approval 18

19 TIP System Impact Study Scope of Study: Identification of the need for any additional facilities ( Network Upgrades ) to meet reliability criteria Development of non-binding cost estimates and time to construct required Network Upgrades Similar to a System Impact Study/System Reliability Impact Study performed today with thermal, voltage, stability and short circuit analyses, plus an evaluation of transfer limit degradation 19

20 TIP System Impact Study Applicable Standard Transmission security analyses consistent with Minimum Interconnection Standard (i.e., thermal, voltage, stability and short circuit analyses) Transfer limit impact analysis A project will trigger an upgrade if it degrades pre-project transfer limits of any NYISO transmission planning interface (documented in the NYISO s Area Transmission Review) more than 25 MW Project responsible for upgrades necessary to mitigate impacts to the controlling limit (e.g., voltage, stability, thermal) as well as any impact to the thermal limit Even if thermal transfer limit is not the controlling limit, project must mitigate impact to the thermal transfer limit Project that triggers an upgrade would have to fully restore the impacted transfer limits to the pre-project limits 20

21 TIP System Impact Study Base Case Starting case is the most recent Class Year ATBA case If the proposed transmission project is related to/in response to a system condition not reflected in the ATBA, NYISO may, as appropriate, evaluate the proposed transmission project while taking that system condition into consideration Projects responding to solicitation under NYISO Planning Processes may, as appropriate, require modification to the existing system representation in the ATBA based on, for example, a stated Public Policy For a transmission project proposed in response to reliability need triggered by deactivation of a generator, the NYISO may evaluate the proposed transmission project without that generator in-service Allows evaluation of transmission project under the conditions the project is intended to address 21

22 TIP Facilities Study $100,000 study deposit Two-party study agreement Scope of Study: Stand- alone engineering study (similar to a Part 1 Study) for most projects More detailed, focused study of upgrades identified in System Impact Study but not a re-evaluation of analyses performed in the System Impact Study Facilities Study scope and report subject to TPAS review and OC approval 22

23 Network Upgrades Project will be required to post security for Network Upgrades identified in the Facilities Study Transmission projects moving forward in the same time frame that both contribute to a Network Upgrade should share the cost of the Network Upgrade 23

24 Interconnection Agreement Unless proposed transmission project is connecting to facilities it already owns, TIP would require a multi-party interconnection agreement among: Proposing entity; NYISO; and Connecting Transmission Owner(s) 24

25 Modeling of TIP Projects in Interconnection Base Cases For proposed TIP project in an Attachment Y Planning Process to be treated as firm and modeled in the interconnection ATBA: Must have been triggered, selected, or approved Triggered (for reliability projects) Selected (for PPTPP projects;) Approved by beneficiaries (CARIS projects) Must have an Article VII application deemed complete (if applicable) and completed SIS (if applicable); and Must be making reasonable progress under the applicable Attachment Y process 25

26 Modeling of Other Transmission in Interconnection Base Cases For other transmission projects (unless subject to Attachments X and S) to be treated as firm and modeled in the interconnection ATBA: Must have commenced a Facilities Study (if applicable) Must have an Article VII application deemed complete (if applicable) 26

27 Transition Rule NYISO to propose a transition rule for projects in the queue before the effective date of the proposed TIP Transition rule will seek to transition project to the TIP without subjecting the project to unnecessary rework or delay 27

28 Projects Remaining in the Transmission Expansion Process Leave existing pro forma transmission expansion language in OATT 3.7 and 4.5 with slight revisions to clarify its purpose: Change name of study (not really an impact study) Clarify that it would only apply to requests from Eligible Customers for the NYISO to identify potential projects that could meet a stated objective E.g., request to study how to relieve the constraints currently curtailing a generator E.g., request to study how to create incremental transfer capability resulting in incremental TCCs If Eligible Customer decides to move forward with project, it would do so through the new Transmission Interconnection Process 28

29 Next Steps Comments requested by February 17 NYISO to consider comments and bring proposal back for discussion at March 7 Joint ESPWG/TPAS meeting Time permitting, NYISO to share draft tariff language at March 7 Joint ESPWG/TPAS meeting and/or March 18 Operating Committee Review of proposal at March 17 Operating Committee meeting Compliance filing deadline: March 22 29

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