Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast February 7, 2012 -SUMMARY OF ACTIONS TAKEN- # MOTION PROVIDED BY (SECOND) STATUS -SUMMARY OF ACTION ITEMS- # ACTION ITEMS ASSIGNED TO 1. Send the technical definition of sustained parallel to Matt Jim Hotovy Harward to incorporate into BPR 018 2. Revise BPR018 to address concerns where a Transmission Owner s processes direct an interconnection customer to the SPP Generation Interconnection Procedure. 3. Coordinate the applicable Generation Interconnection and Aggregate Study process user surveys to be presented at the next BPWG meeting. Matt Harward Clint Savoy and Grant Wilkerson Page 1 of 3
Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast February 7, 2012 AGENDA ITEM 1 - ADMINISTRATIVE ITEMS a) Chairman Grant Wilkerson called the meeting to order at 1:03 p.m. There were 18 people in attendance, representing 7 BPWG members, 5 SPP Staff members, and 6 guests.(attachment 1 BPWG_Attendance_Record_2_7_2012) b) Proxies recognized were Jenni Leger for Kara Whillock. (Attachment 2 Proxies for BPWG Meeting on 2-7-2012) c) The agenda was reviewed, revised, and accepted. (Attachment 3 Agenda 2_7_2012_Revised). AGENDA ITEM 2 UPDATE ON BPR 027 Chairman Wilkerson updated the group on the status of BPR 027 Revisions to Notification to Construct Business Practice, which was approved by the BPWG at the previous meeting. Mr. Wilkerson reported that the BPR was to be reviewed by the RTWG for Tariff implications and the TWG for comments. AGENDA ITEM 3 BPR018 GENERATION INTERCONNECTION PROCESS Jim Hotovy reported that the SPP Legal staff had suggested some revisions to BPR 018 following their review. Matt Harward reviewed the suggested revisions, reporting that the majority of the changes were for clarity only and would not qualify as a substantive change. Participants voiced a concern that the revisions seemed to prevent a generation interconnection customer from utilizing the SPP Generation Interconnection Process, even if they chose to do so or were directed to do so because of the processes of the host Transmission Owner. Mr. Harward asked to take the comments received and attempt to address them. The group suggested other revisions. (Attachment 4 BPR 018-Generator Interconnection Procedures_BPWG Review 02_07_2012) Action Item: Matt Harward will revise BPR018 to address concerns where a Transmission Owner s processes direct an interconnection customer to the SPP Generation Interconnection Procedure. Chairman Wilkerson the presented the comments and suggested revisions that had been submitted by the Wind Coalition. Mr. Hotovy expressed an issue with the definition of sustained parallel and stated that there was a technical definition of the term. Mr. Wilkerson also pointed out the requirement suggested by the Wind Coalition to require Transmission Owners to inform SPP of a request to interconnect generation any time one was made, regardless of size and whether or not it was determine that SPP is an Affected System. Some participants did not agree with that requirement but were not Page 2 of 3
Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast February 7, 2012 opposed to a threshold, such as 10 MW or more, which a request to interconnect a generator above the threshold shall be reported to SPP. Action Item: Jim Hotovy will send the technical definition of sustained parallel to Matt Harward to incorporate into the BPR 018 revisions. AGENDA ITEM 4 GENERATOR INTERCONNECTION AND AG STUDY CUSTOMER SURVEY Chairman Wilkerson reported to the group that the next step for the GI and Ag Study process improvements is to put a list of questions together to be sent out as a survey to all of the process users. The group went through some questions and Mr. Wilkerson stated that any other questions that anyone wanted to be included in the surveys should be sent by email to Clint Savoy (csavoy@spp.org). (Attachment 5 Ag and GI Study Improvement Questions) Action Item: Grant Wilkerson and Clint Savoy will coordinate the GI and Ag Study process surveys to be presented at the next BPWG meeting. AGENDA ITEM 5 FUTURE MEETINGS The next meeting will be a teleconference to be held on Tuesday, February 28, 2012, from 1:00 pm CST to 3:00 pm CST. AGENDA ITEM 6 - ADJOURNMENT Chairman Wilkerson adjourned the meeting at 3:11 p.m. Respectfully submitted, Clint Savoy BPWG Secretary Page 3 of 3
BUSINESS PRACTICES WORKING GROUP Meeting Attendance February 7, 2012 NAME ATTENDANCE STATUS COMPANY E MAIL PHONE Grant Wilkerson Y M Westar Grant.L.Wilkerson@westar.com 785 575 8074 David Adamczyk M KCPL David.Adamczyk@kcpl.com 952 984 3747 Ed Hammons Y M GRDA ehammons@grda.com James Hotovy Y M NPPD jrhotov@nppd.com 918 599 2966 Rick McCord Y M EDE RMccord@empiredistrict.com 417 625 5129 Kara Whillock M Tenaska Richard Ross Y M American Electric Power rross@aep.com Jessica Collins Y M Xcel Randy Gillespie M Kelson Energy randy.gillespie@kelsonenergy.com Robert Walker M Cargill Robert_walker@cargill.com Jenni Leger Y P Tenaska 402 563 5674 Clint Savoy Y S SPP csavoy@spp.org 501 614 3590 Charles Hendrix Y S SPP chendrix@spp.org 501 614 3546 Susan Polk Y S SPP spolk@spp.org Matthew Harward Y S SPP mharward@spp.org Terry Fang Y S SPP tfang@spp.org Robert Safuto Y G rsafuto@ces ltd.com Virat Kapur Y G The Wind Coalition vkapur@epeconsulting.com John Seck Y G KMEA seck@kmea.com Kristen Rodriguez Y G The Wind Coalition Shawn McBroom Y G OGE Bob Tumilty Y G American Electric Power Status: M Member P Proxy S SPP Staff G Guest
Clint Savoy From: Sent: To: Cc: Subject: Whillock, Kara [KWhillock@tnsk.com] Tuesday, February 07, 2012 8:46 AM Clint Savoy Leger, Jenni BPWG Hi Clint, Please give Jenni Leger my proxy for the BPWG meeting today. Thanks so much! Kara Whillock Director, Mid-Term Trading Tenaska Power Services Co. Office: 817-462-1523 Cell: 972-333-6122 1
Southwest Power Pool, Inc. BUSINESS PRACTICES WORKING GROUP MEETING February 7, 2012 1:00pm to 3:00pm CST Conference Call and Webcast AGENDA 1. Administrative Items... Grant Wilkerson a. Call to Order b. Receipt of Proxies c. Review the Agenda 2. Update on BPR027... Grant Wilkerson 3. BPR018 Generation Interconnection Process... Jim Hotovy 4. Generator Interconnection and Ag Study Customer Survey... Grant Wilkerson 5. Future Meetings... Clint Savoy a. February 28, 2012 Teleconference 1-3pm CST 6. Adjourn... Grant Wilkerson Deleted: <#>BPR018 Generation Interconnection Process Jim Hotovy
Business Practice Revision BPR BPR0018 Number Business Practice Section(s) Requiring Revision (include Section No., Title, and Protocol Version) Impact Analysis Required (Yes or No) MMU Report Required (Yes or No) Requested Resolution (Normal or Urgent) BPR Title Guideline for Clarifying Application of the SPP Generator Interconnection Procedures New business practice No No Normal Deleted: determining Jurisdiction Revision Description New BP Reason for Revision To provide a guideline to clarify application of the SPP Generator Interconnection Procedures set forth in Attachment V to the SPP OATT Deleted: determine which generator interconnection requests fall under the jurisdiction Tariff Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Yes, this proposed new business practice may impact, or be impacted by, language in Attachment V of the SPP OATT. Deleted: --This Deleted: the tariff Deleted: tariff Criteria Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Credit Implications (Yes or No, and summary of impact) Working Group/Committee Review and Results No No BPWG Pending final email approval by 11/17/2011 ORWG Pending final review for reliability impacts on 8/16/2011 RTWG Reviewed on 1/6/2011 and submitted comments. Reviewed on 8/25/11 and submitted comments. TWG Reviewed on 2/2/2011 and submitted comments. MOPC Voted to send the approved language back to the BPWG on 4/12/2011 for further editing. Page 1 of 4
Business Practice Revision Sponsor Name James R. Hotovy E-mail Address jrhotov@nppd.com Company Nebraska Public Power District Company Address 1414 15 th Street, Columbus, Nebraska 68601 Phone Number 402 563-5674 Fax Number Proposed New Business Practice Deleted: Language Revision X.XX GUIDELINE FOR CLARIFYING APPLICATION OF THE SPP GENERATOR INTERCONNECTION PROCEDURES Deleted: JURISDICTION OF Business Practice Guideline for Clarifying Application of the SPP Generator Interconnection Procedures Deleted: s Basic Principles of Applicability As set forth in Section 2.1 of Attachment V to the SPP Open Access Transmission Tariff ( OATT ), the OATT s Generator Interconnection Procedures ( GIP ) apply to the processing of Interconnection Requests for generator interconnections to the Transmission System that are subject to FERC jurisdiction. Any generator interconnecting to the Transmission System that is subject to FERC jurisdiction must submit an Interconnection Request pursuant to Attachment V to the SPP OATT. Exceptions to Applicability This guideline serves to clarify application of the GIP by providing examples of instances where the GIP would not apply because the interconnection request is not subject to FERC jurisdiction. Examples include, but are not limited to instances where: 1. The Generating Facility will be a Qualifying Facility ( QF ) where the QF s total output will be sold to its host utility according to PURPA and subject to state jurisdiction. 1 1 Interconnection Customer must provide documentation of Qualifying Facility FERC certification, substantiating state jurisdiction and documentation from the host that 100% of the output will be sold to the Deleted: of any size Deleted: Southwest Power Pool (SPP) Deleted: (IR) Deleted: the Generator Interconnection Procedures (GIP) found in Deleted: of Deleted: Regional OATT, with the following exceptions: Deleted: Where the Deleted: 100% of Deleted: A) The interconnection customer may still be required to enter into the appropriate SPP studies and agreements, provided that the Transmission Owner s Tariff directs the interconnection customer to the SPP Tariff. Page 2 of 4
Business Practice Revision 2. The Generating Facility will interconnect to a facility not already subject to the SPP OATT at the time the request is submitted, whether or not it plans to make wholesale electric energy sales. 2 3. The Generating Facility will produce electric energy to be consumed only on the Interconnection Customer s site. 3 4. The Generating Facility will be used to supply energy only to unbundled retail customers over local Distribution Facilities. 4 5. The Generating Facility will not operate in sustained parallel with the Transmission System. Deleted: Where the Deleted: under Tariff jurisdiction Deleted: B) The interconnection customer may still be required to enter into the appropriate SPP studies and agreements, provided that the Transmission Owner s Tariff directs the interconnection customer to the SPP Tariff. Deleted: Where the Deleted: C) Deleted: Where the Deleted: D) Deleted: Where the System Studies for Non-jurisdictional Facilities Generator interconnections, although not subject to the SPP OATT, may still require studies to identify impacts on SPP s or the Host Transmission Owner s transmission system. SPP and the Transmission Owner will evaluate each interconnection request not subject to OATT requirements and will make the final determination whether the interconnection request must be submitted to SPP or to the Transmission Owner for further study. In instances where further study is warranted, such studies will be performed by the Transmission Owner or SPP, at the direction of the Transmission Owner. Non-jurisdictional generator interconnection customers may be required to enter into the appropriate study agreements with SPP to facilitate an Affected System Agreement. Additionally, requests for non-jurisdictional generator interconnections to the Transmission System may be required to be coordinated with SPP in accordance with NERC standards. Deleted: the request Deleted: if Deleted: If any Deleted: above exceptions applies, the Generating Facility does not fall under the GIP. However, Deleted: request for interconnection Although such studies may be performed within SPP s GIP for planning purposes, the non-jurisdictional generator interconnection customer will not be subject to the SPP OATT. In such instances, the following shall apply: host utility. See FERC Order No.2003 PP 813-814; FERC Order No. 2006-A, PP 100-102; PURPA 292.203.a (3); PURPA 292.303. 2 See FERC Order No. 2006, PP 5, 8; FERC Order No. 2003 P 804; FERC Order No. 2003-A P 710; FERC Order No. 2003-C P 51. At the time an Interconnection Request is made to interconnect to a nonjurisdictional facility, the interconnection is not subject to the GIP. After a Generation Facility that makes wholesale electric energy sales has been connected, the interconnection facility is now subject to an OATT for Interconnection Requests made after that time. 3 See FERC Order No. 2003, P 805; FERC Order No. 2003-A, P 747, n. 173. 4 Unbundled retail service over local distribution facilities is not under FERC jurisdiction. See FERC Order No. 2006, PP 7-8 & n.8. Page 3 of 4
Business Practice Revision 1) When notified, the Transmission Owner is responsible for conducting any required studies to determine if the request may impact the Transmission System. 2) Should the Transmission Owner determine that the generator interconnection may impact the Transmission System, the Transmission Owner shall notify SPP of such impacts and provide to SPP any system impact studies that detail such impacts. 3) As an impacted system, SPP will determine what additional studies will be required to coordinate the impacts, up to and including studying the impact in the Definitive Interconnection System Impact Studies. The Transmission Owner/distribution provider shall require as a condition of interconnection with the interconnection customer, that all SPP required studies be completed. The Transmission Owner/distribution provider shall have the option to enter into the applicable Affected System study agreements and to be financially responsible for such studies 5, or as a condition of interconnection, to require the interconnection customer to submit an Interconnection Request to enter the Definitive Interconnection System Impact Study process or other SPP study process as applicable 6... 7 Deleted: Deleted: ; Deleted: Generator Deleted: Deleted: Queue Deleted: Queue 4) It shall remain the Transmission Owner s responsibility to complete any generator interconnection agreements in accordance with the Transmission Owner s generator interconnection procedures regarding the completion of Network Upgrades required on the Distribution System and on the Transmission Owner s transmission system. 5) If SPP s studies show that Network Upgrades are required on the Transmission System, the Transmission Owner/distribution provider shall have the option to enter into a facilities agreement with SPP or require, as a condition of interconnection, the interconnection customer to enter into a facilities agreement with SPP and any affected Transmission Owner(s)/distribution provider(s) to complete the Network Upgrades required on their Transmission System. 6) All Network Upgrades must be completed prior to operation of the Generating Facility, unless other mitigations have been approved by SPP until the Network Upgrades are completed. Explanation / Rationale This Business Practice is intended to be general information for SPP customers. 7 The Transmission/Distribution Owner has the ability to pass-through the Interconnection Study costs to its customer. 7 The Transmission/Distribution Owner has the ability to pass-through the Interconnection Study costs to its customer. 7 The Transmission/Distribution Owner has the ability to pass-through the Interconnection Study costs to its customer. Comment [s1]: 8/25/11 RTWG Chair Dennis Reed suggested that this subpart be revised to make it an option, rather than a requirement, for the Interconnection Customer to fund the upgrades. Deleted: Applicable References <#>Interconnection customer must provide documentation of Qualifying Facility FERC certification, substantiating state jurisdiction and documentation from the host that100% of the output will be sold to the host utility. See FERC Order No.2003 PP 813-814; FERC Order No. 2006-A, PP 100-102; PURPA 292.203.a (3); PURPA 292.303. <#>See FERC Order No. 2006, PP 5, 8; FERC Order No. 2003 P 804; FERC Order No. 2003-A P 710; FERC Order No. 2003-C P 51. At the time an Interconnection Request is made to interconnect to a non-jurisdictional facility, the interconnection is not subject to the GIP. After a Generation Facility that makes wholesale electric energy sales has been connected, the interconnection facility is now subject to an OATT for Interconnection Requests made after that time. <#>See FERC Order No. 2003, P 805; FERC Order No. 2003-A, P 747, n. 173. <#>Unbundled retail service over local distribution facilities is not under FERC jurisdiction. See FERC Order No. 2006, PP 7-8 & n.8. Deleted: 5 The Transmission/Distribution Owner has the ability to pass through the Interconnection Study costs to its customer. 6 As allowed by FERC Page 4 of 4
Business Practice Revision Page 5 of 4
Why do you interact with the study process in the way that you do? (ATSS) Why do you submit when you submit? (ATSS & GIP) What do you consider at the completion of each iteration? (ATSS) How much does the cost factor into the decision? (ATSS) Why would you withdraw? (ATSS) What do you think could change which would impact your behavior and help overall shorten the time line? (ATSS & GIP) Would you oppose a deposit to be required in order to be considered in each iteration? Would it be more beneficial to increase the deposit requirements as the study progresses? (ATSS) What kind of research is being performed by you prior to entering into the GIP? (GIP) Would you oppose a time limit for generators to construct their entire generating facility that has been granted interconnection service under the GIA? (GIP) At what point should the service agreements be issued? (ATSS) Would you be interested in a scoping and post-study review that would be coordinated with SPP prior to and following a request to interconnect completing the GIP? (GIP)