lgip_presentation_wcsc_mtg_012910 by t4Ri061


									   LGIP Issues/Background
 FERC issued Order 2003 in an attempt to
  standardize Large Generator Interconnection
  Procedures and Agreements amongst
  jurisdictional entities and ensure that all
  generators were being treated equally

                                       January 29, 2010
   LGIP Issues/Background
 Transmission Provider Queues are backlogged
 No assurance on cost or study timeframes for
 Large drop out rate causing restudies
 Volume of requests higher than anticipated
 Evolution of renewable technology
 Complications due to large number of JPP’s in
  the Western Region                    January 29, 2010
              LGIP Reform
   Joint Participation Projects
   Public Service Company of New Mexico
   Imperial Irrigation District
   Tri-State

                                      January 29, 2010
         JPP LGIP Reform
Create Standard LGIP/LGIA for JPP’s in Arizona
(and beyond) based on FERC standard LGIP/A
With variations as needed for:
   Different obligations of FERC-jurisdictional and
    public power co-owners
   Characteristics of interconnection to JPP’s
   Unique requirements of specific JPP facilities
                                              January 29, 2010
         JPP LGIP Reform
JPP’s with E & O approved LGIP’s:
     Southeast Valley Project, ANPP, Mead Phoenix
      Project, Mead – Adelanto Project and Southwest
      Valley Project

JPP’s working on LGIP’s for E & O approval:
     Navajo Project (STS), Four Corners, PV-NG1
      and Morgan Pinnacle Peak Project

                                           January 29, 2010
            JPP LGIP Reform
Participants in approved JPP LGIP’s:
  Arizona Public Service, City of Anaheim, City of Azusa, City of Banning,
  City of Burbank, City of Colton, City of Glendale, City of Pasadena,
  City of Riverside, City of Vernon, Electrical District No. 2, Electrical
  District No. 3, Electrical District No. 4, El Paso Electric Company
  Los Angeles Department of Water and Power, M-S-R Public Power
  Agency, Public Service Company of New Mexico, Salt River Project
  Southern California Edison Company, Southern California Public Power
  Authority, Southwest Transmission Cooperative,
  Tucson Electric Power Company, Western Area Power Administration

                                                            January 29, 2010
            JPP LGIP Reform
Stand Alone JPP LGIP/LGIA:
      FERC Jurisdictional entities to file as proforma JPP
       documents (these are not part of individual OATTs)
      Application submitted to Operating Agent of JPP
      Operating Agent responsible for coordinating studywork
       with owners and other affected utilities
      $250,000 at time of application
      $25,000 non-refundable

Site Control:
      $250,000 deposit will be accepted in lieu of site control

                                                        January 29, 2010
         JPP LGIP Reform
Eliminate Energy Resource and Network
Resource Interconnections and offer single basic
interconnection service:

Interconnection customer will have options for
study work:
     Same as existing FERC pro forma LGIP:
      Feasibility, System Impact and Facilities Studies
     Detailed study to identify network upgrades
      needed to accommodate firm transmission
      service to a specific system
                                              January 29, 2010
          JPP LGIP Reform
   LGIP’s approved by SEV, ANPP, MPP, SWV and
    Mead-Adelanto at spring 2009 E & O committee
   Have been publically posted (except SEV)
   LGIA’s available for E & O approval at spring 2010
   Jurisdictional entities are in the process of drafting
    FERC filing

                                                January 29, 2010
                PNM LGIP Reform
Application Fees:
    Projects 20 – 50 MW $50,000
    Projects 50 – 200 MW $100,000
    Projects greater than 200 MW $250,000

Site Control:
    Applicant must provide definitive proof of site control (some provision
     may be made the accommodate BLM site issues)

Feasibility Study Process:
    Eliminate Feasibility Study
    Replace with a pre-application consulting meeting
    PNM will provide system data base that reflects the existing PNM
     system so that customer can perform their own feasibility study

Tiered Clusters by Region
                                                                January 29, 2010
                   IID LGIP Reform
Deposit Requirements:
    $50,000 initial deposit is applied to cost of first study (additional
     $50,000 if no site control)
    $0 Feasibility Study Deposit
    $50,000 System Impact Study Deposit
    $70,000 Facilities Study Deposit
    30 days after a study review meeting, the deposit becomes non-
Data Acquisition:
    If a customer is unresponsive to the engineering staff, a ten (10)
     day termination notice will be given to the customer, if date is not
     provided, project will lose its queue position
                                                             January 29, 2010
            Tri-State LGIP Reform
     Deposit increased to $250,000
     $25,000 of deposit non-refundable
     Eliminated separate deposits for System Impact and Facilities Studies
Site Control:
     Eliminated deposit in lieu of site control
Queue Priority:
     Retained the concept of first come-first served for new Interconnection
      Requests through the System Impact Study stage with the following
     If a Customer shows that it can meet the milestones for a Facilities
      Study, a System Impact Study may be provided on a priority basis.

                                                                 January 29, 2010
      Tri-State LGIP Reform
Facilities Study Milestones:
    Customer must show continued site control

Network Resource Interconnection Service:
    Certification from a Tri-State Network Customer that the
     resource has been designated as a Network Resource; or
    Power Purchase Agreement

Energy Resource Interconnection Service:
    At Customer’s request, Tri-State will only study
     Interconnection Facilities
                                                        January 29, 2010
        Tri-State LGIP Reform
In mid-2010 Tri-State will implement a second round of
  LGIP reforms.
    These reforms include:
    Tiered deposits: $75,000 for 75 MW and below;
                        $250,000 above 75 MW
    Tiered Site Control: 25% at application, 50% prior to Facilities
     Study, and 100% prior to LGIA execution
    First come-first served through System Impact Study
    First ready-first served for Facilities Study:
        Have a customer, a transmission service reservation or agree to
         interconnect with no guarantee of transmission availability

                                                                 January 29, 2010
           LGIP Workgroup
 FERC Technical Conference in December
 Subsequently, FERC asked ISO’s and RTO’s
  to provide input for LGIP Reform:
   Increase deposits
   Streamline process by eliminate Feasibility Studies
   Prioritizing Queue Management
 Members of WestConnect also wanted to
                                              January 29, 2010
    LGIP Work Group Participation
   Arizona Public Service          Public Service of New
   BrightSource                     Mexico
   Element Power                   RES-America
   El Paso Electric                Salt River Project
    Company                         Shell Wind
   EnXco                           Southwestern Power Group
   Foresight Wind                  Southwest Transmission
   Grid Power                       Cooperative
   Imperial Irrigation District    Tessera Solar
   NMRETA                          Tri-State G & T Association
   NV Energy                       Tucson Electric Power
   PDS Consulting                  Western Area Power
                                                        January 29, 2010
              LGIP Work Group Goals
 Create more certainty for Transmission Provider and Interconnection
  Customer in regards to study timeframes and interconnection costs
 Reduce the length of time it takes to go through interconnection
 Standardize Process among WestConnect transmission providers
 Expedite process for interconnection customers that are ready to
  move forward (those with PPA, site control, financing)
 Reduce Re-studies
 Better alignment of interconnection requests and transmission
  service request studies
 Coordination of queues among multiple providers
 Integrate interconnection request study process with transmission
  planning study process within individual utilities and within region

                                                        January 29, 2010
   SGIP/SGIA issues are not included in this effort
   Approximately 25 possible issues were identified
   Phase 1 items were selected based on immediate impact
    and/or relative ease of implementation
   Remaining process improvements will be considered in
    the future
   Many Phase 1 items have been approved by FERC or
    have been viewed favorably in other areas (primarily ISO’s
    and RTO’s)
   FERC Staff has been briefed on the elements of this
    proposal and has encouraged us to move forward with
    this regional process
   Technical Task Force has been established to provide
    input on technical issues                       January 29, 2010
    Elimination of Feasibility Study
    Many interconnectors are requesting to waive the Feasibility study
    Many interconnectors are already hiring outside consultants to
     perform the Feasibility study
    The Feasibility studies are performed serially and not by cluster
     and therefore results can change substantially in the System
     Impact Study stage
    If some interconnectors in a cluster window elect to have a
     Feasibility study performed and others want to move directly to a
     System Impact Study, it causes a delayed start date for the
     System Impact Study for those that wanted to skip the Feasibility
    Eliminates duplication of cost by not having to perform both
     feasibility and system impact studies
                                                          January 29, 2010
   Amounts
   Interest
   Refundability
   Deposits in lieu of site control

                                   January 29, 2010
               Deposit Amounts
Option 1 – $250K regardless of MW size
    Based on FERC approved deposit requirements in
       other jurisdictions

Option 2 – $160K up to 75MW and 250K above 75MW
    It matches the total deposit amount in the current
    We wanted the amount to be large enough that it
       did not encourage generators to submit multiple
       smaller applications

                                               January 29, 2010
             Deposit Interest
 Non – Jurisdictionals to make their own
 Utilities would like to pay actual interest
  earned on deposits instead of the FERC
  rate in order to ensure that they remain
  cost neutral
 We are investigating the possibility of
  using escrow accounts                 January 29, 2010
     Refundability of Deposits
 Actual costs are non-refundable
 $25K non-refundable at the start of the SIS
  (Start of SIS is when actual study work starts)
 $50K non-refundable when the Facilities Study
  Agreement is signed
 The non-refundable amount is in addition to
  actual costs
 The non-refundable amounts are not cumulative
 Forfeited deposit money to fund re-studies for
  other applicants required due to higher queued
  generators dropping
                                        January 29, 2010
       Deposits in lieu of Site Control
Deposits will be accepted in lieu of site control
(each utility to determine criteria for acceptable
site control)
      The proposed elimination of feasibility studies
      The utilities recognize that a generator that is
       seeking to use state, federal or tribal land may not
       be able to complete that process in a timely
       manner                                      January 29, 2010
Deposits in Lieu of Site Control Amounts

 Option 1 – $250K regardless of MW size
 Option 2 – $160K up to 75MW and $250K above

    $25K non-refundable at the start of the SIS (Start
     of SIS is when actual study work starts)
    $50K non-refundable when the Facilities Study
     Agreement is signed

                                                January 29, 2010
 Deposits in Lieu of Site Control Amounts

A total of $250K deposit for any size
project would be required prior to signing
the LGIA. (This is the same requirement
as the current LGIP).

                                    January 29, 2010
         Cluster Windows
 Six month windows
 Need to determine best way to
  implement new cluster windows –
  some utilities may wish to grandfather
  existing requests and others may want
  to request a waiver similar to El Paso
 Facilities Study Clusters
                                 January 29, 2010
Eliminate +/- 10 or 20% Cost Option for Facilities Studies

    Estimates are based on the best information
     at the time the facilities study is performed.
    The most common fluctuation in cost is
     related to the time span between when the
     Facilities Study is performed and when
     facilities are actually built
    The interconnector will pay actual
     construction costs regardless of the
                                              January 29, 2010
Grandfathering of existing interconnection
    requests prior to reformed LGIP

Need to determine if all utilities will use the
same methodology or if each utility should
develop their own methodology for
grandfathering changes into existing queue.
Some utilities may need to clear backlog
more than others.
                                            January 29, 2010
Standard Engineering and Procurement

 To be comparable to Western, Tri-State,
 and FERC approved PNM Agreement

                                     January 29, 2010
WestConnect LGIA WorkGroup


                       January 29, 2010

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