ISO-NE PUBLIC
Al McBride
Initial Interconnection Analysis
General Overview of FCM Interconnection Standards
J U L Y 1 8 - 1 9 , 2 0 1 7 | M E R E D I T H , N E W H A M P S H I R E
D I R E C T O R , T R A N S M I S S I O N S T R A T E G Y & S E R V I C E S
Carissa P. Sedlacek D I R E C T O R , R E S O U R C E A D E Q U A C Y
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Today’s Discussion
• To provide an overview of the current procedures governing the integration of the new generator and Elective Transmission Upgrade (ETU) interconnection process with the Forward Capacity Market (FCM) – Background – Timelines for Interconnection – Resource Deliverability, Application of the Overlapping Impact Test
• At a future RC meeting, if there is interest by the committee, the ISO can provide an overview of other features available for interconnecting resources such as Long Lead Treatment and Conditional Qualification – Described in the Appendix of this presentation
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How we got here?
• Minimum Interconnection Standard (1998) – Minimum required upgrades, consistent with no degradation in transfer capability and
meeting reliability standards must be met such that system reliably is preserved
• In Order 2003, FERC promulgated the pro-forma Large Generator Interconnection Procedure (LGIP)
– Order 2006 covered Small Generator Interconnection Procedure (SGIP)
• In its November 8, 2004 Order, FERC stated that it may not be just and reasonable
– “For a generator in one location to sell its capacity as a capacity resource to, and receive capacity payments from, a load in another location if the generator's output is not deliverable to the load that buys the capacity”
• FCM/Queue Reforms (2008) – Improved coordination between the requirements of the Forward Capacity Market and
the Generator Interconnection Process – Addressed Intra-Zonal Deliverability in New England – Replaced the “first-come, first-served” approach with a combination of a “first-come,
first-served” and “first-cleared, first-served” approach for CNRIS – Result: Established two types of Interconnection Service
• Capacity Network Resource Interconnection Service (CNRIS) • Network Resource Interconnection Service (NRIS)
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Background How to Interconnect and Governing Documents
• Schedules 22, 23, and 25 of the Open Access Transmission Tariff OATT (LGIP/SGIP/ETU Interconnection Procedures) govern the process for interconnection – Provides interconnection service for participation in the energy market
• Market Rule 1, Section 13 (Forward Capacity Market Qualification) govern the process for load zone deliverability – The initial interconnection analysis is performed pursuant to Section
III.13.1.1.2.3. of the ISO-NE tariff and Planning Procedure No. 10 - Section 5.7 (Initial Interconnection Analysis under the Network Capability Interconnection Standard) and Section 5.8 (Analysis of Overlapping Interconnection Impacts)
– Milestones required to achieve interconnection service for participation in the capacity market
• Participation in the Forward Capacity Market is not required for interconnection to the New England transmission system
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TIMELINE
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LGIP/SGIP/ETU Interconnection Process
• Studies are separate and distinct from the FCM studies
• Timeframe to perform these studies are described in Schedules 22/23/25 of the OATT, and successful completion results in an Interconnection Agreement
Feasibility Study*
System Impact Study
Facilities Study*
Interconnection Agreement
Development Construction
* Optional Studies Note: Details of these studies is provided in Appendix A of this presentation
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FCM Participation
• Qualification includes a Critical Path Schedule review and initial interconnection analyses, including application of the overlapping impact analyses. Result is a Qualification Notification Determination (QDN)
• Uses LGIP/SGIP/ETU study results whenever possible
3 years, 2 months 2 months
Show of
Interest FCAx CCPx
4 years, 1 ½ months
Qualification Package QDN
3 ½ months*
*During this time, ISO-NE staff will seek input from Transmission Owners before finalizing the necessary interconnection transmission upgrades
4 months
FCA Restudy
~ 2 months
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Timeline of FCA and Interconnection Queue Process
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*aka Preliminary Non-Binding Overlapping Impact Study (PP5-6)
Preliminary Non-Binding Analysis*
If project clears in FCAn it undergoes post FCA restudy to determine final upgrade responsibility
FCM Qualification Reviews
(5 ½ months)
Auction Prep FERC Review
(4 months) FCAn
Capacity Commitment
Periodn
3 years, 4 months
QDN Notification
Project applies to FCAn
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RESOURCE DELIVERABILITY Application of the Overlapping Impact Test
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FCM Initial Interconnection Analyses Objective
• Assess the ability to interconnect a resource subject to the Network Capability Interconnection Standard (NCIS)* – Steady State Analysis – Short Circuit Analysis
• Assess the ability of a resource to provide incremental capacity in accordance with the Capacity Capability Interconnection Standard (CCIS) – Thermal Analysis
* LGIP/SGIP/ETU interconnection study results are used when available
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Overview of Initial Interconnection Standards
• The transmission line between Substation 1 & Substation 2 (1-2) becomes overloaded when Gen A is added
• Generators that add to the loading of 1-2 are called Harmer Generators
• Generators that reduce the loading of 1-2 are called Helper Generators “Helper”
Generation
“Harmer”
Generation
Zone
1 2
New Study Generator
Gen A Potential Overload
From 1 to 2
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Description of Initial Interconnection Standards
• Under NCIS, other Harmer Generation energy can be re-dispatched down to relieve overload
• Combined new generator & re-dispatched energy must not degrade transfer or import capability
• Although energy dispatch is achieved, the new generator may not be incrementally useful as new capacity
• Under the CCIS, Harmer Generation may not be re-dispatched to relieve the constraint in an attempt to make the new generator incrementally useful as a capacity resource
• New Generator must not degrade transfer or import capability
NCIS
CCIS
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OVERLAPPING IMPACT ANALYSIS
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Goal of Overlapping Impact Analysis
• To determine if a proposed New Generating Capacity Resource, External ETU or active Demand Resource provides incremental capacity to the system in a manner that meets Capacity Capability Interconnection Standards (CCIS) – Provides an incremental capacity benefit; able to operate without re-
dispatch of other capacity resources – Is deliverable to the rest of the Load Zone
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OVERLAPPING IMPACT ANALYSIS Study Criteria
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Generator Re-dispatch Criteria
• Generation re-dispatch is dependent on the Distribution Factor (DFAX) of the generators (on a transmission element) in the study subsystem
• DFAX is a measure of the change in electrical loading on an element such as transmission line or transformer due to a change in output from a given generator – This distribution factor is computed by the power system software
that is used for the analysis (e.g. PSSE and PowerGEM TARA)
• Harmer generation with DFAX ≥ 3% on a monitored element for a given contingency is not to be re-dispatched to relieve the constraint for a given study dispatch
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Transfer Level Criteria
• Transfer levels from external control areas are modeled to reflect various conditions ranging from 0 MW transfer up-to the associated interface import capability
• Internal transfer levels are modeled to reflect various conditions ranging from 0 MW transfer up-to the internal interface transfer capability
• Generation under study is not required to upgrade interface transfer capability between Load Zones but it is responsible to maintain current limits
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General Test Conditions
• Test is performed at 100% of the 90/10 summer peak load including the Solar Photovoltaic Forecast
• Existing generation that has not permanently de-listed or retired in a previous FCA is modeled at its CNRC
• Existing Demand Resources are included in the base case
• All single element contingencies and multiple element contingencies as used in the interconnection analyses
• The post contingency system is analyzed, if appropriate, to confirm that the system can be brought to a state that is prepared for the occurrence of a subsequent contingency (n-1-1) in the time required by, and using the actions allowed in, the applicable ISO New England Planning Procedures and Operating Procedures
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Study Outcome and Determinations
• Generators and ETUs projects are studied in queue order* and required transmission upgrades allocated accordingly
• Qualification is restricted by overlapping interconnection impacts when the upgrade(s) identified for a new generator cannot be completed by the start of the requested CCP
• Where upgrades can be completed in time, the resource will be qualified – Upgrades identified in the analysis that are the same/similar to a
Transmission Upgrade in RSP will be paid for by the region – Upgrades associated with generator interconnection findings will be
paid for by Project Sponsor
• If applicable, the resource may be partially qualified * Non-FERC jurisdictional generation shall be evaluated based on the date a request was accepted by the interconnecting transmission owner
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Study Outcome – Example 1 (Disqualified)
Overload of Line S1S2 a) There is 150 MW of existing
generation at S1, but only 150 MW
can run without upgrading the
S1S2 line
b) If upgrades cannot be done by the
start of the Capacity Commitment
Period, new resource Gen A
cannot qualify for the FCA
100 MW 150 MW
200 MW
S1 S2
S3
S4
Gen A
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Study Outcome – Example 2 (Qualified)
Overload of Line S1S2 a) There is 300 MW of generation at
S1 (including 100 MW of existing
generation), but only 200 MW can
run without upgrading the S1S2 line
b) Alternatives are
1. If upgrade cannot be done by the
start of the Capacity Commitment
Period, qualify Gen A at 100 MW
(provided that Gen A Eco Min is ≤
100 MW)
2. If upgrade can be done by the start
of the Capacity Commitment Period,
then qualify Gen A at 200 MW
• The resource is required to
work with the TO to ensure the
upgrade is completed by the
start of the Capacity
Commitment Period
100 MW 100 MW
200 MW
S1 S2
S3
S4
S1S2 line overload
eliminated by backing down
100MW @ S1
Gen A
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Qualification Transmission Upgrades (QTU)
• QTUs are identified through the Overlapping Impact Analysis
• The study resource is responsible for impacts where addition of the study resource’s capacity results in an overload on a transmission element that is: – Greater than or equal to 2% of the applicable thermal rating (LTE) – Greater than 10 MVA of applicable thermal rating (LTE)
• Reference Section 5.8. of Planning Procedure 10 for additional information on QTU identification
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ASSIGNING CAPACITY NETWORK RESOURCE CAPABILITY Post-FCA Restudy
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Assign Capacity Network Resource Capability
• After the FCA, upon completion of the post-FCA restudy, the project sponsor will be provided a final list of transmission upgrades – Progress of these transmission upgrades will be included in the FCM
Critical Path Schedule report
• CNRC is the highest megawatt amount of the Capacity Supply Obligation (CSO) obtained by the Generating Facility in accordance with Section III.13 of the Tariff*
• A new generating resource that obtains a CSO in the FCA will be assigned a CNRC value equal to its CSO MW
• An existing capacity resource that cleared additional CSO in the FCA will be assigned a CNRC value that is equal to the total of existing CNRC and additional CSO MW – CNRC = Existing CNRC + Additional CSO MW(above the existing CNRC) – The Interconnection Agreement for a resource that obtains a CSO will be
amended to reflect the resource’s Capacity Network Resource Capability
* CNRC is achieved upon completion of the required transmission upgrades and commercial operation
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Summary
Today’s presentation provided detailed information regarding:
• Timelines for Interconnection
• Resource Deliverability, including application of the Overlapping Impact Test
• Examples of how the Overlapping Impact Test is applied
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APPENDIX A Description of LGIP/SGIP/ETU Studies and Process
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What is a Scoping Meeting?
• Attended by representatives of ISO New England, interconnection customer, interconnecting transmission owner, and affected parties (as identified by ISO New England)
• Held within 30 days of valid LGIP or ETU Interconnection Request; within 10 days of valid SGIP Interconnection Request
• Meetings have standard agendas
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What is the Feasibility Study Process?
• Study analysis consists of preliminary power system analyses – Includes: thermal analysis, voltage analysis, short circuit analysis, and protection system
assessment
• Determine physical feasibility of interconnection
• Develop good faith estimates of interconnection costs, system upgrades and construction time for interconnection facilities and upgrades
• Hold study results meeting within 10 days of issuance of draft report to the Interconnection Customer
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Feasibility Study
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What is the System Impact Study Process?
• To expedite Interconnection, Feasibility Study can be performed as first step of SIS – SIS includes short circuit, stability, power flow, including thermal and
voltage, analyses – Determination of Bulk Power System (BPS) status – Special analysis, if needed – Note: under SGIP, separate distribution studies may be warranted
• Hold study results meeting within 10 days of draft report provided to interconnection customer*
System Impact Study
* Interconnection customer may request a sensitivity analysis, excluding interconnection requests, earlier in the queue. Request for optional study must be made within five (5) business days of SIS results meeting
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Preliminary Non-Binding Analysis of Overlapping Impacts
• Developer can specify which earlier queued projects to model – Allows the generator to make assumptions to approximate the
outcome of the overlapping impact analysis
• Developers can specify which Regional System upgrades to include in the network model
• Useful if interconnection customer is concerned about potential transmission upgrades
• Most useful when performed prior to submitting an SOI for FCM ~ usually takes 2-3 months to perform study
• Note: Final binding upgrade responsibilities are determined in the FCM Group Study and post-FCA restudy
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What is the Facilities Study Process?
• Specifies and estimates cost of the equipment, engineering, procurement, and construction work needed to implement the conclusion of the SIS
• May be waived to expedite the Interconnection Agreement
• Study results meeting must be held within 10 days of draft report being provided to interconnection customer
Facilities Study
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What does the Interconnection Agreement Include?
• Provides terms and conditions on: – Scope and Limitations of Agreement – Inspection, Testing, Authorization, and Right of Access – Effective Date, Term, Termination, and Disconnection – Cost Responsibility for Interconnection Facilities and Distribution Upgrades – Cost Responsibility for Network Upgrades – Billing, Payment, Milestones, and Financial Security – Assignment, Liability, Indemnity, Force Majeure, Consequential Damages, – and Default – Confidentiality – Disputes & Taxes – Notices
• Includes detailed descriptions of: – The generating facilities or Elective Transmission Upgrade – The interconnection facilities – Network or Distribution Upgrades – Affected System upgrades – Type and amount of Interconnection Service – Milestones to achieve commercial operation
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Engineering & Procurement (E&P) Agreement
• Interconnection customer may request an Engineering & Procurement Agreement to accelerate its project
• E&P Agreement is a two-party agreement between the interconnection customer and transmission owner
• Deposit of 100% of study costs required
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I.3.9 Approval Process
• The Interconnection Customer or Transmission Owner makes a Proposed Plan Application (PPA) after SIS is complete – RC makes recommendation to ISO New England – ISO-NE issues letter stating project has no adverse impact – Must be approved/completed before a project can synchronize – Generating Facilities 5 MW or less only required to notify ISO-NE and
the RC
• I.3.9 approval letters are available at: http://www.iso-ne.com/system-planning/transmission-planning/proposed-plan-applications
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ISO New England Interconnection Queue
• Interconnection Queue is available on the ISO website at: – http://www.iso-
ne.com/genrtion_resrcs/nwgen_inter/status/index.html
• Queue contains: – Active projects connecting to Administered Transmission System – Active projects connecting to distribution systems in the New England
area or nearby transmission systems – Commercial projects – Withdrawn projects
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APPENDIX B Other Features Available for Interconnecting Resources
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Elective Transmission Upgrades
• In April 2015, FERC approved the interconnection procedures for Elective Transmission Upgrades (ETUs) – New Schedule 25 in the ISO OATT that governs the interconnection of
all forms of ETUs to the New England system • Closely modeled on, and integrated with, the generator interconnection
procedures
– Established interconnection service rights for certain ETU types • New controllable External ETUs
– Enabled an Internal ETU to become directly associated with a specific Generating Facility seeking CNRIS
• So that it can be studied together with the Generating Facility and thereby increase the Generating Facility’s ability to qualify for the FCM
– Did not alter the existing Tariff structure • ETUs must function within the existing dispatch, market and tariff
structures of the New England system
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Attachment K
• Attachment K, Section 4.1(f) of the ISO New England Inc. Open Access Transmission Tariff (OATT) governs the treatment of market solutions in Needs Assessments
• Under Attachment K, the ISO is required to include New Capacity Resources that are contractually committed pursuant to a state-sponsored Request for Proposal or a similar financially binding contract in the ISO's planning process – Includes FCM, transmission build-out, etc...
• For FCM, PP-10 requires a written statement confirming the new resource's selection or assumption of its contractually binding obligations before including the resource in its base case for reliability reviews performed as part of the delist bid analyses
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Queue Position Timeout
• Queue position timeout rules were not created or changed as a part of the FCM/Queue reforms – Timeout rules are long standing features of the FERC pro forma
interconnection procedures
• In Order 2003, when constructing the pro forma timeout provisions, FERC sought to balance: – Varying lead times associated with different generation development
types, and, – Delays that can be experienced in generation development – Need to maintain some limits on the extent of uncertainty introduced
to the overall transmission planning process
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Queue Position Timeout cont’d
• (In the Interconnection Request) The expected In-Service Date shall be no more than the process window for the regional expansion planning period… not to exceed seven years from the date the Interconnection Request is received by the Transmission Provider – Up to 10 years lead-time can be requested, if required by the
development timeline
• Extensions of less than three (3) cumulative years in the Commercial Operation Date of the Large Generating Facility to which the Interconnection Request relates are not material and should be handled through construction sequencing
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FCM Participation
3 years, 4 months 9 ½ months
Show of Interest FCAx CCPx CCPx+1 CCPx+2
7 years, 1 ½ months An in-service date for CCPx+3 is more than 7 years after the date of the Interconnection Request
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Long-Lead Facility Treatment
• Power plants with development life-cycles that are longer than the time between the FCA and the beginning of the Capacity Commitment Period will be allowed advance opportunity to study and “secure” transmission plans/obligations sufficient for FCM participation through the LGIP/SGIP/ETU process
• Long-Lead Facility Treatment can be elected along with the original Interconnection Request (IR) or after the IR
• The resource would initially present a Critical Path Schedule in the same format as a resource seeking qualification for an FCA
• The resource will be included in each FCA’s qualification study after the completion of its System Impact Study (SIS)
• Until the resource clears in an FCA, the resource will provide Financial Assurance (FA) in the form of an annual interconnection deposit
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Conditional Qualification
• Where multiple new generating resources cannot be qualified because they overlap with each other – Interconnection Queue order is used to choose between the
overlapping generators
• Conditional qualification provisions exist in instances where a resource may not qualify as a result of overlapping interconnection impacts with another resource – Resource with lower queue priority (Queue Position X+n) is accepted
for participation in the FCA as a Conditional Qualified New Generating Capacity Resource
– The Conditional Qualified Resource may clear in the FCA if the resource with higher queue priority (Queue Position X) “withdraws” prior to or during the auction
– Reference Section III.13.1.1.2.3(f) of the Tariff for additional information on Conditional Qualified Resources
