Large Generator Interconnection Procedures
Reform
2nd Stakeholder Meeting
May 5, 2009
May 5, 2009
2
Agenda
• Background
• Review of Overall Process and Discussion of Comments
• Proposed Schedule
May 5, 2009
3
February Proposal
• Most of the changes adopted in January 2009 were retained.
• Interconnection process based on Load and Resource Study and related Transmission Study.
• New options for determining Network Upgrades.
• Biannual Interconnection Request Windows.
May 5, 2009
4
February Proposal
• Queue Management:– First Come-First Served through the System
Impact Study;– First Ready-First Served after the System
Impact Study.
• Multiple Customer options for proceeding to Facilities Study.
Customer Shows
Designation as Network Resource &
submits deposit
Review Published
Load & Resource
Trans-mission Study
LGIA100% Site
Control Required
Two month windows to
submit application.
IR Applications reviewed on semi-annual
basis.
Attend Information Session at Beginning
of IR Application
Window
Customer will have access to Base Case Data and may perform own
Optional Feasibility Studies
Facilities Study
Customer submits deposit & TSR or proceeds at own
risk
Defer up to 1 year
Submit IR
Network Upgrade Studies
Customer
TSR Path
At Risk Path
$250,000 Study Deposit for >75 MW ProjectsOR,
$125,000 Study Deposit for ≤ 75 MW Projects (Includes $25,000 non-refundable for both
generation levels)
Proof of 50% site control at time of application
SIS Scoping Meeting
Three levels of generation
allowed and specified for study at time of meeting
SIS After power flow portion
of SIS, customer is must select
one generation
level
SIS Review
(with cost estimates)
and FS
Scoping Meeting Verify 50% of
Site Control
A B C DIC Facilities & Unit Specific
Network Upgrades
Review Published Load & Resource
Transmission Study
Attend Information Session at beginning
of IR Application Window
Customer will have access to Base Case Data and may
perform Optional Feasibility Studies
Customer
A
$250,000 Study Deposit for >75 MW ProjectsOR,
$125,000 Study Deposit for ≤ 75 MW Projects
(Includes $25,000 non-refundable for both generation levels)
Two-month windows to submit application IR Applications reviewed on semi-annual basis.
Submit IR
B
Proof of 50% site control at time of application
SIS
After power flow portion of SIS, customer is asked to select one
generation level
SIS Scoping Meeting
Three levels of generation allowed and specified for study at time of meeting
IC Facilities and Unit-Specific
Network Upgrades
C
Customer shows designation as Network
Resource & deposits 50% of IC Facilities & unit-specific Network
Upgrades money
LGIA
SIS Review (with cost
estimates) and FS Scoping Meeting
Verify 50% of Site Control
Facilities Study
Customer deposits 50% of IC Facilities and unit-specific
Network Upgrades money and submits TSR or proceeds at own risk
Defer up to 1 year
Network Upgrade Studies
TSR Path
At Risk Path
D
May 5, 2009
10
Network Resource Path• Network Customers submit Annual Load and
Resource Plan.• Tri-State prepares Load and Resource Plan and
related Transmission Plan.– Resource Zones identified
– Network Upgrades identified
– Tri-State funds the cost of Network Upgrades
• Customer demonstrates that it is a planned Network Resource within Resource Zone.
May 5, 2009
11
Network Resource Path• Facilities Study includes:
– Interconnection Facilities– Unit-specific Network Upgrades required to interconnect
the facility• Example: Ring Bus at Interconnection Substation is considered a
Network Upgrade
• Interconnection Customer will fund Interconnection Facilities and unit-specific Network Upgrades.
• Interconnection Customer will receive transmission credits for Network Upgrades.
Customer shows designation as Network
Resource & deposits 50% of IC Facilities & unit-specific Network
Upgrades money
LGIA
SIS Review (with cost
estimates) and FS Scoping Meeting
Verify 50% of Site Control
Facilities Study
Customer deposits 50% of IC Facilities and unit-specific
Network Upgrades money and submits TSR or proceeds at own risk
Defer up to 1 year
Network Upgrade Studies
TSR Path
At Risk Path
D
May 5, 2009
13
Transmission Reservation Path• Customer’s Generating facility is not a
Network Resource within a Resource Zone.• Customer requests transmission under Tri-
State’s Open Access Transmission Tariff.• Tri-State performs Transmission System
Impact Study. – Identifies Network Upgrades required to deliver
power across the system, not unit-specific Network Upgrades.
May 5, 2009
14
Transmission Reservation Path
• Interconnection Facilities Study:– Studies Interconnection Facilities and unit-specific
Network Upgrades.– Incorporates results of Transmission System Impact
Study Interconnection Customer funds Network Upgrades.
• Interconnection Customer will fund Interconnection Facilities and unit-specific Network Upgrades.
• Interconnection Customer will receive transmission credits for Network Upgrades.
Customer shows designation as Network
Resource & deposits 50% of IC Facilities & unit-specific Network
Upgrades money
LGIA
SIS Review (with cost
estimates) and FS Scoping Meeting
Verify 50% of Site Control
Facilities Study
Customer deposits 50% of IC Facilities and unit-specific
Network Upgrades money and submits TSR or proceeds at own risk
Defer up to 1 year
Network Upgrade Studies
TSR Path
At Risk Path
D
May 5, 2009
16
At-Risk Path• Customer’s Generating facility is not a Network
Resource within a Resource Zone.• Customer chooses not to request transmission.• Interconnection Facilities Study:
– Studies Interconnection Facilities and unit-specific Network Upgrades
• Interconnection Customer will fund Interconnection Facilities and unit-specific Network Upgrades.
• Interconnection Customer will receive transmission credits for Network Upgrades.
• Customer may use transmission system on an as-is basis, at its own risk for deliverability.
May 5, 2009
17
Facilities Study Deferral
• If Customer has not met all Facilities Study requirements, it may request one-time delay of up to 1 year.
• When Customer is ready for Facilities Study, it is scheduled behind any other request that has previously met Facilities Study milestones. – First Ready First Served
• Tri-State will use the original System Impact Study but may be required to update the study to reflect system changes during the deferral period.
Customer Shows
Designation as Network Resource &
submits deposit
Review Published
Load & Resource
Trans-mission Study
LGIA100% Site
Control Required
Two month windows to
submit application.
IR Applications reviewed on semi-annual
basis.
Attend Information Session at Beginning
of IR Application
Window
Customer will have access to Base Case Data and may perform own
Optional Feasibility Studies
Facilities Study
Customer submits deposit & TSR or proceeds at own
risk
Defer up to 1 year
Submit IR
Network Upgrade Studies
Customer
TSR Path
At Risk Path
$250,000 Study Deposit for >75 MW ProjectsOR,
$125,000 Study Deposit for ≤ 75 MW Projects (Includes $25,000 non-refundable for both
generation levels)
Proof of 50% site control at time of application
SIS Scoping Meeting
Three levels of generation
allowed and specified for study at time of meeting
SIS After power flow portion
of SIS, customer is must select
one generation
level
SIS Review
(with cost estimates)
and FS
Scoping Meeting Verify 50% of
Site Control
A B C DIC Facilities & Unit Specific
Network Upgrades
May 5, 2009
19
Proposed Schedule
• May 15th—Tri-State will post draft LGIP.
• June 12th —Comments due on draft LGIP.
• 30 days prior to Effective Date—post final LGIP on OASIS.
• Late Summer 2009—LGIP is effective.
• 30 days after Effective Date—publish Load and Resource Transmission Study.
May 5, 2009
20
Addendum
• Summary of Comments and Tri-State responses
May 5, 2009
21
Key Comments and Responses
• Feasibility Studies—elimination of Feasibility Study has negative impact on applicants —Establish Pre-Application Queue process and make Feasibility Study optional.
• Experience for Tri-State is that Feasibility Studies provide little value.
• Encourage applicants to conduct own screening studies using available WECC base-case data.
May 5, 2009
22
Key Comments and Responses
• Deposits—request for reduced, staged deposits: $40,000 to $90,000
• Tri-State deposits are intended to cover the estimated cost of Interconnection Studies and administration costs.– The suggested deposits will not cover study costs.
– $25,000 will be non-refundable
• The deposits will be used for study costs plus cost of administering requests.
May 5, 2009
23
Key Comments and Responses
• Site Control—requirements are too burdensome and too soon in the process.
• Site Control is key to assessing the validity of interconnection requests.– Retain existing requirement for 50% of site control at
application.– Delay 100% site control until execution of LGIA.
• Strict site control requirements benefit both Tri-State and Interconnection Customers by helping to identify valid projects.
May 5, 2009
24
Key Comments and Responses
• Site Control—continued Tri-State expectations: At application Tri-
State expects the application to include documentation of lease or ownership rights as along with a GIS map of the entire site with the areas under contract or option highlighted on the map. Documentation would typically include copies of leases, deeds, or option agreements, which Tri-State will treat as confidential information.
May 5, 2009
25
Key Comments and Responses
• Cluster Studies will be more effective than stand-alone studies proposed by Tri-State.
• Tri-State does not agree that cluster studies will be more effective way of studying Interconnection Requests.
• However, Tri-State has retained the right to use cluster studies where it determines that they may be a more efficient way of studying Interconnection Requests.
• Tri-State is prepared to discuss this issue as part of the stakeholder process.
May 5, 2009
26
Key Comments and Responses
• Interconnection Studies should be linked to Long-Range Transmission Planning.
• Tri-State will continue to use WECC base-cases modified to meet the needs of the Interconnection process. – Facilities identified in long range plans are often
scheduled after the generators’ in service date.
– Long-Range projects do not have CPCNs and can not be counted out for planning Network Upgrades.
May 5, 2009
27
Key Comments and Responses
• Suspension—Tri-State should expand ability to suspend construction—developers need more flexibility.
• Suspension undermines certainty of planning process.• Customer has the ability to delay in-service date up to
5 years, but construction will proceed if it affects other requests.
• Option to delay Facilities Study for up to one year.
May 5, 2009
28
Key Comments and Responses• Proposal is discriminatory and may violate FERC
Order 2003• Tri-State, as a non-jurisdictional, is subject to
limited FERC jurisdiction – Tri-State must meet FERC’s comparability and non-
discrimination requirements
– Tri-State’s proposal meets those thresholds
• Tri-State proposes 3 paths for interconnection.– The paths are not intended to be equivalent but to
provide customers options to interconnect