FERC last week partially accepted SPP’s compliance filing to Orders 845 and 845-A, directing the RTO to submit a further changes (ER19-1954).
The commission found SPP complied with six of the 10 revisions it was directed to make to its pro forma large generator interconnection agreement (LGIA) and pro forma large generator interconnection procedures, but only partially complied with the other four.
It gave the RTO 60 days to submit compliance filings related to identification and definition of contingent facilities; provisional and surplus interconnection service; and material modifications and incorporation of advanced technologies.
FERC found that SPP’s method for determining contingent facilities — unbuilt interconnection facilities and network upgrades upon which the interconnection request is dependent — lacked the “requisite” transparency to ensure it will be applied on a nondiscriminatory basis. The commission directed the RTO to specify the thresholds or criteria it will use in its technical screens or analysis.
The commission said SPP’s revision to allow interconnection customers to request provisional service only if its requested in-service date precedes the study’s projected completion did not comply with Order 845. It ordered SPP to remove the limitation in its compliance filing.
FERC also found that the RTO failed to support its proposed “independent entity variation” from the Order 845 requirement to identify any additional necessary interconnection facilities and network upgrades in surplus interconnection service study results. SPP had proposed to identify only necessary interconnection facilities — and not network upgrades — in those studies. The commission also rebuffed a proposal to hold the original customer, instead of the surplus customer, responsible for any study costs beyond the original deposit to be unjust and unreasonable. The commission ordered further compliance filings for both revisions.
Finally, FERC said that because SPP’s proposed “permissible technological advancement” definition and change procedure was silent on whether SPP will explain to the customer why a proposed technological advancement is a material modification, it required the RTO provide an explanation if it cannot accommodate a proposed technological advancement without triggering the material modification provisions.
FERC issued Orders 845 and 845-A in 2018 and 2019, respectively, to increase the transparency and speed of generator interconnection processes. (See FERC Order Seeks to Reduce Time, Uncertainty on Interconnections.)
The commission last year approved SPP’s three-stage study process, meant to improve its interconnection procedures. (See FERC OKs New SPP Interconnection Process.)
Commission Rejects Springfield’s Rehearing Request
The commission last week denied City Utilities of Springfield’s (Mo.) request to rehear a 2019 order rejecting the utility’s complaint against SPP over how the RTO administers transmission cost allocations (EL19-62).
Springfield had appealed FERC’s August decision that SPP’s administration of regional cost allocation reviews (RCARs) was not unjust and unreasonable. The utility filed a complaint under Federal Power Act Section 206 alleging that SPP’s highway/byway cost allocation methodology has produced unintended consequences in its pricing zone that violated the cost-causation principle and the “roughly commensurate” standard. (See FERC Denies Springfield Utilities’ Complaint vs. SPP.)
The order also clarified that FERC’s denial “should not be construed as eliminating SPP’s obligations” under the Tariff.
Springfield contended that the commission erred in its initial finding by not finding that the Tariff language provides for retroactive adjustments to allocated costs if “analysis show[s] an imbalanced cost allocation in one or more [transmission] zones.” The utility said “reallocation of … costs … is well within [FERC’s] remedial authority” and argued that the Tariff does “prescribe a methodology for changing cost allocations based on the outcome of the RCAR studies.”
FERC disagreed that the language “unambiguously” provides for retroactive adjustments. It said the language is ambiguous because a recommendation to change allocated costs “could refer to a prospective adjustment for future allocations.”
The utility’s transmission zone in southwestern Missouri is the only one where the benefit-cost ratio does not meet SPP’s minimum threshold, Springfield said in its original complaint.
The commission said it did not dispute that the first two RCAR analyses revealed “an imbalanced cost allocation to Springfield’s zone, and we do not minimize or discount the significance of this imbalance.” However, it also said the “unintended consequence” of a cost imbalance “does not compel the conclusion that SPP’s administration … is unjust, unreasonable, or unduly discriminatory or preferential.”
FERC said SPP’s Tariff provides avenues to address alleged imbalanced cost allocations. It suggested Springfield request the grid operator’s Regional State Committee, composed of state regulators, to provide recommendations to adjust or change the allocated costs.
Changes for Sponsored Upgrade Security Costs
FERC on Jan. 14 issued an order accepting SPP’s Tariff revisions to reduce the risk of incurring unnecessary financial security expense related to certain transmission upgrades (ER19-2669).
The Tariff changes, effective Oct. 20, 2019, apply to sponsored upgrades outside of SPP’s transmission planning processes and that are proposed by entities that will assume the cost of the new facilities. The changes also apply to system upgrades needed to fulfill eligible customers’ requests for long-term transmission service.
Under the revision, no payment security will be required when the project sponsor and TO are the same entity. The security requirements will also be waived when the TO building an upgrade to meet a service request notifies SPP it has already received sufficient payment security from the customer.
— Tom Kleckner
