By Tom Kleckner

OKLAHOMA CITY — SPP’s Markets and Operations Policy Committee last week continued to hash through the difficulties of reporting behind-the-meter (BTM) load, a holdover issue from its previous two meetings.

In July, the committee directed a stakeholder group to address “inconsistency and uncertainty” over which BTM generation qualifies as network load. In October, the committee rejected the Regional Tariff Working Group’s proposal of a 1-MW threshold for reporting BTM network load, and the Board of Directors declined to reverse the decision on an appeal by Southwestern Public Service. (See “Stakeholders Unable to Reach Consensus on Network Load,” SPP Markets and Operations Policy Committee Briefs.)

SPP staff shared with the MOPC and the Strategic Planning Committee initial results of a survey of network integration transmission service (NITS) customers. The survey focused on NITS load reporting, with an emphasis on grandfathered agreements (GFAs), BTM generation and “special circumstances.”

“It was unclear to us in whether all the behind-the-meter gen was identified, and then netted with the load,” said SPP COO Carl Monroe. “There was some controversy as to whether you can net the load with behind-the-meter generation.”

Monroe said staff are reviewing the survey responses and asking follow-up questions, such as:

• What load and BTM generation is netted versus added?
• Why are some grandfathered megawatts not being included in resident load? (Resident load is a term SPP uses to ensure all load is paying Tariff rates.)
• What are the details of the “special circumstances”?

Monroe said the aim is to foster continued discussion and education, and to determine the consistency of members’ NITS reporting practices. He hopes to produce a final report in April.

“One of the real concerns is that stakeholders with network load may not really understand what needs to be reported. Your survey results may indicate a lack of knowledge,” said Golden Spread Electric Cooperative’s Mike Wise. “That is what I was hopeful of finding. You are really highlighting some of the folks in our footprint don’t understand the rules and don’t understand FERC’s requirements.”

“We just asked what people were doing. We didn’t proclaim what needed to be done,” Monroe responded.

At the same time, SPP’s legal staff met with FERC to gain a better understanding of what is and what isn’t net metering.

“As we thought, since SPP has a pro forma Tariff, all load, if reported, can’t be netted,” said General Counsel Paul Suskie. “If somebody thinks they have a good case because of behind-the-meter load, it can be filed at FERC. To our knowledge, no SPP member has ever done that.”

Suskie said his department is working to further clarify for members what the BTM rules are today, and “what it would be tomorrow if we make a filing at FERC.”

“Once we get the results finalized and understood, we can see which ones don’t line up with what we believe FERC has said through its pronouncements,” Monroe said.

MOPC Chair Paul Malone, of Nebraska Public Power District, pushed unsuccessfully for a face-to-face educational meeting to help bring some consistency to network load reporting and “make sure we have a legal understanding of what FERC requires.”

“That’s critical, because that’s what billing is based on,” he said. “I think some of it is just different interpretations,” he said. “Looking at the [survey] items, it’s no wonder. ‘GFAs’? Lots of issues there. ‘Special circumstances’? I think we’re getting murkier, rather than clearer.”

Kansas City Power & Light’s Denise Buffington pressed both the MOPC and the SPC as to whether the 1-MW exemption would go before the Board of Directors next week. Monroe reminded members the board took no action on SPS’ appeal; Suskie said SPS could still place the issue on the agenda.

“I thought we made a commitment that it should be on the agenda in January,” said Board Chair Jim Eckelberger.

An agenda and meeting materials for the board’s Jan. 30 meeting had yet to be posted as of Monday.

Suskie said staff will present the board with draft reporting rules based on its “pretty extensive” discussion with FERC and the survey results “later this month.”

Separately, MOPC approved a revision request (RR 251) from the Supply Adequacy Working Group that addresses three issues FERC used in once again rejecting SPP’s resource adequacy package last year. (See FERC Again Rejects SPP’s Resource Adequacy Revisions.)

The commission said:

• SPP’s proposal failed to include requirements that all power purchase agreements are backed by verifiable capacity to meet the RTO’s resource adequacy requirement (RAR), and that provisions to allow SPP to verify the agreements are backed by capacity;
• the proposed treatment of firm power purchases and sales in determining net peak demand is unduly discriminatory; and
• SPP has not supported as just and reasonable its proposal to publicly post a list of load-responsible entities that had not met their RAR.

The motion was opposed by the Kansas Municipal Energy Agency, while 10 other members abstained.