By Hudson Sangree

Four Western utilities generally complied with FERC rules intended to make it easier for generators to connect to transmission grids but had shortcomings in several common areas, the commission found last week.

FERC evaluated the filings against Order 845’s 10 reforms meant to increase the transparency and timeliness of the generator interconnection process. (See FERC Order Seeks to Reduce Time, Uncertainty on Interconnections.)

Problems arose under reforms involving contingent facilities, provisional interconnections and new technologies.

Contingent Facilities

In Avista’s filing, for example, FERC said the company had failed to identify specific requirements for contingent facilities. Contingent facilities are unbuilt interconnection facilities and network upgrades on which an interconnection request’s costs, timing and study findings depend.

“Avista’s proposed Tariff revisions lack the requisite transparency required by Orders No. 845 and 845-A because the proposed Tariff revisions do not detail the specific thresholds or criteria that Avista will use as part of its method to identify contingent facilities,” FERC wrote. “Without this information, an interconnection customer will not understand how Avista will evaluate potential contingent facilities to determine their relationship to an individual interconnection request.”

FERC directed Avista to file a further compliance filing within 60 days with the “specific thresholds or criteria it will use in its technical screens … to achieve the level of transparency required by Order No. 845.”

Similar deficiencies were identified and ordered corrected by FERC in the filings by PacifiCorp, PSCo and PNM.

FERC’s findings on contingent facilities echoed last month’s determinations on the Order 845 filings of Portland General Electric, Tampa Electric Co. and others. (See FERC Finds Partial Compliance on Order 845.)

Provisional Interconnection

PacifiCorp, PSCo and PNM fell short when it came to provisional interconnection services, FERC found.

Order 845 required transmission providers to let interconnection customers request provisional interconnection service when studies show there’s a level of service available to accommodate an interconnection request without new interconnection facilities or network upgrades, and when the interconnection customer wants to make use of that service while it completes facilities for its full interconnection.

PacifiCorp’s proposed language stated that it would update provisional interconnection studies “as system conditions warrant.”

That, FERC said, would “create too much discretion for PacifiCorp regarding the frequency for updating provisional interconnection studies.”

PSCo proposed to conduct updated provisional interconnection studies “if necessary, on a quarterly basis” — a proposal FERC rejected.

“While the commission gave the transmission provider discretion to determine the frequency for updating provisional interconnection studies in Order No. 845, PSCo’s proposed inclusion of the phrase ‘if necessary’ provides PSCo unfettered discretion to determine the frequency at which it will update provisional interconnection studies,” the commission wrote.

PNM had the same issue, FERC found.

Incorporation of Advanced Technologies

In Order 845, the commission allowed an interconnection customer to incorporate some technological advancements to its interconnection request without losing its queue position. It required transmission providers to develop and include in their procedures a definition of permissible technological advancements that, by definition, do not constitute a material modification.

Avista said it would use “reasonable efforts” to assess a technological change request. FERC said that language wasn’t acceptable. The company also failed to explain how it would evaluate a technological-advancement request to decide if it was a material modification and didn’t establish a time frame for making an evaluation, FERC said.

“Accordingly, we direct Avista to file, within 60 days of the date of this order, a further compliance filing that cures these deficiencies or explains why these requirements are not necessary for this aspect of Avista’s proposed procedure,” FERC said.

PNM and PacifiCorp had similar problems with their technological-change request procedures, FERC said.