RENSSELAER, N.Y. — NYISO left members of the Transmission Planning Advisory Subcommittee bewildered and dissatisfied on Monday when it presented another revised proposal for overhauling its interconnection study process.

Mark Younger, president of Hudson Energy Economics, summarized the mood: “You have succeeded in totally confusing me,” he said to laughter in the room.

NYISO’s new concept incorporates previous stakeholder feedback but still left many wondering if the revised proposal would solve existing project backlogs, reduce delays plaguing the queue and address stakeholder concerns. (See “Queue Window Comments,” NYISO Shares Details of Potential Long Island Tx Projects.)

NYISO has been investigating ways to improve its interconnection process, which has been getting longer and more complicated as projects with more advanced technologies enter the queue.

Thinh Nguyen, NYISO senior manager of interconnection projects, said the ISO “wants to create a process that improves interconnection studies by reducing time and increasing efficiency while maintaining system reliability and providing sufficient incentives and disincentives to commercial projects.”

Overview of Approach

The approximately three-year-long class year queue window (CYQW) concept keeps parts of the interconnection study process that are popular, such as the class year study but gives developers more opportunities to exit the queue without significantly compromising their finances or impacting other queued projects.

For example, the proposal would maintain current class year structures with a defined application phase and a clustered feasibility study that replaces individual system reliability impact studies, but it would use a two-staged class year study with more stringent validation requirements and run queue window groups in parallel.

NYISO’s presentation to the TPAS on Monday delved broadly into the three portions that constitute the CYQW: the application phase, the clustered feasibility study and the two-stage studies.

The application phase would be a 90-day period when project applications are submitted and validated, developers post their preliminary study deposits, and the initial interconnection diagrams are provided.

The next stage, the cluster feasibility study, would be when projects in a group are initially evaluated. During this 180-day period, NYISO would conduct environmental review, perform multiple sensitivity analyses, identify any system upgrades necessary to accommodate a project and give nonbinding cost estimates. Afterward, project developers would have 15 days to decide whether they want to either move forward to the class year study or leave the queue if they are found to be infeasible. Projects electing to leave the queue would see 75% of their study deposit refunded.

The class year study would consist of two eight-month stages where two project groups (i.e., Group A and B) are studied. Each stage would be followed by a 30-day decision period.

In stage 1, NYISO would perform localized analyses, which developers can use to inform their decision about whether to move ahead. Projects that take this initial offramp would lose only 50% of their application deposit.

In stage 2, study results would be refined based on projects that left, and remaining analyses would be conducted to identify any system upgrades required to install the proposed projects. Projects withdrawing during stage 2 would forfeit their entire deposit, while developers who accept their cost allocations would post security for any system upgrades identified for their projects.

NYISO asked stakeholders to address several open issues left unanswered in the proposal, including definitions, penalty determinations and whether prioritization processes should be established for projects proposing to interconnect at a similar location.

The ISO will spend the summer with stakeholders discussing and refining the CYQW proposal and hopes to begin vetting tariff language in the fall. It requests stakeholder comments on the proposal be sent to stakeholder_services_IPsupport@nyiso.com before June 16.

Stakeholder Comments

Stakeholders expressed discomfort about many aspects of NYISO’s proposal, but their focus was on the interactions between different groups of projects in the queue and dissecting the graphic that the ISO created to explain the construct. Many stakeholders were confused by how all the groups interact and impact one another.

Mark Reeder, representing the Alliance for Clean Energy New York, was concerned about how projects in Group C or D could simultaneously conduct their own feasibility studies as earlier CYQW projects (i.e., Groups A and B) conduct class year studies, even though there may be potential interactions.

Anthony Abate, lead energy market adviser with the New York Power Authority, sought to clarify, saying, “If you’re in Group C or D and are worried about potential interactions, what’s key to me is that the feasibility work for Groups A and B have likely already vetted or weeded out any surprises. So theoretically, this design should result in fewer dropouts because projects have already gotten feasibility evaluations.” Nguyen said Abate gave a nice summary.

Nguyen would expand on this issue in response to later questions posed by Hudson’s Younger, who asked how CYQW timelines overlap and what the graphic’s different colors represent.

“These are parallel processes where a transition class year study is ongoing, and at the same time, we have Group A and B undergoing their cluster’s feasibility studies,” Nguyen said. “Then, once those [feasibility studies] are complete, we start the class year for Group A and B, and as that class year study begins, we start the next group of feasibility studies for Group C and D.”

Given the novelty of the CYQW proposal, a swarm of questions was perhaps inevitable, but the complicated styling of the graphic seemed to make the proposal even harder to understand for stakeholders.

“I am having trouble understanding Group A and B interactions because [the graph] seems to show no overlap and just sequential pieces,” Younger said. “And so I don’t understand the benefit of having a Group A and a Group B if you’re going to do Group A’s analysis and then just wait to proceed to the class year for Group B’s analyses.”

Ngyuen responded, “Let’s say a developer in Group A cluster discovers some issues in the feasibility study; [developers] have the opportunity to submit a new interconnection request for Group B, so that’s why we have two groups. Then we also want to make sure that the class year does not run into any problems; therefore, as we conduct Group B’s feasibility analyses, we include Group A’s results in the baseline to allow us to consider potential interactions.”

Ngyuen clarified that Group B constitutes a separate cluster queue window that includes both projects from Group A that found out about problems and resubmitted an application and other potential projects not already studied.

Howard Fromer, who represents Bayonne Energy Center, asked why projects in Group A that already completed their feasibility studies had to wait for projects in Group B to move ahead to class year studies.

NYISO attorney Sara Keegan responded that “whether or not there’s a Group B, Group A cannot enter into the class year until the start date and so are stuck pending the subsequent class, so [NYISO] is just taking advantage of that time between class years to do as much as we can.”

Multiple stakeholders requested NYISO redo the graphic and come back to stakeholders with a picture that more explicitly shows the interactions and the timing between both different groups and windows.

NYISO did not explicitly promise to redraw the graphic but said it will return with updates after considering stakeholder feedback.