By Tom Kleckner

FERC last week partially approved Golden Spread Electric Cooperative’s Order 845 compliance filing but directed the Texas utility to make another filing proving compliance within 120 days (ER19-1900).

The commission in November partially accepted Golden Spread’s first compliance filing but found the cooperative’s proposed tariff revisions lacked the requisite transparency required by Orders 845 and 845-A. It directed Golden Spread to make another compliance filing, which it did in January. (See FERC Finds Partial Compliance on Order 845.)

FERC issued the two orders in 2018 to increase the generator interconnection process’ transparency and speed. The changes are grouped into three categories: improved certainty for interconnection customers; promoting more informed interconnection decisions; and process improvements. (See FERC Order Seeks to Reduce Time, Uncertainty on Interconnections.)

The commission found Golden Spread’s tariff revisions related to provision of interconnection service and surplus interconnection service complied with the orders.

But it said Golden Spread’s proposed revisions to determine contingent facilities that provide sufficient transparency “appears to conflate” those facilities with network upgrades and interconnection facilities assigned to the interconnection customer and does not distinguish between the two.

“Golden Spread does not indicate how it will determine which of these facilities are contingent facilities applicable to a particular interconnection request,” FERC said. It directed the cooperative to describe in its pro forma large generator interconnection procedures (LGIP) the specific technical screens and/or analyses that it will employ to determine which facilities are contingent facilities and to describe the specific triggering thresholds or criteria applied to identify a facility as a contingent facility.

FERC defines contingent facilities as “unbuilt interconnection facilities or network upgrades upon which the interconnection request’s costs, timing and study findings are dependent and, if delayed or not built, could cause a need for restudies of the interconnection request or a reassessment of the interconnection facilities and/or network upgrades and/or costs and timing.”

The commission also found proposed revisions to the LGIP allowing interconnection customers to submit “proposed modifications” if they seek to incorporate technological advancements into their large generating facility did not comply with its November order.

FERC directed Golden Spread to revise its technological change procedure to state that an interconnection customer should submit a “technological advancement request” if it seeks to incorporate technological advancements into its proposed large generating facility. It also ordered the cooperative to make clear it will reach its final determination on whether a proposed technological change is a material modification within 30 days of receiving the request.