By Christen Smith

FERC told MISO, PJM and SPP last week that their joint operating agreements don’t provide enough clarity on how the RTOs’ handle generator interconnections along their seams (EL18-26).

The commission agreed in part with EDF Renewable Energy and ordered the RTOs to update their JOAs and Tariffs to make the queue priority process more transparent within 60 days of its ruling Thursday. The commission declined the company’s related request (AD18-8) to expand the review of affected-system coordination in the generation interconnection process beyond MISO, PJM and SPP, however.

“Because the queue priority processes are not described in their tariffs or JOAs, we find that there is a lack of transparency in MISO, SPP and PJM that makes it difficult for interconnection customers to understand how affected-system network upgrade costs are being allocated to them,” FERC wrote. “Requiring the RTOs to detail this information in their JOAs will provide additional transparency to interconnection customers on their potential responsibility for affected system network upgrade costs, thereby reducing uncertainty that may hinder interconnection development.”

The order comes nearly 18 months after FERC staff held a technical conference with the RTOs to address the issues raised in EDF’s October 2017 complaint that their governing documents, particularly the JOAs, lack details about the timing of affected-system analyses, the standards applied to determine impacts from proposed interconnections and how network upgrade costs are assigned. (See FERC Orders Review of PJM, MISO, SPP Generator Studies.)

FERC Order 2003 requires a transmission provider to coordinate interconnection studies and planning meetings with affected systems — electric systems other than the host transmission provider that may be affected by a proposed interconnection.

EDF argued that the lack of clarity regarding the RTOs’ delivery requirements and modeling standards violates the commission’s requirement for transparent, open-access interconnection service.

FERC said that despite insistence from the RTOs to the contrary, their existing documents lack transparency and cause “harm due to uncertainty” for EDF and other interconnection customers who struggle with decisions about whether to remain in the queue for fear of incurring unknown costs.

“Cost uncertainty presents a significant obstacle to the development of new resources, as some interconnection customers are less able to absorb unexpected and potentially higher costs for interconnection facilities and network upgrades that may occur once affected-system study results are considered,” FERC wrote. “This lack of transparency in the current affected-systems coordination process between MISO, SPP and PJM has the potential to hinder the timely development of new resources and thereby to stifle competition in the wholesale markets, resulting in rates that are not just and reasonable or are unduly discriminatory or preferential.”

The commission, however, rejected EDF’s request that the RTOs unify their modeling systems and study timelines, deeming neither necessary for providing greater transparency.

The RTOs’ compliance filings must include:

• Current affected-system coordination processes, including the provision of clear references to where affected-system study information can be found in their business practice manuals;
• A description of the modeling standard (external resource interconnection service or network resource interconnection service) they use to study, as the affected RTO, interconnection customers that request ERIS in the host RTO and interconnection customers that request NRIS in the host RTO;
• The location in their manuals or other coordination documents where interconnection customers can find the modeling details that they use when studying a project as ERIS or NRIS for interconnection requests on their own systems;
• For MISO and SPP specifically, a description of how they study the impacts on the affected RTO and clarify that the each RTO’s study criteria apply to its own facilities;
• How the three RTOs monitor each other’s systems during the course of each of their interconnection studies;
• PJM’s process for monitoring neighboring systems for affected-system impacts; and
• PJM’s timeline provided to interconnection customers to review affected-system study results.