ALBANY, N.Y. — NYISO stakeholders discussed the merits and pitfalls of the ISO’s proposed phased window approach to fundamentally rework its interconnection study processes after it was presented in greater detail during the Transmission Planning Advisory Subcommittee’s meeting April 19.

After studying how to expedite its interconnection queue, which has experienced project backlogs and delays since New York passed the Climate Leadership and Community Protection Act in 2019, NYISO recently settled on a three-stage approach that would stack a group of overlapping projects into a queue window. (See NYISO Previews Plan to Expedite Interconnection Queue.)

Stakeholders were mostly receptive but still had many concerns about the proposal, including about its timelines and scheduling; penalties for leaving the queue; and whether certain studies in one phase might be more appropriate elsewhere.

NYISO will take stakeholder feedback from last week’s meeting and address them at the subcommittee’s next meeting on May 5.

Application Review Period

Thinh Nguyen, NYISO senior manager of interconnection projects, summarized the proposal.

“The queue window leverages all the class year processes,” but instead of performing studies at the end, after developers have made significant financial commitments, “it puts all the analyses upfront to be done together so developers can make more informed decisions,” Nguyen said.

Therefore, the critical first step in the queue window would be the application review period. This “pre-act” review would serve as a “project filter,” said Nguyen, because during this time, developers would submit site-control requirements and application fees, undergo initial modeling demonstrations and create their base cases, which are the starting points for any interconnection study, showing much about a project’s feasibility.

Proposed structure of the interconnection queue window approach (*boxes not at scale*) | NYISO

 

The idea is to enable developers to make important decisions about whether they want to enter or exit the queue without either facing withdrawal penalties or disrupting other potential projects in the queue window. Nguyen also said that the intention of this period is to validate a certain project application’s worthiness and if it can be considered in the interconnection study.

After submitting all required application materials and a nonrefundable application fee, developers would be able to submit a study deposit if they decide they want to proceed into the queue window.

Phase 1

“Phase 1 is similar to late-stage [Class Year] optional physical feasibility studies but is a more limited clustered study, rather than the individual studies as done today,” Nguyen said.

During this period, NYISO would review project design requirements provided by developers to determine a project’s feasibility, such as if existing infrastructure can physically accommodate the project or if it has environmental issues.

This would allow developers with projects identified by NYISO as having potential feasibility issues to decide whether they want to study this issue further or if it is enough to dissuade them from moving on.

Nguyen said Phase 1 “lets developers know if they may run into some problems,” so that they can decide to either exit the queue entirely or rejoin later in another window “without delaying other projects.”

Should a developer withdraw their project in Phase 1, NYISO would refund them 80% of the study deposit, though projects that move forward to Phase 2 and then decide to withdraw would forfeit the entire deposit.

At the end of this period, NYISO would publicly publish every developer’s decision so that others can understand how a given queue window or project could be affected.

Phase 2

Projects that pass Phase 1 feasibility requirements and posted relevant deposits would enter Phase 2, which is “almost like the system impact reliability study but with a twist,” said Nguyen.

Phase 2 would create binding cost estimates that are based on identified equipment and work upgrades necessary to interconnect a proposed project, which is unlike current processes that produce a nonbinding cost estimate.

Nguyen said Phase 2 is “tailored” to gives developers a “heads-up about some of their potential system upgrades that would be beyond the POI [point of interconnection].”

“This could be a step where we can streamline a lot of processes that we have today,” he said.

During Phase 2 the queue’s base cases would also be updated to reflect projects that were either rejected or withdrew during Phase 1 and the ISO performs limited analyses, such as short circuit, localized stability and screening deliverability analyses to generate useful information that reduces Phase 3 study times.

Developers who accept Phase 2’s results and project binding cost estimates would be required to post a project’s dollars-per-megawatt cash deposit before moving to Phase 3. Projects withdrawn during Phase 3 would see 25% of the cash deposit forfeited.

Like Phase 1, project decisions made in Phase 2 would be posted publicly by NYISO.

Phase 3

“Phase 3 is basically the final study for developers to know the certainty of their cost allocations,” Nguyen said.

During Phase 3, NYISO would update relevant base cases to reflect any projects that withdrew and perform any additional analyses needed to determine a project’s final cost allocation based on potential upgrades identified by the ISO.

Doreen Saia, an attorney with Greenberg Traurig, sought clarification, asking whether “Phase 3 is essentially becoming an additional deliverability study and additional SUF [system upgrade facility] study,” which Nguyen confirmed as correct.

Nguyen explained that the structure of NYISO’s proposal intentionally stacks projects together into a single queue window and staggers their study processes to “minimize the potential restudy or interaction between projects as much as possible.” This means, for example, a project might not commence Phase 3 studies until another project finishes its processes in the same window.

“The idea is that subsequent queue window projects will be able to consider upgrades identified in prior queue window projects,” which makes the queue “more manageable, because subsequent projects will know exactly who the group of projects prior to them are and what decisions they have to make,” he said.

Nguyen said that NYISO’s proposed “concept is much better than what we have today because when we studied projects individually, they had no idea what going on with other Class Year members … creating more uncertainty for those project developers.”

A developer who accepts their Phase 3 cost allocations would be required to post security for any system deliverability or facility upgrades necessary for interconnection to complete the queue window study process.

The Phase 3 decision-making period, like the end of the Class Year process, would be an iterative process that repeats until every queue window project member either accepts or rejects their cost allocations.

Stakeholder Comments

Stakeholders shared many concerns, both specific and general, about NYISO’s proposed revisions during last week’s meeting.

Several stakeholders commented that the proposed penalties incurred by developers withdrawing from the queue window may be overly burdensome, prohibitive and unequal, as bigger projects may be susceptible to higher fines than smaller ones. Some singled out the 20% for a Phase 1 departure as too high.

NYISO attorney Sara Keegan, however, said the amount is “consistent with other ISOs,” with SPP taking 20% from projects leaving at the end of its Phase 1 study. Nguyen said this is “a penalty that deters projects that are just not ready yet.”

Mark Reeder, representing the Alliance for Clean Energy New York, concurred, saying how he saw the 20% forfeiture “as the penalty for those starting and not being ready,” which to him seemed good because “we don’t want a lot of people jumping in and then out [of the queue] without a good reason.”

Vitaly Spitsa of Consolidated Edison asked what deliverables would come out of Phase 2 and whether, by this point in the process, developers would have access to sufficient information to make critical decisions about moving ahead in the queue.

Nguyen said that by the end of Phase 2, “developers will know exactly what the potential cost is of their binding POI” and about any necessary upgrades, which “definitely isn’t all the information but is sufficient information for a developer to make a decision about whether they want to move to the next phase.”

Anthony Abate, lead energy market adviser with the New York Power Authority, said NYISO’s illustrations of its queue window were “deceptively simple” and that “the devil’s in the details,” referencing how lengthy discussions during the meeting show that stakeholders need more information about the structure and timeline of the proposal.

Although much of the meeting was spent answering stakeholder questions or addressing comments of concern, some attendees expressed optimism about the ISO’s proposal.

Shane O’Brien, senior director with Aypa Power, said “from the developer’s side, this is a step in the right direction,” because NYISO’s proposal addresses “administrative inefficiencies” and “those downtime wait periods” where developers may be waiting for others before they can make their own decisions.

However, a remark by Saia seemed to best capture the sentiment among the stakeholders present at the meeting.

In reference to how NYISO’s proposal would remove much of the Class Year studies, such as the system impact reliability study or siting and permitting processes, Saia said, “We must make sure that whatever we do in this new process, [former] processes align, because if they don’t, then it’s great that you fixed this, but it’s going to create discordance somewhere else that causes the whole thing to die under its own weight.

“NYISO needs to indicate that you acknowledge and recognize [these concerns] because I don’t think you’re going to be able to get any real signoff on this without those assurances,” she said.