By Rich Heidorn Jr.

FERC on Friday ordered a technical conference on how PJM, MISO and SPP coordinate generator interconnection studies on projects near their seams, saying their practices may not be just and reasonable.

The commission called the conference to address issues raised in an October complaint by EDF Renewable Energy, which contends that inconsistencies and a lack of clarity in the RTOs’ rules for “affected systems” interferes with developers’ ability to judge the commercial viability of proposed projects (EL18-26).

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 complained that the RTOs’ tariffs and the MISO-SPP and MISO-PJM joint operating agreements lack detail regarding: the timing of affected system analyses; the standards applied to determine impacts from proposed interconnections; and how network upgrade costs are assigned.

The company said the lack of clarity regarding the RTOs’ study delivery requirements and modeling standards violates the commission’s requirement for transparent open access interconnection service and its purpose for establishing pro forma interconnection processes.

The commission rejected the RTOs’ requests to dismiss the complaint, saying their “tariffs and JOAs do not fully explain the guidelines and timelines that the RTOs use to coordinate with affected system RTOs during the interconnection process.”

It noted that the MISO-SPP and MISO-PJM JOAs require SPP and PJM to provide MISO with affected system results twice a year — in conflict with MISO’s Tariff, which requires four to five system impact studies, including affected system results, each year, per sub-region.

EDF cited several problems it said have resulted:

• The timing mismatch delayed MISO’s system impact studies for its February 2016 West, February 2016 East and August 2016 Central interconnection study groups; MISO will not receive affected system information from PJM for its August 2016 Central study group until this month.
• Affected system data were provided late to generation being studied in the PJM queue.
• Affected systems information sent to MISO from SPP erroneously included a $38 million affected system network upgrade to be assessed to generation projects in the MISO February 2016 West study group, although the line SPP listed had already been included in its Integrated Transmission Plan.

The company also said it is unclear whether MISO and SPP are using the same base case models for their studies and that there is no clarity over the process the three RTOs use to assign network upgrade costs for interconnection projects located near their seams.

In the MISO February 2016 West study process, for example, EDF said SPP’s 2016 study of new generation near its MISO seam (SPP DISIS 2016-1) identified network upgrades near the Cooper South constraint in SPP.

SPP’s studies were completed before the MISO February 2016 West studies began, yet the MISO February 2016 West SIS included SPP affected systems costs of $311 million for a new line to upgrade the Cooper South constraint. EDF said the RTOs inappropriately shifted costs for upgrades identified in the SPP study from generation locating within SPP to generation locating within MISO.

The commission ruled that EDF had provided sufficient evidence that the lack of transparency and clarity may result in “inappropriate affected system network upgrade costs; a lack of information necessary to accurately estimate the cost of interconnection service; and delayed interconnection study results.”

The commission also rejected the RTOs’ request to dismiss EDF’s complaint as duplicative of the commission’s December 2016 Notice of Proposed Rulemaking on its pro forma large generator interconnection rules (RM17-8). The commission said EDF’s complaint raised issues specific to the MISO, SPP and PJM tariffs and JOAs that were not raised in the NOPR. (See FERC Proposes Changes to Interconnection Rules.)

“We find that a technical conference is an appropriate vehicle to develop a more complete record concerning these issues and the specific reforms proposed by EDF in the complaint,” FERC said. “We note that commission staff at the technical conference will also consider issues related to affected systems coordination that were raised in response to the Generator Interconnection NOPR. We find that holding a joint technical conference on affected systems issues identified both in this complaint and in the Generator Interconnection NOPR will offer the commission and interested parties the opportunity to consider specific reforms in MISO, SPP and PJM at the same time as more generic reforms.”

FERC said it expects to issue a ruling within 12 months of the technical conference.

Chairman Kevin McIntyre did not participate in the ruling.