By William Opalka

NYISO asked FERC Thursday to approve Tariff revisions that would make it easier for generators to get a place in the transmission queue “class year” (ER16-1627).

The ISO’s large facility interconnection procedures require generators to complete a three-step study process, starting with a high level feasibility study, which evaluates the configuration and local system impacts, followed by a system reliability impact study (SRIS), which evaluates the project’s impact on transfer capability and system reliability.

Finally, the class year study evaluates the cumulative impact of a group of projects that has completed similar milestones. This study identifies the upgrades needed to interconnect the project and maintain reliability.

In order to preserve its place in the transmission queue and enter the class year study, the project must acquire necessary permits from the state within two years of the NYISO Operating Committee deeming its application complete following an SRIS.

The state permitting process for generators over 25 MW “is a relatively new power plant siting process that ‘front loads’ much of the process,” the ISO explained. “As a result, there are concerns that projects may not be able to reach the ‘completed application’ stage in time to enter a desired class year study, despite having an Operating Committee-approved SRIS.”

NYISO cited a recent example in which a generator needed a FERC waiver to enter the class year study. On April 1, FERC granted the 33-MW Dry Lots Wind project in Herkimer County a waiver allowing it to join the study despite lacking a state siting board permit (ER16-1047). In granting the waiver, the commission cited its expectations of the ISO’s pending Tariff filing.

The proposed Tariff changes would extend the deadline for meeting the regulatory milestone requirement to 90 days after the start of the third class year study following the OC’s SRIS approval.

“This gives additional time for the project to meet the regulatory milestone while not permitting the project to remain in the queue indefinitely,” NYISO said. “This revision will help minimize delays to projects that are close to completing their regulatory milestone when a class year study begins. If a project provisionally enters a class year study, it will be withdrawn from the class if its regulatory milestone is still not met after the 90th day.”

NYISO asked for acceptance of the revision by July 5.