Issue of Coordination with Affected Systems Rises to Forefront at FERC

by Jennings, Strouss & Salmon, PLC

The issue of coordination with Affected Systems has long been a proverbial “elephant in the room” when generation project developers request interconnection service from a Transmission Provider and the interconnection may impact neighboring systems. The Federal Energy Regulatory Commission (FERC) largely side-stepped the issue when it originally promulgated its pro forma Large Generator Interconnection Procedures (LGIP) and Large Generator Interconnection Agreement (LGIA) in Order No. 2003.  The pro forma LGIP, for example, includes loose concepts of “coordination” and “cooperation,” without specific details or deadlines.  A Transmission Provider generally is required to coordinate studies with Affected System Operators to determine the impact of an interconnection request, but the Transmission Provider must include the results of the Affected System Operators’ studies in the Transmission Provider’s own studies only “if possible” and “if available.” The Interconnection Customer and Affected System Operator generally are required to cooperate with the Transmission Provider in matters related to the conduct of studies. There is no language, however, that specifically compels an Interconnection Customer to execute a study agreement with an Affected System Operator by a set deadline nor is there any language requiring an Affected System Operator to complete a study by a set deadline after the execution of such a study agreement.  This may change, however, following a technical conference scheduled by FERC to occur on April 3-4, 2018.

The technical conference will address issues raised in a complaint filed recently by EDF Renewable Energy, Inc. (EDF) against the Midcontinent Independent System Operator, Inc. (MISO), PJM Interconnection, L.L.C. (PJM), and Southwest Power Pool, Inc. (SPP) as well as in a Notice of Proposed Rulemaking on Reform of Generator Interconnection Procedures and Agreements (NOPR) released by FERC in 2016.  In EDF’s complaint, it argued that the PJM, SPP, and MISO tariffs and joint operating agreements do not contain sufficient detail on Affected Systems coordination, which unjustly and unreasonably hinders proposed generation developers from assessing the commercial viability of projects.  The NOPR proposed reforms to the pro forma LGIP and LGIA with the aim of improving certainty and transparency in the interconnection process, including with respect to coordination with Affected Systems.

Topics to be addressed at the technical conference include:

  • Allocation of Affected System Costs among MISO, SPP, and PJM;
  • Timing of Affected System Coordination among MISO, SPP, and PJM;
  • Modeling and Study Procedures Used for Affected Systems Information between MISO, SPP, and PJM;
  • General Affected Systems Coordination Processes;
  • Affected Systems Studies & System Reliability; and
  • Affected Systems Coordination Best Practices and Guidelines.

Often, after a technical conference, FERC will provide an opportunity for the submission of written comments. Thus, if these issues are of concern to your company, it will be important to watch for a notice setting a comment deadline.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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