Interconnection for Wind Energy, 75005-75016 [05-24173]

Agencies

• DEPARTMENT OF ENERGY
• Federal Energy Regulatory Commission

[Federal Register Volume 70, Number 242 (Monday, December 19, 2005)]
[Rules and Regulations]
[Pages 75005-75016]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 05-24173]


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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 35

[Docket No. RM05-4-001; Order No. 661-A]


Interconnection for Wind Energy

Issued December 12, 2005.

AGENCY: Federal Energy Regulatory Commission, DOE.

ACTION: Order on rehearing and clarification.

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SUMMARY: The Federal Energy Regulatory Commission is granting in part 
and denying in part the requests for rehearing and clarification of its 
Final Rule on Interconnection for Wind Energy, Order No. 661. Order No. 
661 requires public utilities that own, control, or operate facilities 
for transmitting electric energy in interstate commerce to append to 
their standard large generator interconnection procedures and large 
generator interconnection agreements in their open access transmission 
tariffs standard procedures and technical requirements for the 
interconnection of large wind generation.

DATES: Effective Date: Changes made to Order No. 661 in this order on 
rehearing and clarification will become effective on January 18, 2006.

FOR FURTHER INFORMATION CONTACT:

Bruce A. Poole (Technical Information), Office of Markets, Tariffs and 
Rates, Federal Energy Regulatory Commission, 888 First Street, NE., 
Washington, DC 20426. (202) 502-8468.
G. Patrick Rooney (Technical Information), Office of Markets, Tariffs 
and Rates, Federal Energy Regulatory Commission, 888 First Street, NE., 
Washington, DC 20426. (202) 502-6205.
P. Kumar Agarwal (Technical Information), Office of Markets, Tariffs 
and Rates, Federal Energy Regulatory Commission, 888 First Street, NE., 
Washington, DC 20426. (202) 502-8923.
LaChelle Brooks (Technical Information), Office of Markets, Tariffs and 
Rates, Federal Energy Regulatory Commission, 888 First Street, NE., 
Washington, DC 20426. (202) 502-6522.
Jeffery S. Dennis (Legal Information), Office of the General Counsel, 
Federal Energy Regulatory Commission, 888 First Street, NE., 
Washington, DC 20426. (202) 502-6027.

SUPPLEMENTARY INFORMATION:

Order No. 661-A; Order on Rehearing and Clarification

    1. On June 2, 2005, the Commission issued Order No. 661, the Final 
Rule on Interconnection for Wind Energy (Final Rule).\1\ Several 
entities have filed timely requests for rehearing and clarification of 
the Final Rule.\2\ In this order, the Commission grants in part and 
denies in part the requests for rehearing and clarification.
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    \1\ Interconnection for Wind Energy, Order No. 661, 70 FR 34993 
(June 16, 2005), FERC Stats. & Regs. ] 31,186 (2005) (Final Rule); 
see also Order Granting Extension of Effective Date and Extending 
Compliance Date, 70 FR 47093 (Aug. 12, 2005), 112 FERC ] 61,173 
(2005).
    \2\ Those entities requesting rehearing and/or clarification, 
and the acronyms used to refer to them in this order, are listed in 
Appendix A to this order.
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I. Background

    2. In Order No. 2003,\3\ the Commission adopted standard procedures 
and a standard agreement for the interconnection of large generation 
facilities. The Commission required public utilities that own, control, 
or operate facilities for transmitting electric energy in interstate 
commerce to file revised Open Access Transmission Tariffs (OATTs) 
containing these standard provisions, and use them to provide 
interconnection service to generating facilities having a capacity of 
more than 20 megawatts.
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    \3\ Standardization of Generator Interconnection Agreements and 
Procedures, Order No. 2003, 68 FR 49845 (Aug. 19, 2003), FERC Stats. 
& Regs., Regulations Preambles ] 31,146 (2003) (Order No. 2003), 
order on reh'g, 69 FR 15,932 (Mar. 24, 2004), FERC Stats & Regs., 
Regulations Preambles ] 31,160 (2004) (Order No. 2003-A), order on 
reh'g, 70 FR. 265 (January 4, 2005), FERC Stats & Regs., Regulations 
Preambles ] 31,171 (2004) (Order No. 2003-B), order on reh'g, 70 FR 
37661 (June 30, 2005), FERC Stats. & Regs. ] 31,190 (2005) (Order 
No. 2003-C); see also Notice Clarifying Compliance Procedures, 106 
FERC ] 61,009 (2004).
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    3. In Order No. 2003-A, on rehearing, the Commission noted that the 
standard interconnection procedures and agreement were based on the 
needs of traditional generation facilities and that a different 
approach might be more appropriate for generators relying on other 
technologies, such as wind plants.\4\ Accordingly, the Commission 
granted certain clarifications, and also added a blank Appendix G to 
the standard Large Generation Interconnection Agreement (LGIA) for 
future adoption of requirements specific to other technologies.\5\
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    \4\ Order No. 2003-A at P 407, n.85.
    \5\ Id.
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    4. The Commission issued a Notice of Proposed Rulemaking (NOPR) 
that proposed technical standards applicable to the interconnection of 
large wind generating plants \6\ to be included in Appendix G of the 
LGIA.\7\ We proposed the standards in light of our findings in Order 
No. 2003-A noted above and in response to a petition submitted by the 
American Wind Energy Association (AWEA).\8\ Specifically, the 
Commission proposed to establish uniform standards in Appendix G that 
would require large wind plants seeking to interconnect to the grid to: 
(1) Demonstrate low voltage ride-through capability; in other words, 
show that the plant can remain on line during voltage disturbances up 
to specified time periods and associated voltage levels; (2) have 
supervisory control and data acquisition (SCADA) capability to transmit 
data and receive instructions from the Transmission Provider; and (3) 
maintain a power factor within the range of 0.95 leading

[[Page 75006]]

to 0.95 lagging, measured at the high voltage side of the substation 
transformers. The Commission proposed to permit the Transmission 
Provider to waive the low voltage ride-through requirement on a 
comparable and not unduly discriminatory basis. We proposed to permit 
the Transmission Provider to waive or defer compliance with the power 
factor requirement where it is not necessary. The Commission did not 
propose to adopt a proposal by AWEA to allow a wind generator to 
``enter the interconnection queue and conduct its own Feasibility 
Study, having obtained the information necessary to do so upon paying 
the initial deposit and submitting its interconnection application'' 
(referred to as ``self-study'' provisions).\9\ The Commission did, 
however, ask for comments on how to balance the need of wind generators 
to obtain certain data from the Transmission Provider before completing 
their Interconnection Requests with the need to protect critical energy 
infrastructure information and commercially sensitive data against 
unwarranted disclosure.
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    \6\ Large wind generating plants are those with an output rated 
at more than 20 MW at the point of interconnection. The 
interconnection requirements for small generators rated at 20 MW or 
less are set forth in Standardization of Small Generator 
Interconnection Agreements and Procedures, Order No. 2006, 70 FR 
34190 (June 13, 2005), FERC Stats. & Regs. ] 31,180 (2005), reh'g 
pending.
    \7\ See Interconnection for Wind Energy and Other Alternative 
Technologies, Notice of Proposed Rulemaking, 70 FR 4791 (Jan. 31, 
2005), 110 FERC ] 61,036 (2005) (NOPR).
    \8\ See Petition for Rulemaking or, in the Alternative, Request 
for Clarification of Order No. 2003-A, and Request for Technical 
Conference of the American Wind Energy Association (May 20, 2004), 
filed in Docket Nos. RM02-1-005 and PL04-15-000 (AWEA Petition).
    \9\ See AWEA Petition at 13.
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    5. In the Final Rule, the Commission adopted final standard 
procedures and technical requirements for the interconnection of large 
wind plants in Appendix G, and required all public utilities that own, 
control, or operate facilities for transmitting electric energy in 
interstate commerce to append Appendix G to the Large Generator 
Interconnection Procedures (LGIPs) and LGIAs in their OATTs. As 
described in more detail below, the Commission adopted provisions 
establishing standards for low voltage ride-through and power factor 
design criteria, and requiring that wind plants meet those standards if 
the Transmission Provider shows, in the System Impact Study, that they 
are needed to ensure the safety or reliability of the transmission 
system. Additionally, the Appendix G adopted by the Commission included 
a SCADA requirement applicable to all wind plants. Finally, as 
described in more detail below, the Commission adopted in Appendix G to 
the LGIP limited special interconnection procedures applicable to wind 
plants.

II. Requests for Rehearing and Clarification and Commission Conclusions

A. Low Voltage Ride-Through Provisions

    6. In the Final Rule, the Commission adopted a low voltage ride-
through standard, but provided that a wind plant is required to meet 
the standard only if the Transmission Provider shows, in the System 
Impact Study, that low voltage ride-through capability is needed to 
ensure safety or reliability. The standard (adopted in Figure 1 of 
Appendix G to the LGIA), if applicable, requires the wind plant to stay 
online for specified time periods and at associated voltage levels 
where there is a disturbance on the transmission system. The Final Rule 
requires that the required voltage levels be measured at the Point of 
Interconnection.
    7. Several entities requested rehearing of various aspects of the 
low voltage ride-through requirement and standard included in the Final 
Rule, including: (1) Provisions that require low voltage ride-though 
only when the System Impact Study shows that such capability is 
necessary for safety or reliability; (2) the specific low voltage ride-
through standard adopted in the Final Rule; (3) the point of 
measurement for the standard; and (4) arguments that Transmission 
Providers should be permitted to adopt other provisions of the German 
low voltage ride-through standard (which the Commission referenced in 
the Final Rule).
    8. However, as described in more detail below, NERC and AWEA 
jointly requested that the Commission delay the effective date of the 
Final Rule to give them time to resolve concerns expressed by NERC 
regarding the low voltage ride-through provisions. The Commission 
granted this extension, and on September 19, 2005, NERC and AWEA 
submitted a joint report with recommended revisions.
1. Case-by-Case Application/Burden of Proof for Applying the Low 
Voltage Ride-Through Standard
    9. Prior to the NERC/AWEA joint report, several entities objected 
on rehearing to the Final Rule's adoption of a low voltage ride-through 
requirement on a case-by-case basis, placing the burden of proof on the 
Transmission Provider to show that low voltage ride-through capability 
is needed. ATC, EEI, NERC, NRECA/APPA, and SCE, among others, urged the 
Commission to return to the approach in the NOPR, which would have 
required low voltage ride-through for all wind plants unless waived by 
the Transmission Provider on a not unduly discriminatory basis. ATC 
noted that interconnection studies only consider a snapshot of the 
transmission system, and do not take into account changes in the future 
that may cause a need for low voltage ride-through capability to ensure 
reliability. ATC, as well as EEI and SCE, argued that under the case-
by-case approach adopted in the Final Rule, Transmission Providers will 
need to perform additional analyses to determine if a reliability need 
will exist over the life of the wind plant. SCE, for example, noted 
that while a particular System Impact Study may not conclusively 
demonstrate that low voltage ride-through is needed at that time, if 
other generation projects are built, the first wind plant may come to 
need low voltage ride-through. According to various entities, the 
additional analyses needed to take these scenarios into account will 
increase the time, cost and complexity of wind plant interconnections 
and could be a barrier to their development.\10\
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    \10\ New York ISO asserts that the case-by-case approach could 
lead to acute problems in New York, where it has received 
interconnection applications from wind plants totaling over 5000 MW 
of generation. According to New York ISO, conducting case-by-case 
reviews for each of these projects could greatly complicate the 
study process and result in substantial delays.
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    10. Furthermore, ATC asserted that the case-by-case approach 
imposes the responsibility for resolving reliability concerns that 
arise in the future on the Transmission Provider because wind 
generating plants cannot be retrofitted with low voltage ride-through 
capability. Similarly, NRECA/APPA argued that this approach unduly 
discriminates in favor of wind plants in that low voltage ride-through 
capability may not be ``necessary'' (and therefore required) for a 
specific plant because other generators or Transmission Providers can 
``make up the difference.'' \11\ ATC also contended that the case-by-
case approach may require the Transmission Provider to incur capital 
costs that should have been incurred by the wind plant.
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    \11\ Request for Rehearing of NRECA/APPA at 6.
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    11. EEI and NU argued that the case-by-case approach adopted by the 
Commission in the Final Rule ``lowers the bar for reliability.'' \12\ 
NERC similarly asserted that requiring Transmission Providers to 
justify common elements of good utility practice on a case-by-case 
basis is unwise and may deter Transmission Providers from implementing 
and following good utility practice.\13\ Southern Company states that 
the Transmission Provider, as the entity responsible for maintaining 
reliability, should not bear the burden of proof to establish what is 
required to maintain system reliability. Southern Company states that 
it supports the Commission's statement that Transmission Providers 
should not be permitted to require wind plants to install costly 
equipment that is not needed for reliability, but argues

[[Page 75007]]

that the burden of proof should be shifted, and the System Impact Study 
should establish that such equipment is not required. Also, NRECA/APPA 
argued that the case-by-case approach imposes unreasonable reliability 
risks, and effectively voids the requirement that wind plants have low 
voltage ride-through capability ``in a broad range of circumstances.'' 
\14\
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    \12\ Request for Rehearing of EEI at 8.
    \13\ New York ISO states that it adopts NERC's position on this 
issue.
    \14\ Request for Rehearing of NRECA/APPA at 6.
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    12. Those requesting rehearing raised several other arguments 
regarding the case-by-case approach and burden of proof for applying 
the low voltage ride-through standard. NERC believed that the case-by-
case approach could unintentionally create a ``patchwork'' of varying 
requirements. EEI and NU also suggested that requiring a showing of 
need may introduce prolonged uncertainties into the interconnection 
process if parties disagree as to the study assumptions. SCE asserted 
that rather than limiting opportunities for undue discrimination, the 
requirement of a showing of need could result in discriminatory 
treatment in areas with large amounts of wind generation because 
projects lower in the queue may be responsible for additional costs 
since the need for low voltage ride-through could not be demonstrated 
for earlier projects. EEI contended that Order No. 2003 already 
contains provisions allowing the parties to an interconnection to 
exercise their discretion in complying with system reliability 
obligations, and that there is no evidence of problems with these 
procedures that justifies such a significant departure from them in the 
Final Rule. Further, EEI argued that the Final Rule was a significant 
departure from the NOPR and that the Commission should not adopt it 
without providing an opportunity for comments on it. Finally, NRECA/
APPA argued that the Commission has not explained how this approach is 
consistent with NERC and WECC standards.
2. Specific Low Voltage Ride-Through Standard
    13. Certain requests for rehearing and clarification also addressed 
the specific low voltage ride-through standard adopted by the 
Commission in the Final Rule. In its request for rehearing, NERC 
asserted that the standard in Figure 1 of the Final Rule is not 
appropriate. More specifically, NERC contended that Figure 1, by 
allowing a wind plant to disconnect from the transmission system when 
the voltage drops below 15 percent of the nominal voltage, could result 
in violation of NERC Reliability Standard TPL-002-0. This standard 
requires transmission planners to ensure that the system will remain 
stable and within applicable thermal and voltage ratings, with no loss 
of demand or curtailment of firm transfers, where there is a normally 
cleared fault on a single element, which is typically four to eight 
cycles or 0.067 to 0.133 seconds (67 to 133 milliseconds). According to 
NERC, a fault occurring on a transmission line near a wind plant could 
cause the voltage at that point to drop to zero for this clearing time. 
NERC stated that because Figure 1 would allow the wind plant to 
disconnect when the voltage drops below 15 percent of the nominal 
voltage, the loss of the single grid element (the transmission line) 
would be compounded by the loss of the real power (and any reactive 
power) produced by the wind plant. This ``double contingency event'' 
(loss of both the transmission line and wind plant) violates 
Reliability Standard TPL-002-0, NERC asserted.
    14. To remedy this problem, NERC requested that the Commission 
simply require wind plants to meet NERC and regional reliability 
council requirements.\15\ Alternatively, NERC argued that the rule 
should be modified to require wind plants to remain connected through a 
normally cleared single line to ground or three phase fault. 
Specifically, NERC asserted that Figure 1 should be altered to require 
a wind plant to remain online for 0.167 seconds (167 milliseconds), or 
ten cycles, if voltage at the high side of the wind plant step-up 
transformer is reduced to zero. After 0.167 seconds (167 milliseconds), 
but before 0.625 seconds (625 milliseconds), NERC argued that Figure 1 
should require the wind plant to stay connected as long at the voltage 
is at or above 15 percent of the nominal voltage. NERC contended that 
these modifications would reduce the risk to the reliability of the 
electric system to an acceptable level.\16\
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    \15\ ISO-NE argued that the Commission should have required wind 
plants to be subject to the same system performance standards that 
are applied to other generating technologies.
    \16\ ISO-NE also suggested that, if the Commission adopted a low 
voltage ride-through standard, it be modified to require the wind 
plant to be connected at zero voltage for ``a time period associated 
with the typical clearing time of a normal design contingency 
fault.'' Request for Rehearing of ISO-NE at 4.
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    15. Similarly, NU asserted that wind plants should be required to 
``remain on-line for all faults cleared by normal operation of all 
protective equipment unless clearing the fault * * * isolates the plant 
from the rest of the grid.'' \17\ According to NU, this change would 
require generators to have low voltage ride-through capability down to 
zero percent of the nominal voltage at the Point of Interconnection. 
CenterPoint also contend that wind plants should be required to 
maintain low voltage ride-through capability down to zero percent of 
the rated line voltage 150 milliseconds (.150 seconds) (the time 
generally needed for the transmission system protective equipment to 
clear the fault). NU and CenterPoint argued that this change would 
reduce the likelihood that a low voltage event would escalate to a 
cascading outage or voltage collapse. NU also asserted that this 
requirement is similar to those applicable to other generators, and 
could be achieved by wind turbines that are currently available. NU 
stated that the standard adopted in the Final Rule would threaten 
reliability by allowing a wind plant to reduce output, or trip offline, 
simply due to a typical system fault.
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    \17\ Request for Rehearing of NU at 5.
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    16. NRECA/APPA also objected to the low voltage ride-through 
standard adopted in the Final Rule. Specifically, they contended that 
the Final Rule should not have established the low voltage ride-through 
curve as an absolute standard, and instead should have permitted 
Transmission Providers to adopt an alternative curve (subject to review 
by the Commission if there is a dispute) when the System Impact Study 
shows that it is necessary. ISO-NE, going further, requested that if 
the Commission adopted a low voltage ride-through standard, it should 
be only a guideline for wind turbine manufacturers. NRECA/APPA asserted 
that the Final Rule did not conclude that the low voltage ride-through 
standard will protect reliability or address the technical concerns 
raised by comments, and, by stating that the Commission might consider 
an alternative low voltage ride-through standard, recognizes that it 
may not be adequate to preserve reliability in all circumstances. 
Alternatively, NRECA/APPA asked that the Commission clarify that 
Transmission Providers may support variations from the low voltage 
ride-through curve in the Final Rule, based on local and subregional 
reliability conditions, under the three variation standards adopted in 
the Final Rule.
    17. EEI asserted that the technical challenges presented by wind 
generation are being considered by the industry worldwide, and that 
many international standards differ from the Commission's Final Rule. 
Both EEI and SCE objected to the specific low voltage ride-through 
standard through comparison to the German

[[Page 75008]]

interconnection guidelines. Particularly, EEI noted that the German 
grid code requires wind plants to remain connected to the grid 
following a fault that results in the voltage at the Point of 
Interconnection dropping to 15 percent of the nominal voltage for as 
long as 0.15 seconds. According to EEI, revisions to the German grid 
code are nearing completion that will require wind plants to remain 
connected to the transmission system following a fault that drops the 
voltage at the Point of Interconnection to zero percent of the nominal 
voltage for as long at 0.15 seconds. Further, EEI reported that the 
Hydro-Qu[eacute]bec requirements for wind farm interconnection are 
stricter than the Commission's Final Rule; they require wind plants to 
ride through a fault resulting in a voltage drop to zero percent of 
nominal voltage for as long as 0.15 seconds. Finally, EEI noted that 
Ireland requires wind plants to stay online after a fault that drops 
the voltage to 15 percent of nominal voltage for as long as 0.15 
seconds. SCE additionally asserted that the requirement that low 
voltage ride-through be shown to be necessary in the System Impact 
Study conflicts with the German wind interconnection guidelines because 
those guidelines assume that all generation will meet the low voltage 
ride-through standard. SCE stated that the Final Rule should adopt low 
voltage ride-through capability as a governing standard, with 
exceptions approved by the governing technical body (NERC or the 
Western Electricity Coordinating Council (WECC), a regional reliability 
council), as in the German standard.
    18. In the Final Rule, the Commission stated that ``the low voltage 
ride-through requirement, and the time periods and associated voltage 
levels set forth in Appendix G, Figure 1, apply to three-phase 
faults.'' ATC sought clarification as to whether the low voltage ride-
through requirement applied only to three-phase faults. Assuming that 
is the case, ATC asked whether there was a requirement for single-phase 
and double-phase faults.
3. Point of Measurement for the Low Voltage Ride-Through Standard
    19. NERC argued on rehearing that because the Point of 
Interconnection may be some distance from a wind plant, the plant might 
actually disconnect at voltages higher than 15 percent of the nominal 
voltage at the high side of the wind plant step-up transformer. 
According to NERC, this could create a further risk of a double 
contingency event.\18\ To avoid this risk, NERC contended that low 
voltage ride-through capability should be measured at the high voltage 
terminal of the wind plant step-up transformer. Southern Company stated 
that a revision to section A.i.2 of the LGIA Appendix G was necessary 
to reflect the Commission's decision in the Final Rule to adopt the 
Point of Interconnection as the measurement point.
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    \18\ See supra, P 13.
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4. Adoption of Other Provisions From the German Standards
    20. SCE noted that while the Final Rule adopted a low voltage ride-
through standard based on the German wind interconnection guidelines, 
the Commission did not adopt the related requirements in the German 
guidelines. It noted several provisions of the German guidelines that 
it stated go hand-in-hand with the low voltage ride-through 
standard.\19\ SCE asked the Commission to clarify that Transmission 
Providers may implement these other guidelines in the German standard.
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    \19\ See Request for Rehearing and Clarification of SCE at 9-10.
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5. NERC/AWEA Recommended Revisions to Low Voltage Ride-Through 
Provisions
    21. As noted above, NERC filed a request for rehearing of the Final 
Rule contending, in part, that the specific low voltage ride-through 
standard adopted by the Commission would permit violations of a NERC 
system performance standard.\20\ On August 4, 2005, NERC and AWEA filed 
a request to extend the effective date of the Final Rule to allow for 
discussions to resolve the reliability concerns expressed by NERC. They 
committed to submitting to the Commission a joint final report on their 
discussions. On August 5, 2005, the Commission issued an order granting 
this request.\21\
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    \20\ See supra, P 13.
    \21\ Interconnection for Wind Energy, 70 FR 47093 (Aug. 12, 
2005), 112 FERC ] 61,173 (2005).
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    22. On September 19, 2005, NERC and AWEA submitted their joint 
final report, which recommended revisions to the low voltage ride-
through provisions of the Final Rule. They state that the recommended 
revisions are supported by the NERC Planning Committee and AWEA 
members. NERC states that the concerns expressed in its request for 
rehearing will be resolved if the Commission adopts the recommended 
revisions.
    23. Specifically, NERC and AWEA recommend a different low voltage 
ride-through section to be inserted in Appendix G. The recommended 
provisions include a transition period standard, which would apply to 
wind plants that either: (a) Have interconnection agreements signed and 
filed with the Commission, filed with the Commission in unexecuted 
form, or filed with the Commission as non-conforming agreements between 
January 1, 2006 and December 31, 2006, with a scheduled in-service date 
no later than December 31, 2007; or (b) involve wind turbines subject 
to a procurement contract executed before December 31, 2005 for 
delivery through 2007. During this transition period, wind plants would 
be required to ride through low voltage events down to 0.15 per unit 
for normal clearing times up to a maximum of nine cycles.
    24. Following this transition period, the NERC/AWEA proposal would 
require wind plants to ride through low voltage events down to a zero 
voltage level for ``location-specific'' clearing times up to a maximum 
of nine cycles. If the fault on the transmission system remained after 
this clearing time, the joint recommendation would permit the wind 
plant to disconnect from the system.
    25. Under the joint recommendation of NERC and AWEA, during both 
the transition period and after, low voltage ride-through capability 
would be required for all new wind plant interconnections, instead of 
only when the System Impact Study shows that such capability is needed 
for safety or reliability, as in the Final Rule. Additionally, in both 
cases the point of measurement for the requirement would be at the high 
side of the wind plant step-up transformer, instead of at the Point of 
Interconnection, as in the Final Rule. NERC and AWEA also recommend 
eliminating Figure 1 during both the transition period and after the 
transition period because the low voltage ride-through standard 
described in their Joint Report replaces the voltage trace represented 
by Figure 1.
    26. Finally, NERC and AWEA recommend limiting the variations to the 
low voltage ride-through provisions that were permitted by the Final 
Rule. The Final Rule permits Transmission Providers to justify 
variations between their pro forma tariff and the Final Rule Appendix G 
based on the regional reliability, the ``consistent with or superior 
to,'' or the independent entity variation standards in Order No. 
2003.\22\ NERC and AWEA recommend that variations to their proposed low 
voltage ride-through provisions be permitted on an interconnection-wide 
basis only, reasoning that such a limitation is appropriate because the 
provisions are intended to satisfy a NERC reliability

[[Page 75009]]

standard, and because wind generators could incur significant 
additional costs if they had to meet many different standards. NERC and 
AWEA note that limiting variations would not restrict the ability to 
request a deviation in a specific non-conforming agreement filed with 
the Commission (as opposed to a variation built into a pro forma 
tariff).
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    \22\ Final Rule at P 107, 109.
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    27. The Commission issued notice of the NERC/AWEA joint report on 
September 21, 2005, and provided interested parties with the 
opportunity to submit comments on or before October 3, 2005. FPL 
Energy, National Grid, New York ISO and PJM all filed comments 
supporting the technical recommendations in the joint report.
    28. National Grid also asks that the Commission make two 
clarifications. First, it asks the Commission to clarify that while the 
point of measurement for compliance with the low voltage ride-through 
standard would be at the high side of the step-up transformer, the 
point of measurement for reactive power would remain at the Point of 
Interconnection. Second, National Grid requests that the nine cycle 
maximum clearing time in the low voltage ride-through provision applies 
only to three-phase faults. It says that single line-to-ground faults 
are typically much longer than nine cycles, so a general, non-specified 
standard is more appropriate for such faults.
    29. New York ISO, while strongly supporting the technical aspects 
of the NERC/AWEA joint recommendations, urges the Commission to reject 
the proposal that variations to the low voltage ride-through provision 
be permitted only on an interconnection-wide basis or through 
individually-filed interconnection agreements. It argues that this 
could hamper efforts to preserve reliability in individual regions, and 
asserts that satisfying NERC planning standards is not sufficient to 
preserve reliability because New York State, as well as other regions, 
sometimes need more stringent reliability requirements than those of 
NERC. New York ISO says that the Commission has viewed NERC's criteria 
as being minimum reliability requirements, which individual regions may 
exceed if necessary. Therefore, New York ISO argues that at a minimum, 
the Commission should permit independent entities to seek variations 
from the low voltage ride-through standards recommended by NERC and 
AWEA.
    30. Finally, New York ISO asks the Commission to clarify that, 
assuming the NERC/AWEA recommendations are adopted, the ``filing date'' 
for purposes of the proposed transition period includes the date that 
conforming interconnection agreements are fully and finally executed. 
New York ISO notes that executed conforming agreements need not be 
filed with the Commission. Therefore, it contends that the transition 
period should apply to agreements executed within its timeframe but not 
filed with the Commission.
Commission Conclusion on Low Voltage Ride-Through Provisions
    31. The Commission grants rehearing with regard to the low voltage 
ride-through provisions, and adopts the joint recommendation of NERC 
and AWEA without modification. This provides a standard that will 
ensure that wind plants are interconnected to the grid in a manner that 
will not degrade system reliability. Furthermore, this standard 
satisfies the reliability concerns expressed by NERC, and either 
satisfies or renders moot many of the rehearing requests described 
above, including those related to the case-by-case application of the 
low voltage ride-through standard and point of measurement for the low 
voltage ride-through standard. Additionally, the joint recommendation 
also responds to the arguments on rehearing of EEI and SCE regarding 
comparison to the German interconnection guidelines.
    32. We are eliminating Figure 1 from Appendix G because the 
standard we are adopting in Appendix G replaces that figure. 
Accordingly, all references to Figure 1 in the preamble to the Final 
Rule should be read to apply to the standard now described in Appendix 
G.
    33. We also adopt the NERC/AWEA proposal to permit variations to 
the low voltage ride-through provisions of Appendix G only on an 
interconnection-wide basis. The low voltage ride-through provisions we 
adopt in this order on rehearing were crafted specifically, after 
negotiation among the wind industry and NERC, to ensure that NERC 
Reliability Standard TPL-002-0 is met in all regions. While other 
interconnection standards may be more susceptible to variation among 
Transmission Providers or independent entities, the close connection of 
this standard to an industry-wide reliability standard persuades us 
that limiting variations to those made on an interconnection-wide basis 
will best ensure that reliability is protected. Accordingly, we reject 
SCE's request that we clarify that Transmission Providers may implement 
other guidelines from the German interconnection standard. Adoption of 
other guidelines from the German standard on a Transmission Provider-
specific basis could result in varying requirements that may not meet 
established reliability standards. For the same reasons, we also reject 
New York ISO's assertion that the Commission should continue to permit 
variations to the low voltage ride-through provisions under the three 
variation standards in the Final Rule, and particularly the independent 
entity variation. We note, however, that under section 1211 of the 
Energy Policy Act of 2005, the State of New York ``may establish rules 
that result in greater reliability within that State, as long as such 
action does not result in lesser reliability outside the State than 
that provided by the reliability standards.'' \23\ Therefore, the 
Commission will consider proposed variations from the State of New York 
under this statutory provision.
---------------------------------------------------------------------------

    \23\ Energy Policy Act of 2005, Pub. L. 109-58, Sec.  1211, 119 
Stat. 594, 945 (2005).
---------------------------------------------------------------------------

    34. In response to the arguments of NRECA/APPA that the Final Rule 
should have permitted Transmission Providers to adopt alternative low 
voltage ride-through standards, and ISO-NE's contention that the 
standard in the Final Rule should be only a guideline, we find that the 
definitive standard we adopt here will provide certainty to wind 
developers and manufacturers and ensure that reliability is maintained 
and NERC planning standards are met. If another standard is necessary 
for a specific wind plant interconnection to maintain reliability, a 
non-conforming agreement may be filed with the Commission.
    35. In response to ATC and National Grid, we clarify that the low 
voltage ride-through provisions we are adopting apply to all types of 
faults, not just to three-phase faults. The standard refers to three-
phase faults with normal clearing as well as single line to ground 
faults with delayed clearing. In response to National Grid's specific 
concern, we clarify that the nine cycle maximum clearing time expressed 
in the low voltage ride-through provisions applies only to three-phase 
faults. Single line to ground faults have typically much longer 
clearing times, as National Grid notes, and the low voltage ride-
through provisions adopted here recognize this difference by 
specifically referring to ``single line to ground faults with delayed 
clearing.'' This non-specified standard is appropriate for those types 
of faults.

B. Power Factor (Reactive Power) Provisions

    36. In the Final Rule, the Commission adopted in Appendix G to the 
LGIA a power factor standard applicable to

[[Page 75010]]

wind plants. The Final Rule provides that wind plants are required to 
meet this standard only if the Transmission Provider shows, in the 
System Impact Study, that reactive power capability is necessary to 
ensure the safety or reliability of the transmission system. The 
specific power factor standard in Appendix G to the LGIA, if 
applicable, requires a wind plant to maintain a power factor within the 
range of 0.95 leading to 0.95 lagging (hereinafter +/-0.95), to be 
measured at the Point of Interconnection.
    37. Requests for rehearing and/or clarification of these provisions 
concern whether wind plants should have to maintain a required power 
factor only where the System Impact Study shows that it is required for 
reliability or safety, and whether the power factor standard and point 
of measurement adopted by the Commission in the Final Rule are 
appropriate.
1. Case-by-Case Application/Burden of Proof for Applying the Power 
Factor Standard
    38. Several entities object to the provisions in the Final Rule 
that require wind plants to maintain the required power factor only 
when the Transmission Provider, in the System Impact Study, shows that 
it is necessary to ensure safety or reliability. NERC objects to this 
approach because it may deter Transmission Providers from implementing 
and following good utility practice and could create a ``patchwork'' of 
varying requirements. NU argues that this approach ``lowers the bar for 
reliability,'' and will add complexity, cost and delay to the generator 
interconnection process because Transmission Providers will be required 
to perform more studies to determine whether reactive power capability 
is necessary for reliability or safety. Southern Company states that 
the Transmission Provider, as the entity responsible for maintaining 
reliability, should not bear the burden of proof to establish what is 
required to maintain system reliability. It supports the Commission's 
statement that Transmission Providers should not be permitted to 
require wind plants to install costly equipment that is not needed for 
reliability, but argues that the burden of proof should be shifted to 
the generator.
    39. NRECA/APPA notes that traditional generators are required to 
meet the power factor standard not because reactive power is needed in 
every case to preserve reliability, but instead because the 
transmission system is dynamic and requires flexibility over time to 
maintain reliability. They state that the need for reactive power in 
the future under a variety of operating conditions cannot be determined 
with perfect certainty in the System Impact Study. The case-by-case 
approach, they contend, grants an undue preference to wind plants, 
imposes risks to system reliability, and shifts costs to consumers and 
other generating plants. The risk to system reliability is that the 
Final Rule may only require a wind plant to provide reactive power 
after other wind plants have been installed without such capability, 
and that at that point the resources from that single plant may not be 
enough to protect the transmission system. NRECA/APPA also asserts that 
the case-by-case approach increases uncertainty, contrary to the 
Commission's conclusion in the Final Rule, because each wind plant will 
face different requirements based on the outcome of the System Impact 
Study. Additionally, it contends that this approach creates more 
opportunities for discrimination because it would permit wind plants to 
be treated differently.
    40. ATC contends that the Commission has offered no guidance as to 
what power factor range would be acceptable if a reliability need is 
not identified (and thus reactive power is not required), and whether 
wind plants in this instance must operate within any particular 
reactive power operating band. Similarly, NU expresses concern that 
wind plants could operate at any power factor in the absence of a 
showing of need in the System Impact Study, and thus avoid a physical 
requirement for delivering power onto the transmission system. 
According to ATC, the rule could be interpreted to permit wind plants 
to operate at any power factor they choose. It claims that reactive 
power is needed for each generator, and that each generator should be 
obligated to operate within a range of power factors, regardless of 
whether the transmission system as a whole needs additional reactive 
power capability. ATC recommends that at a minimum, the Commission 
require all wind plants to meet a power factor range of 0.95 leading to 
1.0 (unity), and allow the Transmission Provider to require a range of 
1.0 (unity) to 0.95 lagging if the System Impact Study shows that there 
is a reliability need.
Commission Conclusion
    41. The Commission will not modify the Final Rule to require wind 
plants to meet the power factor standard without a showing by the 
Transmission Provider, through the System Impact Study, that it is 
needed for safety or reliability. The case-by-case approach to a 
reliability needs assessment adopted in the Final Rule will not 
threaten reliability, as several of those seeking rehearing argue. As 
we noted in the Final Rule, if reactive power is necessary to maintain 
the safety or reliability of the transmission system, the System Impact 
Study performed by the Transmission Provider will establish that 
need.\24\ We stated in the Final Rule, and reiterate here, that the 
System Impact Study is the appropriate study for determining whether 
reactive power capability is needed.\25\ Furthermore, we reasoned in 
the Final Rule that requiring wind plants to maintain the power factor 
standard only if the System Impact Study shows it to be necessary will 
not only ensure that increased reliance on wind power will not degrade 
system safety or reliability, but also will limit opportunities for 
undue discrimination by ensuring that Transmission Providers do not 
require costly equipment that is not necessary for reliability.\26\
---------------------------------------------------------------------------

    \24\ Final Rule at P 51.
    \25\ Id.
    \26\ Id.
---------------------------------------------------------------------------

    42. NERC states that the decision in Order No. 661 to use a case-
by-case approach may deter Transmission Providers from following Good 
Utility Practice, and may have the unintended consequence of spawning a 
patchwork of varying requirements. We agree with NERC that Transmission 
Providers must follow Good Utility Practice when interconnecting all 
generating plants, including wind plants, and that not following Good 
Utility Practice when performing System Impact Studies could lead to 
problems. However, the Commission points out that every Transmission 
Provider is required under Order No. 2003 to follow Good Utility 
Practice. Transmission Providers are required to complete a detailed 
System Impact Study, and are required to ensure that NERC reliability 
standards are met in all instances. This includes performing studies to 
determine what is necessary to ensure that the interconnection of a 
wind generating facility does not degrade grid reliability. The 
Commission recognizes that the industry (and particularly NERC) is 
continuing to address technical issues involved in the interconnection 
of wind plants. If NERC through its stakeholders and Board approval 
process develops a new standard, the Commission will entertain such a 
standard. Finally, we disagree with NRECA/APPA's suggestion that the 
Final Rule threatens the reliability of the transmission system because 
it may require only wind plants later in the queue to provide reactive 
power, which may not

[[Page 75011]]

be sufficient to protect the grid. The System Impact Study will take 
into account the system's need for reactive power, both as it exists 
today and under reasonable anticipated assumptions. NRECA/APPA has not 
explained how assessing the need for reactive power through the System 
Impact Study process will result in too little reactive power being 
available in the future. Whenever a new generator is added to its 
system, the Transmission Provider must complete a new System Impact 
Study to ensure that reliability requirements are met; this may require 
a new wind generator later in the queue to meet the reactive power 
requirement.
    43. We also reject arguments that the case-by-case approach is 
inappropriate because of the dynamic nature of the transmission system. 
The fact that the transmission system is constantly changing is not new 
or unique to the study of wind plant interconnections. The studies that 
are part of the interconnection process should take into account likely 
circumstances that could occur on the Transmission Provider's system, 
whether the studies are conducted in connection with a proposed wind 
plant or another type of generating facility.
    44. Furthermore, we are not persuaded that the approach adopted in 
the Final Rule will result in additional studies, increased costs and 
delays, and cost shifts. First, as noted previously, the System Impact 
Study, as well as the other interconnection studies, should take into 
account a variety of assumptions concerning anticipated transmission 
system conditions. If additional or expanded studies are needed to 
determine whether the power factor standard is necessary, the 
Commission does not believe that the additional burden will outweigh 
the cost considerations underlying the case-by-case approach. Finally, 
although the case-by-case approach may result in some delay, we remind 
the parties to a wind plant interconnection, like other 
interconnections, that they are still required to meet the milestones 
set forth in the LGIP. Any increased costs from completing expanded or 
additional studies within the timeframe required by this rule will be 
borne by the wind plant Interconnection Customer, as provided in Order 
No. 2003, which will leave other generators and the Transmission 
Provider unharmed.
    45. The Commission also rejects arguments that the case-by-case 
approach provides more opportunities for discrimination. As we noted in 
the Final Rule Appendix G was adopted to take into account the 
technical differences between wind plants and traditional generating 
plants. One of these differences is that for wind plants, reactive 
power capability is a significant added cost, while it is not a 
significant additional cost for traditional generators. Given these 
technical differences, treating wind plants differently with regard to 
reactive power requirements is not unduly discriminatory or 
preferential. Additionally, we note that the outcome of the System 
Impact Study, which determines whether reactive power will be required, 
can be challenged, which will serve to minimize the opportunities for 
discrimination by the Transmission Provider. Also, the wind plant 
Interconnection Customer will have recourse to the Commission if it 
believes the Transmission Provider has acted in a discriminatory 
manner.
    46. The Commission declines to adopt ATC's request that all wind 
plants, at a minimum, operate within a power factor range of 0.95 
leading to 1.0 (unity). This requirement would essentially require 
reactive power in every case, which we have already rejected. If 
reactive power capability is needed, including a power factor range of 
0.95 leading to 1.0 (unity), the System Impact Study will demonstrate 
this need.
2. Specific Power Factor Standard
    47. NRECA/APPA argues that the Commission should clarify that wind 
generators must meet the same reactive power requirements as other 
generators, provided the requirements are imposed in a 
nondiscriminatory manner. It notes that some Transmission Providers 
impose a power factor range wider that +/-0.95 on all new generation, 
and argues that in such cases, the same range should be applied to wind 
plants. It argues that not imposing the same range threatens 
reliability and shifts the costs of preserving reliability to customers 
or competing generators.
    48. EEI and NU assert that wind plants should regulate voltage to a 
set point established by the Transmission Provider, as do synchronous 
generators. EEI contends that the language it offered in its initial 
comments would provide this necessary clarity, while also maintaining 
the flexibility provided in Order No. 2003 so that individual, site-
specific conditions may be addressed.\27\ NU states that wind turbines 
have this capability, either inherently (doubly fed induction 
generators) or through external equipment.
---------------------------------------------------------------------------

    \27\ EEI's March 2, 2005 comments in this proceeding suggest 
that we require the wind plant to maintain a power factor within the 
range specified by the Transmission Provider ``from time to time,'' 
but would not require that it operate outside of the 0.95 leading to 
0.95 lagging range. See Comments of EEI (March 2, 2005) at 5-6.
---------------------------------------------------------------------------

    49. NRECA/APPA also expresses concern that the phrase ``taking into 
account any limitations due to voltage level, real power output, etc.'' 
in the power factor requirements section of Appendix G could create 
operational problems for Transmission Providers with wind plants on 
their systems. Specifically, it is concerned that this language could 
exempt wind plants from their reactive power requirements during 
startup and low output periods, which could degrade reliability during 
a system contingency.
Commission Conclusion
    50. With regard to NRECA/APPA's request for clarification that wind 
generators must meet a wider power factor range because some 
Transmission Providers impose a power factor range wider that +/-0.95 
on all new generation, we note that if we were to allow the 
Transmission Provider to impose a wider power factor range as a matter 
of routine, that would defeat the purpose of adopting a reactive power 
standard for wind generators. However, we note that if the System 
Impact Study shows the need for a power factor range wider than +/-0.95 
for safety or reliability, the Transmission Provider must file a non-
conforming agreement, as Order No. 2003 permits. The Commission will 
consider these non-conforming agreements on a case by case basis. If a 
Transmission Provider has a different power factor range in its LGIA 
and wishes to apply that same range in Appendix G, it may seek a 
variation from the Commission under the variation standards approved in 
the Final Rule.\28\ We remind Transmission Providers, however, that the 
Commission has adopted a specific power factor standard for wind plants 
because of their technical differences. Any proposed variations will be 
viewed in light of these technical differences.
---------------------------------------------------------------------------

    \28\ Final Rule at P 109.
---------------------------------------------------------------------------

    51. In response to the assertion of EEI and NU that wind plants 
should regulate voltage to a set point established by the Transmission 
Provider, we note that in the Final Rule we concluded that article 
9.6.2 of the LGIA (which applies to all plants, including wind plants) 
already requires that the ``Interconnection Customer * * * operate the 
Large Generating Facility to maintain the specified output voltage or 
power factor at the Point of Interconnection.'' \29\
---------------------------------------------------------------------------

    \29\ Id. at P 55.
---------------------------------------------------------------------------

    52. Finally, the Commission addressed in the Final Rule the

[[Page 75012]]

concerns raised by NRECA/APPA regarding the phrase ``taking into 
account any limitations due to voltage level, real power output, etc.'' 
We stated that this language was necessary due to the technical 
limitations of wind generating technology.\30\ We noted that all wind 
generating equipment vendors cannot meet the required power factor 
range at all levels of output. We reiterate that these technical 
differences make the disputed language necessary. Furthermore, without 
this language, a Transmission Provider could discriminate against a 
wind plant by requiring that it operate at the stated power factor at 
voltages where it is technically infeasible to do so.
---------------------------------------------------------------------------

    \30\ Id. at P 56.
---------------------------------------------------------------------------

3. Point of Measurement of Power Factor
    53. National Grid asks that if the Commission adopts the 
recommended revisions to the low voltage ride-through provisions filed 
jointly by AWEA and NERC, it clarify that while the point of 
measurement for compliance with the low voltage ride-through standard 
would be at the high-side of the step-up transformer, the point of 
measurement for reactive power is at the Point of Interconnection.
Commission Conclusion
    54. We clarify that the point of measurement for the reactive power 
standard is at the Point of Interconnection.

C. Self-Study of Interconnection Feasibility

    55. In the Final Rule, the Commission adopted special 
interconnection procedures that allow the wind plant Interconnection 
Customer, when completing the Interconnection Request form required by 
section 3.3 of the LGIP, to provide the Transmission Provider with a 
simplified set of preliminary data depicting the wind plant as a single 
equivalent generator.\31\ Once the wind generator has provided this 
data and satisfied all other applicable Interconnection Request 
conditions, the special procedures permit the wind plant to enter the 
queue and receive the base case data as provided for in the LGIP. 
Finally, the special procedures adopted in the Final Rule require the 
wind plant Interconnection Customer to submit, within six months of 
submitting the Interconnection Request, completed detailed electrical 
design specifications and other data (including collector system layout 
data) needed by the Transmission Provider to complete the System Impact 
Study.
---------------------------------------------------------------------------

    \31\ ``Single equivalent generator'' information is design data 
that represents the aggregate electrical characteristics of the 
individual wind generators as a single generator.
---------------------------------------------------------------------------

    56. Southern Company argues on rehearing that these provisions give 
wind developers a special preference that unfairly disfavors other 
generating technologies.
    57. EEI, NU and Southern Company contend that the ``self-study'' 
provisions of the Final Rule will add further complexity and 
uncertainty to the queue process and make queue management and 
assignment of cost responsibilities more difficult for Transmission 
Providers with large wind-powered generation projects in their queue. 
Southern Company adds that the self-study provisions could increase 
costs to market participants because the Transmission Provider will 
have to run multiple studies. EEI argues that until the industry can 
fully address the issues raised by these provisions in a technical 
forum, the Commission should remove the provisions from Appendix G. EEI 
and NU assert that the provisions do not protect against a wind plant 
Interconnection Customer making significant revisions to its project 
proposal. If the Commission does not remove the provisions entirely, 
EEI and NU suggest that the Commission allow the Transmission Provider 
to determine whether the detailed electrical design specifications 
later submitted by the wind plant Interconnection Customer are a 
material modification to the initial proposal, which would result in 
the initial Interconnection Application being withdrawn.
    58. Midwest ISO agrees with the Commission that a wind plant should 
be able to enter the queue and receive base case data based on 
preliminary design specifications. However, it seeks rehearing of the 
provision that permits a wind plant to wait up to six months before 
submitting final design specifications. It argues that this procedure 
promotes inefficiency because the Transmission Provider may be able to 
evaluate the proposed interconnection, but cannot do so because it 
lacks necessary data. Midwest ISO requests that the Commission revise 
the Appendix G self-study provisions to permit the Transmission 
Provider to notify the wind plant Interconnection Customer of its 
intent to start the System Impact Study. Once this notice is given, the 
wind plant developer would have five business days to ``submit either 
actual design specifications or generic specifications based on typical 
equipment used in the industry.'' \32\ Further, Midwest ISO proposes 
that if the wind plant Interconnection Customer submits generic 
specifications, it should have to accept cost uncertainty, because 
additional facilities may be required when the actual design 
specifications are taken into account. Midwest ISO asserts that this 
would limit delays in the study process and would allow the 
Transmission Provider to identify potential problems or eliminate 
tenuous or technically deficient projects earlier and to better use its 
resources to study proposed interconnections.
---------------------------------------------------------------------------

    \32\ Request for Rehearing of Midwest ISO at 4.
---------------------------------------------------------------------------

Commission Conclusion
    59. The Commission will deny these requests for rehearing. We will 
make one minor revision to label these special interconnection 
procedures for wind plants as ``Appendix 7'' to the LGIP, as discussed 
in more detail below.
    60. In response to arguments that the self-study procedures for 
wind plants give these plants a preference, we reiterate that these 
procedures were developed to recognize the technical differences of 
wind plants. Unlike conventional generators, wind plant design 
specifications and configurations can change significantly based on 
their placement on the transmission system.\33\ For example, the 
placement of wind turbines, voltage support devices, transformers, and 
other equipment (including the layout of the medium voltage collector 
system) depend on the location of the wind plant, the location of other 
generators on the transmission system, and other information included 
in the base case data.\34\ To accommodate these differences, the Final 
Rule permits wind plants to enter the interconnection queue with a set 
of preliminary electrical design specifications depicting the wind 
plant as a single generator, instead of providing detailed design 
specifications as required by Order No. 2003. Treating wind plants 
differently in this regard is not unduly discriminatory or 
preferential, but as noted elsewhere, simply recognizes that wind 
plants have different technical characteristics than the more 
traditional forms of generation that the LGIP and LGIA were designed to 
accommodate. We continue to believe that without this reasonable 
accommodation, Transmission Providers could frustrate the 
interconnection of wind plants by requiring them to submit detailed 
design data, which they cannot do until later in the interconnection 
process.
---------------------------------------------------------------------------

    \33\ Final Rule at P 97.
    \34\ Id.
---------------------------------------------------------------------------

    61. We are not persuaded that the reasonable self-study provision 
we adopted will make the interconnection

[[Page 75013]]

queue process significantly more difficult or complex. Wind plant 
Interconnection Customers who provide the preliminary single generator 
equivalent data are required to provide final detailed electrical 
design specifications no later than six months after submitting the 
initial Interconnection Request. This six-month time period takes into 
account the procedures needed before the start of the System Impact 
Study, including the Feasibility Study and negotiation of study 
agreements. Therefore, the Transmission Provider will receive from the 
wind plant the detailed design information needed to conduct the System 
Impact Study. For this reason, we also deny Midwest ISO's request to 
modify the six-month deadline. If we adopted Midwest ISO's proposed 
modifications, the Transmission Provider could request that the wind 
plant provide detailed design specifications at any time it believes it 
is ready to begin the System Impact Study, even a day after the initial 
Interconnection Request is submitted. As a result, this modification 
would defeat the purpose of permitting wind plants to submit 
preliminary design specifications, and could allow Transmission 
Providers to frustrate the interconnection of wind plants.
    62. With respect to the alternative suggestion by EEI and NU that 
the Transmission Provider be permitted to determine that a detailed 
design specification later submitted by the wind plant Interconnection 
Customer is a material modification of the Interconnection Request, we 
note that section 4.4 of the LGIP already addresses modifications and 
will apply to wind plants as well as other generating technologies. 
When applying this section to wind plant Interconnection Requests that 
first submit preliminary design specifications, Transmission Providers 
are not to consider the detailed design data provided later by the wind 
plant Interconnection Customer to be a material modification unless it 
significantly departs from the preliminary specifications provided. In