Reform of Affected System Coordination in the Generator Interconnection Process, EDF Renewable Energy, Inc. v. Midcontinent Independent System Operator, Inc., Southwest Power Pool, Inc., and PJM Interconnection, L.L.C.; Notice Inviting Post-Technical Conference Comments, 18285-18288 [2018-08722]
Download as PDF
Federal Register / Vol. 83, No. 81 / Thursday, April 26, 2018 / Notices
viewing on the internet at https://
www.regulations.gov as they are
received without change, including any
personal identifiers or contact
information.
DOD Clearance Officer: Mr. Frederick
Licari.
Requests for copies of the information
collection proposal should be sent to
Mr. Licari at whs.mc-alex.esd.mbx.dddod-information-collections@mail.mil.
Dated: April 18, 2018.
Shelly E. Finke,
Alternate OSD Federal Register Liaison
Officer, Department of Defense.
[FR Doc. 2018–08744 Filed 4–25–18; 8:45 am]
BILLING CODE 5001–06–P
DEPARTMENT OF EDUCATION
[Docket No.: ED–2018–ICCD–0047]
Agency Information Collection
Activities; Comment Request; 21st
Century Community Learning Centers
Annual Performance Report
Office of Elementary and
Secondary Education (OESE),
Department of Education (ED).
ACTION: Notice.
AGENCY:
In accordance with the
Paperwork Reduction Act of 1995, ED is
proposing a revision of an existing
information collection.
DATES: Interested persons are invited to
submit comments on or before June 25,
2018.
ADDRESSES: To access and review all the
documents related to the information
collection listed in this notice, please
use https://www.regulations.gov by
searching the Docket ID number ED–
2018–ICCD–0047. Comments submitted
in response to this notice should be
submitted electronically through the
Federal eRulemaking Portal at https://
www.regulations.gov by selecting the
Docket ID number or via postal mail,
commercial delivery, or hand delivery.
Please note that comments submitted by
fax or email and those submitted after
the comment period will not be
accepted. Written requests for
information or comments submitted by
postal mail or delivery should be
addressed to the Director of the
Information Collection Clearance
Division, U.S. Department of Education,
400 Maryland Avenue SW, LBJ, Room
216–44, Washington, DC 20202–4537.
FOR FURTHER INFORMATION CONTACT: For
specific questions related to collection
activities, please contact Daryn
Hedlund, 202–401–3008.
SUPPLEMENTARY INFORMATION: The
Department of Education (ED), in
accordance with the Paperwork
amozie on DSK30RV082PROD with NOTICES
SUMMARY:
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Reduction Act of 1995 (PRA) (44 U.S.C.
3506(c)(2)(A)), provides the general
public and Federal agencies with an
opportunity to comment on proposed,
revised, and continuing collections of
information. This helps the Department
assess the impact of its information
collection requirements and minimize
the public’s reporting burden. It also
helps the public understand the
Department’s information collection
requirements and provide the requested
data in the desired format. ED is
soliciting comments on the proposed
information collection request (ICR) that
is described below. The Department of
Education is especially interested in
public comment addressing the
following issues: (1) Is this collection
necessary to the proper functions of the
Department; (2) will this information be
processed and used in a timely manner;
(3) is the estimate of burden accurate;
(4) how might the Department enhance
the quality, utility, and clarity of the
information to be collected; and (5) how
might the Department minimize the
burden of this collection on the
respondents, including through the use
of information technology. Please note
that written comments received in
response to this notice will be
considered public records.
Title of Collection: 21st Century
Community Learning Centers Annual
Performance Report.
OMB Control Number: 1810–0668.
Type of Review: A revision of an
existing information collection.
Respondents/Affected Public: Private
Sector.
Total Estimated Number of Annual
Responses: 54.
Total Estimated Number of Annual
Burden Hours: 1,488.
Abstract: The purpose of the 21st
Century Community Learning Centers
(21st CCLC) program, as authorized
under Title IV, Part B, of the Elementary
and Secondary Education Act, as
amended by the Every Student Succeeds
Act (ESSA) (20 U.S.C. 7171–7176) is to
create community learning centers that
provide academic enrichment
opportunities for children, particularly
students who attend high poverty and
low-performing schools, to meet State
and local student standards in core
academic subjects, to offer students a
broad array of enrichment activities that
can complement their regular academic
programs, and to offer literacy and other
educational services to the families of
participating children. Present in all 50
states, the District of Columbia, Puerto
Rico, U.S. Virgin Islands, and the
Bureau of Indian Education, academic
enrichment and youth development
programs are designed to enhance
participants’ well-being and academic
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18285
success. In support of this program,
Congress appropriated nearly $1.2
billion for 21st CCLC programs for fiscal
year 2016. Consisting of public and
nonprofit agencies, community- and
faith-based organizations, postsecondary
institutions, and other community
entities, 3,695 sub-grantees—operating
9,252 centers—provided academic and
enrichment services and activities to
over 1.8 million participants.
Dated: April 20, 2018.
Tomakie Washington,
Acting Director, Information Collection
Clearance Division, Office of the Chief Privacy
Officer, Office of Management.
[FR Doc. 2018–08735 Filed 4–25–18; 8:45 am]
BILLING CODE 4000–01–P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket No. AD18–8–000; Docket No. EL18–
26–000]
Reform of Affected System
Coordination in the Generator
Interconnection Process, EDF
Renewable Energy, Inc. v.
Midcontinent Independent System
Operator, Inc., Southwest Power Pool,
Inc., and PJM Interconnection, L.L.C.;
Notice Inviting Post-Technical
Conference Comments
On April 3 and April 4, 2018, Federal
Energy Regulatory Commission
(Commission) staff conducted a
technical conference to discuss issues
related to affected systems that have
been raised in the complaint filed by
EDF Renewable Energy, Inc. against
Midcontinent Independent System
Operator, Inc., Southwest Power Pool,
Inc., and PJM Interconnection, L.L.C. in
Docket No. EL18–26–000 and in the
Commission’s Notice of Proposed
Rulemaking (Generator Interconnection
NOPR) on the interconnection process
in Docket No. RM17–8–000.
All interested persons are invited to
file initial and reply post-technical
conference comments on the questions
listed in the Supplemental Notice of
Technical Conference issued in this
proceeding on March 26, 2018 and the
questions listed in the attachment to
this notice. Commenters need not
respond to all topics or questions asked.
Commenters may reference material
previously filed in this docket but are
encouraged to submit new or additional
information rather than reiterate
information that is already in the record.
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In particular, commenters are
encouraged, when possible, to provide
examples in support of their answers.
Initial and reply comments are due
within 30 days and 45 days,
respectively, from the date of this
notice.
For more information about this
notice, please contact:
Myra Sinnott (Technical Information),
Office of Energy Policy and
Innovation, (202) 502–6033,
Myra.Sinnott@ferc.gov.
Kathleen Ratcliff (Technical
Information), Office of Energy Market
Regulation, (202) 502–8018,
Kathleen.Ratcliff@ferc.gov.
Lina Naik (Legal Information), Office of
the General Counsel, (202) 502–8882,
Lina.Naik@ferc.gov.
Dated: April 19, 2018.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
Post-Technical Conference Questions
for Comment
For any of the following questions,
please also describe any issues
presented when an affected system is a
non-public utility transmission
provider.
amozie on DSK30RV082PROD with NOTICES
General Affected Systems Coordination
Processes
1. Please describe any affected system
coordination processes and guidance
available for your market or balancing
authority area, including, but not
limited to, tariff provisions, joint
operating agreements (JOA), and
business practice manuals (BPM).
2. Please explain the role of the host
transmission provider in managing the
coordination and communication
between an interconnection customer
and an affected system during the
course of an interconnection request
process. If the interconnection customer
has primary responsibility to coordinate
and communicate with the affected
system, please explain how the host
transmission provider ensures that
affected system matters are addressed
before proceeding with an
interconnection for which affected
system impacts have been raised.
3. With respect to Midcontinent
Independent System Operator, Inc.
(MISO), Southwest Power Pool, Inc.
(SPP), and PJM Interconnection, L.L.C.
(PJM) specifically, once the need for an
affected system study is determined,
please describe how each RTO then
coordinates with the other RTO to
consider the affected system impacts
due to an interconnection request on the
host system. Please include the steps in
the process and any timelines and other
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procedural matters, and reference any
tariff, JOA, BPM, and/or other
provisions that describe the process for
such coordination.
4. Should there be a pro forma
affected system study agreement that
provides for firm timelines for the
affected system to provide the relevant
studies? If so, what terms and
conditions should it contain, and what
entities should be parties to the affected
system study agreement (e.g., host
transmission provider, host
transmission owner, affected system,
interconnection customer)? What
modifications would need to be made to
such a study agreement to accommodate
a non-public utility affected system?
5. Regardless of whether the
Commission proceeds with
development of a pro forma affected
systems study agreement, should MISO,
SPP, and PJM develop a common
affected systems study agreement? If so,
what terms and conditions should this
agreement contain, and what entities
should be parties to the agreement (e.g.,
host transmission provider, host
transmission owner, affected system,
interconnection customer)? If possible,
please provide a sample of a commonly
used affected systems study agreement.
6. As part of the affected systems
study agreement, if affected systems
were allowed to charge interconnection
customers an administrative fee for
conducting affected system studies, in
addition to receiving reimbursement for
the actual costs of conducting affected
system studies, would such a fee
motivate affected systems that lack
resources, such as full-time employees,
to conduct affected system studies in a
more timely manner? If so, how should
the fee be determined and what
milestones of the affected system should
be tied to the fee? Should such an
administrative fee be tied to the affected
system providing its study results by a
certain date?
7. Describe any planned or in-process
affected system coordination
improvement efforts taking place in
your market or balancing authority area
(through a stakeholder process, etc.).
Please provide links or directions to any
publicly available materials related to
these improvement efforts.
Modeling and Study Procedures Used
for Affected Systems Information
1. Please explain how Network
Resource Interconnection Service
(NRIS) and Energy Resource
Interconnection Service (ERIS) are
modeled both when conducting studies
on your system and when conducting
studies as an affected system, and
provide a reference to where that
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information is located in your tariff. Are
the standards (e.g. shift factors,
contingency lists) for modeling NRIS
and ERIS available to customers, and if
so, where is this information located?
2. Explain the reasons an affected
system would study an interconnection
request made in a host system using
NRIS criteria when the interconnection
customer is only requesting NRIS in the
host system. What are the benefits and
drawbacks to studying and also
requiring an interconnection customer
seeking NRIS in the host system to be
responsible for network upgrade costs in
an affected system in the same manner
as an interconnection customer who
requests NRIS in the affected system?
3. Explain the reasons an affected
system could or should study an
interconnection request using ERIS
criteria when the interconnection
customer is requesting NRIS in the host
system. If you believe affected system
transmission providers should study
NRIS requests as ERIS, please include
an explanation of how ERIS criteria
address reliability concerns associated
with an NRIS interconnection request in
both the host and affected systems.
4. Should there be a standard
approach to determine if an
interconnection customer requesting
NRIS in the host system is studied as
NRIS or ERIS on an affected system? If
so, what should the standard be and
why?
5. If there is no generic reform that
dictates how affected systems study
interconnection customers who request
NRIS on the host system, should MISO,
SPP, and PJM develop a standard
approach to determining whether such
an interconnection customer should be
studied as NRIS or ERIS on the affected
system(s) during the modeling process?
If so, what should the standard be and
why?
6. Please explain the process used to
calculate generation shift factors,
including how and where the reference
bus is selected, when conducting an
affected system study for
interconnection requests made in a host
system.
7. What are the dispatch assumptions
used in affected systems studies? Are
the dispatch assumptions the same for
already interconnected resources on the
host system that affect flows on the
affected system and resources already
interconnected in the affected system?
Are these dispatch assumptions
consistent with the assumptions an
affected system uses when it performs
an interconnection request within its
footprint? Are the dispatch assumptions
an affected system uses in affected
system studies provided to
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interconnection customers? To the
extent already interconnected resources
on the host system are assumed to be
dispatched at full output, what is the
rationale for that assumption?
8. What criteria do transmission
providers use to determine whether an
interconnection request on the host
system requires an affected system
study on an affected system? Please
provide references to tariff, JOA, BPM,
and any other provisions that include
this criteria. If the determination is
based on ‘‘engineering judgment,’’ is
this judgment adequately explained to
the interconnection customer? If so, in
what form does the interconnection
customer receive that information? If
there is a disagreement regarding this
determination, is there a process for the
customer to challenge it? If so, please
provide a detailed description of that
process.
9. Should MISO, SPP, and PJM be
required to use the same criteria to
determine whether an interconnection
request on the host system requires an
affected system study on an affected
system?
10. Please comment on the possibility
of implementing jointly developed
interconnection-wide transmission
models between transmission providers
in affected system studies to detect
topology changes to a transmission
provider’s region that might not be
visible by the affected systems until the
next interconnection-wide model
update.
11. When an affected system studies
an interconnection request, should it
model its entire footprint or a subregion(s) of its system? If a sub-region(s)
would be sufficient, please explain what
criteria would be used to determine the
sub-region(s) in an affected system that
are impacted by an interconnection
request in a host system.
12. What are the benefits and
drawbacks for the interconnection
customer, the host transmission
provider and the affected system to an
affected system studying all
interconnection requests in a host
system study cluster or queue to
determine affected system impacts? Is
there a way the host system could
employ some type of pre-screening
process to limit affected systems
analysis to only those requests that may
impact an affected system? What criteria
should be used in such a pre-screening
process?
13. At what point in the
interconnection process should
interconnection customers be required
to provide relevant modeling data to
best avoid delays in both the host
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interconnection and affected system
study processes?
Timing of Affected System
Coordination
1. Does the host system’s
interconnection process include an
opportunity for the host system and
interconnection customer to review an
affected system study and discuss the
results with the host system or affected
system, as necessary, before the
interconnection process either requires
a financial milestone payment or
execution of an interconnection
agreement? If so, please provide
references to the relevant tariff or
manual descriptions of this opportunity.
Is this opportunity to review included
in the host system’s interconnection
queue timeline? If so, how much time is
allowed?
2. Should all host system
transmission providers be required to
align their interconnection study
process schedules with any relevant
affected systems in order to allow for
both host system and affected system
studies to occur on the same timeline?
Would such alignment improve the
timing at which an interconnection
customer receives affected system study
results? What actions could the host
system, affected system, and
interconnection customer take to better
align the completion of affected system
study results? Should the Commission
require that an interconnection
customer receive affected system study
results at the same time it receives a
host system’s system impact study
results? If so, would there be any
concerns with that approach?
3. Should MISO, SPP, and PJM be
required to adopt a common timeline for
conducting affected systems studies and
providing results to interconnection
customers and/or the host transmission
provider? If not, why not? If so, please
explain how this common timeline
could be implemented. For example,
would each RTO begin affected system
studies at certain set dates throughout
the year and commit to providing
results by certain set dates, or are there
other ways of implementing a common
timeline? Please also provide an
example of how this common timeline
could be developed—that is, by
providing sample tariff, JOA, BPM, or
other language.
4. Should affected systems be
required to adhere to a time limit or
point in the host system’s
interconnection process (such as when
a generator interconnection agreement
(GIA) is tendered or system impact
study data is provided by the host
system to the interconnection customer)
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18287
by which the affected system should
notify the interconnection customer
and/or host transmission provider of
network upgrade costs?
5. Should affected system study
results be aligned with the host system’s
system impact study results to allow
interconnection customers to have an
estimate of all of their potential network
upgrade costs prior to proceeding in the
queue with an at-risk financial
payment? Alternatively, if an
interconnection customer is required to
proceed with an at-risk financial
payment or move forward with an
interconnection agreement without
having the affected system study results,
should the affected system or host
system be required to provide the
interconnection customer with an
option for a refund of its payment if it
withdraws due to late-received affected
system study results?
6. Please comment on the potential for
an alternative affected system study
process in which the host system
obtains the model from the affected
system and performs the impact
analysis on the affected system for
interconnection customers itself, with
the host system following up with the
affected system to verify results. Would
such an approach be beneficial or
practicable? Would the additional
analysis and verification add time to the
interconnection process? Should the
host system be compensated for
performing the impact analysis?
7. Should the Commission require
that time be allowed to potentially
identify and consider either alternatives
to the dispatch assumptions or
adjustments to the interconnection
request that could mitigate the cost of a
network upgrade on an affected system?
If so, what duration of time would be
sufficient?
8. With respect to MISO, SPP, and
PJM specifically, should the
Commission require that time be
allowed to potentially identify and
consider either alternatives to the
dispatch assumptions or adjustments to
the interconnection request that could
mitigate the cost of a network upgrade
on an affected system? If so, what
duration of time would be sufficient?
Even if a common timeline is not
required by the Commission, should
MISO, SPP, and PJM nevertheless be
required to build time into their own
interconnection processes to allow for
further consideration of affected system
study results and potential mitigation
measures as an alternative to the
network upgrades included in an
affected system study? For example,
should interconnection customers in
MISO be allowed more than 15 days
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after receipt of affected system study
results to decide to proceed to the next
phase of the definitive planning phase
(DPP)?
9. Should MISO perform fewer
affected systems studies than the three
studies currently required as part of the
three-phase DPP process? If so, which
phase(s) in the DPP is most important to
the analysis of potential impacts on
affected systems? Should an
interconnection customer in MISO be
permitted to proceed to the next DPP
phase even if an affected system study
is not ready and therefore not included
in the system impact study of the prior
phase?
Allocation of Affected System Costs
1. Are there improvements that could
be made to transmission planning
processes to better identify transmission
projects that benefit host systems and/
or affected systems but that are
currently identified only in
interconnection studies and affected
system studies? If so, please explain
how such improvements should be
made? What are the benefits and
drawbacks of such an approach?
2. If study results from affected
systems are significantly delayed, and
the interconnection customer is
required to proceed in the process
without affected system study results,
should the customer still be responsible
for the full cost of an affected system
upgrade? Should there be a time after
which the affected system has ‘‘lost its
chance’’ to have the interconnection
customer be responsible for the network
upgrade? If so, how would the affected
system then address the need for the
network upgrade?
3. How should costs be allocated
among affected system and host system
interconnection customers in instances
where a major network upgrade on a
transmission provider’s system is only
identified through an affected system
study and not identified in the host
system studies? Should host system
interconnection customers be
responsible for any portion of those
network upgrade costs? Should an
interconnection customer needing such
an affected system upgrade have the
ability to challenge the assignment of
network upgrade costs? Please also
discuss this issue specifically in the
context of the Cooper South constraint
in SPP.
4. Should the host system and
affected system be required to conduct
a ‘‘least-cost alternative’’ analysis for
identified affected system upgrades? If
so, please explain how that will
improve the issues with affected
systems.
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5. If the same network upgrade is
required by interconnection requests on
both a host system and an affected
system, is there cost sharing among the
interconnection customers? Does this
cost sharing extend to lower-queued
customers, whether they are host system
customers or affected system customers?
6. How are interconnection requests
made on an affected system aligned
with host system interconnection
requests for the purpose of determining
queue order and cost responsibility? For
instance, where the affected system uses
a cluster study approach, are
interconnection requests external to the
affected system integrated into the
affected system’s current cluster study
with queue priority and cost
responsibility equivalent to the other
interconnection requests in the cluster?
7. Should MISO, SPP, and PJM be
required to develop a network upgrade
construct that avoids a ‘‘higher-queued’’
penalty, whereby network upgrade costs
are assigned to higher-queued projects
(earlier in time) rather than to lowerqueued projects (later in time)? How do
MISO, SPP, and PJM determine whether
affected system interconnection
customers or host system
interconnection customers are
responsible for the cost of a specific
network upgrade? Please list the tariff,
JOA, or BPM provisions that may govern
this process.
8. With respect to MISO, SPP, and
PJM specifically, should they be
required to develop a unified approach
to determine queue priority in affected
systems analysis to determine cost
responsibility for network upgrade
costs?
9. Please describe whether
interconnection customers that fund
network upgrades on an affected system
and pursuant to an affected system
study receive transmission credits,
transmission rights, or any other
consideration for funding those network
upgrades on the affected system. Please
provide any tariff or other provisions
that govern this issue.
10. Please describe whether
interconnection customers that fund
network upgrades on an affected system
and pursuant to an affected system
study in MISO, SPP, or PJM receive
transmission credits, transmission
rights, or any other consideration for
funding those network upgrades on the
affected system. Please provide any
tariff, JOA, BPM or other provisions that
govern this issue. Does any disparity in
approaches between MISO, SPP, and
PJM impact the interconnection
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customers and/or affected system study
process? If so, how?
[FR Doc. 2018–08722 Filed 4–25–18; 8:45 am]
BILLING CODE 6717–01–P
FEDERAL COMMUNICATIONS
COMMISSION
[AU Docket No. 17–143; DA 18–260]
Auction of Cross-Service FM
Translator Construction Permits
Scheduled for May 15, 2018; Notice
and Filing Requirements, Minimum
Opening Bids, Upfront Payments, and
Other Procedures for Auction 99
Federal Communications
Commission.
ACTION: Final action; requirements and
procedures.
AGENCY:
This document summarizes
the procedures and announces upfront
payment amounts and minimum
opening bids for the auction of crossservice FM translator construction
permits (Auction 99). The Public Notice
summarized here is intended to
familiarize applicants with the
procedures and other requirements for
participation in the auction.
DATES: A sufficient upfront payment
and a complete and accurate FCC
Remittance Advice Form (FCC Form
159) must be submitted before 6:00 p.m.
Eastern Time (ET) on April 19, 2018.
Bidding in Auction 99 is scheduled to
start on May 15, 2018.
FOR FURTHER INFORMATION CONTACT: For
auction legal questions, Lynne Milne in
the Wireless Telecommunications
Bureau’s Auctions and Spectrum Access
Division at (202) 418–0660. For auction
process and procedures, the FCC
Auction Hotline at (717) 338–2868. For
FM translator service questions, James
Bradshaw, Lisa Scanlan or Tom
Nessinger in the Media Bureau’s Audio
Division at (202) 418–2700. To request
materials in accessible formats (Braille,
large print, electronic files, or audio
format) for people with disabilities,
send an email to fcc504@fcc.gov or call
the Consumer and Governmental Affairs
Bureau at (202) 418–0530 or (202) 418–
0432 (TTY).
SUPPLEMENTARY INFORMATION: This is a
summary of Auction of Cross-Service
FM Translator Construction Permits
Scheduled for May 15, 2018; Notice and
Filing Requirements, Minimum Opening
Bids, Upfront Payments, and Other
Procedures for Auction 99, (Auction 99
Procedures Public Notice) released on
March 23, 2018. The complete text of
the Auction 99 Procedures Public
Notice, including attachments and any
SUMMARY:
E:\FR\FM\26APN1.SGM
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Agencies
[Federal Register Volume 83, Number 81 (Thursday, April 26, 2018)]
[Notices]
[Pages 18285-18288]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-08722]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket No. AD18-8-000; Docket No. EL18-26-000]
Reform of Affected System Coordination in the Generator
Interconnection Process, EDF Renewable Energy, Inc. v. Midcontinent
Independent System Operator, Inc., Southwest Power Pool, Inc., and PJM
Interconnection, L.L.C.; Notice Inviting Post-Technical Conference
Comments
On April 3 and April 4, 2018, Federal Energy Regulatory Commission
(Commission) staff conducted a technical conference to discuss issues
related to affected systems that have been raised in the complaint
filed by EDF Renewable Energy, Inc. against Midcontinent Independent
System Operator, Inc., Southwest Power Pool, Inc., and PJM
Interconnection, L.L.C. in Docket No. EL18-26-000 and in the
Commission's Notice of Proposed Rulemaking (Generator Interconnection
NOPR) on the interconnection process in Docket No. RM17-8-000.
All interested persons are invited to file initial and reply post-
technical conference comments on the questions listed in the
Supplemental Notice of Technical Conference issued in this proceeding
on March 26, 2018 and the questions listed in the attachment to this
notice. Commenters need not respond to all topics or questions asked.
Commenters may reference material previously filed in this docket but
are encouraged to submit new or additional information rather than
reiterate information that is already in the record.
[[Page 18286]]
In particular, commenters are encouraged, when possible, to provide
examples in support of their answers. Initial and reply comments are
due within 30 days and 45 days, respectively, from the date of this
notice.
For more information about this notice, please contact:
Myra Sinnott (Technical Information), Office of Energy Policy and
Innovation, (202) 502-6033, [email protected].
Kathleen Ratcliff (Technical Information), Office of Energy Market
Regulation, (202) 502-8018, [email protected].
Lina Naik (Legal Information), Office of the General Counsel, (202)
502-8882, [email protected].
Dated: April 19, 2018.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
Post-Technical Conference Questions for Comment
For any of the following questions, please also describe any issues
presented when an affected system is a non-public utility transmission
provider.
General Affected Systems Coordination Processes
1. Please describe any affected system coordination processes and
guidance available for your market or balancing authority area,
including, but not limited to, tariff provisions, joint operating
agreements (JOA), and business practice manuals (BPM).
2. Please explain the role of the host transmission provider in
managing the coordination and communication between an interconnection
customer and an affected system during the course of an interconnection
request process. If the interconnection customer has primary
responsibility to coordinate and communicate with the affected system,
please explain how the host transmission provider ensures that affected
system matters are addressed before proceeding with an interconnection
for which affected system impacts have been raised.
3. With respect to Midcontinent Independent System Operator, Inc.
(MISO), Southwest Power Pool, Inc. (SPP), and PJM Interconnection,
L.L.C. (PJM) specifically, once the need for an affected system study
is determined, please describe how each RTO then coordinates with the
other RTO to consider the affected system impacts due to an
interconnection request on the host system. Please include the steps in
the process and any timelines and other procedural matters, and
reference any tariff, JOA, BPM, and/or other provisions that describe
the process for such coordination.
4. Should there be a pro forma affected system study agreement that
provides for firm timelines for the affected system to provide the
relevant studies? If so, what terms and conditions should it contain,
and what entities should be parties to the affected system study
agreement (e.g., host transmission provider, host transmission owner,
affected system, interconnection customer)? What modifications would
need to be made to such a study agreement to accommodate a non-public
utility affected system?
5. Regardless of whether the Commission proceeds with development
of a pro forma affected systems study agreement, should MISO, SPP, and
PJM develop a common affected systems study agreement? If so, what
terms and conditions should this agreement contain, and what entities
should be parties to the agreement (e.g., host transmission provider,
host transmission owner, affected system, interconnection customer)? If
possible, please provide a sample of a commonly used affected systems
study agreement.
6. As part of the affected systems study agreement, if affected
systems were allowed to charge interconnection customers an
administrative fee for conducting affected system studies, in addition
to receiving reimbursement for the actual costs of conducting affected
system studies, would such a fee motivate affected systems that lack
resources, such as full-time employees, to conduct affected system
studies in a more timely manner? If so, how should the fee be
determined and what milestones of the affected system should be tied to
the fee? Should such an administrative fee be tied to the affected
system providing its study results by a certain date?
7. Describe any planned or in-process affected system coordination
improvement efforts taking place in your market or balancing authority
area (through a stakeholder process, etc.). Please provide links or
directions to any publicly available materials related to these
improvement efforts.
Modeling and Study Procedures Used for Affected Systems Information
1. Please explain how Network Resource Interconnection Service
(NRIS) and Energy Resource Interconnection Service (ERIS) are modeled
both when conducting studies on your system and when conducting studies
as an affected system, and provide a reference to where that
information is located in your tariff. Are the standards (e.g. shift
factors, contingency lists) for modeling NRIS and ERIS available to
customers, and if so, where is this information located?
2. Explain the reasons an affected system would study an
interconnection request made in a host system using NRIS criteria when
the interconnection customer is only requesting NRIS in the host
system. What are the benefits and drawbacks to studying and also
requiring an interconnection customer seeking NRIS in the host system
to be responsible for network upgrade costs in an affected system in
the same manner as an interconnection customer who requests NRIS in the
affected system?
3. Explain the reasons an affected system could or should study an
interconnection request using ERIS criteria when the interconnection
customer is requesting NRIS in the host system. If you believe affected
system transmission providers should study NRIS requests as ERIS,
please include an explanation of how ERIS criteria address reliability
concerns associated with an NRIS interconnection request in both the
host and affected systems.
4. Should there be a standard approach to determine if an
interconnection customer requesting NRIS in the host system is studied
as NRIS or ERIS on an affected system? If so, what should the standard
be and why?
5. If there is no generic reform that dictates how affected systems
study interconnection customers who request NRIS on the host system,
should MISO, SPP, and PJM develop a standard approach to determining
whether such an interconnection customer should be studied as NRIS or
ERIS on the affected system(s) during the modeling process? If so, what
should the standard be and why?
6. Please explain the process used to calculate generation shift
factors, including how and where the reference bus is selected, when
conducting an affected system study for interconnection requests made
in a host system.
7. What are the dispatch assumptions used in affected systems
studies? Are the dispatch assumptions the same for already
interconnected resources on the host system that affect flows on the
affected system and resources already interconnected in the affected
system? Are these dispatch assumptions consistent with the assumptions
an affected system uses when it performs an interconnection request
within its footprint? Are the dispatch assumptions an affected system
uses in affected system studies provided to
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interconnection customers? To the extent already interconnected
resources on the host system are assumed to be dispatched at full
output, what is the rationale for that assumption?
8. What criteria do transmission providers use to determine whether
an interconnection request on the host system requires an affected
system study on an affected system? Please provide references to
tariff, JOA, BPM, and any other provisions that include this criteria.
If the determination is based on ``engineering judgment,'' is this
judgment adequately explained to the interconnection customer? If so,
in what form does the interconnection customer receive that
information? If there is a disagreement regarding this determination,
is there a process for the customer to challenge it? If so, please
provide a detailed description of that process.
9. Should MISO, SPP, and PJM be required to use the same criteria
to determine whether an interconnection request on the host system
requires an affected system study on an affected system?
10. Please comment on the possibility of implementing jointly
developed interconnection-wide transmission models between transmission
providers in affected system studies to detect topology changes to a
transmission provider's region that might not be visible by the
affected systems until the next interconnection-wide model update.
11. When an affected system studies an interconnection request,
should it model its entire footprint or a sub-region(s) of its system?
If a sub-region(s) would be sufficient, please explain what criteria
would be used to determine the sub-region(s) in an affected system that
are impacted by an interconnection request in a host system.
12. What are the benefits and drawbacks for the interconnection
customer, the host transmission provider and the affected system to an
affected system studying all interconnection requests in a host system
study cluster or queue to determine affected system impacts? Is there a
way the host system could employ some type of pre-screening process to
limit affected systems analysis to only those requests that may impact
an affected system? What criteria should be used in such a pre-
screening process?
13. At what point in the interconnection process should
interconnection customers be required to provide relevant modeling data
to best avoid delays in both the host interconnection and affected
system study processes?
Timing of Affected System Coordination
1. Does the host system's interconnection process include an
opportunity for the host system and interconnection customer to review
an affected system study and discuss the results with the host system
or affected system, as necessary, before the interconnection process
either requires a financial milestone payment or execution of an
interconnection agreement? If so, please provide references to the
relevant tariff or manual descriptions of this opportunity. Is this
opportunity to review included in the host system's interconnection
queue timeline? If so, how much time is allowed?
2. Should all host system transmission providers be required to
align their interconnection study process schedules with any relevant
affected systems in order to allow for both host system and affected
system studies to occur on the same timeline? Would such alignment
improve the timing at which an interconnection customer receives
affected system study results? What actions could the host system,
affected system, and interconnection customer take to better align the
completion of affected system study results? Should the Commission
require that an interconnection customer receive affected system study
results at the same time it receives a host system's system impact
study results? If so, would there be any concerns with that approach?
3. Should MISO, SPP, and PJM be required to adopt a common timeline
for conducting affected systems studies and providing results to
interconnection customers and/or the host transmission provider? If
not, why not? If so, please explain how this common timeline could be
implemented. For example, would each RTO begin affected system studies
at certain set dates throughout the year and commit to providing
results by certain set dates, or are there other ways of implementing a
common timeline? Please also provide an example of how this common
timeline could be developed--that is, by providing sample tariff, JOA,
BPM, or other language.
4. Should affected systems be required to adhere to a time limit or
point in the host system's interconnection process (such as when a
generator interconnection agreement (GIA) is tendered or system impact
study data is provided by the host system to the interconnection
customer) by which the affected system should notify the
interconnection customer and/or host transmission provider of network
upgrade costs?
5. Should affected system study results be aligned with the host
system's system impact study results to allow interconnection customers
to have an estimate of all of their potential network upgrade costs
prior to proceeding in the queue with an at-risk financial payment?
Alternatively, if an interconnection customer is required to proceed
with an at-risk financial payment or move forward with an
interconnection agreement without having the affected system study
results, should the affected system or host system be required to
provide the interconnection customer with an option for a refund of its
payment if it withdraws due to late-received affected system study
results?
6. Please comment on the potential for an alternative affected
system study process in which the host system obtains the model from
the affected system and performs the impact analysis on the affected
system for interconnection customers itself, with the host system
following up with the affected system to verify results. Would such an
approach be beneficial or practicable? Would the additional analysis
and verification add time to the interconnection process? Should the
host system be compensated for performing the impact analysis?
7. Should the Commission require that time be allowed to
potentially identify and consider either alternatives to the dispatch
assumptions or adjustments to the interconnection request that could
mitigate the cost of a network upgrade on an affected system? If so,
what duration of time would be sufficient?
8. With respect to MISO, SPP, and PJM specifically, should the
Commission require that time be allowed to potentially identify and
consider either alternatives to the dispatch assumptions or adjustments
to the interconnection request that could mitigate the cost of a
network upgrade on an affected system? If so, what duration of time
would be sufficient? Even if a common timeline is not required by the
Commission, should MISO, SPP, and PJM nevertheless be required to build
time into their own interconnection processes to allow for further
consideration of affected system study results and potential mitigation
measures as an alternative to the network upgrades included in an
affected system study? For example, should interconnection customers in
MISO be allowed more than 15 days
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after receipt of affected system study results to decide to proceed to
the next phase of the definitive planning phase (DPP)?
9. Should MISO perform fewer affected systems studies than the
three studies currently required as part of the three-phase DPP
process? If so, which phase(s) in the DPP is most important to the
analysis of potential impacts on affected systems? Should an
interconnection customer in MISO be permitted to proceed to the next
DPP phase even if an affected system study is not ready and therefore
not included in the system impact study of the prior phase?
Allocation of Affected System Costs
1. Are there improvements that could be made to transmission
planning processes to better identify transmission projects that
benefit host systems and/or affected systems but that are currently
identified only in interconnection studies and affected system studies?
If so, please explain how such improvements should be made? What are
the benefits and drawbacks of such an approach?
2. If study results from affected systems are significantly
delayed, and the interconnection customer is required to proceed in the
process without affected system study results, should the customer
still be responsible for the full cost of an affected system upgrade?
Should there be a time after which the affected system has ``lost its
chance'' to have the interconnection customer be responsible for the
network upgrade? If so, how would the affected system then address the
need for the network upgrade?
3. How should costs be allocated among affected system and host
system interconnection customers in instances where a major network
upgrade on a transmission provider's system is only identified through
an affected system study and not identified in the host system studies?
Should host system interconnection customers be responsible for any
portion of those network upgrade costs? Should an interconnection
customer needing such an affected system upgrade have the ability to
challenge the assignment of network upgrade costs? Please also discuss
this issue specifically in the context of the Cooper South constraint
in SPP.
4. Should the host system and affected system be required to
conduct a ``least-cost alternative'' analysis for identified affected
system upgrades? If so, please explain how that will improve the issues
with affected systems.
5. If the same network upgrade is required by interconnection
requests on both a host system and an affected system, is there cost
sharing among the interconnection customers? Does this cost sharing
extend to lower-queued customers, whether they are host system
customers or affected system customers?
6. How are interconnection requests made on an affected system
aligned with host system interconnection requests for the purpose of
determining queue order and cost responsibility? For instance, where
the affected system uses a cluster study approach, are interconnection
requests external to the affected system integrated into the affected
system's current cluster study with queue priority and cost
responsibility equivalent to the other interconnection requests in the
cluster?
7. Should MISO, SPP, and PJM be required to develop a network
upgrade construct that avoids a ``higher-queued'' penalty, whereby
network upgrade costs are assigned to higher-queued projects (earlier
in time) rather than to lower-queued projects (later in time)? How do
MISO, SPP, and PJM determine whether affected system interconnection
customers or host system interconnection customers are responsible for
the cost of a specific network upgrade? Please list the tariff, JOA, or
BPM provisions that may govern this process.
8. With respect to MISO, SPP, and PJM specifically, should they be
required to develop a unified approach to determine queue priority in
affected systems analysis to determine cost responsibility for network
upgrade costs?
9. Please describe whether interconnection customers that fund
network upgrades on an affected system and pursuant to an affected
system study receive transmission credits, transmission rights, or any
other consideration for funding those network upgrades on the affected
system. Please provide any tariff or other provisions that govern this
issue.
10. Please describe whether interconnection customers that fund
network upgrades on an affected system and pursuant to an affected
system study in MISO, SPP, or PJM receive transmission credits,
transmission rights, or any other consideration for funding those
network upgrades on the affected system. Please provide any tariff,
JOA, BPM or other provisions that govern this issue. Does any disparity
in approaches between MISO, SPP, and PJM impact the interconnection
customers and/or affected system study process? If so, how?
[FR Doc. 2018-08722 Filed 4-25-18; 8:45 am]
BILLING CODE 6717-01-P