2014 Modification Assessment Cost and Accounting Report July 1, 2015

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Wesley Elliott
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1 2014 Modification Assessment Cost and Accounting Report July 1, 2015 Prepared by: Raeann Quadro Version: 1 California Independent System Operator

2 Table of Contents 1. Executive Summary 1.1. Purpose and Scope 1.2. Background 1.3. Process Modification Assessment Cost and Accounting Report 2.1 Cost 2.2 Timing 2.3 Outcomes Doc ID: XWK2E22ZZR Page 1 of 6

3 1.0 Executive Summary 1.1 Purpose and Scope The CAISO evaluates a variety of modification requests for Customers generator projects. In doing so, the CAISO coordinates with the relevant Participating TO(s) and Affected System Operator(s), if any. Effective December 3, 2013, the CAISO Tariff requires that Customers themselves bear the costs of these modification assessments. To provide transparency, the Tariff also requires the CAISO to publish cost data for modification assessments. This report contains a description of the number, types, duration, and costs of modification requests in Background The CAISO generally uses the same process and criteria to review modification requests for all generation projects. 1 A high level-depiction of the modification process is below: Customers are required to provide a $10,000 deposit for the modification assessment, and after the modification assessment is complete, the CAISO invoices for the actual costs of the modification assessment. The invoices include an itemized account of expenses incurred, including those incurred by the CAISO, the Participating TOs, and third parties at the direction of the CAISO or Participating TO). Whenever the actual cost of performing the modification assessment exceeds the modification assessment deposit, the invoice directs the Customer to pay the excess amount. However, it is far more common for the deposit to exceed the invoice, 2 in which case the Customer is refunded the balance. 1 The modification assessments discussed in this report are governed by CAISO Tariff Appendix S, Section 1.3.4; Appendix T, Section 3.4.5; Appendix U, Section 4.4.3; Appendix Y, Section ; or Appendix DD, Article as applicable, and the BPM for Generator Management. 2 Or the Customer withdraws its modification request before most costs are incurred. Doc ID: XWK2E22ZZR Page 2 of 6

4 1.3 Process Types of Modifications The Customer must submit to the CAISO, in writing, a request to modify any information provided in the Request. 3 The variety, content, and scope of modification requests are as unique and complex as the Generating Facilities themselves, but for the purpose of this report, modification requests have been grouped into three buckets : 1) Commercial Operation Date ( COD ) extensions and/or requests for project Phasing; 2) Technology changes, e.g., inverter, transformer, and equipment changes; and 3) changes, e.g., generation tie route changes, Point of changes, Point of Change of Ownership Changes, and Site Location changes. Time The modification assessment commences when the CAISO and Participating TO (1) deem the modification request (including all of the necessary technical documents) valid and data complete, and (2) receive the Customer s modification assessment deposit. Per the Tariff, the CAISO targets providing a written response to the Customer within 45 days of commencement. If the modification assessment cannot be completed within that period, the CAISO notifies the Customer and provides an estimated completion date and explains why additional time is required. 3 Please note that, inter alia, requests to increase the maximum output of a project are not permitted in the modification process. Doc ID: XWK2E22ZZR Page 3 of 6

5 Modification Assessment Cost and Accounting Report 2.1 Cost The CAISO completed 94 modification assessments in Of those requests, 51 were charged the actual costs of their assessment. The remaining 43 requests were initiated before the CAISO obtained Tariff Authority to charge for the requests. The average cost for the 51 modification assessments that were charged was $2, The highest cost modification assessment was $14, The lowest cost modification assessment was $ The average cost for Commercial Operation Date ( COD ) modifications was $1, The average cost for technology changes was $2, The average cost for interconnection changes was $8, The average cost for a combined COD and technology changes was $1, The average cost of a combined COD, technology, and interconnection changes was $ $10, $8, $6, $4, $2, $0.00 Total COD COD & Technology Technology COD, Technology, & 4 The CAISO tariff requires that The Participating TO(s) shall invoice the CAISO for any assessment work within seventy-five (75) calendar days of completion of the assessment. These values include modification assessments where the ISO received no invoice from the Participating TO. Doc ID: XWK2E22ZZR Page 4 of 6

6 2.2 Timing The average time for the 94 modification assessments completed in 2014 was 88 days. However, it is important to note that these figures may be unrepresentative of the CAISO s current process because the CAISO formerly tracked when the request arrived and not when the data for the request was complete. As such, the times from the previous data set are long. The quickest modification assessment was completed in 10 days. The longest modification assessment was 335 days. The average time for COD modifications was 92 days. The average time for technology changes was 76 days. The average time for interconnection changes was 42 days. The average time for COD and technology changes was 100 days. The average time of COD, technology, and interconnection changes was 87 days COD COD & Technology COD, Technology, & 20 Technology 0 Total Doc ID: XWK2E22ZZR Page 5 of 6

7 2.3 Outcomes Of the 94 modification assessments completed in 2014, 30 were approved, 61 were conditionally approved, 1 was partially approved, 5 and 2 were denied. Total Approved Conditional Approval Denied Partially Approved Conditional approval was generally based on the following conditions: Execute the Generator Agreement within a certain period. Continue to make payments and postings for Network Upgrades. Propose different CODs from the request due to Participating TO construction times. For storage devices, respond to CAISO dispatch, a mechanism in place to ensure that the project does not deliver more to the CAISO controlled grid than studied, and separate metering and telemetry. For inverter changes, install a mechanism to ensure that the project does not deliver more to the CAISO controlled grid than studied. 5 One or more components of a multi-part request was denied. Doc ID: XWK2E22ZZR Page 6 of 6

2015 Modification Assessment Cost and Accounting Report March 1, 2017

2015 Modification Assessment Cost and Accounting Report March 1, 2017 Prepared by: Raeann Quadro California Independent System Operator Table of Contents 1. Executive Summary 1.1. Purpose and Scope 1.2.