Submitted to the CAISO through the CAISO BPM Change Management application

Transcription

1 March 18, 2014 Submitted to the CAISO through the CAISO BPM Change Management application RE: Appeal of the Large-scale Solar Association to CAISO BPM Change Management Executive Committee on limited issues in the final BPM for Queue Management (PRR 700) The Large-scale Solar Association (LSA) hereby submits this Appeal of the final new BPM for Queue Management (BPM). LSA supports the CAISO s centralization of Queue Management provisions in a separate BPM, including those related to Material Modification Assessments (MMAs) that resulted from the stakeholder process for Interconnection Process Enhancements (IPE) Topic 15. LSA has been an active participant in the stakeholder process for PRR 700 and very much appreciates the CAISO s incorporation of most of the changes recommended by LSA in its various comment submissions. However, there are two remaining issues where LSA fears that the language in the BPM will be detrimental to the generator-interconnection process. Those issues, which are the subject of this Appeal, are as follows: Timing for processing MMA requests: The BPM would prohibit processing of MMA and other modification requests for nearly half of every year (5.5 consecutive months), potentially delaying consideration of project equipment or configuration changes needed to meet critical Power Purchase Agreement (PPA) or Generator Interconnection Agreement (GIA) development deadlines. Moreover, the applicability of those restrictions is not clear, and the restrictions themselves are not clearly defined in any posted document. PTO submission of modification requests to CAISO: The BPM states that the CAISO believes that Participating Transmission Owners (PTOs) should submit requests to the CAISO for approval of schedule changes due to construction delays for Network Upgrades (NUs) or PTO s Interconnection Facilities (IFs). However, the safeguards contained in the information requirements for such submission would be meaningless if the PTO can simply choose not to follow this process. LSA asks the CAISO to revise the BPM in the manner described below. (1) Remove the timing prohibition on submission and processing MMA and other modification requests during and just before interconnection studies, especially during the GIDAP Reassessment process. (2) Require PTO submission of requests to the CAISO for approval of schedule changes due to NU or IF construction delays, and notice to ICs of such changes. These issues, and the grounds for the Appeal in each area, are explained further below. 1

2 TIMING FOR PROCESSING MMA REQUESTS Background Section 3 of the BPM states as follows: The CAISO will not process modification requests from projects while the project is being studied during the Phase I Interconnection Study process or Phase II Interconnection Study process for that project, or other studies applicable to that project. The reason for this is that once a study commences, the study assumptions cannot be changed. Otherwise, the study would need to be re-started with the updated information based on the modification requests. In addition, it would not be possible for the CAISO to evaluate the potential impacts of the proposed modification on other projects during the pendency of one of these studies. Information about study timeframes is available on the CAISO website under Planning> Generator Interconnection > GIDAP Customer guidelines ( Modification requests should be submitted no later than 45 calendar days prior to the start of a study that applies to the affected generation project to avoid processing delays due to the study process. As stated elsewhere in this BPM, if an assessment cannot be completed within the 45 day timeline, the CAISO will notify the Interconnection Customer and provide an estimated completion date with an explanation of the reasons why additional time is required. Modification requests received during applicable studies will be logged and reviewed for completeness and, when the study process is complete, the modification requests will be evaluated Grounds for Appeal LSA appeals these provisions on several grounds. Modifications that are not material would not impact ongoing studies. According to CAISO figures provided in the IPE process, the vast majority of MMA requests from Interconnection Customers (ICs) are found not to be material, i.e., they do not adversely impact other projects in the queue or PTOs. If the changes are not material, they would not require study changes or re-starts, so this rationale does not seem rational. The BPM and referenced document are unclear and confusing. It was clear from the discussions in the stakeholder process that the other studies applicable to that project is intended to include the annual GIDAP Reassessment, which technically applies to all cluster-study projects even those that were processed under the prior GIP rules and not the GIDAP. However, despite several LSA questions and comments on this point, the final BPM does not include any mention of the Reassessment. Moreover, the referenced document (Document) for which the link is provided is entitled Cluster 5. While the Document does contain dates for the annual GIDAP Reassessment, an IC with a project in another cluster would have to know that: (1) the information in this document applies to its project even though it only references Cluster 5; and (2) the annual GIDAP Reassessment applies to its project at all (see above). Also, CAISO study schedules can vary from year to year. Thus, LSA s recommendation during the stakeholder process that the CAISO issue a Market Notice and/or make a more obvious posting of the MMA processing timelines is needed so that the market is aware of the applicable dates each study cycle. 2

3 The modification-processing timing restrictions are simply unworkable. That is the most serious problem with this section of the BPM. First, the Reassessment process timeframe in the Document is approximately 4 months. Adding 45 days lead time (1.5 months), per the BPM, would mean that no cluster-project modification requests would be processed for 5.5 consecutive months each year (with much tighter timing for projects still going through the interconnection-study process (where Phase I and Phase II Study times would also be off-limits)). Prohibiting modification-request processing for nearly half of every year could significantly hamper the interconnection process. For example, critical project equipment or configuration changes could wait many months for CAISO approval, potentially delaying project development and construction schedules (which, of course, would require additional modification requests) and impairing IC ability to meet critical PPA deadlines. Second, it is not clear whether these timing limitations apply to PTO requests for schedule or plan-of-service changes (see below), since the BPM language appears to apply to all modification requests. As opposed to project equipment or configuration changes (which would only be allowed if found to be immaterial), such PTO requests would almost surely impact study results, and thus should be accounted for in ongoing studies, to the extent possible. Certainly, once the PTO identifies potential GIA milestone delays, the PTO and IC should not have to wait many months for the CAISO to process the request. Such delays could postpone conforming GIA amendments and delay permitting and construction activities during the wait. Prompt processing of MMA requests is particularly critical given the potential expiration of vital tax credits at the end of Aside from the PPA consequences of failure to meet GIA deadlines, loss of those tax credits and other financial incentives could well render some projects uneconomic and thus cause them to fail. The off-takers for those projects would then lose the RPS credits and other benefits that they are counting on receiving from the projects. Requested change The CAISO should revise the BPM to remove the prohibition against MMA request processing during most interconnection studies, especially annual GIDAP Reassessments. Reasonable exceptions (circumstances when MMA requests would not be processed) should be limited, if at all, to: MMA requests within 45 days of, and during, Phase I Studies. Projects at this stage are still in an early form, and there are opportunities to make many of the same changes that would otherwise be processed in an MMA request through resubmission of Interconnection Request Appendix B, after the Phase I Study Results Meeting. MMA requests that are more likely to impact the outcome of Interconnection Studies. MMA requests for other changes should be allowed at any time. 3

4 The CAISO has had considerable experience by now with the MMA request process and could define a limited number of MMA request types that have sometimes been found to be material in the past (for example, maybe COD extensions for more than 6 months). This list could be defined in a BPM and modified over time to reflect additional experience in the future. If the CAISO does not accept the recommendations above and retains the MMA request restrictions in the final BPM, it should at least: (1) clarify in the BPM that the annual GIDAP Reassessment is one of the applicable studies; and (2) publish (with a Market Notice) a separate annual study schedule before the start of each year, updated whenever changes become apparent. PTO SUBMISSION OF MODIFICATION REQUESTS The BPM addresses PTO submission of modifications to the CAISO in two places (emphases added): 3. Overview of Modification Provisions The CAISO believes the Participating TO should submit a modification request to the CAISO if the Participating TO proposes changes to the scope of, or schedule for, planned Network Upgrades or PTO's Interconnection Facilities. The Participating TO should include in the request a description of the proposed changes, the Interconnection Customers that they believes will be impacted, the impacts on those Interconnection Customers, a description of potential alternatives considered, if applicable, and the reason for selecting the proposed modification Milestone Extension When Network Upgrades Are Delayed (sub-section of Section Modifications That Are Approved Without Material Modification Assessment) In the event that the Participating TO determines that construction of a Network Upgrade, required pre-cursor Network Upgrade, or Participating TO s Interconnection Facilities are delayed and that any project milestones must be modified due to that schedule change, the Participating TO shall provide notice to the CAISO and the Interconnection Customer(s) it believes are impacted by the delay that includes the previous In-Service Date and the new In- Service Date, as well as any other required modifications. The Participating TO notice to the CAISO should include a description of the proposed changes, the Interconnection Customer(s) that they believe will be impacted, the impacts on those Interconnection Customer(s), a description of potential alternatives considered, if applicable, and the reason for selecting the proposed modification. The Participating TO notice to the Interconnection Customer should include a description of the proposed changes, a description of potential alternatives considered, if applicable, and the reason for selecting the proposed modification. Grounds for Appeal LSA supports PTO submission of changes due to NU or IF construction delays to the CAISO and affected ICs, and CAISO examination of the justification for the changes and alternatives considered. These provisions will implement a clear process for changes that today are often dictated by PTOs without adequate notice or explanation to ICs. The language regarding content of the change notices was suggested by LSA, and we appreciate the CAISO s incorporation of those suggestions. 4

5 However, LSA appeals the BPM language because it is contradictory. Section 3 states that the CAISO believes that PTOs should submit these changes, while Section says that PTOs shall submit them. Requested change The BPM should require PTO submission for CAISO approval, and notice to affected ICs, of schedule changes due to NU or IF construction delays. The CAISO oversight process will not be effective if PTOs can simply skip it. Specifically, BPM Section 3 should be revised as follows, to be consistent with BPM Section : 3. Overview of Modification Provisions The CAISO believes tthe Participating TO should must submit a modification request to the CAISO if the Participating TO proposes changes to the scope of, or schedule for, planned Network Upgrades or PTO's Interconnection Facilities. The Participating TO should include in the request a description of the proposed changes, the Interconnection Customers that they believes will be impacted, the impacts on those Interconnection Customers, a description of potential alternatives considered, if applicable, and the reason for selecting the proposed modification. 5