regarding Class Year Process Improvements

Transcription

1 Proposed Tariff Revisions regarding Class Year Process Improvements Steve Corey Manager, Interconnection Projects New York Independent System Operator Management Committee (MC) October 31, New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY

2 Topics Proposed Process Changes Alternate Class Year Start Dates Revise Class Year Milestones Increase Flexibility Within the Class Year Preliminary Evaluation of Deliverability in the SRIS Streamline Cost Allocation Decisions Headroom Payment Options Security Reductions Additional Class Year Improvements, Clarifications and Tariff Clean Up Stakeholder Involvement & Schedule 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 2

3 1. Alternate Class Year Start Dates Current Process Class Year study commences on March 1 st of every year. To qualify for Class Year entry, a project must satisfy all required milestones by March 1 st even if the prior Class Year is not complete. Proposal Allow for alternative Class Year start dates such that a Class Year does not begin until the prior Class Year concludes Class Start t Date would be the first of the following dates that t post-dates the completion (i.e., final settlement and posting of security) for the prior Class: March 1, June 1, or September 1. Rules and procedures that currently apply to the March 1 Class entry date would apply to the applicable Class Year Start Date 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 3

4 1. Alternate Class Year Start Dates (continued) Effective Date Starting with the Class Year subsequent to Class Year 2012 Class Years 2011 and 2012 overlap, but subsequent to Class Year 2012, the next Class Year will not begin until the prior Class Year ends. Starting with the Class Year subsequent to Class Year 2012, the Open Class which an eligible project may elect to enter would be the Class that begins after the current Class Once the deadline to enter a Class has passed, that Class is no longer an open Class for purposes of Section of Attachment t S). This would not apply to Class Year 2011 members that reject their Project Cost Allocations for Class Year 2011; if they are eligible to enter a subsequent Class Year, projects that drop out of Class Year 2011 may enter Class Year New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 4

5 2. Revise/Clarify Class Year Milestones Current Process Class Year ATRA to begin on March 1 each year, with planned completion date six months thereafter Deliverability Study schedule linked to ATRA schedule Proposal Establish major milestones Reasonable Efforts required to complete basic required evaluations and cost estimates for SUFs and SDUs and present the Class Year Study to the Operating Committee for approval within 12 months from Class Year Start Date An additional 6 additional months for detailed studies will be permitted if a new SDU is identified (i.e., an SDU not the same as or substantially similar to an SDU previously identified and cost allocated in the Class Year process Effective Date Starting ti with the Class Year subsequent to Class Year New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 5

6 3. Increased Flexibility Within the Class Year Current Process Class Year Projects must remain in the Class for its full duration at the full level of requested CRIS (if they requested CRIS). Projects that drop out of the Class Year prior to the completion of the Class Year Study are withdrawn from the Interconnection Queue Proposal If faced with additional SDU studies, projects may (1) drop out of the Class; (2) withdraw their CRIS requests and proceed ERIS only, or (3) keep their CRIS request, but elect to have no SDU identified to make the project fully deliverable (with option of accepting just the deliverable MWs) If a project elects to drop out of the Class at this juncture, the Class from which the project drops out will still count as one of the two Classes a project may enter under Section of Attachment S. Effective Date Starting with Class Year New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 6

7 4. Preliminary evaluation of Deliverability Current Process Deliverability of requested CRIS and SDUs performed only within the Class Year Process Proposal Perform a preliminary, nonbinding evaluation of Deliverability, at Developer s option, as part of the SRIS Such evaluation would identify potential System Deliverability Upgrades at a high level and provide preliminary System Deliverability Upgrade cost estimates t which h may be based on generic information. Only Developers that elect to have a CRIS request evaluated in the Interconnection Request would be permitted to exercise this option. Developers would be responsible for the additional study costs related to such election (additional $30,000 deposit) Effective Date applicable to projects that do not have an OC- approved SRIS scope as of the effective date specified in FERC s Order accepting the tariff revisions 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 7

8 5. Streamline Cost Allocation Decisions Current Process If a Developer accepts its SUF or SDU cost allocation in one Class Year decision round, it may reject that same allocation in a subsequent round, triggering additional decision i rounds Proposal A Developer that accepts an SDU and/or SUF cost allocation cannot later reject an SDU and/or SUF cost allocation in a subsequent decision round unless either the SUF or the SDU cost allocation increases Effective Date Starting with Class year New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 8

9 6. Headroom Payment Options Current Process Headroom payments only permitted in the form of cash Proposal For Headroom obligations that a project is required to pay for SUFs that are not yet fully constructed, such Headroom obligation may be satisfied by Headroom Security in the form of a bond, irrevocable letter of credit, parent company guarantee or other form of security from an entity with an investment grade rating, executed for the benefit of and meeting the respective commercially reasonable requirements of the Headroom payee. Clarification that If Headroom is required under Attachment S, payment or a Security posting for such Headroom must be made within 5 business days after the end of the Initial Decision Period or Subsequent Decision Period, as applicable. Effective Date Starting with Class Year New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 9

10 7. Security Reductions Current Process Developers must post Security in the full amount of their Project Cost Allocation at end of Class Year process to cover the period ending on the date on which full payment is made to the Connecting Transmission Owner Proposal SUFs constructed by the Developer: security yposting required for the associated SUF could be reduced after discrete portions of the SUFs have been fully constructed, subject to review by the TO, and transfer of ownership to the TO as applicable. SUFs constructed by the TO: security posting required for the associated SUF could be reduced after discrete portions of the SUF has been fully constructed by the TO and paid for by the Developer. Effective Date upon acceptance by FERC 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 10

11 Additional Class Year Improvements, Clarifications and Tariff Clean Up Acceptable regulatory milestones to include a determination that an Article 10 application is in compliance with Article 10 Definitions of Class Year Project, Class Year Start Date, Eligible Class Project, and Open Class Year Clarification that for Attachment S, references to Developers include Interconnection Customers subject to Attachment S Clarification that withdrawal cure period does not extend the time to satisfy certain milestones with specific tariff-defined deadlines Clarification that failure to notify the NYISO by the prescribed deadline as to whether a Developer accepts or rejects its cost allocation will be deemed a rejection of its cost allocation Revisions in Attachments X and S, consistent with Attachment Z, regarding the applicability of the interconnection procedures to FERCjurisdictional Distribution Systems Miscellaneous ministerial and tariff clean-up revisions 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 11

12 Stakeholder Involvement & Schedule Straw proposals discussed with TPAS on 4/3/12, 5/7/12, 6/5/12, 8/7/12, 9/4/12 and 9/18/12 Draft tariff language provided to TPAS on 9/4/12 and 10/9/12 Draft tariff language provided to OC on 9/20/12 and 10/18/12 On 10/18/12, OC recommended d approval by the MC (with the exception of applicable effective dates not posted with OC tariff language) Next Steps October 2012 Present proposed tariff changes to MC for approval. November 2012 Present proposed tariff changes to Board for approval December 2012 File with FERC (ASAP after Board approval) February 2013 anticipated FERC Order 2012 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 12

13 The New York Independent System Operator (NYISO) is a not-for-profit corporation responsible for operating the state s bulk electricity grid, administering New York s competitive wholesale electricity markets, conducting comprehensive long-term planning for the state s electric power system, and advancing the technological infrastructure of the electric system serving the Empire State New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 13