Transmission for Renewable Energy: Efficient Solutions to Integration Issues Law of Renewable Energy WEBINAR SERIES ● PRODUCED BY EUCI June 23, 2011 Law of Renewable Energy WEBINAR SERIES 1
To order any of these books please contact Angel Giovannone at (503) 294-9422 or amgiovannone@stoel.com Law of Renewable Energy WEBINAR SERIES 2
Jason A. Johns Associate Portland, OR (503) 294-9618 jajohns@stoel.com Law of Renewable Energy WEBINAR SERIES 3
Marcus Wood Partner Portland, OR (503) 294-9434 mwood@stoel.com Law of Renewable Energy WEBINAR SERIES 4
Jennifer H. Martin Partner Portland, OR (503) 294-9852 jhmartin@stoel.com Law of Renewable Energy WEBINAR SERIES 5
Timothy L. McMahan Partner Portland, OR (503) 294-9517 tlmcmahan@stoel.com Law of Renewable Energy WEBINAR SERIES 6
Agenda • Interconnection • Reliability • Transmission Service • Market Changes • Permitting Law of Renewable Energy WEBINAR SERIES 7
Interconnection • Which interconnection procedures apply? – First, you need to determine if your interconnection is subject to state or federal jurisdiction – If Federal, the procedures that apply may depend on the facility’s size • Small Generator = ≤ 20 MW • Large Generator = > 20 MW Law of Renewable Energy WEBINAR SERIES 8
Interconnection Services • What types of interconnection service are available? – Energy Resource service = Allows generator to connect to the transmission system and be eligible to deliver electric output using existing firm or non-firm transmission on an “as available” basis – Network service = Allows generator to connect to the transmission system: • In a manner comparable to that which the TP integrates its own generating facilities to serve native load customers; or • In an RTO or ISO with market-based congestion management, in the same manner as all other Network Resources • Which service should I choose? Law of Renewable Energy WEBINAR SERIES 9
Negotiating the Interconnection Agreement • Under FERC’s LGIA, the terms are standard and changes must be approved by FERC • Negotiations focus on: – Milestones (schedule and payments) – Cost allocation (contingent facilities) – Operational Characteristics • Facilitating use of one interconnection capacity by more than one project or owner – Phasing – Joint Ownership Agreements – Partial Termination Law of Renewable Energy WEBINAR SERIES 10
Queue Congestion • Small financial commitment to enter queue ($10k) • Three serial studies – Feasibility Study – System Impact Study – Facilities Study • Little disincentive to withdraw; restudies were common • So was suspension • Little tied an interconnection customer to its LGIA, resulting in some walking away Law of Renewable Energy WEBINAR SERIES 11
Interconnection Queue Reform • December 2007 Technical Conference – Serial study practices being slowed by new entry into queues & speed at which projects could develop – Interconnection delays causing trouble in meeting RPS obligations • March 2008 – Order issued as a result of technical conference – RTOs/ISOs ordered to report status of respective queues – Identified three needed changes: • Increased requirements for entering the queue • Eliminate the Feasibility Study • First-ready, first-served vs. first-come, first-served Law of Renewable Energy WEBINAR SERIES 12
Queue Backlogs • California ISO – 361 pending interconnection requests (105,000 MW) – 68,000 MW of renewable energy – CAISO’s historic peak demand: 50,270 MW • Southwest Power Pool – 255 pending interconnection requests (57,000 MW) – 50,000 MW related to wind generation (176/196 requests over two years) • Midwest ISO – 348 pending interconnection requests (80,000 MW) – 65,000 MW related to wind generation – Could not clear queue until 2050 Law of Renewable Energy WEBINAR SERIES 13
The Results • California ISO – Clustering with queue windows (two per year) – 2 studies (Phase I and Phase II) – Increased, non-refundable financial requirements • Southwest Power Pool – 3 queues, your choice (IFS, PISIS, DISIS) – Suspension only allowed for 18 months after Effective Date – Shared Network Upgrades will be built upon execution • Midwest ISO – Milestones provide “first-ready, first-to-proceed” – No suspension for economic reasons (force majeure only) – Once a GIA is signed, Network Upgrades will be built – ABSOLUTELY NO AMENDMENT TO ISD Law of Renewable Energy WEBINAR SERIES 14
Risk Analysis What are the risks in filing unexecuted? Law of Renewable Energy WEBINAR SERIES 15
Interconnection Capacity Rights Aero Energy , 116 FERC ¶ 61,149 • Developer sought interconnection and transmission service on jointly-owned transmission line • Transmission line joint owners intended to develop generation that would use respective capacity rights • Sagebrush claimed all but 3 MW of transmission capacity was reserved • FERC stated Sagebrush partners have capacity rights, if: – Demonstrate pre-existing contractual obligations; or – Specific expansion plans, including definitive dates, and milestones met Law of Renewable Energy WEBINAR SERIES 16
Milford Wind Corridor 129 FERC ¶ 61,149 • Milford’s Request: – 88-mile, 345 kV interconnection line with 1,000 MW capacity – Built to serve multi-phase wind development – Closed financing for entire line; PPA for 200 MW – Accelerated 100 MW of Phase II – All phases to be operational by 2015 • FERC approved request based on specific expansion plans, and material progress toward meeting milestones Law of Renewable Energy WEBINAR SERIES 17
Terra-Gen Dixie Valley 132 FERC ¶ 61,215 • Owner of the Dixie Valley Line • 60 MW existing geothermal facility • Sought priority rights to 360 MW • FERC Ruling – Awarded priority to 60 MW capacity – Remaining 300 MW subject to open access Law of Renewable Energy WEBINAR SERIES 18
Boundary Tested Puget Sound Energy , 133 FERC ¶ 61,160 • Developing multi-phased 1,250 MW wind project • 1,250 MW interconnection built with 350 MW Phase I • Environmental studies; EIS; conditional use permit • Interconnection agreement signed for 1,250 MW • Phases IV and V targeted for 2029 • FERC Ruling – Puget may reserve to serve native load – Line must be placed under OATT Law of Renewable Energy WEBINAR SERIES 19
Reliability Standards • Are reliability standards mandatory? – YES 10 – Generators are obligated to register • Who is subject to registration? • Single 20 MVA unit • Multiple units at 75 MVA • Regardless, are you material to reliability? • Who oversees compliance? NERC, RROs Law of Renewable Energy WEBINAR SERIES 20
WECC vs. Gen Ties Cedar Creek Wind Milford Wind Corridor • 76-miles, 230 kV tie • 88-mile, 345 kV tie • Ownership change 4 miles • Full ownership from POI • Interconnecting at sub with • TO operated 2 GW connected relaying/protection systems • 2 x 168 MVA GSUs on site at POI at generator • 10 x 34.5 kV, 3 x 230 kV • Registered as TO/TOP breakers at generator • Registered as TO/TOP Law of Renewable Energy WEBINAR SERIES 21
FERC Decision Cedar Creek Wind Milford Wind Corridor • Material to reliability • Material to reliability • CC owns/controls • Owns/operates equipment equipment on one end of at generator the tie line • Must be coordinated with • Must be coordinated with equipment at remote end equipment at remote end • Fault could lead to loss of • Fault could lead to loss of 1800 MW 600 MW CCGT Law of Renewable Energy WEBINAR SERIES 22
Nobody wants responsibility for a blackout Law of Renewable Energy WEBINAR SERIES 23
Transmission Service • My facility is already interconnected, why do I need transmission service? – Interconnection service provides no delivery rights – Unless your purchaser is taking power at the busbar, you will need to purchase transmission service • Where do I reserve and buy transmission service? OASIS • What types of service are available? – Point-to-point vs. Network – Short-term vs. Long-term – Firm vs. Non-firm – Conditional firm Law of Renewable Energy WEBINAR SERIES 24
Transmission Service • Are transmission providers required to treat everyone by the same rules? – Yes, FERC Order 888 requires that transmission service be provided on an open, non-discriminatory basis – Transmission providers particularly may not favor affiliates • What are the types of transmission providers? – RTOs/ITCs are independent because they do not actually own or control electric generation resources – Many transmission owners, however, remain as integrated transmission and generation utilities – Some types of transmission providers ( e.g. , BPA, TVA, WAPA) are subject to limited FERC authority Law of Renewable Energy WEBINAR SERIES 25
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