Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
PRR #
1159
Title Interconnection procedure enhancements implementation 2018
Date Submitted 5/31/2019 9:47 AM
PRR Category C
Priority Normal
Owner Strouse, Nancy (CAISO)
Status Closed
Status End Date 8/20/2019 11:59 PM
Related BPM Generator Management
BPM Section 4.0; 6.1.4; 6.1.5; 6.2.1.5; 6.4.2; 6.5.2.1; 6.5.3; 6.5.4.1; 10.2; 10.4; 13.1; 13.1.2; 13.2; 13.4
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Existing Language
Please see attached Redlined BPM 
 
4.0 This BPM, and specifically this Section, focuses on the process for transitioning to a three party GIA among the customer, the Participating TO, and the CAISO.  This BPM does not provide explicit detail about the requirements for the New Resource Implementation process, which includes all of the steps for a Generating Unit to become a CAISO participating resource.  Information on those requirements is available at http://www.caiso.com/participate/Pages/NewResourceImplementation/Default.aspx.
 

6.1.4 et al:  New.

 

 6.1.5 New. 

 

 

6.2.1.5:  If the Interconnection Customer requests an inverter change for the project that is only a change in manufacturer, (i.e. the technology and electrical characteristics are unchanged, including the number and size of inverters), the change may be made without going through the MMA process provided the Participating TO concurs that dynamic analysis is not required.  The Interconnection Customer shall include in its notice the current and proposed inverter manufacturer, the number of inverters, their respective MW capabilities, the maximum fault currents, and the power factor regulation range.

Changes that do not qualify under this Section may be evaluated under section 6.5.1.4 of this BPM.

6.4.2:  The Interconnection Customer or Participating TO should submit all modification requests to QueueManagement@caiso.com for review.  The subject of this email should include the project name, queue position, and study process (i.e., serial, SGIP, C4, etc.).  In addition to the modification assessment deposit, all requests should include:

·         a description of the proposed changes to the Interconnection Request ;

·         applicable technical information and diagrams (except for changes to Appendix B milestones, all change requests should be accompanied by a complete revised Attachment A to the Interconnection Request, including both PSLF load flow and dynamic models.  The load flow model should be provided in GE PSLF .epc format.  The dynamic model should be provided using GE PSLF library models in .dyd format.  In case the GE PSLF library does not contain the model for the technology of the Generating Facility, a user written *.p EPCL file should be submitted.  Because of a limitation on the number of user-defined models that can be used, it is recommended that the best available WECC-approved dynamics model be used);

o   Supplemental requirements for energy storage requests are provided in http://www.caiso.com/Documents/EnergyStorageProjects-SupplementalInformation.pdf.  The CAISO requests supplemental information to ensure that the energy storage project is studied appropriately in consideration of the unique characteristics. This information is required for both energy storage additions, i.e. adding energy storage to a proposed or existing generation project, ad for energy storage capacity conversions, i.e. changing the fuel type for a portion of the generation project capacity to energy storage technology

·         proposed updates to the project milestones; and

·         a description of project status including the reason for the requested change (the description of the reason for the change is the starting point for the CAISO business assessment described in Section 6.4.6 of this BPM).

6.5.4.1: 

Changes that do not qualify under Section 6.2.1.5 of this BPM must be reviewed in the MMA process.

As part of the MMA process, the CAISO will consider inverter changes that would result in a capacity increase greater than the project net capacity listed in the Interconnection Customer’s interconnection request subject to the limits set forth below.  The CAISO will approve such inverter changes only where the Interconnection Customer either (a) installs an automatic generator tripping scheme, or (b) provides specific design information regarding a mechanism that the Generating Facility’s controller will use, to ensure that the total output of the Generating Facility never exceeds the project’s net capacity before the inverter changes. 

At no time may the Generating Facility’s inverter configuration increase the project’s net capacity by more than the greater of:

·         ten percent (10%); or

·         three (3) MW 

For example:

Generating Facility net-to-grid MW

Proposed Configuration

Resulting Increase

Outcome

10 MW

12 inverters @ 1 MW each

+2 MW

Approved, less than 3 MW

10 MW

9 inverters @ 1.5 MW each

+3.5 MW

Denied, greater than 3 MW and 10%

200 MW

100 MW @ 2.2 MW

+20 MW

Approved, not greater than 10%

 

After the new inverter configuration is approved, the Interconnection Customer will provide the CAISO with the detailed specifications on limiting the Generating Facility’s capacity to its approved net capacity.  Once the CAISO has approved the specifications to limit the Generating Facility’s capacity, the Interconnection Customer must install this approved control mechanism before the additional inverters are energized for testing. 

 

 

 

6.5.3 Generally, a change in the project’s fuel type absent a reduction in total MW capacity cannot be evaluated without a re-study, because the energy output profile of various fuel-types is different. In the deliverability study performed by the CAISO, the CAISO establishes an on-peak exceedance factor for each resource type as discussed in the table below.  As outlined in Section 6.1.3 of this BPM, where the CAISO has granted modifications after the conclusion of an Interconnection Customer’s Phase II Interconnection Study phase, the CAISO must be able to evaluate the change and find it acceptable without the need to undertake a re-study (Phase I and Phase II) in order to approve it as non-material.  The CAISO will consider a change in fuel type if the Interconnection Customer is willing to retain the maximum deliverability associated with the maximum on-peak exceedance level used in the most recent Deliverability Assessment.  The exceedance factors in the table below are provided for illustrative examples only.  Exceedance factors sometimes vary based on fuel type, project location, and renewable energy production data.  The CAISO will provide Interconnection Customers with specific details on their exceedance values upon request. Generation projects will retain Deliverability Status for energy storage capacity conversions to the extent that the proposed storage technology meets the resource adequacy requirements of the applicable Local Regulatory Authority, including any separate metering and output duration requirements.  For example, the current CPUC resource adequacy rules for storage limit resource adequacy to the amount continuously sustainable for 4-hour minimum.  However if storage could meets the resource adequacy requirements, and all delivery network upgrades and pre-cursor transmission projects are completed, the following is an example of how FCDS would be evaluated for project modifications:

 

6.5.2.1 For projects studied in the serial study process, the In-Service Date shall not exceed ten (10) years from the date the Interconnection Request is received by the CAISO.  For projects studied in the cluster study process the COD shall not exceed seven (7) years from the date the Interconnection Request is received by the CAISO.[1]

Interconnection Customers requesting COD extensions beyond those timeframes must demonstrate that the Generating Facility is commercially viable, as defined by the CAISO Tariff and discussed further below, in order to both extend the project COD beyond that date and retain the project’s deliverability status.

To demonstrate commercial viability, the Interconnection Customer must meet all of the following criteria for the project requesting an extension of COD:

a)       the Interconnection Customer must have applied for the necessary governmental permits or authorizations  appropriate at the time of the request considering the proposed construction schedule of the project, and that the permitting authority has deemed such provided documentation is data adequate for the authority to initiate its review process.  The CAISO, in consultation with the PTO, will determine what permits are appropriate for the project based on the project’s specific facts.

b)      either:

                                                                           i.      the Interconnection Customer has an executed and regulator-approved power purchase agreement (PPA), and the PPA must have the following in common with the proposed Generating Facility in the GIA

1.       the Point of Interconnection;

2.       MW capacity (allowing differences in utility defined project size before transformation and line losses);

3.       fuel type and technology; and

4.       site location.

or

                                                                         ii.      the Interconnection Customer must attest, under penalty of perjury, that the Generating Facilities will be balance-sheet financed, or otherwise receiving a binding commitment of project financing. An affidavit attesting to balance sheet financing is available at http://www.caiso.com/Documents/AffidavitTemplate_AffidavitConfirmingGeneratingFacilityBalanceSheetFinancing.doc; and

c)       the Interconnection Customer must demonstrate Site Exclusivity for 100% of the property necessary to construct the Generating Facility through the Commercial Operation Date requested in the modification request.  A Site Exclusivity Deposit does not satisfy this criterion; and

d)      the Interconnection Customer has an executed GIA; and

e)      the GIA for the Generating Facility must be in good standing such that: (1) neither the Participating TO nor the CAISO has provided a Notice of Breach; or (2) if such Notice has been issued, the breach has either been cured or the Interconnection Customer has commenced sufficient curative actions consistent with the relevant terms of the GIA.

Requests to extend the COD beyond 7 or 10 years must be accompanied by evidence that the Generating Facility meets the commercial viability criteria, including a copy of the Power Purchase Agreement(s) (“PPA(s)”) and evidence of its regulatory approval.  The CAISO will review the PPA(s) to confirm the PPA(s) align with the GIA.  Please see Section 6.5.2.3 of this BPM for more details on aligning the PPA COD with the GIA COD.  The Interconnection Customer may be asked to clarify differences between the PPA(s) and GIA, should they exist, and an MMA may be required to reconcile any date differences.

If the Interconnection Customer fails to meet all of the commercial viability criteria but informs the CAISO that it intends to proceed with the modified COD and does not qualify for the limited exemptions described in Section 6.5.2.1.1 below, the Generating Facility’s Deliverability Status will become Energy-Only Deliverability Status.

Additionally, in order for the CAISO to approve the MMA request that does not meet commercial viability criteria or qualify for the limited exemptions described below, clearly demonstrate that engineering, permitting and construction will take longer than the applicable maximum period and that circumstances that caused the delay were beyond the control of the Interconnection Customer.  In addition, the IC must demonstrate how the requested COD is achievable in light of any engineering, permitting and/or construction impediments.  The CAISO and Participating TO will not unreasonably withhold agreement to this extension, but the Interconnection Customer must provide sufficient documentation to support the request in its modification request.

Exceptions to Commercial Viability Criteria

Limited Exception for Interconnection Customers who do not have a PPA

If an Interconnection Customer satisfies all commercial viability criteria except criterion (b)(i) above, the CAISO will postpone converting the Generating Facility to Energy-Only Deliverability Status for one year from the day the Interconnection Customer submits the modification request, or eight years after the CAISO received the Interconnection Request, whichever is later.  Interconnection Customers exercising this provision must continue to meet all other commercial viability criteria during this extension period.

 

One-time Exception for Customers with Recently Published Phase II Study Results

Interconnection Customers in Queue Cluster 7 and beyond whose Phase II Interconnection Study reports identify a Network Upgrade required for the project that is beyond the 7-year threshold are exempt from the commercial viability criteria provided that they modify their project dates, including the Commercial Operation Date within six (6) months of the CAISO’s publishing the Phase II Interconnection Study report.  Such change should be enacted by the Interconnection Customer providing a MMA in accordance with Section 6 of this BPM.  This exemption is inapplicable to report addenda or revisions required by a request from an Interconnection Customer to modify its project for any reason.  In other words, if, at the time the Phase II study results are published, the earliest achievable In-Service and Commercial Operation dates for the project are beyond 7 years, the Generating Facility will not be subject to the commercial viability criteria if they request to extend the project milestones to the earliest achievable In-Service Date and Commercial Operation Date. 

If the Interconnection Customer desires In-Service and Commercial Operation Dates beyond these earliest-achievable dates, such a request will be subject to the commercial viability criteria.

No Other Exceptions

In order to retain deliverability, there are no exceptions to the commercial viability criteria other than the two listed above.  Inquiries regarding exception criteria as it relates to GIA execution and GIA suspension come up frequently.  To better understand the CAISO’s usage of the commercial viability criteria, the CAISO offers the following examples:

Example 1: GIA is not yet executed, and earliest achievable In-Service Date is beyond 7/10 years

There is no exception available to Generating Facilities Cluster 6 and earlier-queued projects where the Interconnection Customer had not yet executed a GIA at the time that the CAISO received approval to implement commercial viability criteria from the Federal Energy Regulatory Commission.  Generating Facilities in Cluster 6 and earlier-queued clusters had ample notice and time to execute GIAs before the commercial viability criteria took effect. 

However, if the earliest achievable In-Service Date is delayed because the PTO’s Network Upgrade construction is delayed, and the delay was caused by reasons other than the GIA not being executed, the PTO should submit a PTO delay notice as described in Section 6.2.1.3 of this BPM If the delay was caused by the GIA not being executed, an MMA is required and the commercial viability criteria will still apply. 

Example 2:  GIA is executed, but Interconnection Customer believed historical delays prior to GIA execution created cascading delays, “using up” the pre-7/10 year threshold time

Interconnection Customers have inquired if the Generating Facility is eligible for an exception to commercial viability criteria because, for whatever reason, it took a number of years to execute the GIA, and thus some of the pre-7/10 year threshold time was used for the project prior to GIA execution.  There is no exception for this reason because GIAs are executed with an achievable COD date.  The CAISO will only consider the events that occurred since GIA execution when reviewing post GIA-execution COD extension requests.

Example 3: project suspended the GIA for 3 years, and is now beyond the 7/10 year threshold

Suspension pursuant to section 5.16 of the LGIA does not exempt a project from meeting the commercial viability criteria; nor does it change the calculation of time from Interconnection Request submission date to COD.  Suspension only allows an Interconnection Customer “to suspend at any time all work associated with the construction and installation of the Participating TO’s Interconnection Facilities, Network Upgrades, and/ or Distribution Upgrades required under the LGIA other than Network Upgrades identified in the Phase II Interconnection Study as common to multiple Generating Facilities.”  A suspension pursuant to Section 5.16 does not automatically provide for a corresponding extension to the COD or any other timeline.  As discussed in Section 10 of this BPM, if a requested suspension will require a corresponding extension to the COD, the Interconnection Customer must submit an MMA request, and if the MMA request would extend the COD beyond the 7/10 year threshold, the request will be subject to the commercial viability criteria.

Annual Review to confirm that Commercial Viability Criteria is maintained

In order to ensure that Generating Facilities maintain the level of commercial viability upon which the COD extension approval was conditioned, the CAISO will perform an annual review of the Generating Facility’s commercial viability during the TP Deliverability allocation process.  Interconnection Customers are required to submit a notarized affidavit confirming that they continue to meet the commercial viability criteria.  A separate commercial viability affidavit is not required, the CAISO will review information provided in the TPD affidavits to confirm commercial viability levels are maintained.  If any Interconnection Customer fails to meet the commercial viability criteria, the Deliverability Status of the Generating Facility corresponding to the Interconnection Request will convert to Energy Only Deliverability Status.  The due date for such affidavits is announced via CAISO market notice.  The CAISO will provide a template for the affidavit on its website.  Failure to submit an affidavit will result in the Deliverability Status of the Generating Facility (or relevant portion corresponding to the COD extension request) converting to Energy Only Deliverability Status.

Projects with One or More Portions Online

If an Interconnection Customer has declared Commercial Operation for a portion of a Generating Facility, including one or more Phases of a Phased Generating Facility, the CAISO will not convert the portion of the Generating Facility that is in service and operating in the CAISO markets to Energy-Only.

Instead, the portion of the Generating Facility that has not been developed will be converted to Energy-Only Deliverability Status, resulting in Partial Capacity Deliverability Status for the Generating Facility.  However, where the Generating Facility has multiple Resource IDs for different portions of the Generating Facility, each such portion will have its own Deliverability Status independent from the entire Generating Facility.  The portion of the Generating Facility assigned to any individual Resource ID may have Full Capacity Deliverability Status where the portion assigned to another Resource ID may have Energy-Only Deliverability Status and the Generating Facility as a whole would have Partial Capacity Deliverability Status.

If the Generating Facility downsizes pursuant to CAISO Tariff Appendix DD Section 7.5 to the portion of the project in service and operating in the CAISO markets, and that portion of the Generating Facility has Full Capacity Deliverability Status, the whole Generating Facility will revert to Full Capacity Deliverability Status.

 

 

 

[1]          See Appendix U, Section3.5.1; Appendix Y, Section 3.5.1.4; Appendix DD, Section 3.5.1.4; as applicable.

 

 

Section 10.2:  also; section.

Section 10.4:  Last paragraph is new.

 

13.1.1:  The repowered Generating Unit must utilize the same fuel source and its existing point of interconnection to the CAISO Controlled Grid as the existing Generating Unit.  Combustible fuel sources, such as coal, oil, bio-gas, and natural gas, will be considered the same for repowering purposes for thermal plants.  Please see section 6.5.3 and 11.1.3 for specific considerations for energy storage capacity conversions.[1]

13.1.2:  Repowering the facility cannot result in exceeding the existing Generating Unit’s maximum deliverability associated with the maximum on-peak exceedance level used in the most recent Deliverability Assessment.  Interconnection Customers seeking additional Deliverability for their project may either:

1) submit a new FCDS Interconnection Request in the next cluster study open window;

2) submit an ISP interconnection request if the project can meet the ISP technical and business eligibility criteria; or

3) submit a request for FCDS via the Additional Deliverability Assessment Options.[2]

13.4 •    A $10,000 deposit

 

 

 

 

 

[1] Whether the project is a new project or a repowering of an existing project, the examples in Section 6.5.3 will apply for the addition of storage to an existing Generating Facility.

[2] CAISO Tariff Appendix DD Section 9

 

 

 

13.2 Section 25.1.2 of the CAISO tariff provides that owners of existing Generating Units can be exempted from the CAISO’s interconnection study process if the “total capability and electrical characteristics of the Generating Unit will remain substantially unchanged.” [1]  Section 25.1.2 does not indicate what changes, if any, in transmission system performance would be considered by the CAISO and the applicable Participating TO to confirm the Generating Unit owner’s representation that the existing Generating Unit’s electrical characteristics are substantially unchanged. The two most common scenarios that arise in the context of Section 25.1.2 of the CAISO tariff are:

 

1.    existing Generating Units that have not, to date, been required to enter into a three-party GIA, such as previously grandfathered qualifying facilities that must now comply with the CAISO tariff and enter into a three-party GIA; and
 

 

2.    existing power plants that propose to repower one or more Generating Units. 

Existing Generating Units that are not repowering (those falling into category (1) generally meet the “substantially unchanged” requirement and can move directly to a GIA without an assessment.  For existing resources that are not seeking repowering see Section 4 of this BPM.  This Section focuses on the informational requirements and the assessments needed to determine whether a repowering request can be handled pursuant to Section 25.1.2 or if it needs to be studied in the same manner as a new project pursuant to the CAISO’s GIDAP.

 

It is understood that any repower of a Generating Unit, unless replaced with identical equipment, will result in some changes to the total capability and electrical characteristics of the Generating Unit, and therefore some degree of change to the performance of the transmission system.  Most of these changes can be attributed to improvements in technology or the unavailability of original equipment.  The CAISO will consider changes to be “substantial” if there is a proposed change in fuel source or they are found to have an adverse impact on the transmission system, either of which would require the project to be evaluated pursuant to the CAISO’s GIDAP.

 

Adverse impacts to a transmission system include increasing the power flow during normal or contingency conditions, any increase in the short circuit duty impacts, or adverse angular or voltage stability impacts, as compared to the impacts associated with the original Generating Unit.  These types of impacts are described in more detail as follows:

 

Adverse Flow Impact – If a repower of a Generating Unit results in the same MW capacity and Net Qualifying Capacity, or a decrease in MW capacity at the Point Of Interconnection and Net Qualifying Capacity, and all CAISO tariff requirements regarding reactive power are met by the new Generating Unit, the repowering will not be considered to cause a substantial change to the total capability of the Generating Unit from a flow impact standpoint.  In this case, there would be no adverse power flow impact on the CAISO Controlled Grid under normal and contingency conditions as compared with the original Generating Unit.  Conversely, any increase in MW capacity or Net Qualifying Capacity would be considered a substantial change in total capability as this would increase the Generating Unit’s power flow impacts.

 

Short Circuit Duty Impact – Any reduction in the short circuit duty of the repowered Generating Unit as compared with the original Generating Unit will not be considered an adverse impact and will not be considered a substantial change to the unit’s electrical characteristics.  Conversely, an increase in short circuit duty impact would be considered a substantial change to the electrical characteristics of the Generating Unit.

 

Angular or Voltage Stability Impact - The angular and voltage stability impacts of a Generating Unit directly depends on the type of generator and the power system control functions that the Generating Unit encompasses.  A technical assessment may be required to determine if the system performance with the repowered generator has substantially deteriorated.

 

 

[1] Section 25.1.2 refers to existing Generating Units “whose total Generation was previously sold to a Participating TO or on-site customer.”   However, Section 25.1 of the CAISO Tariff provides that existing units connected to the CAISO Controlled Grid that will be modified without increasing the total capability of the power plant need not be studied (or re-studied) by the CAISO so long as their electrical characteristics do not change such that their re-energization may violate Applicable Reliability Criteria.  The determination of whether a repowering “may violate Applicable Reliability Criteria” essentially is the same as whether a unit’s “total capability and electrical characteristics . . . will remain substantially unchanged,” and therefore the CAISO applies the “substantially unchanged” test to repowerings that involve units converting from grandfathered interconnection arrangements as well as repowerings that have, or had, CAISO interconnection agreements.

 

 

 

 

Proposed Language
 Please see attached Redlined BPM
 

This BPM, and specifically this section, focuses on the process for transitioning to a three party GIA among the customer, the Participating TO, and the CAISO.  All such existing Generating Units must complete the New Resource Implementation process in accordance with CAISO Tariff Section 25.1.2.1.  This BPM does not provide explicit detail about the requirements for the New Resource Implementation process, which includes all of the steps for a Generating Unit to become a CAISO participating resource.  Information on those requirements is available at http://www.caiso.com/participate/Pages/NewResourceImplementation/Default.aspx.

 

 

6.1.4 Requests For Changes After Allowable Time in Queue

For projects studied in the serial study process, the In-Service Date shall not exceed ten (10) years from the date the Interconnection Request is received by the CAISO.  For projects studied in the cluster study process the COD shall not exceed seven (7) years from the date the Interconnection Request is received by the CAISO.[1]

Interconnection Customers requesting COD extensions beyond those timeframes, or requesting changes to the project when the COD is already beyond those timeframes must demonstrate that the Generating Facility is commercially viable, as defined by the CAISO Tariff and discussed further below, in order to both extend the project COD beyond that date, change the project equipment, and retain the project’s deliverability status.  Insubstantial changes including type, number, or manufacturer of inverters or insubstantial changes to the Generating Facility and energy storage additions will not be included in this requirement.

Fuel type changes are prohibited after the allowable time in queue, including when the fuel type change is submitted with a request to extend the COD.[2]  Interconnection Customers seeking to change their fuel type (e.g., natural gas, solar, wind, biomass, geothermal) after they already have or will exceed the tariff’s timeline would need to submit a new interconnection request.  Energy storage is not considered a fuel type change and is not subject to this prohibition.  De minimis fuel type changes are allowed after the time in queue has been exceeded.  This includes additions or replacements of no more than the greater of five percent or 10 MW but by no more than twenty-five percent of the capacity specified in the project’s GIA.[3]

 

Commercial Viability

To demonstrate commercial viability, the Interconnection Customer requesting an extension of COD must meet all of the following criteria for the project:

a)       the Interconnection Customer must have applied for the necessary governmental permits or authorizations appropriate at the time of the request considering the proposed construction schedule of the project, and that the permitting authority has deemed such provided documentation is data adequate for the authority to initiate its review process.  The CAISO, in consultation with the Participating TO, will determine what permits are appropriate for the project based on the project’s specific facts;

b)      the Interconnection Customer has an executed and regulator-approved power purchase agreement (PPA), and the PPA must have the following in common with the proposed Generating Facility in the GIA:

                                                   i.      the Point of Interconnection;

                                                 ii.      MW capacity (allowing differences in utility defined project size before transformation and line losses);

                                               iii.      fuel type and technology; and

                                               iv.      site location;

c)       the Interconnection Customer must demonstrate Site Exclusivity for 100% of the property necessary to construct the Generating Facility through the Commercial Operation Date requested in the modification request.  A Site Exclusivity Deposit does not satisfy this criterion;

d)      the Interconnection Customer has an executed GIA; and

e)      the GIA for the Generating Facility must be in good standing such that: (1) neither the Participating TO nor the CAISO has provided a Notice of Breach; or (2) if such Notice has been issued, the breach has either been cured or the Interconnection Customer has commenced sufficient curative actions consistent with the relevant terms of the GIA.

If the Interconnection Customer fails to meet all of the commercial viability criteria but informs the CAISO that it intends to proceed with the modification and does not qualify for the limited exemptions described in Section 6.1.4.2 below, the Generating Facility’s Deliverability Status will become Energy-Only Deliverability Status.

Exceptions to Commercial Viability Criteria

Limited Exception for Interconnection Customers who do not have a PPA

If an Interconnection Customer satisfies all commercial viability criteria except criterion (b) above, the CAISO will postpone converting the Generating Facility to Energy-Only Deliverability Status for one year from the day the Interconnection Customer submits the modification request, or eight years after the CAISO received the Interconnection Request, whichever is later.  Interconnection Customers exercising this provision must continue to meet all other commercial viability criteria during this period.

One-time Exception for Customers with Recently Published Phase II Study Results

Interconnection Customers in Queue Cluster 7 and beyond whose Phase II Interconnection Study reports identify a Network Upgrade required for the project that is beyond the 7-year threshold are exempt from the commercial viability criteria provided that they modify their project dates, including the Commercial Operation Date within six (6) months of the CAISO’s publishing the Phase II Interconnection Study report.  Such change should be enacted by the Interconnection Customer providing a MMA in accordance with Section 6 of this BPM.  This exemption is inapplicable to report addenda or revisions required by a request from an Interconnection Customer to modify its project for any reason.  In other words, if, at the time the Phase II study results are published, the earliest achievable In-Service and Commercial Operation dates for the project are beyond 7 years, the Generating Facility will not be subject to the commercial viability criteria if they request to extend the project milestones to the earliest achievable In-Service Date and Commercial Operation Date. 

If the Interconnection Customer desires In-Service and Commercial Operation Dates beyond these earliest-achievable dates, such a request will be subject to the commercial viability criteria.

Examples of Time in Queue

To better understand the CAISO’s usage of the commercial viability criteria, the CAISO offers the following examples:

Example 1: modification is requested for a project with a COD that is beyond 7/10 years

Modification requests for a project that has a COD beyond the 7/10 year threshold will be required to meet commercial viability criteria.  Interconnection customers will need to submit documentation in accordance with Section 6.1.4.1 above.

Example 2: GIA is not yet executed, and earliest achievable In-Service Date is beyond 7/10 years

There is no exception available to Generating Facilities Cluster 6 and earlier-queued projects where the Interconnection Customer had not yet executed a GIA at the time that the CAISO received approval to implement commercial viability criteria from the Federal Energy Regulatory Commission.  Generating Facilities in Cluster 6 and earlier-queued clusters had ample notice and time to execute GIAs before the commercial viability criteria took effect. 

However, if the earliest achievable In-Service Date is delayed because the PTO’s Network Upgrade construction is delayed, and the delay was caused by reasons other than the GIA not being executed, the PTO should submit a PTO delay notice as described in Section 6.2.1.3 of this BPM If the delay was caused by the GIA not being executed, an MMA is required and the commercial viability criteria will still apply. 

Example 3: GIA is executed, but Interconnection Customer believed historical delays prior to GIA execution created cascading delays, “using up” the pre-7/10 year threshold time

Interconnection Customers have inquired if the Generating Facility is eligible for an exception to commercial viability criteria because, for whatever reason, it took a number of years to execute the GIA, and thus some of the pre-7/10 year threshold time was used for the project prior to GIA execution.  There is no exception for this reason because GIAs are executed with an achievable COD date.  The CAISO will only consider the events that occurred since GIA execution when reviewing post GIA-execution COD extension requests.

Example 4: project suspended the GIA for 3 years, and is now beyond the 7/10 year threshold

Suspension pursuant to Section 5.16 of the LGIA does not exempt a project from meeting the commercial viability criteria; nor does it change the calculation of time from Interconnection Request submission date to COD.  Suspension only allows an Interconnection Customer “to suspend at any time all work associated with the construction and installation of the Participating TO’s Interconnection Facilities, Network Upgrades, and/ or Distribution Upgrades required under the LGIA other than Network Upgrades identified in the Phase II Interconnection Study as common to multiple Generating Facilities.”  A suspension pursuant to Section 5.16 does not automatically provide for a corresponding extension to the COD or any other timeline.  As discussed in Section 10 of this BPM, if a requested suspension will require a corresponding extension to the COD, the Interconnection Customer must submit an MMA request, and if the MMA request would extend the COD beyond the 7/10 year threshold, the request will be subject to the commercial viability criteria.

Example 5: Commercial viability criteria was previously met using balance sheet financing and now the interconnection customer wants to make other modifications to the project

Modifications for projects where the COD is beyond the 7/10 year threshold are subject to current commercial viability criteria as described in Section 6.1.4 of this BPM.  Current criteria requires a PPA, as balance sheet financing is no longer accepted for meeting this criteria.  If commercial viability criteria for a previous COD change had been met using balance sheet financing but a new modification is being requested, then a PPA will now be required to meet commercial viability.  If the project does not have a PPA but all of other commercial viability criteria is met, then the Interconnection Customer may be eligible for the limited exception as described in Section 6.1.4.2 of this BPM where conversion to Energy Only Deliverability Status is postponed for one year from the day the modification request was submitted, or eight years after the Interconnection Request was submitted, whichever is later.

 

Annual Review to confirm that Commercial Viability Criteria is maintained

In order to ensure that Generating Facilities maintain the level of commercial viability upon which the modification was conditioned, the CAISO will perform an annual review of the Generating Facility’s commercial viability during the TP Deliverability allocation process.  Interconnection Customers are required to submit a notarized affidavit confirming that they continue to meet the commercial viability criteria.  A separate commercial viability affidavit is not required, the CAISO will review information provided in the TPD affidavits to confirm commercial viability levels are maintained.  If any Interconnection Customer fails to meet the commercial viability criteria, the Deliverability Status of the Generating Facility corresponding to the Interconnection Request will convert to Energy Only Deliverability Status.  The due date for such affidavits is announced via CAISO market notice.  The CAISO will provide a template for the affidavit on its website.  Failure to submit an affidavit will result in the Deliverability Status of the Generating Facility (or relevant portion corresponding to the COD extension request) converting to Energy Only Deliverability Status.

Projects with One or More Phases Online

If an Interconnection Customer has declared Commercial Operation for one or more Phases of a Phased Generating Facility, the CAISO will not convert the portion of the Generating Facility that is in service and operating in the CAISO markets to Energy-Only.

Instead, the portion of the Generating Facility that has not been developed will be converted to Energy-Only Deliverability Status, resulting in Partial Capacity Deliverability Status for the Generating Facility.  However, where the Generating Facility has multiple Resource IDs for different portions of the Generating Facility, each such portion will have its own Deliverability Status independent from the entire Generating Facility.  The portion of the Generating Facility assigned to any individual Resource ID may have Full Capacity Deliverability Status where the portion assigned to another Resource ID may have Energy-Only Deliverability Status and the Generating Facility as a whole would have Partial Capacity Deliverability Status.

If the Generating Facility downsizes pursuant to CAISO Tariff Appendix DD Section 7.5 to the portion of the project in service and operating in the CAISO markets, and that portion of the Generating Facility has Full Capacity Deliverability Status, the whole Generating Facility will revert to Full Capacity Deliverability Status.

 

 

 

 

 

6.1.5 Post-COD Modification Review Process

The Interconnection Customer or the Participating TO may undertake modifications to its facilities, subject to Section 25 of the CAISO Tariff, Article 5.19 of the LGIA, and Article 3.4.5 of the SGIA if the Interconnection Customer has achieved its Commercial Operation Date.  The post-COD modification review process is similar to the Material Modification Assessment process with the exception that any modification request submitted after the project achieves COD will be evaluated based on changes to the total MW capacity of the generating facility and changes to its electrical characteristics. 

 

[1]          See Appendix U, Section3.5.1; Appendix Y, Section 3.5.1.4; Appendix DD, Section 3.5.1.4; as applicable.

[2]              [[Citation to tariff.]]

[3]      Energy storage additions and de minimis fuel type changes may require installation of equipment to ensure that their output at the point of interconnection does not exceed the interconnection service capacity amount the Interconnection Customer requested and which was studied.

 

 

 

6.2.1.5:  If the Interconnection Customer requests an inverter change for the project that is only a change in manufacturer (i.e. the technology and electrical characteristics are unchanged, including the number and size of inverters), the change may be made without going through the MMA process provided the Participating TO concurs that dynamic analysis is not required.  The Interconnection Customer shall include in its notice the current and proposed inverter manufacturer, the number of inverters, their respective MW capabilities, the maximum fault currents, and the power factor regulation range.  The Interconnection Customer shall complete and provide the CAISO with the Inverter Data Information Sheet, containing the new inverters’ information and characteristics.

Changes that do not qualify under this Section may be evaluated under section 6.5.1.4 of this BPM.

6.4.2:  The Interconnection Customer or Participating TO should submit all modification requests to QueueManagement@caiso.com for review.  The subject of this email should include the project name, queue position, and study process (i.e., serial, SGIP, C4, etc.).  In addition to the modification assessment deposit, all requests should include:

             a description of the proposed changes to the Interconnection Request;

             applicable technical information and diagrams (except for changes to Appendix B milestones, all change requests should be accompanied by a complete revised Attachment A to the Interconnection Request, including both PSLF load flow and dynamic models.  The load flow model should be provided in GE PSLF .epc format.  The dynamic model should be provided using GE PSLF library models in .dyd format.  In case the GE PSLF library does not contain the model for the technology of the Generating Facility, a user written *.p EPCL file should be submitted.  Because of a limitation on the number of user-defined models that can be used, it is recommended that the best available WECC-approved dynamics model be used);

o             For inverter changes, the Interconnection Customer shall complete and submit the Inverter Data Information Sheet and upload it via the Documents section in Resource Interconnection Management System (“RIMS”)

             proposed updates to the project milestones; and

             a description of project status including the reason for the requested change (the description of the reason for the change is the starting point for the CAISO business assessment described in Section 6.4.6 of this BPM).; and

             changes after the allowable time in queue must be accompanied by evidence that the Generating Facility meets the commercial viability criteria described in Section 6.1.4 of this BPM, including the following:

o             Proof that necessary governmental permits or authorizations have been applied for

o             A copy of the Power Purchase Agreement(s) (PPA) and evidence of its regulatory approval.  The CAISO will review the PPA(s) to confirm the PPA(s) align with the Point of Interconnection, MW capacity, fuel type and technology, and site location listed in the GIA.  Please see Section 6.5.2.3 of this BPM for more details on aligning the PPA COD with the COD in the Generator Interconnection Agreement (GIA).  The Interconnection Customer may be asked to clarify differences between the PPA(s) and GIA, should they exist, and an MMA may be required to reconcile any date differences.

o             Proof of site exclusivity for 100% of the property necessary to construct

6.5.4.1:  Changes that do not qualify under Section 6.2.1.5 of this BPM must be reviewed in the MMA process.

As part of the MMA process, the CAISO will consider inverter changes that would result in a capacity increase greater than the project net capacity listed in the Interconnection Customer’s interconnection request subject to the limits set forth below.  The CAISO will approve such inverter changes only where the Interconnection Customer either (a) installs an automatic generator tripping scheme, or (b) provides specific design information regarding a mechanism that the Generating Facility’s controller will use, to ensure that the total output of the Generating Facility never exceeds the project’s net capacity before the inverter changes. 

At no time may the Generating Facility’s inverter configuration increase the project’s net capacity by more than the greater of:

             ten percent (10%); or

             three (3) MW 

For example:

Generating Facility net-to-grid MW          Proposed Configuration Resulting Increase           Outcome

10 MW 12 inverters @ 1 MW each           +2 MW Approved, less than 3 MW

10 MW 9 inverters @ 1.5 MW each         +3.5 MW              Denied, greater than 3 MW and 10%

200 MW               100 MW @ 2.2 MW        +20 MW               Approved, not greater than 10%

 

After the new inverter configuration is approved, the Interconnection Customer will provide the CAISO with the detailed specifications on limiting the Generating Facility’s capacity to its approved net capacity.  Once the CAISO has approved the specifications to limit the Generating Facility’s capacity, the Interconnection Customer must install this approved control mechanism before the additional inverters are energized for testing. 

In addition, the CAISO will review the inverters’ voltage and frequency ride-through capabilities in order to accomplish the following reliability objectives:

1)      Eliminating unnecessary momentary cessation for inverters during the clearing of a transmission line fault;

2)      Eliminating inverter tripping for momentary losses of synchronism; and

3)      Requiring coordination of the central plant controller with the individual inverter control systems to facilitate reconnection of the inverters following a fault on the transmission system.

The CAISO and the Participating TO will review the Interconnection Customer’s submitted Inverter Data Information Sheet, a complete revised Attachment A to the Interconnection Request, dynamic model, PSLF load flow model, and the revised single-line and three-line diagrams to ensure that inverters meet the following ride-through criteria:

1)            The project remains online for the voltage disturbance caused by any fault on the transmission grid having a duration of less than the normal three-phase fault clearing time (4-9 cycles) or one-hundred fifty (150) milliseconds;

2)            The project remains online for any voltage disturbance caused by a single-phase fault on the transmission grid with delayed clearing; and

3)            The project eliminates momentary cessation during transient low-voltage conditions on the transmission grid.

 

 

6.5.3 Generally, a change in the project’s fuel type absent a reduction in total MW capacity cannot be evaluated without a re-study, because the energy output profile of various fuel-types is different. In the deliverability study performed by the CAISO, the CAISO establishes an on-peak exceedance factor for each resource type as discussed in the table below.  As outlined in Section 6.1.3 of this BPM, where the CAISO has granted modifications after the conclusion of an Interconnection Customer’s Phase II Interconnection Study phase, the CAISO must be able to evaluate the change and find it acceptable without the need to undertake a re-study (Phase I and Phase II) in order to approve it as non-material.  As detailed in Section 6.1.4 of this BPM, fuel type changes are prohibited after a project has exceeded the allowable time in queue with the exceptions for de minimis changes and energy storage additions.  The CAISO will consider a change in fuel type before the time in queue has been exceeded if the Interconnection Customer is willing to retain the maximum deliverability associated with the maximum on-peak exceedance level used in the most recent Deliverability Assessment. 

 

The exceedance factors in the table below are provided for illustrative examples only.  Exceedance factors sometimes vary based on fuel type, project location, and renewable energy production data.  The CAISO will provide Interconnection Customers with specific details on their exceedance values upon request. Generation projects will retain Deliverability Status for energy storage capacity conversions to the extent that the proposed storage technology meets the resource adequacy requirements of the applicable Local Regulatory Authority, including any separate metering and output duration requirements.  For example, the current CPUC resource adequacy rules for storage limit resource adequacy to the amount continuously sustainable for 4-hour minimum.  However if storage could meets the resource adequacy requirements, and all delivery network upgrades and pre-cursor transmission projects are completed, the following is an example of how FCDS would be evaluated for project modifications:

 

As noted above in Section 6.1.4, projects studied in the serial study process, the In-Service Date shall not exceed ten (10) years from the date the Interconnection Request is received by the CAISO and projects studied in the cluster study process the COD shall not exceed seven (7) years from the date the Interconnection Request is received by the CAISO.

 Interconnection Customers requesting to remain in the queue beyond those timeframes must clearly demonstrate that engineering, permitting and construction will take longer than the applicable maximum period and that circumstances that caused the delay were beyond the control of the Interconnection Customer.  In addition, the Interconnection Customer must demonstrate how the requested COD is achievable in light of any engineering, permitting and/or construction impediments.  The CAISO and Participating TO will not unreasonably withhold agreement to this extension, but the Interconnection Customer must provide sufficient documentation to support the request in its modification request.

Additionally, Interconnection Customers requesting COD extensions beyond the allowable time in queue must demonstrate that the Generating Facility meets the Commercial Viability Criteria as described in Section 6.1.4 of this BPM.

If the Interconnection Customer fails to meet all of the commercial viability criteria but informs the CAISO that it intends to proceed with the modification and does not qualify for the limited exemptions described in Section 6.1.4 of this BPM, the Generating Facility’s Deliverability Status will become Energy-Only Deliverability Status. 

In order to ensure that Generating Facilities maintain the level of commercial viability upon which the modification was conditioned, the CAISO will perform an annual review of the Generating Facility’s commercial viability during the TP Deliverability allocation process.  This is described in further detail in Section 6.1.4 of this BPM.

 

 

Section 10:2:  removed “also”, capitalized “Section”.

Section 10.4:  Ninety days before an approved suspension’s anticipated end, the CAISO and the Participating TO transmission owner will tender an amended LGIA with new construction milestones. The parties will negotiate in good faith and will execute the amended LGIA prior to the suspension’s end.   

 

 

13.1.1:  The repowered Generating Unit must utilize the same fuel source and its existing point of interconnection to the CAISO Controlled Grid as the existing Generating Unit.  Combustible fuel sources, such as coal, oil, bio-gas, and natural gas, will be considered the same for repowering purposes for thermal plants.  Please see Sections 6.5.3 and 11.1. 3 for specific considerations for energy storage capacity conversions.[1]

13.1.2:  Repowering the facility cannot result in exceeding the existing Generating Unit’s deliverability associated with the on-peak exceedance level used in the most recent Deliverability Assessment.  Interconnection Customers seeking additional Deliverability for their project may either:

1) submit a new FCDS Interconnection Request in the next cluster study open window; or

2) submit an ISP interconnection request if the project can meet the ISP technical and business eligibility criteria.

13.4 •    A $50,000 deposit

 

 

 

13.2 Section 25.1.2 of the CAISO tariff provides that owners of existing Generating Units can be exempted from the CAISO’s interconnection study process if the “total capability and electrical characteristics of the Generating Unit will remain substantially unchanged.”[1]  Section 25.1.2 does not indicate what changes, if any, in transmission system performance would be considered by the CAISO and the applicable Participating TO to confirm the Generating Unit owner’s representation that the existing Generating Unit’s electrical characteristics are substantially unchanged. The two most common scenarios that arise in the context of Section 25.1.2 of the CAISO tariff are:

1.       existing Generating Units that have not, to date, been required to enter into a three-party GIA, such as previously grandfathered qualifying facilities that must now comply with the CAISO tariff and enter into a three-party GIA; and
 

2.       existing power plants that propose to repower one or more Generating Units. 
 

Existing Generating Units that are not repowering (those falling into category (1) generally meet the “substantially unchanged” requirement and can move directly to a GIA without an assessment.  For existing resources that are not seeking repowering see Section 4 of this BPM.  This Section focuses on the informational requirements and the assessments needed to determine whether a repowering request can be handled pursuant to Section 25.1.2 or if it needs to be studied in the same manner as a new project pursuant to the CAISO’s GIDAP.

It is understood that any repower of a Generating Unit, unless replaced with identical equipment, will result in some changes to the total capability and electrical characteristics of the Generating Unit, and therefore some degree of change to the performance of the transmission system.  Most of these changes can be attributed to improvements in technology or the unavailability of original equipment.  The CAISO will consider changes to be “substantial” if there is a proposed change in fuel source or they are found to have an adverse impact on the transmission system, either of which would require the project to be evaluated pursuant to the CAISO’s GIDAP.

Adverse impacts to a transmission system include increasing the power flow during normal or contingency conditions, any increase in the short circuit duty impacts, or adverse angular or voltage stability impacts, as compared to the impacts associated with the original Generating Unit.  These types of impacts are described in more detail as follows:

Adverse Flow Impact – If a repower of a Generating Unit results in the same MW capacity and Net Qualifying Capacity, or a decrease in MW capacity at the Point Of Interconnection and Net Qualifying Capacity, and all CAISO tariff requirements regarding reactive power are met by the new Generating Unit, the repowering will not be considered to cause a substantial change to the total capability of the Generating Unit from a flow impact standpoint.  In this case, there would be no adverse power flow impact on the CAISO Controlled Grid under normal and contingency conditions as compared with the original Generating Unit.  Conversely, any increase in MW capacity or Net Qualifying Capacity would be considered a substantial change in total capability as this would increase the Generating Unit’s power flow impacts.

Short Circuit Duty Impact – Any reduction in the short circuit duty of the repowered Generating Unit as compared with the original Generating Unit will not be considered an adverse impact and will not be considered a substantial change to the unit’s electrical characteristics.  Conversely, an increase in short circuit duty impact would be considered a substantial change to the electrical characteristics of the Generating Unit unless both of the following criteria are met:

·         Increase of the short circuit duty at network breakers that require upgrades in the generation interconnection study is less than the amount that would be flagged by the Participating TO as meaningful contribution; and

·         The total short circuit duty from the repowered Generating Unit and all the active generation projects in the queue at network breakers that do not require upgrades in the generation interconnection study does not exceed the breaker capacity.

Angular or Voltage Stability Impact - The angular and voltage stability impacts of a Generating Unit directly depends on the type of generator and the power system control functions that the Generating Unit encompasses.  A technical assessment may be required to determine if the system performance with the repowered generator has substantially deteriorated.

 

[1] Section 25.1.2 refers to existing Generating Units “whose total Generation was previously sold to a Participating TO or on-site customer.”   However, Section 25.1 of the CAISO Tariff provides that existing units connected to the CAISO Controlled Grid that will be modified without increasing the total capability of the power plant need not be studied (or re-studied) by the CAISO so long as their electrical characteristics do not change such that their re-energization may violate Applicable Reliability Criteria.  The determination of whether a repowering “may violate Applicable Reliability Criteria” essentially is the same as whether a unit’s “total capability and electrical characteristics . . . will remain substantially unchanged,” and therefore the CAISO applies the “substantially unchanged” test to repowering’s that involve units converting from grandfathered interconnection arrangements as well as repowering’s that have, or had, CAISO interconnection agreements.

 

[1] Whether the project is a new project or a repowering of an existing project, the examples in Section 6.5.3 will apply for the addition of storage to an existing Generating Facility.

 

 

 

Reason For Revision
 
Interconnection Process Enhancements (IPE) Implementation 2018
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Strouse, Nancy (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

The ISO accepts the recommendation as modified.
Identification of the authorship of comments

Joint comments from: Large Scale Solar Association, EDF Renewables, SPower

San Diego Gas and Electric Company
Action

Approve the BPM PRR as modified.

N/A
Statement of apparent requirements of the BPM PRR

N/A
Priority and rank for any BPM PRR requiring a CAISO system change

N/A
Proposed effective date(s) of the BPM PRR

Upon completion of the PRR process
Other recommended actions

N/A
Click here to view the Final Decision for this PRR
Final Decision

The ISO adopts the recommendation as modified.
Stakeholder Comment

None.

Effective Date

8/5/2019
Action

Adopt the recommendation as modified

The ISO adopts the recommendation as modified. 
Announcements
The ISO has posted a response to recommendation comments.
Posted On - 7/26/2019 4:17 PM
The ISO has attached a revised version of the BPM for Generator Management to provide responses to comments and ISO recommendation.
Posted On - 6/28/2019 1:19 PM
Impact Analysis
Impact Analysis not available.
Initial Comments
Joint comments from LSA, EDF-Renewables, and SPower
6/19/2019 4:45 PM
Logged By - Susan R. Schneider (Phoenix Consulting)
San Diego Gas & Electric Company has no objections to PRR# 1159 at this time.
6/18/2019 9:16 AM
Logged By - SDG&E Generation Interconnections (San Diego Gas & Electric Company)
Recommendation Comments
ISO response to recommendation comments.
7/26/2019 4:12 PM
Logged By - Strouse, Nancy (CAISO)
Joint comments from EDF-Renewables, Large-scale Solar Association, and SPower
7/16/2019 10:25 AM
Logged By - Susan R. Schneider (Phoenix Consulting)
Click here to view the Appeals for this PRR
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# of Appeals In Progress - 0
# of Appeals Closed - 0
# of Appeals Abandoned - 0
There are no Appeals on this PRR.
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