On February 2, 2018, FERC directed Commission Staff to convene a technical conference to explore issues concerning interconnection issues that affect neighboring utilities or regions. In particular, the technical conference is to address issues raised in a complaint by EDF Renewable Energy, Inc. ("EDF") against the Midcontinent Independent System Operator, Inc. ("MISO"), Southwest Power Pool, Inc. ("SPP"), and PJM Interconnection, L.L.C. ("PJM) related to the Affected Systems coordination procedures contained in the MISO, SPP, and PJM tariffs, the MISO-PJM Joint Operating Agreement ("JOA"), and the MISO-SPP JOA, as well as the Affected Systems coordination issues raised in FERC's Interconnection Reform Rulemaking proceeding in Docket No. RM17-8-000 (see December 20, 2016 edition of the WER).
In Order No. 2003, FERC required transmission providers—such as Regional Transmission Organizations ("RTOs") like MISO, SPP, and PJM—to coordinate interconnection studies and planning meetings with "Affected Systems"—neighboring transmission systems that may be impacted by the interconnection of a generator to a transmission provider's system. FERC found that although the owner or operator of an Affected System is not bound to a transmission provider's Large Generator Interconnection Procedures ("LGIP") or Large Generator Interconnection Agreement ("LGIA"), a transmission provider must nonetheless allow any Affected System to participate in the interconnection study process and include the Affected System's legitimate safety and reliability needs. The tariffs of MISO, SPP, and PJM, as well as the MISO-PJM JOA and the MISO-SPP JOA, all identify requirements for a host RTO to coordinate with any neighboring RTO that is an Affected System.
On October 30, 2017, EDF filed a complaint against MISO, SPP, and PJM, arguing, among other things, that there is a lack of detail in the RTO tariffs and JOAs regarding: (1) the timing for RTOs to complete Affected Systems analyses; (2) the standard the Affected System applies to determine impacts from proposed generation interconnecting in the host RTO; and (3) how network upgrade costs are assigned between proposed generation connecting in the host RTO versus the Affected System RTO. EDF contended that this lack of clarity impedes the ability of a proposed generation developer to assess the commercial viability of its project, which, according to EDF, is contrary to FERC's requirement that a transmission provider apply transparent open access interconnection service, and FERC's purpose for establishing pro forma generation interconnection processes in Order No. 2003. EDF also argued that there is no clear process by which MISO, SPP, and PJM assign network upgrade costs for interconnection projects located near RTO seams, and that MISO, SPP, and PJM use different modeling standards to determine Affected System impacts and that their tariffs and the JOAs do not specifically disclose what those modeling standards actually are. EDF requested that FERC find that the MISO, SPP, and PJM tariffs and the JOAs are unjust, unreasonable, unduly discriminatory and preferential, and order the RTOs to file tariff and JOA revisions addressing their concerns.
In its February 2 order, FERC found that EDF's complaint raised a number of issues related to the Affected Systems coordination between MISO, SPP, and PJM that warranted further examination, and accordingly directed Commission staff to establish a technical conference to further explore the issues raised in EDF's complaint, as well as the issues raised in FERC's Interconnection Reform Rulemaking proceeding in Docket No. RM17-8-000.
FERC's order can be found here.
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