Renewable energy developers have until Oct. 12 to file comments with the Federal Energy Regulatory Commission about their experiences with interconnection. The ANOPR provides a forum for small and large developers to voice their concerns with RTO interconnection rules.
Developers should ask FERC to mandate RTO studies and tools such as MISO’s Point Of Interconnection tool to reduce the speculative nature of site selection. Not all RTOs have calculated locational capacity values for distributed renewables and storage. Hence developers should ask FERC to mandate RTOs conduct ELCC studies that are input into the capacity credit process.
This ANOPR is the opportunity that combines both transmission planning and generator interconnection planning. Since developers sit at the junction where they cannot build renewable projects without transmission and cannot afford expensive network upgrades, this opportunity for comments should also highlight the issues with utilities dragging their feet on adopting grid-enhancing technologies.
Renewable energy developer comments should focus on experiences with RTOs
FERC is the federal regulator for RTOs. While FERC is aware of the interconnection delays, FERC seeks comments from renewable energy developers and others to address gaps in the planning and interconnection requirements at RTOs. Now is the time for renewable energy developers to narrate their experiences with RTOs.
FERC is seeking comments on how RTOs could do better in interconnecting renewables because FERC realizes that interconnection delays in RTO studies lead to developers not meeting the terms of their PPAs, which could have impacts on PPA off-takers such as states, cities, and corporate buyers not able to meet their renewable energy goals. FERC realizes the state’s role in transmission siting for interconnecting renewables which is evident in the first workshop with state and federal regulators on Nov. 10 in Louisville, Kentucky.
Small developer concerns should amplify their voice
Until now, it is likely that FERC only heard from large renewable energy developers and associations that represent those developers. This ANOPR provides a perfect opportunity for small developers to send comments directly at FERC, since FERC has opened a new Office of Public Participation to hear from diverse stakeholders, including small and large developers.
Small generator interconnections (less than 20 MW) or Fast Track processes for projects less than 5 MW do not get enough attention during RTO stakeholder committee discussions because those requests are few, and most small developers don’t have the availability to follow RTO committees regularly.
Now is the time for small developers to raise their concerns with RTOs at FERC. RTOs must be technology-neutral, as well as size neutral. They cannot prefer small developers or large developers, for that matter. And FERC must keep wholesale rates just and reasonable, which small developers can do with their projects.
Renewable energy developers should tell FERC what information they need from RTO planning studies
Developers need information on a location such as interconnection capacity at the substation, planned transmission in the area, energy market opportunities at present and in the future for the injection capacity, how frequently their renewable project is curtailed, and for how long, and what rules might change in the future such as capacity accreditation.
Some RTOs, like MISO, provide a Point Of Interconnection (POI) tool that shows possible violations based on a recent planning model right there on the MISO website. POI self-check tool is handy for developers to assess the site and prospects of interconnecting at a 69 kV substation versus a 115 kV substation. Not all RTOs provide this POI tool. Developers can insist FERC mandate a planning tool made available on all RTO websites similar to MISO’s POI self-check tool because not all developers can hire power flow consultants to run shadow interconnection studies before entering the queue.
Storage developers should ask FERC to mandate ELCC studies
Energy storage adds another level of the revenue stream to solar and wind project developers because storage can increase the capacity value of renewables. When wind and solar penetration increase, in the Effective Load Carrying Capability (ELCC) calculations, capacity values reduce with more historical data points on the grid. Adding storage at the same POI helps stem that reduction in capacity value but not all RTOs have ELCC calculations for storage+ combinations.
Developers should comment that FERC requires these ELCC studies. Capacity values for wind are common knowledge. But capacity values for solar, solar+storage, distributed solar +distributed storage are not known to all developers. Conducting ELCC studies for these combinations is beyond the scope for small developers. Hence RTOs should be required to conduct ELCC studies to provide these values transparently to developers.
On including Grid Enhancing Technologies, developers should narrate their experiences with TOs and RTOs
RTOs and TOs want to do the right thing in interconnecting renewables without showing any preference. And when RTO studies show the need for network upgrades, they expect the developers to either choose from paying for the network upgrade or dropping from the queue to make room for others who might be willing to pay for those upgrades.
But there is a third option – mitigation of that network upgrade costs with Grid Enhancing Technologies such as Smart Wires, LineVision, Ampacimon tools that use existing transmission capacity more until a new T line is built. But TOs are reluctant to try these new technologies, and RTOs don’t want to mandate TOs to use GETs. This back and forth with RTOs and TOs is where FERC can help. Hence FERC needs to hear directly from developers with expensive network upgrades who dropped out of the queue without realizing this third option exists. We know FERC is taking GETs seriously because Chairman Glick named Elizabeth Salerno as Lead on Transmission and Technology Initiatives.
The last date to submit comments to FERC is October 12. Late Friday, September 3, FERC has denied extending the time to submit comments in this ANOPR. With a quorum at FERC Commissioners, FERC would likely move quickly from the ANOPR stage to the NOPR stage. By that time, it is also likely that a fifth Commissioner could be appointed at FERC, a replacement for Commissioner Chatterjee. Hence now is the time for renewable developers to impress upon FERC the issues they see with generator interconnection processes at RTOs.
This Advance Notice of Proposed Rulemaking (ANOPR) comes before a NOPR. Hence developers should note that they will have another opportunity to comment. But if they choose to sit back in the ANOPR, their issues may not make the NOPR. That is the reason for developers to comment now.