[Federal Register: June 13, 2005 (Volume 70, Number 112)]
[Rules and Regulations]
[Page 34189-34301]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr13jn05-5]
[[Page 34189]]
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Part II
Department of Energy
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Federal Energy Regulatory Commission
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18 CFR Part 35
Standardization of Small Generator Interconnection Agreements and
Procedures; Final Rule
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 35
[Docket No. RM02-12-000; Order No. 2006; 111 FERC 61,220]
Standardization of Small Generator Interconnection Agreements and
Procedures
Issued: May 12, 2005
AGENCY: Federal Energy Regulatory Commission.
ACTION: Final rule.
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SUMMARY: The Federal Energy Regulatory Commission (Commission) is
amending its regulations under the Federal Power Act to require public
utilities that own, control, or operate facilities for transmitting
electric energy in interstate commerce to amend their open access
transmission tariffs to include standard generator interconnection
procedures and an agreement that the Commission is adopting in this
order and to provide interconnection service to devices used for the
production of electricity having a capacity of no more than 20
megawatts. A non-public utility that seeks voluntary compliance with
the reciprocity condition of an open access transmission tariff may
satisfy this condition by adopting these procedures and agreement.
DATES: Effective Date: This Final Rule will become effective August 12,
2005.
FOR FURTHER INFORMATION CONTACT:
Kumar Agarwal (Technical Information), Office of Market, Tariffs
and Rates, Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426. (202) 502-8923.
Bruce Poole (Technical Information), Office of Market, Tariffs and
Rates, Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426. (202) 502-8468.
Kirk Randall (Technical Information), Office of Market, Tariffs and
Rates, Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426. (202) 502-8092.
Patrick Rooney (Technical Information), Office of Market, Tariffs
and Rates, Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426. (202) 502-6205.
Abraham Silverman (Legal Information), Office of the General
Counsel, Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426. (202) 502-6444.
SUPPLEMENTARY INFORMATION:
Before Commissioners: Pat Wood, III, Chairman; Nora Mead Brownell,
Joseph T. Kelliher, and Suedeen G. Kelly.
I. Introduction
1. This Final Rule requires all public utilities \1\ to adopt
standard rules for interconnecting new sources of electricity no larger
than 20 megawatts (MW). It continues the process begun in Order No.
2003 of standardizing the terms and conditions of interconnection
service for Interconnection Customers of all sizes.\2\ It will reduce
interconnection time and costs for Interconnection Customers and
Transmission Providers,\3\ preserve reliability, increase energy
supply, lower wholesale prices for customers by increasing the number
and types of new generation that will compete in the wholesale
electricity market, facilitate development of non-polluting alternative
energy sources, and help remedy undue discrimination, as sections 205
and 206 of the FPA require.\4\ Public utilities must amend \5\ their
open access transmission tariffs (OATTs) to include a Small Generator
Interconnection Procedures document (SGIP--Appendix E to this Preamble)
and a Small Generator Interconnection Agreement (SGIA--Appendix F to
this Preamble).
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\1\ For purposes of this Final Rule, a public utility is a
utility that owns, controls, or operates facilities used for
transmitting electric energy in interstate commerce, as defined by
the Federal Power Act (FPA). 16 U.S.C. 824(e) (2000). A non-public
utility that seeks voluntary compliance with the reciprocity
condition of an open access transmission tariff may satisfy that
condition by adopting these procedures and agreement.
\2\ Standardization of Generator Interconnection Agreements and
Procedures, Order No. 2003, 68 FR 49845 (Aug. 19, 2003), FERC Stats.
& Regs. ] 31,146 (2003) (Order No. 2003), order on reh'g, Order No.
2003-A, 69 FR 15932 (Mar. 26, 2004), FERC Stats. & Regs. ] 31,160
(2004) (Order No. 2003-A), order on reh'g, Order No. 2003-B, 70 FR
265 (Jan. 4, 2005), FERC Stats. & Regs. ] 31,171 (2005), reh'g
pending (Order No. 2003-B). See also Notice Clarifying Compliance
Procedures, 106 FERC ] 61,009 (2004). We refer to the large
generator interconnection rulemaking as Order No. 2003 throughout
this document. The Order No. 2003 Large Generator Interconnection
Agreement and Large Generator Interconnection Procedures, as amended
by Order Nos. 2003-A and 2003-B, are referred to in this Final Rule
as the LGIA and the LGIP, respectively.
\3\ Capitalized terms used in this Final Rule have the meanings
specified in the Glossaries of Terms or the text of the Small
Generator Interconnection Procedures (SGIP) or the Small Generator
Interconnection Agreement (SGIA). Small Generating Facility means
the device for which the Interconnection Customer has requested
interconnection. The owner of the Small Generating Facility is the
Interconnection Customer. The utility entity with which the Small
Generating Facility is interconnecting is the Transmission Provider.
A Small Generating Facility is a device used for the production of
electricity having a capacity of no more than 20 MW. The
interconnection process formally begins with the Interconnection
Customer submitting an application for interconnection, called an
Interconnection Request, to the Transmission Provider.
We are omitting from the SGIP and SGIA glossaries terms that are
defined through their use in the documents themselves or are in such
common use in the industry that a definition is unnecessary. Many
terms that were capitalized in the Small Generator Interconnection
Notice of Proposed Rulemaking are therefore not capitalized in this
Preamble, SGIP, and SGIA.
The documents put forward in the Small Generator Interconnection
NOPR are called the ``Proposed SGIP'' and the ``Proposed SGIA'' in
this Preamble. The documents that are being adopted in this Final
Rule for inclusion in a Transmission Provider's OATT are called
simply the SGIP and SGIA. Provisions of the SGIP are referred to as
``sections'' and provisions of the SGIA are referred to as
``articles.''
\4\ 16 U.S.C. 824d and 824e (2000).
\5\ Compliance procedures are discussed in Part II.I, below.
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2. The SGIP contains the technical procedures the Interconnection
Customer and Transmission Provider (the Parties) must follow once the
Interconnection Customer requests interconnection of its Small
Generating Facility. It provides three ways to evaluate the
Interconnection Request. They are the default Study Process that could
be used by any Small Generating Facility, and two procedures that use
technical screens to evaluate proposed interconnections: (1) The Fast
Track Process for a certified Small Generating Facility no larger than
2 MW \6\ and (2) the 10 kW Inverter Process for a certified inverter-
based Small Generating Facility no larger than 10 kW.\7\ All three are
designed to ensure that the proposed interconnection will not endanger
the safety and reliability of the Transmission Provider's Transmission
System.
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\6\ A Small Generating Facility equipment package is considered
certified if it has been submitted, tested, and listed by a
nationally recognized testing and certification laboratory. The
Small Generator Interconnection NOPR used the term ``precertified''
to describe such a facility. We adopt in this Final Rule the term
``certified'' to be consistent with industry usage. To avoid further
confusion, we also use ``certified'' when describing the Small
Generator Interconnection NOPR. See the SGIP, especially Attachments
3 and 4.
\7\ An inverter is a device that converts the direct current
voltage and current of a DC generator to alternating voltage and
current. For example, the output of a solar panel is direct current.
The solar panel's output must be converted by an inverter to
alternating current before it can be interconnected with a utility's
alternating current electric system.
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3. The SGIA contains contractual provisions appropriate for the
interconnection of a Small Generating Facility, including provisions
for the payment for modifications made to the Transmission Provider's
Transmission System to accommodate the interconnection. The SGIA is
signed by the Parties after they have successfully completed the
evaluation of a proposed interconnection under the SGIP Study Process
or Fast Track Process. The SGIA
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does not apply to requests to interconnect submitted under the 10 kW
Inverter Process, however, which uses a simplified all-in-one
application form/procedures/terms and conditions document that is
included in SGIP Attachment 5.
4. We conclude that general consistency between the Commission's
interconnection procedures document and interconnection agreement
adopted in this Final Rule and those of the states will be helpful to
removing roadblocks to the interconnection of Small Generating
Facilities. To a large extent, this Final Rule harmonizes state and
federal practices by adopting many of the best practices
interconnection rules recommended by the National Association of
Regulatory Utility Commissioners (NARUC). By doing so, we hope to
minimize the federal-state division and promote consistent, nationwide
interconnection rules. We hope that states that do not currently have
interconnection rules for small generators will look to the documents
presented in this Final Rule and NARUC as guides for their own. In
particular, the ``Fast Track Process'' and the ``10 kW Inverter
Process'' should go a long way towards harmonizing state-federal
interconnection practices.
5. Finally, the application of this Final Rule is the same as with
Order No. 2003 for Large Generating Facilities. Specifically, this
Final Rule applies only to interconnections with facilities that are
already subject to the Transmission Provider's OATT at the time the
Interconnection Request is made.
6. The SGIP and SGIA include separate definitions for
``Transmission System'' and ``Distribution System'' to account for the
distinct engineering and cost allocation implications of an
interconnection with a Distribution System. The SGIP and SGIA, like
Order No. 2003, define ``Transmission System'' as ``[t]he facilities
owned, controlled or operated by the Transmission Provider or the
Transmission Owner that are used to provide transmission service under
the Tariff.'' Any interconnection with a Transmission System (under an
OATT) by a Small Generating Facility is subject to this Final Rule.
7. The SGIP and the SGIA, like Order No. 2003, also use the term
``Distribution System.'' ``Distribution System'' is defined as ``[t]he
Transmission Provider's facilities and equipment used to transmit
electricity to ultimate usage points such as homes and industries
directly from nearby generators or from interchanges with higher
voltage transmission networks which transport bulk power over longer
distances. The voltage levels at which Distribution Systems operate
differ among areas.'' If a Small Generating Facility proposes to
interconnect with a portion of the Distribution System subject to an
OATT for the purpose of making wholesale sales, then this Final Rule
would apply.\8\ However, an interconnection to a portion of a
Distribution System that is not already subject to an OATT would not be
subject to this Final Rule.
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\8\ See Detroit Edison v. FERC, 334 F.3d 48 (DC Cir. 2003)
(Detroit Edison). There, the court explained that:
When a local distribution facility is used to delivery [sic]
energy to an unbundled retail customer, FERC lacks any statutory
authority, and the state has jurisdiction over that transaction. By
contrast, when a local distribution facility is used in a wholesale
transaction, FERC has jurisdiction over that transaction pursuant to
its wholesale jurisdiction under FPA Section 201(b)(1). In sum, FERC
has jurisdiction over all interstate transmission service and over
all wholesale service, but FERC has no jurisdiction over unbundled
retail distribution service--i.e., unbundled retail service over
local distribution facilities.
Id. at 51 (citations omitted).
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8. ``Distribution'' is a vague term, usually used to refer to non-
networked, often lower-voltage facilities, that carry power in one
direction. Commission-jurisdictional facilities with these
characteristics are referred to as ``Distribution Systems subject to an
OATT'' throughout this Final Rule. This Final Rule's use of the term
``Distribution System'' has nothing to do with whether the facility is
under this Commission's jurisdiction; some ``distribution'' facilities
are under our jurisdiction and others are ``local distribution
facilities'' subject to state jurisdiction.\9\ This Final Rule does not
violate the FPA section 201(b)(1) provision that the Commission does
not have jurisdiction over local distribution facilities ``except as
specifically provided * * *.'' \10\ This is because the Final Rule
applies only to interconnections to facilities that are already subject
to a jurisdictional OATT at the time the interconnection request is
made and that will be used for purposes of jurisdictional wholesale
sales. Because of the limited applicability of this Final Rule, and
because the majority of small generators interconnect with facilities
that are not subject to an OATT, this Final Rule will not apply to most
small generator interconnections. Nonetheless, our hope is that states
may find this rule helpful in formulating their own interconnection
rules.
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\9\ See Detroit Edison, 334 F.3d at 51. (``For our purposes, the
most important result of these jurisdictional determinations is that
customers can take any FERC-jurisdictional service under a utility's
open access tariff, which the utility is required to file with FERC.
Customers must take non FERC-jurisdictional service, such as
unbundled retail distribution, under a state tariff.'')
\10\ 16 U.S.C. 824 (2000).
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A. Background
9. This Final Rule responds to business and technology changes in
the electric industry. Where the electric industry was once primarily
the domain of vertically integrated utilities generating power at large
centralized plants, advances in technology have created a burgeoning
market for small power plants that may offer economic, reliability, or
environmental benefits.
10. With these developments in mind, the Commission continues in
this rulemaking to work to encourage fully competitive bulk power
markets. The effort took its first significant step with Order No.
888,\11\ which required public utilities to provide other entities
comparable access to their Transmission Systems. The effort continued
with Order No. 2000,\12\ which began the process of developing Regional
Transmission Organizations (RTOs). Most recently, the Commission
established a standard Large Generator Interconnection Procedures
document (LGIP) and a standard Large Generator Interconnection
Agreement (LGIA) for generating facilities larger than 20 MW.\13\
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\11\ Promoting Wholesale Competition Through Open Access Non-
Discriminatory Transmission Services by Public Utilities: Recovery
of Stranded Costs by Public Utilities and Transmitting Utilities,
Order No. 888, 61 FR 21540 (May 10, 1996), FERC Stats. & Regs. ]
31,036 (1996), order on reh'g, Order No. 888-A, 62 FR 12274 (Mar.
14, 1997), FERC Stats. & Regs. ] 31,048 (1997), order on reh'g,
Order No. 888-B, 81 FERC ] 61,248 (1997), order on reh'g, Order No.
888-C, 82 FERC ] 61,046 (1998), aff'd in part sub nom. Transmission
Access Policy Study Group v. FERC, 225 F.3d 667 (DC Cir. 2000),
aff'd sub nom. New York v. FERC, 535 U.S. 1 (2002) (TAPS v. FERC).
\12\ Regional Transmission Organizations, Order No. 2000, 65 FR
810 (Jan. 6, 2000), FERC Stats. & Regs. ] 31,089 (1999), order on
reh'g, Order No. 2000-A, 65 FR 12088 (Mar. 8, 2000), FERC Stats. &
Regs. ] 31,092 (2000), aff'd sub nom. Public Util. Dist. No. 1 v.
FERC, 272 F.3d 607 (DC Cir. 2001).
\13\ See Order No. 2003 passim.
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11. The Commission, pursuant to its responsibility under sections
205 and 206 of the FPA to remedy undue discrimination, is requiring all
public utilities that own, control, or operate facilities for
transmitting electric energy in interstate commerce to append to their
OATTs the SGIP and SGIA we are adopting in this Final Rule. These
documents provide just and reasonable terms and conditions of
interconnection service. They also strike a reasonable balance between
the competing goals of uniformity and flexibility while ensuring safety
and reliability are protected.
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B. Need for a Standard Generator Interconnection Procedures and
Agreement
12. In fulfilling its responsibilities under sections 205 and 206
of the FPA, the Commission is required to remedy undue discrimination.
The Commission must also ensure that the rates, contracts, and
practices affecting jurisdictional transmission service do not reflect
an undue preference or advantage for Transmission Providers and their
affiliates and are just and reasonable. The Commission's regulatory
authority under the FPA ``clearly carries with it the responsibility to
consider, in appropriate circumstances, the anticompetitive effects of
regulated aspects of interstate utility operations* * *.'' \14\
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\14\ Gulf States Utils. Co. v. FPC, 411 U.S. 747, 758-59 (1973);
see City of Huntingburg v. FPC, 498 F.2d 778, 783-84 (DC Cir. 1974)
(noting the Commission's duty to consider the potential
anticompetitive effects of a proposed interconnection agreement).
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13. The record underlying Order No. 888 showed that public
utilities owning or controlling jurisdictional transmission facilities
had the incentive to engage in, and had engaged in, unduly
discriminatory transmission practices.\15\ The Commission in Order No.
888 thoroughly discussed the legislative history and case law involving
sections 205 and 206, concluded that it has the authority and
responsibility to remedy the undue discrimination it found by requiring
open access, and decided to do so through a rulemaking on a generic,
industry-wide basis.\16\ The Supreme Court affirmed the Commission's
decision to exercise this authority by requiring non-discriminatory
(comparable) open access as a remedy for undue discrimination.\17\
However, Order No. 888 did not specifically address interconnection
service.\18\
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\15\ Order No. 888 at 31,679-84; Order No. 888-A at 30,209-10.
\16\ Order No. 888 at 31,668-73, 31,676-79; Order No. 888-A at
30,201-12; TAPS v. FERC at 687-88.
\17\ New York v. FERC, 535 U.S. 1 (2002).
\18\ Order No. 888-A, FERC Stats. & Regs ] 31,048 at 30,230-31.
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14. In Tennessee Power,\19\ the Commission clarified that
interconnection is a critical component of open access transmission
service and thus is subject to the requirement that utilities offer
comparable service under the OATT. The Commission encouraged, but did
not require, each Transmission Provider to revise its OATT to include
interconnection procedures, including a standard interconnection
agreement and specific criteria, procedures, milestones, and timelines
for evaluating applications for interconnection.\20\
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\19\ Tennessee Power Co. (Tennessee Power), 90 FERC ] 61,238 at
61,761 (2000), reh'g denied, 91 FERC ] 61,271 (2000).
\20\ See, e.g., Commonwealth Edison Co., 91 FERC ] 61,083
(2000).
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15. As discussed in Order No. 2003, interconnection is a critical
component of transmission service, and having a standard
interconnection procedures and a standard agreement applicable to Small
Generating Facilities will (1) limit opportunities for transmitting
utilities to favor their own generation, (2) remove unfair impediments
to market entry for small generators by reducing interconnection costs
and time, and (3) encourage investment in generation and transmission
infrastructure, where needed.\21\ We expect the SGIP and SGIA adopted
here will resolve most disputes, minimize opportunities for undue
discrimination, foster increased development of economic Small
Generating Facilities, and protect system reliability.
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\21\ Order No. 2003 at P 10.
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C. The Large and Small Generator Interconnection Rulemaking Proceedings
16. In the Advance Notice of Proposed Rulemaking (ANOPR) issued in
Docket No. RM02-1-000, the Commission initiated a collaborative process
where members of the public, electric industry participants, and
federal and state agencies (collectively, stakeholders) were invited to
draft proposed generator interconnection procedures and a generator
interconnection agreement.\22\ The stakeholders filed their consensus
documents in January 2002. The Commission then issued a Notice of
Proposed Rulemaking (Large Generator Interconnection NOPR) \23\
proposing standard interconnection procedures and a standard
interconnection agreement that generally followed the consensus
documents. The Large Generator Interconnection NOPR also proposed
solutions to issues left unresolved in the consensus documents.
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\22\ Standardizing Generator Interconnection Agreements and
Procedures, Advance Notice of Proposed Rulemaking, 66 FR 55140 (Nov.
1, 2001), FERC Stats. & Regs. ] 35,540 (2002).
\23\ Standardization of Generator Interconnection Agreements and
Procedures, Notice of Proposed Rulemaking, 67 FR 22250 (May 2,
2002), FERC Stats. & Regs. ] 32,560 (2002).
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17. Although the Large Generator Interconnection NOPR provided
special treatment for Small Generating Facilities, some commenters
urged the Commission to initiate a separate proceeding to develop
standard interconnection procedures and agreements that addressed the
unique concerns of Small Generating Facilities.\24\ They proposed one
set of simplified interconnection rules for Small Generating Facilities
no larger than 2 MW, and another for facilities larger than 2 MW but no
larger than 20 MW. Persuaded that different procedures and agreements
were indeed needed, the Commission severed Small Generating Facilities
from the Large Generator Interconnection proceeding and issued a Small
Generator Interconnection Advance Notice of Proposed Rulemaking (ANOPR)
in August 2002.\25\ The Small Generator Interconnection ANOPR proposed
two SGIPs and two SGIAs (ANOPR SGIPs and SGIAs) using 2 MW as a
breakpoint. It encouraged stakeholders to pursue consensus on the ANOPR
SGIPs and SGIAs. To that end, the Commission convened a series of
public meetings designed to enable them to discuss and reach as much
consensus as possible.
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\24\ Those commenters included the Solar Energy Industries
Association, the U.S. Fuel Cell Council, the American Solar Energy
Society, the U.S. Combined Heat and Power Association, the
International District Energy Association, and the American Wind
Energy Association.
\25\ Standardization of Small Generator Interconnection
Agreements and Procedures, Advance Notice of Proposed Rulemaking, 67
FR 54749 (Aug. 26, 2002), FERC Stats. & Regs. ] 35,544 (2002).
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18. The negotiating parties, who we refer to collectively as Joint
Commenters, then filed SGIPs and SGIAs (Joint Commenters' SGIPs and
SGIAs) with the Commission.\26\ While Joint Commenters reached
consensus on some issues, many remained unresolved. Joint Commenters'
SGIPs included two procedures for evaluating whether a proposed Small
Generating Facility could be interconnected safely and without
degrading reliability. The first was a standard Study Process that
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used a scoping meeting and three technical studies to evaluate a
proposed interconnection. The second was a streamlined procedure that
used technical screens to identify those proposed interconnections that
clearly would not jeopardize the safety and reliability of the
Transmission Provider's electric system. Public comments on the Small
Generator Interconnection ANOPR were filed shortly thereafter.
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\26\ This group refers to itself as the Coalition. However, in
this Final Rule we shall refer to the group as ``Joint Commenters''
to distinguish it from the similarly named Small Generator
Coalition. With the exception of these early references to Joint
Commenters' comments submitted in response to the ANOPR, all
references in the remainder of this Preamble to Joint Commenters are
to its supplemental comments. Joint Commenters did not file initial
comments in response to the Small Generator Interconnection NOPR,
only supplemental comments. Joint Commenters is a diverse group of
stakeholders that includes:
Over 25 small generator trade groups, promoters, and
equipment manufacturers, who refer to themselves collectively as the
``Small Generator Coalition,''
State regulatory agencies represented by the National
Association of Regulatory Utility Commissioners,
American Public Power Association (which did not
participate in the filing of Joint Commenters' supplemental
comments), and
Transmission Providers represented by Edison Electric
Institute (EEI) and National Rural Electric Cooperative Association
(NRECA)
A list of commenter acronyms may be found in Appendix A.
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19. In July 2003, the Commission issued Order No. 2003, which
established standard procedures and an interconnection agreement for
the interconnection of large generators and explained the Commission's
jurisdiction over interconnections. The Commission simultaneously
issued the Small Generator Interconnection NOPR.\27\ Certain provisions
in the Large Generator Interconnection Final Rule as well as Joint
Commenters' SGIPs/SGIAs influenced the Small Generator Interconnection
NOPR.\28\ The Commission asked commenters to address whether Small
Generating Facilities should be treated differently from Large
Generating Facilities under the LGIP and LGIA adopted in Order No.
2003.
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\27\ Standardization of Small Generator Interconnection
Agreements and Procedures, Notice of Proposed Rulemaking, 60 FR
49974 (Aug. 19, 2003), FERC Stats. & Regs. ] 32,572 (2003) (Small
Generator Interconnection NOPR).
\28\ See, e.g., Proposed SGIA articles 4.1, 5.1.2, 5.1.2.1, 5.2,
6.1-6.9, 6.12-6.20, 7, and 8.
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20. Sixty-five entities submitted initial comments in response to
the Small Generator Interconnection NOPR. The comments generally
support the Commission's effort to remove barriers to the development
of Small Generating Facilities. Following the issuance of the Small
Generator Interconnection NOPR and the initial comment due date, NARUC
in October 2003 updated its own interconnection procedures and
agreement, referred to here as the NARUC Model. NARUC stated that the
NARUC Model is based on the best practices of the state regulatory
agencies that have interconnection procedures for small generators.
NARUC encouraged state regulators to use the NARUC Model as a basis for
developing their interconnection procedures and suggested that the
Commission's documents reflect these ``best practices.'' On July 7,
2004, the Commission staff added to the record in this proceeding the
latest version of the NARUC Model.\29\ A few commenters favor
terminating this proceeding or, in the alternative, adopting the NARUC
Model.
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\29\ NARUC members had participated in the ANOPR discussions
fostered by the Commission; there was much similarity between the
provisions of the NARUC Model and the Small Generator
Interconnection NOPR.
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21. The Commission then issued a Notice of Request for Supplemental
Comments, observing that the small generator industry had continued to
evolve since the Commission first received comments in this
proceeding.\30\ In the notice, the Commission observed that several
states had recently adopted new guidelines for small generator
interconnections, and that the stakeholders who participated in the
Commission's ANOPR process were continuing to work toward resolving
various SGIP and SGIA issues. The Commission invited joint supplemental
comments describing new consensus positions but discouraged
resubmissions of prior positions.
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\30\ See Notice of Request for Supplemental Comments, 69 FR
51024 (Aug. 17, 2004). The Commission then granted two extensions of
time at the request of Joint Commenters. See Notices issued on
September 30, 2004 and November 30, 2004 in Docket No. RM02-12-000.
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22. Joint Commenters, which as noted above represents a diverse
group of small generator interests, Transmission Providers, and state
regulators who participated in the ANOPR process, was the only group to
file a consensus position. Some Joint Commenters--Small Generator
Coalition, NRECA, and NARUC--filed their own supplemental comments as
well. Ten other entities (mostly state regulatory commissions \31\)
submitted supplemental comments.\32\
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\31\ CT DPUC, Minnesota PUC, and Massachusetts DTE submitted
copies of their recently enacted small generator interconnection
rules.
\32\ The supplemental commenters are listed in Appendix A.
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23. In its supplemental comments, Joint Commenters endorsed a
single SGIP and single SGIA for Small Generating Facilities no larger
than 20 MW. Joint Commenters recommended several revised provisions in
areas where they had not been able to reach consensus during the ANOPR
process. These included dispute resolution, confidentiality, insurance,
equipment certification, and technical screens, among others. Joint
Commenters, which includes NARUC, also endorsed a greatly simplified
all-in-one application form/procedures/terms and conditions document
for the interconnection of certified inverter-based Small Generating
Facilities no larger than 10 kW.
24. In Order No. 2003-A, the Commission determined that the LGIP
and LGIA were designed around the needs of traditional synchronous
technology generators and that generators relying on non-synchronous
technologies, such as wind plants, may find that a specific requirement
is inapplicable or that a different approach is needed.\33\
Accordingly, the Commission added a blank Appendix G (Requirements of
Generators Relying on Non-Synchronous Technologies) to the LGIA as a
placeholder for requirements specific to non-synchronous
technologies.\34\ At a September 24, 2004 technical conference on the
interconnection requirements of non-synchronous technologies, panelists
were asked whether Appendix G type requirements should apply to Small
Generating Facilities. They responded that special capabilities, such
as low voltage ride-through, simply were not needed for any Small
Generating Facility, whether wind powered or not. As a result, the Wind
NOPR issued shortly thereafter applies only to the interconnection of
wind powered generators 20 MW or larger.\35\ In its supplemental
comments, National Grid asks the Commission to implement standards for
Small Generating Facilities that are similar to those proposed for
Large Generating Facilities in the Wind NOPR. This Final Rule does not
include such standards. The wind generating facilities that will
interconnect under this Final Rule will be small and will have minimal
impact on the Transmission Provider's electric system. The reliability
requirements proposed for wind powered Large Generating Facilities are
not needed for small wind generating facilities.
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\33\ Order No. 2003-A at P 407, n. 86.
\34\ Id.
\35\ Interconnection for Wind Energy and Other Alternative
Technologies, Notice of Proposed Rulemaking, 70 FR 4791 (Jan. 31,
2005) (Wind NOPR).
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25. In crafting this Final Rule, we considered all of the comments
received throughout the course of this proceeding, including the
initial documents submitted by Joint Commenters in response to the
ANOPR, the Small Generator Interconnection NOPR and the comments filed
in response, the NARUC Model, and the supplemental comments. We
considered all comments filed in response to the Small Generator
Interconnection NOPR before April 29, 2005, and they are part of the
record in this proceeding.\36\
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\36\ Comments addressing issues filed in other dockets (for
instance, the Wind NOPR) are not part of this proceeding even if
they were cross-filed in Docket No. RM02-12-000.
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II. Discussion
26. Part A of this discussion (Descriptions of the SGIP and SGIA)
describes in general terms the interconnection procedures document
(SGIP) and interconnection agreement
[[Page 34194]]
(SGIA) we are adopting in this Final Rule.
27. Part B (Overview of the Interconnection Process for Small
Generating Facilities) describes the processes that the Interconnection
Customer and the Transmission Provider must follow to interconnect the
Small Generating Facility with the Transmission Provider's Transmission
System.
28. Part C (Issues Related to Both the SGIP and the SGIA) addresses
issues that are common to the interconnection procedures and agreement
documents.
29. Part D (Issues Related to the Interconnection Request)
addresses issues related to the Interconnection Request (application
form) that the Interconnection Customer submits to the Transmission
Provider to request interconnection of its Small Generating Facility.
30. Part E (Issues Related to the SGIP) addresses issues related
only to the interconnection procedures document.
31. Part F (Issues Related to the SGIA) addresses issues related
only to the interconnection agreement.
32. Part G (The 10kW Inverter Process) describes the simplified
all-in-one application form/procedures/terms and conditions document
for the interconnection of certified inverter-based Small Generating
Facilities no larger than 10 kW.
33. Part H (Other Significant Issues) addresses the pricing of
Interconnection Facilities and Upgrades, jurisdictional issues,
variations from the Final Rule, the availability of waivers for small
entities, the effect of this Final Rule on the OATT reciprocity
provisions, and others.
34. Finally, Part I (Compliance Issues) addresses issues pertaining
to the requirement that a Transmission Provider file conforming
amendments to its existing OATT, the treatment to be accorded to
existing interconnection agreements (grandfathering), and how a
Transmission Provider is to file executed and unexecuted
interconnection agreements.
A. Descriptions of the SGIP and SGIA
35. In Order No. 2003, the Commission adopted two documents that
are to be used for the interconnection of Large Generating Facilities--
the Large Generator Interconnection Procedures document and the Large
Generator Interconnection Agreement. The LGIP describes how the
Interconnection Customer's Interconnection Request (i.e., application)
is to be evaluated from an engineering perspective using a four-step
process. These are the scoping meeting, the feasibility study, the
system impact study, and the facilities study. The purpose of the
evaluation is to determine the impact the proposed interconnection will
have on the Transmission Provider's electric system and identify new
equipment and modifications needed to accommodate the interconnection.
The LGIA, which is signed after the proposed interconnection has been
successfully evaluated using the provisions contained in the LGIP,
describes the legal relationships of the Parties, including who pays
for equipment modifications to the Transmission Provider's electric
system.
36. The SGIP and SGIA we adopt in this Final Rule serve the same
purposes as the LGIP and LGIA. The SGIP includes the same four-step
process for evaluating an Interconnection Request as does the LGIP,
except that it is simplified in several aspects and includes timelines
to accelerate the interconnection of Small Generating Facilities. In
the SGIP, this procedure is termed the ``Study Process.'' The SGIP also
includes special procedures for evaluating two subgroups of Small
Generating Facilities, (1) a ``Fast Track Process'' that uses technical
screens to evaluate a certified Small Generating Facility no larger
than 2 MW, and (2) a ``10 kW Inverter Process'' that uses the same
technical screens to evaluate a certified inverter-based Small
Generating Facility no larger than 10 kW. The SGIA serves the same
purpose for the interconnection of a Small Generating Facility as the
LGIA does for a Large Generating Facility. It describes the legal
relationships of the Parties, including who will pay for equipment
modifications to the Transmission Provider's electric system.
37. The Commission received many comments proposing modifications
to the Proposed SGIP and Proposed SGIA, which helped greatly to shape
this Final Rule. NARUC argued that the Commission should adopt portions
of its Model to harmonize federal interconnection rules with those
found in states with interconnection rules. Small Generator Coalition
recommended that the Commission in this proceeding adopt the NARUC
Model instead of the Proposed SGIP and Proposed SGIA. Some of the
provisions proposed by Joint Commenters (which includes NARUC
representation) in its supplemental comments also followed the NARUC
Model. We are adopting in this Final Rule many of these consensus
provisions as well as those proposed by NARUC because they are just and
reasonable and serve the twin goals of removing barriers to the
development of small generation while preserving the safety and
reliability of the nation's electric system.
38. The SGIP, while relying heavily on NARUC's and Joint
Commenters' proposals, is not a significant departure from the Proposed
SGIP. Both use nearly identical interconnection study processes
(``Study Process'') to evaluate Interconnection Requests that do not
qualify for special handling. Regarding special handling, both use
technical screens to identify Small Generating Facilities no larger
than 2 MW that can be interconnected with no adverse impact on safety
or reliability. The SGIP we adopt in this Final Rule, however, includes
two such special procedures, the Fast Track Process and the 10 kW
Process. The choice of which one the Interconnection Customer may use
depends on the size and technology of the Small Generating Facility.
The SGIP also includes the Interconnection Request (application form)
that is to be used by all Interconnection Customers except those
eligible to use the 10 kW Process, and feasibility study, system impact
study, and facilities study agreements that are to be used in the Study
Process.\37\
---------------------------------------------------------------------------
\37\ Note that the scope and payment provisions of the
feasibility, system impact, and facilities studies are contained in
the actual study agreements which are included as Attachments 6, 7,
and 8 to the SGIP, not section 3 of the SGIP.
---------------------------------------------------------------------------
39. The SGIA is to be used for the interconnection of all Small
Generating Facilities subject to this Final Rule, with the exception of
certain very small inverter-based generators that use an all-in-one
application form/procedures/terms and conditions document (the 10 kW
Inverter Process document). The Proposed SGIA included several
provisions that were similar to those contained in the LGIA that was
issued concurrent with the Small Generator Interconnection NOPR. Some
commenters complained that the Proposed SGIA was too long and complex
for owners of Small Generating Facilities, who may be small businesses
or operators of small farms, for example. We are streamlining and
simplifying the SGIA in many ways to address these concerns. We are
adopting Joint Commenters' proposals submitted in its supplemental
comments where appropriate and have given consideration to the
recommendations contained in the NARUC Model and those suggested by
other commenters. In particular, the SGIA does away with the
requirement that Interconnection Customers maintain multiple kinds of
insurance, instead requiring only that they maintain a reasonable
amount based on the specific characteristics of
[[Page 34195]]
the interconnection. We also adopt a streamlined dispute resolution
provision designed to resolve disputes as quickly and inexpensively as
possible. We have also shortened the contract termination provisions
and the various liability related provisions.
40. We adopt in the SGIA the same pricing policy for Network
Upgrades to the Transmission Provider's Transmission System as in Order
No. 2003. For a Small Generating Facility interconnecting with a non-
independent entity such as a vertically integrated utility, the
Interconnection Customer initially funds the cost of any required
Network Upgrades (i.e., Upgrades to the Transmission System at or
beyond the Point of Interconnection) and it is then subsequently
reimbursed for this upfront payment by the Transmission Provider.
However, we expect that, for most interconnections of Small Generating
Facilities, there will be no Network Upgrades. We also allow more
pricing flexibility for a Transmission System that is operated by an
independent entity such as an RTO or Independent System Operator (ISO).
The costs of Distribution Upgrades are directly assigned to the
Interconnection Customer.
41. In conclusion, we encourage the standardization of
interconnection practices across the nation, using as a starting point
the SGIP and SGIA found in this Final Rule. We hope to foster seamless
interconnection procedures for Interconnection Customers and
Transmission Providers. Equipment manufacturers will have compatible
technical specifications to meet. New generation will be located on the
basis of what works best for the Interconnection Customer and the
Transmission Provider, not jurisdictional differences in
interconnection rules.
B. Overview of the Interconnection Process for Small Generating
Facilities
42. Before submitting its Interconnection Request, the
Interconnection Customer may informally discuss the proposed
interconnection with the Transmission Provider.\38\ The Interconnection
Customer then submits an Interconnection Request to the Transmission
Provider and the Transmission Provider assigns the Interconnection
Customer's project a Queue Position based on the date and time the
Interconnection Request is received by the Transmission Provider. The
Interconnection Request must be accompanied by a deposit that goes
toward the cost of the feasibility study, unless it is submitted under
the Fast Track Process or the 10 kW Inverter Process, which have small
processing fees.
---------------------------------------------------------------------------
\38\ Flowcharts depicting interconnection procedures are
presented in Appendices B (Study Process), C (Fast Track Process),
and D (10 kW Inverter Process).
---------------------------------------------------------------------------
43. As noted above, an Interconnection Request can be evaluated in
one of three ways. The Study Process is the default method; it relies
on the scoping meeting and standard feasibility, system impact, and
facilities studies to evaluate the safety and reliability of the
proposed interconnection. It is identical in concept to the evaluation
procedure that is used for the interconnection of Large Generating
Facilities. Two optional methods are available to Interconnection
Customers whose Small Generating Facilities are certified and no larger
than 2 MW. The 10 kW Inverter Process is available for owners of
inverter-based Small Generating Facilities no larger than 10 kW and the
Fast Track Process is available for owners of any kind of Small
Generating Facility no larger than 2 MW.
44. The Study Process normally consists of a scoping meeting, a
feasibility study, a system impact study, and a facilities study. At
the scoping meeting, the Parties discuss the proposed interconnection
and review any existing studies that could aid in the evaluation of the
proposed interconnection. The feasibility study is a preliminary
technical assessment of the proposed interconnection. The system impact
study is a more detailed assessment of the effect the interconnection
would have on the Transmission Provider's electric system and Affected
Systems. The facilities study determines what modifications to the
Transmission Provider's electric system are needed, including the
detailed costs and scheduled completion dates for these modifications.
These studies identify adverse system impacts \39\ that need to be
addressed before the Small Generating Facility may be interconnected
and any equipment modifications required to accommodate the
interconnection. The Interconnection Customer pays the Transmission
Provider's actual cost of performing the studies. Once the
Interconnection Customer agrees to fund any needed Upgrades, the
Parties execute an SGIA that, among other things, formalizes
responsibility for construction and payment for Interconnection
Facilities and Upgrades.\40\
---------------------------------------------------------------------------
\39\ An adverse system impact means that technical or
operational limits on conductors or equipment are exceeded under the
interconnection, which may compromise the safety or reliability of
the electric system.
\40\ The Study Process is similar to the LGIP. However, we
expect that the interconnection of a Small Generating Facility will
take substantially less time and cost substantially less than a
Large Generating Facility.
---------------------------------------------------------------------------
45. A Fast Track Process is available for certified Small
Generating Facilities no larger than 2 MW. Under this process, in place
of the scoping meeting and three interconnection studies, technical
screens are used to quickly identify reliability or safety issues. If
the proposed interconnection passes the screens, the Transmission
Provider offers the Interconnection Customer an SGIA. If the proposed
interconnection fails the screens, but the Transmission Provider
determines that the Small Generating Facility may nevertheless be
interconnected without affecting safety and reliability, the
Transmission Provider also offers the Interconnection Customer an SGIA.
However, if the Transmission Provider is concerned that the
interconnection could degrade the safety and reliability of its
electric system, the Parties may conduct a customer options meeting to
discuss how to proceed. In that meeting, the Transmission Provider must
offer to perform a supplemental review of the proposed interconnection,
paid for by the Interconnection Customer, to identify Upgrades needed
to accommodate the interconnection. Once the Interconnection Customer
agrees to pay for any Upgrades called for in the supplemental review,
the Parties execute an SGIA. If, after the supplemental review, the
Transmission Provider still is unsure whether the proposed
interconnection will degrade the safety and reliability of its electric
system, the Interconnection Request is evaluated using the Study
Process described above; i.e., scoping meeting, feasibility, system
impact, and facilities studies, followed by the execution of an SGIA.
46. Finally, the 10 kW Inverter Process is available for the
interconnection of certified inverter-based generators no larger than
10 kW. The all-in-one 10 kW Inverter Process document includes a
simplified application form, interconnection procedures, and a brief
set of terms and conditions (akin to an interconnection agreement). The
10 kW Inverter Process uses the same technical screens to evaluate the
safety and reliability of the proposed interconnection as the Fast
Track Process. Unless the Transmission Provider demonstrates that the
Small Generating Facility cannot be
[[Page 34196]]
interconnected safely and reliably based on the results of an analysis
using the screens, the Transmission Provider approves the application.
Once the Interconnection Customer certifies that equipment installation
is complete and upon a satisfactory inspection by the Transmission
Provider, the Transmission Provider authorizes the interconnection. To
further simplify the interconnection process, what would normally be
considered a separate interconnection agreement has been distilled into
a terms and conditions document that the Interconnection Customer
agrees to at the time the Interconnection Request is submitted to the
Transmission Provider. The all-in-one 10 kW Process document is
included in Attachment 5 to the SGIP.
C. Issues Related to Both the SGIP and the SGIA
47. This discussion, and those that follow, addresses the evolution
of the SGIP and SGIA from the Proposed SGIP and Proposed SGIA. As is
the custom in most Commission rulemakings, we use the Small Generator
Interconnection NOPR as our point of reference, discussing each issue
in turn, describing the comments addressed to the topic, and closing
with the Commission conclusion. There are differences between the
Proposed SGIP and SGIA and the documents we adopt in this Final Rule
that reflect the helpful comments filed in this rulemaking. For
example, we have in some instances adopted terminology more compatible
with that used in state interconnection documents. This should make for
simpler, more easily understood documents for small generators that are
compatible across jurisdictions for both Interconnection Customers and
Transmission Providers. However, the SGIP and SGIA also need to be
interpreted in the broader context of the entire collection of
generator interconnection documents that will appear in a Transmission
Provider's OATT, including the LGIP and LGIA. Thus, there are some
instances where consistency among generator interconnection documents
within a single tariff makes it necessary to adopt Large Generator
Interconnection terminology or policy. The Commission asked for
comments in the Small Generator Interconnection NOPR addressing this
topic, and it is the first to be addressed in the discussion that
follows.
48. Many of the issues in this rulemaking also arose in the Large
Generator Interconnecting rulemaking and we will not address them again
here at any great length. Where there is no compelling reason to depart
from prior precedent, we affirm the Commission's prior decisions
without detailed discussion. Therefore, this order focuses on those
issues needing a small-generator-specific resolution.
49. Finally, we note that the 10 kW Inverter Process for certified
inverter-based Small Generating Facilities is an all-in-one application
form/procedures/terms and conditions document that does not lend itself
easily to the separate discussions of the Proposed SGIP/SGIA and the
SGIP and SGIA discussions that follow. We will address it in the
separate Part G discussion, below. We emphasize, however, that the
intent of this Final Rule is that the 10 kW Inverter Process fits
within the framework of the SGIP and SGIA, and it is for that reason
that we encourage Interconnection Customers and Transmission Providers
to use this Preamble, the SGIP, and the SGIA for assistance in
interpreting the 10 kW Inverter Process should a dispute arise.
Consistency Between the Large Generator and Small Generator Documents
50. In the Small Generator Interconnection NOPR, the Commission
asked commenters to address the need for consistency between the
provisions of the LGIP/LGIA and the SGIP/SGIA.
Comments
51. NARUC argued that the Small Generator Interconnection NOPR was
too complicated for most small generator interconnections. Instead, the
Commission should adopt portions of the NARUC Model or otherwise
simplify the interconnection process. NARUC pointed out that many Small
Generating Facilities (including most inverter-based generators) will
interconnect with low voltage facilities, whether Commission-
jurisdictional or state-jurisdictional. Thus, this Final Rule should be
as consistent with state interconnection rules as possible to encourage
national consistency and discourage forum-shopping. Joint Commenters
also supports this outcome.
52. AEP supports consistency between the large and small generator
documents. However, it notes that Joint Commenters developed consensus
positions on many issues during the ANOPR process. Where such agreement
was reached, AEP proposes that the Commission adopt that position.
53. Midwest ISO argues that the Commission should ensure
consistency between the large and small generator documents, wherever
possible, because all stakeholders will benefit from a consistent
approach to the interconnection of generation facilities.
54. PJM, on the other hand, proposes that the Commission simply use
the LGIA for all interconnections, arguing that having different rules
for large and small generator interconnections would be overly
burdensome. PJM also states that its own interconnection rules take
this approach and are hailed as being very successful.
55. Baltimore G&E argues that the Commission should require the
same terms for all generators, regardless of size, unless there is a
specific reason not to do so. Therefore, it requests that the
Commission provide a clear explanation wherever these Final Rule
provisions differ from those in Order No. 2003. Southern Company
agrees, arguing that Large and Small Generating Facilities should be
treated similarly ``because both can have * * * significant impacts
upon the Transmission Provider's electric system.'' \41\
---------------------------------------------------------------------------
\41\ Southern Company at 19.
---------------------------------------------------------------------------
56. BPA argues that the procedures and technical requirements
applicable to large generators ``should not apply to the
interconnection of small generators that have minimal impacts on a
transmission grid.'' \42\ However, where the Commission does use
``substantially similar or consistent procedures, contract terms, and
other requirements'' for both Large and Small Generating Facilities,
``the Commission should strive to provide consistency between its large
and small generator rules.'' \43\
---------------------------------------------------------------------------
\42\ BPA at 3.
\43\ Id.
---------------------------------------------------------------------------
57. Nevada Power also supports the concept of having the provisions
applicable to Small Generating Facilities similar to those in Order No.
2003. According to Nevada Power, ``[t]hese commonalities will avoid the
confusion of differing terminologies, facilitate consistent and fair
implementation, and minimize the need for separate, parallel
administrative processes to administer the agreements.'' \44\ However,
Nevada Power also argues that consistency should not compromise the
goals of simplifying and expediting the interconnection of Small
Generating Facilities. Instead, this Final Rule should be designed to
``enable a common language and common administrative procedures to be
implemented and still maintain appropriate distinctions between the
small generators and the large generators.'' \45\ Nevada Power argues
that the benefits of consistency are illustrated by Proposed SGIA
article
[[Page 34197]]
5.1.2.1, which specifies the refund process for advances made by the
Interconnection Customer for Network Upgrades. By having the same
refund process for the amounts advanced for Network Upgrades in the
SGIA and the LGIA, the Transmission Provider can set up one system,
instead of two separate systems, to track and make any such refunds.
---------------------------------------------------------------------------
\44\ Nevada Power at 4.
\45\ Nevada Power at 4-5.
---------------------------------------------------------------------------
58. In their supplemental comments, NARUC and the other Joint
Commenters proposed SGIP and SGIA provisions that balance the need for
simplicity with the need of Transmission Providers to ensure the safety
and reliability of the Transmission Provider's electric system. In
addition, Joint Commenters also proposed a process for certified
inverter-based Small Generating Facilities no larger than 10 kW that
can also be used as a model for the states.
Commission Conclusion
59. Unless expressly changed in this Final Rule, the Commission's
existing interconnection precedent and Order No. 2003 are relevant to
this Final Rule and should be used as guidance for interpretation and
implementation. We have tried to be consistent between the rules for
Large and Small Generating Facilities, unless there is a specific
reason to do otherwise, while considering NARUC's call for federal-
state consistency and the recommendations of other commenters.
60. We note Joint Commenters' proposal of much simpler
interconnection procedures and agreement for inverter-based generators
no larger than 10 kW.\46\ Taking these extremely small units out of the
mix has allowed us to adopt standard rules for larger Small Generating
Facilities. According to NARUC, the process of interconnecting with a
state-jurisdictional facility should not be substantially different
from the process for interconnecting with a Commission-jurisdictional
facility. Standard interconnection procedures are especially important
for Interconnection Customers and manufacturers of off-the-shelf
generating equipment.
---------------------------------------------------------------------------
\46\ The 10 kW Inverter Process is largely based on the work of
the Massachusetts DTE and its stakeholders group.
---------------------------------------------------------------------------
61. In general, we are including standard contractual provisions in
the SGIA that are consistent with their counterparts in the LGIA.
However, in many cases commenters stressed the need to simplify those
provisions to avoid burdening Small Generating Facilities. Many
commenters offered ways to shorten and simplify those provisions. Where
possible, we accept those proposals. These streamlined provisions
adequately protect the Parties while lowering the transaction costs of
entering into an interconnection agreement. The SGIP closely tracks the
revised NARUC Model but adopts the single screen that NARUC and the
other Joint Commenters later proposed in supplemental comments. Last,
we have ensured that provisions common to the SGIP and SGIA (such as
dispute resolution and confidentiality) are consistent.
62. Definitions of Terms Used in the SGIP and SGIA--NARUC and
others propose that the Commission use the defined terms in the NARUC
Model instead of those found in the Small Generator Interconnection
NOPR. We conclude that several of the terms defined in the Proposed
SGIP and SGIA are either unnecessary or add complexity to the
interconnection process. We are simplifying the SGIP and SGIA by
deleting those definitions. Comments on specific terms are discussed
below.
63. Emergency Condition--The Proposed SGIA defined Emergency
Condition as a situation that, in the judgment of the Party making the
claim, is imminently likely to (1) endanger life or property, (2) have
an adverse impact on the safety or reliability of the Transmission
Provider's or an affected third party's electric system (Affected
System), or (3) have a material adverse effect on the safety or
operation of the Interconnection Customer's facilities. If there is an
Emergency Condition, the Transmission Provider may take necessary and
appropriate actions to protect the safety and reliability of its
electric system, including interrupting, suspending, or curtailing
interconnection service. While system restoration and black start are
considered Emergency Conditions, the Small Generating Facility is not
obligated to have black start capability.
Comment
64. Bureau of Reclamation objects to the provision that the Small
Generating Facility is not obligated by the SGIA to have black start
capability. Black start capability is an issue best handled by the
control area rather than the Transmission Provider and that mentioning
black start here raises the question of by whom and when black start
capability could be required of the Small Generating Facility. In
addition, Bureau of Reclamation proposes that the definition of
Emergency Condition also include a ``threat or danger to the
environment.''
Commission Conclusion
65. We see no need to modify the definition of Emergency Condition.
The SGIA does not interfere with the control area's ability to
establish a voluntary restoration plan, including black start. The SGIA
requires the Parties to adhere to all Applicable Laws and Regulations
relating to pollution and protection of the environment or natural
resources. Therefore, Bureau of Reclamations' proposed revision is not
necessary.
66. Network Upgrades--Comments concerning the definition of Network
Upgrades are addressed in Part II.H (Pricing/Cost Recovery for
Interconnection Facilities and Upgrades).
67. Use of Calendar Days v. Business Days--The Proposed SGIP and
Proposed SGIA used both calendar days and Business Days to establish
deadlines for particular activities.
Comments
68. Ameren, EEI, and NYTO request that all references to calendar
day be changed to ``Business Day.'' Ameren and EEI state that doing so
would make the SGIP and SGIA consistent. They also state that this is
particularly important for the three and five day time limits,
especially where the Transmission Provider may not have sufficient
staff to respond within the required time. Ameren and NYTO argue that
using both calendar days and Business Days is confusing. NYTO further
notes that using Business Days rather than calendar days gives the
Parties more time to meet deadlines. In addition, NYTO states that
using calendar days does not account for normal business delays,
including those caused by storm emergencies.
Commission Conclusion
69. We agree that references to the passage of time should be
consistent. Accordingly, we are changing calendar days to Business Days
throughout the SGIP and SGIA, with two exceptions. First, using
calendar days is proper in the SGIA's billing and payment provisions
because these activities are traditionally tied to calendar days.
Second, SGIA article 7.6.1 Default provisions are stated in terms of
calendar days to be consistent with the Commission's regulations that
require at least 60 calendar days notice of a proposed cancellation or
termination of a contract. Where we have replaced calendar days with
Business Days, we have adjusted the number of days to reflect about the
same passage of time. Arguments relating to the amount of time a Party
has to complete an action are discussed below.
[[Page 34198]]
70. Maximum Size of a Small Generating Facility--In the Small
Generator Interconnection NOPR, the maximum size of a Small Generating
Facility is 20 MW. Where there is more than one unit generating power
at a particular site, the Commission proposed to aggregate the total
capacity of all generation units using the same Point of
Interconnection. The Commission sought comments on a circumstance when
the Interconnection Customer desires to increase the capacity of an
existing generating facility. The Commission proposed that the total
size of the facility would be determined by the sum of the existing and
the incremental capacity. Thus, a 10 MW addition to an existing 15 MW
facility would be treated as a 25 MW facility. The Commission also
sought comments on how to evaluate an Interconnection Request that
specifies a level of capacity below the maximum rating of the Small
Generating Facility. Finally, the Commission invited comments on
whether Small Generating Facilities with multiple Points of
Interconnection should be treated separately for queuing and
interconnection study purposes.
Comments
Revising the Maximum Size of a Small Generating Facility
71. Ameren, EEI, and NRECA ask the Commission to reduce the maximum
size of a Small Generating Facility from 20 MW to 10 MW. They argue
that the lower size limit would help ensure safety and reliability of
the Transmission Provider's electric system. They also note that it
would also be consistent with IEEE Standard 1547,\47\ and argue that
the 20 MW size limit is particularly challenging for Transmission
Providers because of the types of analyses required to evaluate their
interconnection and the restrictive time limits placed on performing
them.
---------------------------------------------------------------------------
\47\ IEEE Standard 1547, approved in June 2003, is the Institute
of Electrical and Electronics Engineers' standard for
interconnecting distributed resources with electric power systems.
The standard applies only to generating equipment no larger than 10
MW.
---------------------------------------------------------------------------
72. EEI similarly argues that many states have adopted 10 MW as the
maximum size of a Small Generating Facility and that the Commission
should follow suit. It argues that a 10 MW size limit is better suited
to the Small Generating Facility configurations most likely to be
proposed under the Final Rule. While reducing the size limit to 10 MW
creates a gap between the Large and Small Generating Facility
interconnection provisions, that gap can be easily remedied by making
the LGIP and LGIA applicable to generating facilities larger than 10
MW.
73. NRECA notes in its initial comments that 10 MW is the upper
limit for small generators in Texas, California, New York, and Ohio,
and that no state currently has rules that apply to the interconnection
of generators larger than 10 MW. According to NRECA, the Commission's
statement in the Small Generator Interconnection NOPR that the 20 MW
maximum size would ``encourage the development of a greater number of
small generators and promote the development of innovative small
generation technologies'' is not supported by engineering reality and
industry practice. NRECA participated with Joint Commenters in
developing consensus provisions for the SGIP and SGIA that were
submitted in Joint Commenters' supplemental comments. Based on those
provisions, and in particular the technical screens contained in the
SGIP, NRECA states that, ``while it still believes that 20 MW is too
large a generator to be considered `small,' * * * [Joint Commenters']
SGIA and SGIP will work for all generators up to that size.'' \48\
---------------------------------------------------------------------------
\48\ NRECA Supplemental Comments at 5. NRECA also ``believes
that the screens adopted for review of generators up to 2 MW in
capacity reasonably consider the impact that generators of those
sizes will have on distribution systems.'' Id. The technical screens
of which NRECA speaks are the same screens adopted in this Final
Rule.
---------------------------------------------------------------------------
74. Cummins argues that the 20 MW size limit would result in more
widespread use of on-site Small Generating Facilities.
Commission Conclusion
75. We agree with commenters that generator size does matter when
evaluating the effect of the Small Generating Facility on the
Transmission Provider's electric system. However, we are keeping the 20
MW size limit for Small Generating Facilities because the
interconnection studies and screens will identify any safety and
reliability problems. In particular, the screens we adopt in the SGIP
are supported by small generators, state regulators, and Transmission
Provider representatives such as EEI and NRECA, as being appropriate to
evaluate the safety and reliability of interconnections of Small
Generating Facilities that are eligible for screening. We believe the
higher threshold will remove barriers to the development of a greater
number of Small Generating Facilities and promote the development of
innovative small generation technologies.
Increasing the Capacity of an Existing Small Generating Facility
76. The Small Generator Interconnection NOPR proposed to evaluate
increases in capacity to existing Small Generating Facilities using the
total capacity of the modified facility, and the Commission invited
comments on whether the proposal was reasonable.
Comments
77. Several Transmission Providers \49\ support the NOPR's
proposal. They add that if, for example, the capacity of an existing 18
MW Small Generating Facility were to be increased by 5 MW, the
resulting 23 MW facility should be evaluated under the LGIP. This would
keep the Interconnection Customer from gaming the system by
incrementally increasing the size of an existing Small Generating
Facility so that the capacity addition does not exceed the 20 MW
maximum, even though the ultimate capacity of the facility does. BPA
and ISO New England state that processing the Interconnection Request
for such an expansion on the basis of the total capacity would better
protect the safety and reliability of the Transmission Provider's
electric system. Tangibl, on the other hand, argues that evaluating the
Interconnection Request based on the total increased capacity of the
Small Generating Facility would discourage such increases and hinder
the increased entry of generators into the energy markets.
---------------------------------------------------------------------------
\49\ E.g., BPA, ISO-New England, NRECA, NYTO, PG&E, and Western.
---------------------------------------------------------------------------
Commission Conclusion
78. We are persuaded by BPA and ISO New England that when an
existing Small Generating Facility is expanded, the Interconnection
Request should be evaluated based on the total capacity of the facility
as opposed to the incremental amount of the expansion. Similarly, an
existing Large Generator seeking to increase its capacity by less than
20 MW would also have to follow the Large Generator rule, because the
total capacity of the expanded facility would be more than 20 MW.
Section 4.10.1 of the SGIP reflects this conclusion.
Evaluating the Generating Facility Based on Less Than Its Maximum Rated
Capacity
79. In the Small Generator Interconnection NOPR, the Commission
sought comments on whether the maximum capacity of the Small Generating
Facility should be used to evaluate the Interconnection Request
[[Page 34199]]
when the Interconnection Customer specified an output level below the
facility's maximum capability. For example, the Commission asked
whether an Interconnection Request for a generating facility with a
maximum capacity of 22 MW but seeking an interconnection for only 20 MW
(and agreeing to restrict delivery to the Transmission Provider's
Transmission System to that level) should be evaluated under the SGIP
or the LGIP.
Comments
80. Several Transmission Providers \50\ argue that the
Interconnection Request should be evaluated on the basis of the maximum
capacity of the Small Generating Facility to ensure that safety and
reliability are not jeopardized. They argue that the Commission should
not allow a 22 MW generator to be treated as a 20 MW generator based on
a promise by the Interconnection Customer that it will never generate
more than 20 MW. This would result in an additional administrative
burden on the Commission or market monitors. They also argue that
evaluating the Small Generating Facility at less than its maximum rated
capacity would not ensure that Interconnection Facilities and Upgrades
are properly designed and installed.
---------------------------------------------------------------------------
\50\ E.g., AEP, Ameren, Avista, BPA, CA ISO, Central Maine,
MidAmerican, MISO, NYTO, PG&E, SoCal Edison, and Western.
---------------------------------------------------------------------------
81. BPA argues that evaluating a Small Generating Facility on the
basis of maximum rated capacity would prevent gaming by an
Interconnection Customer and would prevent it from submitting a request
to interconnect its Small Generating Facility at a lower capacity when
it really intend to operate the facility at a higher capacity. Further,
evaluating a Small Generating Facility based on its maximum operational
capacity would avoid the need to perform a reevaluation each time the
Interconnection Customer seeks to operate at a higher output level.
82. Likewise, NYTO claims that even if a Small Generating Facility
supplies local load and delivers only half of its output, it still
contributes its full fault current to the electric system if there is
an electrical fault. Also, stability analysis is based on the full
physical characteristics of the facility, such as maximum power
capability and rotation inertia. It further argues that if the
Commission adopts a value other than the maximum capability of the
Small Generating Facility, the Interconnection Customer could ``forum
shop'' between the Large and Small Generating Facility interconnection
provisions to get the ``best deal.''
83. On the other hand, Allegheny states that if the Interconnection
Customer is willing to accept the economic risks of its decision to
limit the output of its generating facility, the Interconnection
Request should be evaluated at the lower capacity.
84. American Forest, Cummins, Nevada Power, NRECA, and Tangibl also
state that the Interconnection Request should be evaluated on the basis
of requested capacity, not the maximum capability of the generator, if
the Interconnection Customer commits to restrict the output. American
Forest says that this is important for generators that consume most of
their electrical output on-site in various manufacturing processes and
export only a small fraction of their output. In its supplemental
comments, Small Generator Coalition proposes a special set of tests
that could be used to determine whether these kinds of configurations
jeopardize safety and reliability.
Commission Conclusion
85. We are persuaded that the Interconnection Request should be
evaluated based on the Small Generating Facility's maximum rated
capacity. We agree with commenters that evaluating the proposed
interconnection at less than the maximum rated capacity of the
generating facility does not ensure that proper protective equipment is
designed and installed and the safety and reliability of the
Transmission Provider's electric system can be maintained.
86. Nevada Power and other commenters propose that the
Interconnection Request be evaluated on the basis of requested capacity
if the Interconnection Customer agrees to restrict the output of its
facility. We agree with NYTO, however, that even if the Small
Generating Facility delivers only a portion of its capability, it still
contributes its full fault current to the Transmission Provider's
electric system if there is an electrical fault. Therefore, the maximum
capacity of the Small Generating Facility should be used to evaluate
the Interconnection Request (See section 4.10.3 of the SGIP).
Evaluating Small Generating Facilities With Multiple Points of
Interconnection
87. The Small Generator Interconnection NOPR invited comments on
whether Small Generating Facilities with multiple Points of
Interconnection (such as for a wind farm or an industrial cogeneration
project serving multiple facilities) should be treated as separate
projects or as a single project for queuing and interconnection study
purposes.
Comments
88. BPA, CA ISO, ISO New England, and Tangibl argue that Small
Generating Facilities with multiple Points of Interconnection should be
treated as a single project for queuing and interconnection study
purposes. BPA states that this promotes greater efficiency and accuracy
because the effects of all the generators can be evaluated in one
study. According to commenters, evaluating each Point of
Interconnection as a discrete facility may not account for the
aggregate effects when multiple generation resources are
interconnected.
89. Tangibl recommends adopting PJM's approach of one
Interconnection Request for each Point of Interconnection. Tangibl
states that the Interconnection Customer should aggregate the capacity
of the multiple wind or solar projects that lie in close proximity to
one another. However, for geographically dispersed wind or solar
projects, it recommends that the project developer be able to ask the
Transmission Provider to treat each project individually for
interconnection study purposes.
90. Central Maine, Idaho Power, and others argue that evaluating
Interconnection Requests based upon a single Point of Interconnection
may produce flawed results because it may identify Upgrades
incorrectly.
91. NYTO recommends that the Transmission Provider have the option,
subject to Good Utility Practice, to either treat such projects
separately for queuing and interconnection study purposes, or as a
single Point of Interconnection. This is because each proposed Point of
Interconnection presents numerous technical, operational, and
reliability issues.
Commission Conclusion
92. We adopt NYTO's proposal for the reasons cited by NYTO. The
Transmission Provider's evaluation of a project with multiple Points of
Interconnection should be performed, using Good Utility Practice, based
on the project's unique engineering and geographic needs.
93. Dispute Resolution (Proposed SGIA Article 8 and Proposed SGIP
Section 2.11) \51\--The Commission
[[Page 34200]]
proposed adopting the same dispute resolution procedures contained in
the LGIA and LGIP. This was a departure from Joint Commenters' proposal
submitted in response to the ANOPR which obliged the Commission to
supply technical experts to resolve disputes between the Parties.
---------------------------------------------------------------------------
\51\ In the remainder of this Preamble, ``Proposed SGIA Article
xxx'' refers to a numbered article in the Small Generator
Interconnection NOPR, not the SGIA adopted in this Final Rule. The
same follows for references to the Proposed SGIP. This is because
the numbering of the SGIP and SGIA does not follow the Proposed SGIP
and SGIA.
---------------------------------------------------------------------------
Comments
94. Commenters were split as to which type of dispute resolution
procedures should be adopted by the Commission. Small generator
proponents generally support allowing either Party to require binding
arbitration, while Transmission Providers generally oppose such
provisions. However, all commenters stress the need for quick and cost-
effective dispute resolution.
95. CT DPUC argues that the procedures in the Small Generator
Interconnection NOPR are too cumbersome and that state commissions are
best positioned to resolve disputes in a fair manner, especially
disputes over dual use facilities.
96. NRECA and BPA support adopting the dispute resolution
procedures in the LGIA. However, BPA opposes binding arbitration and
asserts that the Parties should keep whatever appeal rights they have.
97. Small Generator Coalition argues that most Interconnection
Customers that own Small Generating Facilities do not have the
resources to enter into protracted dispute resolution procedures with
the larger Transmission Provider. It argues that complex dispute
resolution procedures may discourage Small Generating Facilities from
seeking to interconnect with Commission-jurisdictional facilities.
Small Generator Coalition questions why the Commission would propose
retreating from the ANOPR consensus result. It fears that Transmission
Providers will simply refuse to submit to arbitration, forcing an
Interconnection Customer to engage in expensive and undefined
litigation. This is particularly true for owners of Small Generating
Facilities no larger than 2 MW.
98. AEP proposes that either Party be able to require binding
arbitration. It states that this approach is consistent with the
consensus reached during the ANOPR process. Cummins agrees, asserting
that otherwise one Party can obstruct the process. It points out that
Interconnection Customers often lack the financial resources to pursue
their rights before the Commission or in court, and need access to low-
cost, binding dispute resolution procedures.
99. American Forest proposes allowing the Parties to agree on other
arbitration procedures if they want to further tailor the procedures to
the needs of the specific Parties. It claims that this is the approach
common in the industry.
100. Midwest ISO recommends that where an RTO has Commission-
approved dispute resolution procedures, it be allowed to apply those
procedures to interconnection disputes.
101. NARUC requests that the Commission adopt the dispute
resolution provisions found in its Model. It argues that ``[e]ach State
already has in place a variety of avenues for dispute resolution
oriented to protect the interests of the retail customer, ranging from
a simple phone call to a State commission or consumer advocate
`consumer hotline' to a full-blown complaint proceeding conducted by
the State Commission.''\52\ Specifically, the NARUC Model states that
``[i]f a dispute arises at any time during these procedures [the
Parties] may seek immediate resolution through complaint procedures
available'' through the state regulatory commission.\53\ The Model (1)
states that the Interconnection Customer's Queue Position is not to be
affected by its decision to pursue dispute resolution, (2) allows
either Party to require binding arbitration, (3) allows the Parties to
request that the state regulatory agency appoint a ``technical master''
to conduct the dispute resolution process, and (4) states that ``where
possible, dispute resolution will be conducted in an informal,
expeditious manner in order to reach resolution with minimal costs and
delay. When appropriate and available, the dispute resolution may be
conducted by phone or through Internet communications.'' \54\
---------------------------------------------------------------------------
\52\ NARUC at 12-13.
\53\ NARUC Model at F.
\54\ Id.
---------------------------------------------------------------------------
102. Joint Commenters, in its supplemental comments, proposes that
the Commission's Dispute Resolution Service (FERC DRS) assist Parties
in resolving their disputes. Under Joint Commenters' proposal, one
Party would give the other Party written notice that they have reached
an impasse. As soon as two days afterwards, either Party may consult
with FERC DRS for guidance on how best to resolve the dispute. FERC DRS
may provide the Parties with a neutral venue to work out their dispute
or may recommend alternative avenues of dispute resolution including,
but not limited to, mediation, settlement judge talks, early neutral
evaluation, or arbitration. The Parties could agree to make such
outcomes binding, but would not be required to so agree, or even to
participate in alternative dispute resolution procedures before FERC
DRS.
Commission Conclusion
103. We are adopting a dispute resolution provision for both the
SGIP and SGIA that closely resembles the consensus recommendation of
Joint Commenters. As the widely disparate recommendations show,
different types of interconnection disputes require different types of
dispute resolution procedures. Small Generator Coalition and others
emphasize the need to avoid expensive and time consuming arbitration
provisions. According to these commenters, if a project is forced to go
to arbitration, it will likely never be built. Instead, Joint
Commenters reached consensus on a set of principles designed to
encourage the Transmission Provider and the Interconnection Customer to
use fast and low cost alternative dispute resolution procedures to work
through their differences.
104. Because the nature of the disputes that may arise are so
varied, this approach will allow FERC DRS to make specific
recommendations to the Parties designed to resolve the dispute quickly
and inexpensively. In some cases, FERC DRS may simply provide the
Parties a neutral venue to discuss their differences. In other cases,
FERC DRS may recommend that the Parties put their case before a
settlement judge or technical master for either mediation or
arbitration. The Parties are free to specify whether the outcome of
this alternative dispute resolution is binding.
105. As recommended by Joint Commenters, we will not mandate that
the Parties use the FERC DRS' resources. Alternative dispute resolution
is, by its nature, a collaborative and voluntary process. However, both
Parties must work in good faith to resolve their disputes.
Additionally, the provision specifies that each Party is responsible
for paying one-half of the cost of a neutral third-party employed to
assist in settling the dispute.
106. We agree with CT DPUC, NARUC, and Joint Commenters (in its
supplemental comments) that a state regulatory agency may often be the
best place to quickly resolve a dispute. As mentioned above, the FERC
DRS is well-equipped to recommend to Parties the best avenue for
resolving a dispute. In many cases, that may be a state
[[Page 34201]]
regulatory agency, if that body is willing to mediate or arbitrate the
dispute.\55\
---------------------------------------------------------------------------
\55\ The Commission does not require states to serve a dispute
resolution function; it lacks the statutory authority to do so.
However, because commenters argue that state participation could be
beneficial, we encourage states that have the expertise, resources,
and interest to help resolve these disputes as they arise.
---------------------------------------------------------------------------
107. While we are allowing Parties to select a dispute resolution
process, we count on FERC DRS to ensure that both Parties are treated
fairly. Thus, we disagree with American Forest that the Parties should
be able to deviate from the established dispute resolution procedures
without Commission guidance or oversight. While flexibility is
important, as many commenters have pointed out, the Parties are rarely
on an equal footing. Thus, we will scrutinize the process to ensure
that Interconnection Customers are treated fairly, especially by non-
independent Transmission Providers.
108. In response to Midwest ISO's request to include ISO-specific
dispute resolution rules, under the independent entity variation, it
and other independent Transmission Providers may propose such a plan in
their compliance filings.
109. Confidentiality (Proposed SGIA Article 7 and Proposed SGIP
Section 2.11)--These provisions detailed the rights and
responsibilities of each Party to keep any Confidential Information
shared during the interconnection process.
Comments
110. Avista and Idaho Power assert that the confidentiality
provisions should give state regulators conducting an investigation the
same access to confidential information as is provided to the
Commission when it conducts an investigation. Avista also requests that
the Commission address recent rulings by the Internal Revenue Service
applicable to confidential transactions. Similarly, NARUC is concerned
that the proposed confidentiality provisions might prevent state
regulators from getting the information they need in the course of
conducting an investigation. The NARUC Model SGIP includes a
confidentiality provision that is similar to that proposed in the Small
Generator Interconnection NOPR. The NARUC Model SGIA simply leaves a
place holder to be filled in by the Parties.
111. Southern Company argues that Proposed SGIA article 7.1 should
specify that information supplied ``as part of this [interconnection]
agreement'' be confidential rather than information supplied ``prior to
execution of this agreement.'' It also says that Proposed SGIA article
7.12 allows a broader class of information to qualify for confidential
treatment than does article 7.1, and proposes deleting article 7.12.
Finally, article 7.4 should be revised to prohibit the Interconnection
Customer from sharing Confidential Information with ``potential
purchasers or assignees of the Interconnection Customer.''
112. In its supplemental comments, Joint Commenters propose the
following provision in lieu of the proposal:
Confidential Information is as defined in this Agreement but
does not include information previously in the public domain,
required to be publicly submitted or divulged by Governmental
Authorities (after notice to the other party and after exhausting
any opportunity to oppose such publication or release), or necessary
to be divulged in an action to enforce this agreement. Each party
receiving Confidential Information shall hold such information in
confidence and shall not disclose it to any third party nor to the
public without the prior written authorization from the party
providing that information, except to fulfill obligations under this
agreement, or to fulfill legal or regulatory requirements. Each
party shall employ at least the same standard of care to protect
Confidential Information obtained from the other party as it employs
to protect its own Confidential Information. Each party is entitled
to equitable relief, by injunction or otherwise, to enforce its
rights under this provision to prevent the release of Confidential
Information without bond or proof of damages, and may seek other
remedies available at law or in equity for breach of this provision.
Commission Conclusion
113. We are adopting confidentiality provisions in both the SGIP
and SGIA that closely resemble those proposed by Joint Commenters.
While the provisions we adopt here are shorter than those in the LGIP
and LGIA, they are similar in content.
114. To clarify the Commission's right to otherwise Confidential
Information during an investigation, we include an SGIA provision
similar to LGIA article 22.1.10.\56\ This addition also clarifies that
a Party is not prohibited from disclosing Confidential Information to a
state regulatory body where the state regulatory body has the authority
to request the information.
---------------------------------------------------------------------------
\56\ See Order No. 2003-A at P 486.
---------------------------------------------------------------------------
115. We deny Southern Company's request to remove proposed language
allowing the Interconnection Customer to share Confidential Information
with potential assignees and financers. The Interconnection Customer
must be able to share such information to secure financing and remain
competitive. However, we are modifying the provision to specify that
any such person receiving Confidential Information agree to abide by
the same confidentiality rules as the Parties.\57\ We agree with
Southern Company that confidentiality should apply to all information
shared between the Parties; however, its proposal is obviated by the
new language.
---------------------------------------------------------------------------
\57\ Id. at P 490.
---------------------------------------------------------------------------
116. Keeping the Small Generator Interconnection Rules Current--The
Small Generator Interconnection NOPR did not envision that the SGIP and
SGIA would be periodically revised.
Comment
117. In its supplemental comments, Small Generator Coalition asks
the Commission to adopt a mechanism to allow periodic revisiting of its
interconnection rules as the industry evolves. It proposes that the
Commission encourage or charter a stakeholder committee to meet
periodically to consider and recommend consensus proposals for changes.
Commission Conclusion
118. We commend the persistence of the Joint Commenters who met on
numerous occasions over the duration of this proceeding to aid the
Commission in its decision-making. As one can see in the contents of
this Final Rule, those negotiations have been very successful. We
believe Small Generator Coalition's proposal has merit. We ask the
Joint Commenters to take the lead in this process, and encourage
interested entities to continue to work together on small generator
interconnection issues. We are asking this informal group to meet
biennially, beginning two years from the issuance of this order, to
consider and recommend consensus proposals for changes in the
Commission's rules for small generator interconnection. The Commission
will provide appropriate resources to facilitate the process. To the
extent that this group identifies needed changes, they may file a
petition to amend the Commission's regulations. The Commission will
review the petition and, if appropriate, notice that petition for
public comment.
D. Issues Related to the Interconnection Request
119. The Interconnection Request is the application form that the
Interconnection Customer uses to start the process of interconnecting
its Small Generating Facility with the Transmission Provider's
Transmission System. The issues discussed below either did not arise in
the Large
[[Page 34202]]
Generator Interconnection proceeding or we conclude that a different
conclusion should apply to Small Generating Facilities.
120. Processing Fees and Study Deposits--The Proposed SGIP set out
a fixed processing fee schedule for processing all Interconnection
Requests. The amount of the fee was to be tied to the size of the Small
Generating Facility. Small Generating Facilities no larger than 2 MW in
size would be charged the greater of (1) $0.50/kVA rating, or $100 for
single phase generators no larger than 25 kVA or (2) $500 for
generators larger than 25 kVA. The fee for a Small Generating Facility
larger than 2 MW but no larger than 10 MW would be $1,000, and the fee
for one larger than 10 MW would be $2,000. In addition, if the Small
Generating Facility was to be evaluated using the interconnection
studies, the Interconnection Customer would pay a deposit prior to each
study that would be applied to the Transmission Provider's actual costs
of performing the study.
Comments
121. NARUC urges that the processing fee be cost-based so that
there is no subsidization by either the Transmission Provider or the
Interconnection Customer.
122. NRECA generally supports a fixed processing fee approach, but
says that the proposed fees are unrelated to the actual cost of
conducting the analysis under the screens. It asks the Commission to
let each Transmission Provider file fees that are designed to recover
the actual cost of conducting the analysis under the screens.
123. NYTO asks the Commission to clarify that the proposed fee
covers administrative and engineering costs not covered by other fees.
PacifiCorp states that it does not appear that the owner of a Small
Generating Facility no larger than 2 MW would pay any fee other than
the fee to conduct the analysis under the screens. It asks the
Commission to require the owner of such a generator to pay the actual
cost of interconnection, if any, beyond the processing fee.
124. Southern Company states that the proposed processing fee
schedule conflicts with the deposit provisions of the proposed
interconnection study agreements. It argues that a Small Generating
Facility interconnecting at the transmission level should submit an
interconnection feasibility study deposit rather than the application
fee because it appears that the processing fee is a charge for
conducting the analysis under the screens. Southern Company also states
that evaluating an Interconnection Request for a non-certified Small
Generating Facility requires time and effort, and the Interconnection
Customer should pay twice the processing fee assessed to the owner of a
certified Small Generating Facility.
Commission Conclusion
125. Under this Final Rule, the Interconnection Customer shall
submit with its Interconnection Request a processing fee or feasibility
study deposit, but not both, depending on how the Interconnection
Request is to be evaluated. If it is to be evaluated using the Study
Process, which usually includes a scoping meeting and feasibility,
system impact, and facilities studies, the Interconnection Customer
shall make a deposit towards the cost of the feasibility study at the
time the Interconnection Request is submitted to the Transmission
Provider. The amount of the deposit is the lesser of 50 percent of the
good faith estimated feasibility study costs or $1,000. If the
Interconnection Request is to be evaluated using the Fast Track
Process, it is to be accompanied by a $500 processing fee. If the
Interconnection Request is to be evaluated using the 10 kW Inverter
Process, it is to be accompanied by a $100 processing fee.
126. The purpose of the $100 and $500 processing fees is to recover
the Transmission Provider's costs of evaluating Interconnection
Requests under the 10 kW Inverter Process and Fast Track Process,
respectively. This approach to fees is simple, easy to administer, and
gives many Interconnection Customers the cost certainty they need to
move forward with their projects. However, because administratively
fixed fees will sometimes either under- or over-recover a particular
Transmission Provider's costs, we will allow the Transmission Provider
to charge a cost-based fee for processing Interconnection Requests if
it has first made an appropriate rate filing with appropriate detailed
cost justification under FPA section 205.\58\ If the Transmission
Provider decides to revise its processing fee schedule through a rate
filing, the revised fees would, of course, apply prospectively to all
new Interconnection Requests under the Fast Track Process or the 10 kW
Inverter Process. Otherwise, the processing fees in the SGIP will serve
as a default.
---------------------------------------------------------------------------
\58\ 16 U.S.C. 824d (2000); see also 18 CFR Sec. 35.12 (2004).
---------------------------------------------------------------------------
127. Given our concerns about the need for many Interconnection
Customers to know beforehand the costs they will incur for the
evaluation of their Interconnection Request under the screens, we will
disallow formula rates or true up provisions in any rate submission.
The cost support for the filed fixed processing fee schedule (designed
in a manner similar to the processing fees in the SGIP) shall reflect
the Transmission Provider's costs for processing Interconnection
Requests under the Fast Track and the 10 kW Inverter Processes, as it
would for the embedded cost based pricing of any other jurisdictional
service.
128. Southern Company's first comment highlights an unintended
inconsistency in the NOPR. To clarify, the fixed processing fee
schedule delineated above is only for submissions under the10 kW
Inverter Process and the Fast Track Process which use the technical
screens. A submission under the Study Process instead will include a
deposit towards the Transmission Provider's cost of performing the
feasibility study, not both a deposit and a processing fee. However, an
Interconnection Customer whose proposed interconnection fails the Fast
Track Process or the 10 kW Inverter Process and is then evaluated under
the Study Process would pay both the fixed processing fee with the
initial submission and then a feasibility study deposit before the
Study Process begins.
129. Receipt Confirmation and Requests for Additional Data--
Proposed SGIP sections 3.2 and 4.2 govern the submission and receipt of
the Interconnection Customer's Interconnection Request.
Comments
130. Central Maine argues that the Transmission Provider should be
able to use alternative methods to mail, such as fax and overnight
delivery services, to tell the Interconnection Customer that it has
received the Interconnection Request. It also asks that the Commission
increase the Transmission Provider's notification time period from ten
to fifteen Business Days. Central Maine and EEI note that the
Interconnection Customer does not have a deadline to supply missing
information. They recommend that the Commission establish ten Business
Days as the deadline and to state that failure to provide such
information within that time will result in the Interconnection Request
being deemed withdrawn.
Commission Conclusion
131. We agree that the Transmission Provider may use alternate
methods of confirming receipt of the Interconnection Request. The
notification requirement is needed
[[Page 34203]]
because it provides a date certain for affirming that the Transmission
Provider has received the Interconnection Request. We also decline to
increase the time by which the Interconnection Customer must be told
whether the Interconnection Request is complete. Ten Business Days is
sufficient time for the Transmission Provider to make an initial
assessment as to whether the requisite information has been provided;
an in-depth evaluation of the project is not required during this
period. However, we agree with Central Maine and EEI that the Proposed
SGIP does not address when the Interconnection Customer must furnish
the missing information. Accordingly, the SGIP provides that the
Interconnection Customer has ten Business Days after receipt of the
notice to submit the missing information or to provide an explanation
as to why extension of time is needed to provide such information. If
the Interconnection Customer does not provide the missing information
or a request for an extension of time within the deadline, the
Interconnection Request shall be deemed withdrawn.
132. Interconnection Products and Service Options--The Proposed
Interconnection Request would have directed the Interconnection
Customer to state whether it intends to participate as a ``Network
Resource,'' ``Energy-Only Resource,'' ``Non-Exporting Resource
Participating in a Wholesale Market,'' or ``Other.''
Comments
133. Alabama PSC, EEI, Mississippi PSC, Southern Company, and
others are concerned that the Interconnection Request could be
construed to mean that a Small Generating Facility is eligible for the
same Network Resource Interconnection Service that Order No. 2003 makes
available to Large Generating Facilities. They argue that this service
should not be provided to a Small Generating Facility. For example,
Alabama PSC and Mississippi PSC argue that a Small Generating Facility
does not meet the basic prerequisites to receive a ``network'' type of
service. They state that Small Generating Facilities almost universally
interconnect with either ``distribution'' or sub-transmission
facilities that are not ``networked'' but are radial in nature. The
costs to make such facilities networked to provide such a service would
be prohibitive. Southern Company asks that the references to resource
options be deleted. TAPS states that the Small Generator
Interconnection NOPR correctly dispenses with Order No. 2003's Network
Resource Interconnection Service, which TAPS claims is incompatible
with Network Integration Transmission Service under the OATT.
134. Taking the opposite view, National Grid states that the
Commission should establish two interconnection products for Small
Generating Facilities, arguing that Energy Resource Interconnection
Service and Network Resource Interconnection Service are just as
important for a Small Generating Facility as they are for a Large
Generating Facility. National Grid states that Network Resource
Interconnection Service has important market implications for new
resources, because only generating facilities that meet this
interconnection standard should qualify for installed capacity credits.
It argues that Small Generating Facilities should have the option of
being studied as deliverable network resources so that they may be
eligible for such credits. If the Commission does not mandate two
separate interconnection products for Small Generating Facilities,
National Grid requests that, at a minimum, the single interconnection
product ensure deliverability of generating facility output, consistent
with the Commission's ruling in New England with respect to large
generator interconnections.\59\
---------------------------------------------------------------------------
\59\ New England Power Pool (New England), 109 FERC ] 61,155 at
P 43-44 (2004).
---------------------------------------------------------------------------
135. NARUC asks the Commission to remove the category ``non-
exporting resource participating in a wholesale market'' from the
Interconnection Request. It notes that the Interconnection Request
instructs the Interconnection Customer to declare its intention to sell
electricity at wholesale in interstate commerce. However, the phrase
``non-exporting resource participating in a wholesale market,'' which
is used nowhere else in the Small Generator Interconnection NOPR,
raises unnecessary questions and extends its reach far beyond its
stated intention.
136. PacifiCorp states that none of these service categories is
defined in the Proposed SGIP and that the significance of each
designation is unknown. It argues that the different service options
must be defined in the SGIP and that the additional information needed
to permit a Transmission Provider to conduct studies must be provided.
PacifiCorp asks the Commission to explain the significance of ``Non-
Exporting Resource Participating in a Wholesale Market'' and ``Other.''
It adds that there should be an opportunity for comment on the
workability of these proposals and on what information a Transmission
Provider may need to provide this kind of interconnection service.
137. SoCal Edison seeks clarification that, to interconnect a Small
Generating Facility with a Distribution System, the Transmission
Provider must study deliverability \60\ on the system, even if no
delivery service is sought on either the Transmission or Distribution
System. In studying distribution-level interconnections, the Small
Generating Facility is assumed to be running at maximum output and the
power is flowing onto the directly attached distribution facility.
SoCal Edison argues that there is no way to study an interconnection
with the Distribution System without assuming power flows on that
Distribution System.
---------------------------------------------------------------------------
\60\ Deliverability refers to the ability of the electric system
to accept the Small Generating Facility's output without regard to
the ultimate point of delivery.
---------------------------------------------------------------------------
138. SoCal Edison further argues that, unlike an energy resource on
a Transmission System, the generator cannot for safety and reliability
reasons opt to generate only when distribution ``capacity'' is
available because the characteristics of a Distribution System (i.e.,
radial) differ from those of a Transmission System (i.e., network).
Given how a Distribution System operates, the provision of distribution
interconnection service in the absence of a wholesale distribution
service request is a meaningless exercise, and there are considerable
efficiencies in requesting and studying the two services at the same
time. Also, SoCal Edison is concerned that some Interconnection
Customers may not realize that a separate rate may be charged to use
the Distribution System in addition to the Transmission System. It
states that the Commission should clarify that both interconnection and
wholesale delivery service may be required. Although SoCal Edison does
not believe that the Commission needs to require that wholesale
distribution service and distribution-level interconnection service be
provided only on a bundled basis, it asks the Commission to permit
``bundled'' applications like those under SoCal Edison's Wholesale
Distribution Access Tariff.
Commission Conclusion
139. We clarify that the resource options listed in the Small
Generator Interconnection NOPR's Interconnection Request are not
interconnection service options. Rather, they are merely the possible
ways the Interconnection Customer may use its Small Generating
[[Page 34204]]
Facility once delivery service begins. The purpose of this information
is to give the Transmission Provider an early indication of how the
Small Generating Facility is likely to operate. The one interconnection
service that the Commission proposed to make available to the Small
Generating Facility is similar to the Energy Resource Interconnection
Service that is offered under the LGIA. Nevertheless, based on the
comments, we are concerned that requesting service-related information
in the Interconnection Request could lead to misunderstanding. Because
the information is related to the delivery component of transmission
service, not interconnection service, it is not needed in the SGIP's
Interconnection Request form. Therefore, we are removing this
information from the Interconnection Request. This should address the
concerns of most commenters.
140. In response to National Grid, we note that the LGIA's more
expansive Network Resource Interconnection Service is intended to give
the Interconnection Customer broad access to the backbone of the
Transmission Provider's Transmission System. In essence, it allows the
generating facility to pre-qualify as a Network Resource for any
Network Customer on the Transmission System and, as National Grid
notes, may make it eligible for installed capacity credits. Because
Network Resource Interconnection Service entails high technical
standards, we expect that an Interconnection Customer, particularly one
interconnecting at a lower voltage, would rarely find this service to
be efficient or practical. Nevertheless, we do not want to preclude it
from choosing this option. If it wishes to interconnect its Small
Generating Facility using Network Resource Interconnection Service, it
may do so. However, it must request interconnection under the LGIP and
execute the LGIA.
141. In response to SoCal Edison's request for clarification, we
note that the SGIP lets the Transmission Provider study the potential
impacts of the proposed interconnection on the Distribution System.
Also, we clarify that nothing in this Final Rule (which concerns
interconnection service only) prevents the Transmission Provider from
evaluating the Interconnection Request and requests for wholesale
distribution service and transmission delivery service simultaneously.
However, the Transmission Provider may not require the Interconnection
Customer to request wholesale distribution service or transmission
delivery service as a condition for granting a request for
interconnection service. We expect the Transmission Provider to explain
to the Interconnection Customer what delivery services may be needed to
meet its needs.
142. Ministerial Changes to the Interconnection Request--The
Proposed Interconnection Request was crafted largely by Joint
Commenters in response to the ANOPR. It is similar in many respects to
the NARUC Model. Joint Commenters in its supplemental comments
submitted ministerial changes to the Proposed Interconnection Request.
Other commenters \61\ also seek changes to the Interconnection Request,
most reflecting misplaced or missing technical information. The
Interconnection Request we adopt in this Final Rule largely tracks the
NARUC Model version and also reflects many of the changes proposed by
the commenters.
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\61\ E.g., Bureau of Reclamation, Central Maine, Cummins, EEI,
Joint Commenters, Northwestern Energy, NYTO, PacifiCorp, PG&E, and
Small Generator Coalition.
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E. Issues Related to the SGIP
143. Using Voltage Level to Determine Which Procedures Apply--The
Proposed SGIP divided Interconnection Requests into two groups for
initial processing based on the voltage level of the interconnection.
Interconnections to High-Voltage (at or above 69 kV) would be evaluated
using the interconnection studies. Interconnection to Low-Voltage
(below 69 kV) would be processed differently depending upon the size
and the certification status of the Small Generating Facility as
explained below. An Interconnection Request for a certified Small
Generating Facility no larger than 2 MW interconnecting at Low-Voltage
would be evaluated using super-expedited screening criteria; an
Interconnection Request for a Small Generating Facility no larger than
10 MW interconnecting at Low-Voltage would be evaluated using expedited
screening criteria; and an Interconnection Request for a Small
Generating Facility larger than 10 MW but no larger than 20 MW
interconnecting at Low-Voltage would be evaluated using the
interconnection studies. If an Interconnection Request did not pass the
super-expedited screening criteria or expedited screening criteria, it
would be evaluated using interconnection studies.
Comments
144. Several commenters \62\ object to using voltage level to
distinguish which review process initially applies to an
Interconnection Request. They argue that the distinction should be
based on whether the Small Generating Facility is being interconnected
with distribution or transmission facilities. The decision should be
consistent with the physical facilities and operational realities of
the electric system. They also contend that electric system
configurations vary widely in terms of voltage levels and that the
effect of an interconnection is not necessarily determined by voltage,
but also by location and size of the Small Generating Facility. In
addition, they state that this distinction was not a part of the ANOPR
proposal and that using voltage to distinguish which set of procedures
applies is confusing.
---------------------------------------------------------------------------
\62\ E.g., CA ISO, EEI, Idaho Power, PG&E, PSE&G, SoCal Edison,
and Southern Company.
---------------------------------------------------------------------------
145. In its supplemental comments, Joint Commenters propose using
whether the proposed interconnection is with a transmission line (i.e.,
interconnections with transmission lines may not be evaluated using the
technical screens) to determine whether screens may be used to evaluate
the proposed interconnection.
Commission Conclusion
146. For the reasons given above, we agree with commenters that
interconnection voltage should not be used as a determinative factor
for whether the Interconnection Request may be evaluated using the
technical screens. Instead, we are adopting the technical screens
proposed by Joint Commenters in its supplemental comments. The SGIP
specifies that an Interconnection Request for a certified Small
Generating Facility no larger than 2 MW shall be evaluated using the
technical screens, either under the Fast Track Process or the 10 kW
Inverter Process, whichever applies. Under the first provision of the
screens, SGIP section 2.2.1.1, the proposed Small Generating Facility's
Point of Interconnection must be on a portion of the Transmission
Provider's Distribution System that is subject to the Tariff.\63\
---------------------------------------------------------------------------
\63\ As noted above, ``transmission'' is both an engineering
term of art and a term used in the FPA. As used in the technical
screens, ``transmission'' is used in the engineering sense, not in a
jurisdictional sense. Likewise, references in other technical
screens to ``radial distribution circuits,'' ``3-phase primary
distribution lines,'' and other uses of the word distribution are
used in an engineering sense, not in a jurisdictional sense. In no
case do we intend that this Final Rule applies to non-Commission-
jurisdictional facilities.
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147. Certification of the Small Generating Facility (Proposed SGIP
Section 3.1)--In the Small Generator Interconnection NOPR, the
Commission proposed that Interconnection Requests for certified
generators no larger than 2
[[Page 34205]]
MW would be reviewed using the super-expedited screening criteria that
employed technical screens. The Commission also noted that Joint
Commenters (in its response to the ANOPR) preferred that the Commission
itself implement a single, uniform, nationwide process for the
certification of Small Generating Facility equipment packages no larger
than 2 MW.\64\ The Commission proposed, however, that this function
instead be performed by an industry-recognized testing organization. In
addition, the Commission requested comments as to whether IEEE 1547
(Standard for Interconnecting Distributed Resources with Electric Power
Systems), together with other technical industry documents, could be
the basis for a national certification standard.
---------------------------------------------------------------------------
\64\ A ``certified'' Small Generating Facility is one that has
been certified by a nationally recognized laboratory before the
Interconnection Request is submitted to the Transmission Provider.
Such a facility is said to be ``certified'' for purposes of the
interconnection process.
---------------------------------------------------------------------------
Comments
148. Commenters generally agree with the value of having a
certification process for Small Generating Facilities. They believe
that such a process can speed interconnection and eliminate the need to
``reinvent the wheel'' each time an interconnection is made. In
general, commenters agree that IEEE 1547, in conjunction with other
standards, could be the basis for a certification standard.
149. NYTO requests that the Commission adopt the process and
registry proposal described in the November 12, 2002 Joint Commenters
filing. That would have the Commission maintain a list of certified
equipment and to centralize the registry function. It claims that this
would provide certainty to the industry as to which equipment has been
certified and would avoid the development of competing and potentially
inconsistent lists of certified equipment, which could lead to disputes
and slow down the interconnection process.
150. The NARUC Model certification provision relies on Nationally
Recognized Testing Laboratories (NRTL) to test and certify the safety
of electrical equipment used for the production of electricity. That
provision, which was developed for use by state regulators, requires
that the NRTL be used by the state regulatory authority or approved by
the U.S. Department of Energy.
151. American Forest and others state that if the Commission
chooses not to certify and maintain a registry of equipment, it should
establish and oversee a stakeholder process for the development of
certification criteria. Without the Commission's involvement, the
process of establishing certification standards will languish.
152. Cummins and others, however, argue that a nationally
recognized testing laboratory and agencies like the Department of
Energy should oversee the certification process. They also note that a
national testing laboratory, such as Underwriter Laboratories,
typically not only tests and verifies the performance of prototype
equipment, but also provides follow-up services to verify that
production equipment is designed and manufactured to the same standards
as the tested equipment.
153. Ameren and others complain that the NOPR does not explain what
industry operational and safety standards are applicable. Likewise, the
NOPR does not specify what is needed to qualify as a national testing
laboratory. They claim that leaving these issues open could lead to
unnecessary or improper testing. They recommend that the Commission (1)
adopt a specific set of standards for operation and safety requirements
that are continually updated to meet current safety and reliability
requirements set forth by NERC or the regional reliability councils,
and (2) maintain a list of qualified national testing laboratories.
154. Allegheny Energy argues that certification guarantees the
safety and reliability of the equipment in a stand-alone mode only, but
not safety and reliability when the equipment becomes part of an
integrated system.
155. Joint Commenters, in its supplemental comments, proposes a
consensus equipment certification provision that it states was
developed under a stakeholder process convened by the U.S. Department
of Energy's Office of Electric Transmission and Distribution. The
participants in the process included Joint Commenter members
representing small generator interests, state regulators, and
Transmission Providers, as well as experts from the electrical
equipment manufacturing industry and testing laboratories. Joint
Commenters' proposed certification provision provides that Small
Generating Facility equipment shall be considered certified if (1) it
has been tested in accordance with industry standards for continuous
utility interactive operation in compliance with the appropriate codes
and standards by any NRTL recognized by the United States Occupational
Safety and Health Administration to test and certify interconnection
equipment pursuant to the relevant codes and standards, (2) it has been
labeled and is publicly listed by such NRTL at the time the
Interconnection Request is made, and (3) such NRTL makes readily
available for verification all test standards and procedures it
utilized in performing such equipment certification and, with consumer
approval, the test data itself.
Commission Conclusion
156. We agree with Cummins that nationally recognized laboratories
should oversee the certification process and maintain registries of
certified equipment. A NRTL not only tests and verifies the performance
of prototypes, but it provides follow-up services to verify that
production equipment is designed and manufactured to the same standards
as the tested equipment. In this Final Rule, we are adopting Joint
Commenters' proposal. This certification provision was vetted by a
diverse group of stakeholders and is fundamentally consistent with the
Proposed SGIP as well as the provision contained in the NARUC Model. We
are especially encouraged by the report from Joint Commenters that one
well-known NRTL intends to begin the certification of equipment as soon
as the summer of 2005. This should hasten the development of certified
Small Generating Facilities no larger than 2 MW under the Fast Track
and 10 kW Inverter Processes. The certification provision we adopt in
this Final Rule is contained in Attachments 3 and 4 of the SGIP.
157. Finally, we acknowledge Allegheny Energy's concerns. Electric
system safety and reliability issues are to be addressed when the
proposed interconnection of the certified equipment is evaluated under
the Fast Track Process or the 10 kW Inverter Process.
158. Super-Expedited Procedures (Proposed SGIP Section 3) and
Expedited Procedures (Proposed SGIP Section 4.3)\65\--In the NOPR,
proposed SGIP section 3 stated that if the proposed Small Generating
Facility is certified, no larger than 2 MW, and the interconnection is
with Low-Voltage facilities, the interconnection would be evaluated
using super-expedited screens. Proposed SGIP section 4.3 stated that if
the proposed Small Generating Facility is no larger than 10 MW and the
interconnection is with Low-Voltage facilities, the
[[Page 34206]]
interconnection would be evaluated using expedited screens. Proposed
SGIP section 4.3 also provided that the expedited screens would be used
to evaluate proposed interconnections that failed the super-expedited
screens.
---------------------------------------------------------------------------
\65\ In the Small Generator Interconnection NOPR, the term
Super-Expedited Procedure referred to the process that used the
super-expedited screens and Expedited Procedure referred to the
process that used the expedited screens. In this Final Rule, we are
adopting only one set of screens, which are used in both the Fast
Track Process and the 10 kW Inverter Process.
---------------------------------------------------------------------------
159. The NOPR proposed that if the Transmission Provider determines
that the proposed interconnection fails the super-expedited screens and
is not satisfied that the Small Generating Facility can be
interconnected safely and reliably, the Interconnection Customer can
pay for an additional review. The review would not exceed six hours and
would determine whether minor modifications to the Transmission
Provider's electric system (e.g., changing meters, fuses, relay
settings) could enable the interconnection to be made safely and
reliably. If the results of the review were positive and the
Interconnection Customer agreed to pay for these minor modifications,
the Transmission Provider would tender an executable SGIA to the
Interconnection Customer.
Comments
160. Joint Commenters, Small Generator Coalition, and NARUC
recommend that the Commission require the use of screens to evaluate
Interconnection Requests. NARUC and Small Generator Coalition initially
proposed using two sets of screens. However, Joint Commenters (which
includes both NARUC and Small Generator Coalition) now recommends
adopting a single set of screens that serves the same purpose as the
two initially proposed.
161. Several commenters \66\ asked that the screens be clarified,
modified, or eliminated. EEI recommended that the screens be available
only for interconnection with radial facilities.
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\66\ E.g., ameren, BPA, Bureau of Reclamation, Central Maine,
Cinergy, EEI, Exelon, MISO, NRECA, NYPSC, NYTO, PR&E, PJM, and
Southern Company.
---------------------------------------------------------------------------
162. Cinergy, EEI, Idaho Power, NYTO, and others maintain that even
if the Small Generating Facility is certified and passes the screens,
there is no assurance that safety and reliability or the quality of
service is not degraded as a result of the interconnection. Cinergy and
EEI argue the rule should require a showing that the interconnection
does not degrade safety and reliability.
163. BPA and Central Maine oppose limiting the additional review to
six hours, arguing that each interconnection is unique.
164. PJM argues that the Final Rule should not allow screens to be
used in lieu of the feasibility study. It claims that while screens
allow a project to be expedited, they do not necessarily provide the
type of information needed by the Interconnection Customer to determine
whether the project is viable (e.g., information concerning the
estimated cost of interconnection or the effects on other projects).
165. BPA claims that it is unreasonable to hold the Transmission
Provider to stringent deadlines without establishing corresponding
deadlines for the Interconnection Customer. MISO and BPA contend that
the timelines do not give the Transmission Provider sufficient time to
review the Interconnection Request. MISO proposes that the Transmission
Provider be permitted to notify the Interconnection Customer if it is
unable to meet the target date, along with the reasons for delay.
166. NRECA and others ask the Commission to reduce the maximum size
of a facility that may be evaluated under the screens to as small as 3
kW. In its supplemental comments, Small Generator Coalition argues
against imposing any size limits.
167. Southern Company argues that certain base case assumptions are
necessary for an accurate representation of the electric system when an
Interconnection Request is evaluated under screens. It would like the
evaluation to include all pending higher-queued Interconnection
Requests because only then could the effect of an Interconnection
Request be truly determined.
Commission Conclusion
168. In SGIP section 2.2.1, we are adopting a single set of screens
submitted by Joint Commenters in its supplemental comments, with minor
editorial changes. These are the screens that would be applied in the
Fast Track and the 10 kW Inverter Processes. We are adopting only one
set of screens rather than the two in the NARUC Model and the Small
Generator Interconnection NOPR. The individual screening criteria in
this set are very similar to those in the NARUC Model and closely track
both those contained in the Small Generator Interconnection NOPR and
those proposed by Joint Commenters in the ANOPR process.
169. The NOPR did not contain a screen that would permit
interconnection with a secondary network \67\ and Joint Commenters were
unable to agree on one. We are also not adopting any additional screen
that would permit interconnection with a secondary network in this
Final Rule.
---------------------------------------------------------------------------
\67\ A secondary network is a type of distribution system that
is generally used in large metropolitan areas that are densely
populated in order to provide high reliability of service to
multiple customers. (Source: Standard Handbook for Electrical
Engineers, 11th edition, Donald Fink, McGraw Hill Book Company).
---------------------------------------------------------------------------
170. We are deleting ``and must comply with all requirements of
approved industry standards for interconnection technical
specifications and requirements'' from one of Joint Commenters'
proposed screens because this language is redundant; a Small Generating
Facility that is being evaluated under the Fast Track Process or 10 kW
Inverter Process must meet the codes, standards, and certification
requirements of Attachments 3 and 4 of the SGIP.
171. Concerns raised by commenters that screens do not accurately
reflect the true effect of the interconnection on safety and
reliability are unfounded. We believe the thresholds used in the
screens to be conservative and that there is negligible chance that a
proposed interconnection could pass the screens and actually impact the
safety and reliability of the Transmission Provider's electric system.
These thresholds have been vetted by Transmission Providers, small
generator developers, and representatives of state regulators alike.
172. We reject Small Generator Coalition's argument that there
should be no size restrictions for Small Generating Facilities whose
interconnections may be evaluated using the screens. We are retaining
the proposed 2 MW threshold for certified generators as a critical
eligibility criterion for using the screens. It helps ensure the safety
and reliability of the Transmission Provider's electric system. Small
Generator Coalition, together with a number of Transmission Providers
and representatives of state regulatory agencies, vetted the threshold
when submitting the package of screens through Joint Commenters'
supplemental comments.
173. In response to objections to the NOPR's expedited screening
procedures, the Final Rule SGIP does not include any screens for Small
Generating Facilities larger than 2 MW. Accordingly, only a request to
interconnect a certified Small Generating Facility no larger than 2 MW
shall be evaluated using the screens. A request to interconnect a Small
Generating Facility larger than 2 MW or a Small Generating Facility of
any size that is not certified shall be evaluated using the Study
Process.
174. BPA and others oppose limiting the additional review to six
hours. We
[[Page 34207]]
are eliminating this restriction.\68\ The SGIP includes a customer
options meeting where the Transmission Provider may propose
modifications to the proposed interconnection or the Small Generating
Facility itself, or perform a supplemental review if the
Interconnection Customer agrees to pay for it. This allows the
Transmission Provider to determine the modifications needed to
accommodate the interconnection without the need for detailed and more
costly interconnection studies.
---------------------------------------------------------------------------
\68\ In the Proposed SGIP, the Commission termed this
``additional review.'' In the SGIP, we adopt the NARUC Model's term
``supplemental review.''
---------------------------------------------------------------------------
175. Southern Company and Joint Commenters (in its supplemental
comments) argue that the Transmission Provider should be allowed to
consider the effects of all pending higher-queued Interconnection
Requests when evaluating the Interconnection Request under the screens.
We agree.
176. Queuing Priority (Proposed SGIP Section 4.4)--In the NOPR, the
Commission proposed that each Transmission Provider maintain a single
queue per geographic area. A queue lists Interconnection Requests in
the order in which they are received. The Queue Position determines the
order of performing interconnection studies, if required, and the
Interconnection Customer's cost responsibility for any Upgrades to the
Transmission Provider's electric system. In Order No. 2003, the
Commission decided that the Transmission Provider should maintain a
single integrated queue per geographic region. However, RTOs and ISOs
have flexibility to propose queues and queuing rules designed to meet
their regional needs.\69\ We are adopting the same provision here, for
the same reasons. Accordingly, there is no need to separately address
again the same comments raised in this proceeding on that issue.
---------------------------------------------------------------------------
\69\ Order No. 2003 at P 147.
---------------------------------------------------------------------------
Comments
177. Small Generator Coalition requests that the Commission
establish separate queues for Large and Small Generating Facilities.
Failing that, the Commission should clarify that the interconnection
study periods identified in the SGIP are binding without regard to the
Queue Position of other generating facilities. Alternatively, Small
Generating Facilities should be clustered for study purposes within a
given time frame (e.g., 90 days). It states that requiring a single
queue for all generating facilities undercuts whatever progress has
been made in interconnecting Small Generator Facilities. Small
Generator Coalition, Solar Turbines, and others state that, in light of
their relatively simple interconnection requirements, use of off-the-
shelf equipment, and minimal effects on the Transmission Provider's
electric system, Small Generating Facilities should be able to be
interconnected quickly. They complain that the interconnection can be
delayed by higher-queued Large Generating Facilities that require
longer, more frequent, and more expensive interconnection studies and
restudies.
Commission Conclusion
178. We disagree with Small Generator Coalition that a single queue
is unfavorable to Small Generating Facilities. Although Queue Position
determines the order of the interconnection studies and the cost
responsibility for the Network Upgrades necessary to accommodate the
interconnection, it does not determine the order in which the
interconnections are completed.
179. For many Transmission Providers, the requirement to maintain
two queues could actually delay, rather than speed up, the
interconnection process. Thus, we are requiring a Transmission Provider
to use a single queue for all Generating Facilities, regardless of
size. Also, the SGIP allows Small Generating Facilities to be
interconnected without going through the Study Process if they pass the
screens. However, under the independent entity variation available to
RTOs and ISOs under this Final Rule, such entities may propose multiple
queues in their compliance filings.\70\
---------------------------------------------------------------------------
\70\ See Order No. 2003 at P 185.
---------------------------------------------------------------------------
180. Small Generator Coalition is correct that a non-clustering
Transmission Provider must meet all deadlines established in the SGIP
without regard to queue position or queue-related delays.
181. We reiterate that clustering is the Commission's preferred
method for conducting interconnection studies, and should be seriously
considered by all Transmission Providers.\71\ Clustering of studies
allows the Transmission Provider to study multiple Interconnection
Requests simultaneously, thereby maximizing the effectiveness of its
staff. Clustering may also reduce interconnection study and Upgrade
costs; for example, multiple Interconnection Customers can share the
cost of Upgrades.
---------------------------------------------------------------------------
\71\ Id. at P 155.
---------------------------------------------------------------------------
182. Scoping Meeting (Proposed SGIP Section 4.5)--Proposed SGIP
section 4.5 would require the Parties to hold a scoping meeting within
ten Business Days after the Interconnection Request is deemed complete
by the Transmission Provider. The purpose of the meeting is to review
the characteristics of the Transmission Provider's electric system,
discuss the technical aspects of the proposed interconnection, and
review existing studies and the results of the application of the
technical screens, if applicable. If the Parties agree that a
feasibility study is needed, the Transmission Provider would provide
the Interconnection Customer with a feasibility study agreement.
Comments
183. Central Maine asks that the Transmission Owner also be
included in the scoping meeting. Small Generator Coalition asks that
the provision be revised to allow the Parties to conduct the scoping
meeting by telephone.
Commission Conclusion
184. In the SGIP, Transmission Provider is defined to include both
the Transmission Provider and Transmission Owner, when they are
separate entities. Accordingly, the Transmission Owner may attend the
scoping meeting. Also, there was nothing in the Proposed SGIP that
mandates that the scoping meeting be held face-to-face. We encourage
the Parties to conduct the interconnection process in the most
expeditious manner possible and to take advantage of telephone, fax,
and e-mail. Finally, as in Order No. 2003-A, we are requiring that any
scoping meeting between the Transmission Provider and an affiliate be
announced publicly and transcribed, with the transcripts made available
upon request for a period of three years.\72\ While the Transmission
Provider may redact portions of the transcripts deemed to be
commercially sensitive or containing Critical Energy Infrastructure
Information, the Commission will decide which redacted portions are to
be made public.
---------------------------------------------------------------------------
\72\ Order No. 2003-A at P 101-107.
---------------------------------------------------------------------------
185. Interconnection Studies (Proposed SGIP Sections 4.6, 4.7, and
4.8)--Proposed SGIP sections 4.6, 4.7, and 4.8 and the associated study
agreements described the feasibility, system impact, and facilities
studies (collectively, interconnection studies) and the Interconnection
Customer's cost responsibility for each study. For a Small Generating
Facility larger than 2 MW but no larger than 10 MW interconnecting at
Low-Voltage, the Proposed SGIP would first evaluate the
[[Page 34208]]
proposed interconnection using expedited screens. However, if the
Transmission Provider believed that the interconnection would undermine
safety and reliability even though the proposed interconnection passed
the screens, the Transmission Provider would pay for the feasibility
study if that study subsequently identified no adverse system impact.
The cost of the system impact and facilities studies, however, would
always be paid by the Interconnection Customer.
Comments--Study Cost Obligations
186. Central Maine, Exelon, and PacifiCorp argue that the
Interconnection Customer should always pay for interconnection studies,
regardless of the conclusions reached. Small Generator Coalition
maintains that the Transmission Provider should pay for the feasibility
study only if it shows no adverse impact.
Commission Conclusion
187. The Interconnection Customer should pay for all of the
interconnection studies, regardless of the conclusions reached, because
it is unreasonable to shift this cost to other transmission customers
that do not benefit from the studies, which is what would occur if the
Transmission Provider were to pay for them. The Transmission Provider
should, of course, use existing studies instead of performing
additional analyses to reduce costs for the Interconnection Customer,
whenever possible. The Interconnection Customer is not to be charged
for such existing studies; however, it is responsible for costs
associated with any new study and any modification to an existing study
that is reasonably necessary to evaluate the proposed interconnection.
Comments--Study Requirements
188. PJM and Southern Company argue that a system impact study
should always be performed to detect adverse impacts that may not have
been detected in the feasibility study. Small Generator Coalition
argues that in many situations only a feasibility study or a system
impact study is needed, but not both; Parties should be able to agree
to skip the feasibility study. PacifiCorp states that, for a small
project, the feasibility study is not much different from the system
impact study and recommends that the former be eliminated. SoCal Edison
argues that the provisions of the SGIP dealing with interconnection
studies should refer to the distribution provider, if applicable, and
the Transmission Provider. Bureau of Reclamation asks the Commission to
clarify that the Transmission Provider should perform flicker and
voltage drop studies.
Commission Conclusion
189. We agree that, on occasion, there may be some overlap between
the feasibility study and the system impact study. For a small project,
the distinction may not be enough to require that both studies be
performed. In such cases, it may be reasonable to skip the feasibility
study entirely. Therefore, as the Commission did for Large Generating
Facilities in Order No. 2003-A, we are allowing the Parties to skip the
feasibility study upon mutual agreement. As to SoCal Edison's comment,
we do not see any need to include the term ``distribution provider''
when referring to SGIP provisions. Transmission Provider is already
defined as ``[t]he public utility (or its designated agent) that owns,
controls, or operates transmission or distribution facilities used for
the transmission of electricity in interstate commerce and provides
transmission service under the Tariff.'' As to Bureau of Reclamation's
request for clarification, voltage drop, voltage limit violation, and
grounding studies are indeed included in the study process.
Comments--Study Deadlines and Restudy
190. Southern Company, PG&E, and others contend that the proposed
interconnection study deadlines are too short. NARUC proposes giving
the Transmission Provider 30 Business Days to complete the feasibility
study, 30 Business Days to complete the distribution system impact
study, 45 Business Days to complete the transmission system impact
study, 30 Business Days to complete the facilities study when no
Upgrades are required, and 45 Business Days to complete the facilities
study when Upgrades are required.
191. PacifiCorp states that a restudy provision should be included
in the SGIP so that the Interconnection Request could be restudied if a
higher-queued Interconnection Customer drops out. It argues that the
LGIP included a restudy provision for each of the three studies.
Commission Conclusion
192. We are adopting the deadlines proposed by NARUC and
incorporating them in the interconnection study agreements. They strike
a good balance, allowing sufficient time to complete the studies while
ensuring that Small Generating Facilities can be interconnected within
a reasonable time. Also, as noted above, with the exception of payment
provisions, we are replacing ``calendar days'' with ``Business Days''
in the SGIP and SGIA. However, where appropriate, we are revising the
number of days to correspond to the actual passage of time.
193. We disagree that a restudy provision is needed in the SGIP.
The very purpose of the Small Generator Final Rule is to expedite
interconnections of Small Generating Facilities by removing unnecessary
delays. While a restudy provision in the LGIP context is meaningful
because system conditions may change between completion of a particular
study and the Parties' signing the LGIA, it is unlikely that any
significant change in system conditions will occur that was not
foreseen by the Transmission Provider at the time of study because the
SGIP has a much shorter timeline.
Comments--Post-Operational Evaluation of the Interconnection
194. PacifiCorp argues that, after the Small Generating Facility is
operational, an interconnection may cause problems that were unforeseen
when the project was initially evaluated. For example, wind generators
may need to fine tune their reactive power output. Also, because the
certification and screening processes are new, the Transmission
Provider should be permitted to perform post-interconnection reviews
and adjustments, including additional Upgrades, if necessary, to be
paid for by the Interconnection Customer.
Commission Conclusion
195. The purpose of the evaluation processes in the SGIP is to
determine the effect the interconnection will have on the Transmission
Provider's electric system. Such evaluations are also performed to
ascertain the Interconnection Customer's cost responsibility for
Interconnection Facilities and Upgrades. We reject PacifiCorp's
proposal because accepting it would make determination of cost
responsibility open-ended and create uncertainty for the
Interconnection Customer. Should unforeseen problems arise, the Parties
may make a filing with the Commission and request expedited
consideration.
196. Execution of the SGIA--Although the Proposed SGIP required the
Transmission Provider to deliver an executable SGIA to the
Interconnection Customer within a time certain, the Interconnection
Customer had no deadline to sign and return the document to the
Transmission Provider.
[[Page 34209]]
Comment
197. In its supplemental comments, Joint Commenters propose that
the Interconnection Customer have 30 Business Days to sign and return
the SGIA.
Commission Conclusion
198. We adopt Joint Commenters' proposal. The Transmission Provider
needs to know whether the proposed project will go forward. Giving the
Interconnection Customer a deadline within which to act gives the
Transmission Provider the certainty it needs for system planning
purposes. The SGIP states that, after receiving an interconnection
agreement from the Transmission Provider, the Interconnection Customer
shall have 30 Business Days or another mutually agreeable timeframe to
sign and return the SGIA, or request that the Transmission Provider
file an unexecuted SGIA with the Commission. If that is not done, the
Interconnection Request shall be deemed withdrawn.
F. Issues Related to the SGIA
199. Responsibilities of the Parties (Proposed SGIA Article 2.2)--
Article 2.2 of the Proposed SGIA set out each Party's responsibilities
under the SGIA. It included the obligation of the Interconnection
Customer to interconnect, operate, and construct its facilities in a
safe manner and to follow Good Utility Practice. It would similarly
require the Transmission Provider to operate its electric system in a
safe and reliable manner.
Comments
200. BPA asserts that Proposed SGIA article 2.2 should require the
Interconnection Customer to abide by national and regional reliability
rules, such as those developed by NERC and the Western Electricity
Coordinating Council, that are generally applicable to all generators
in a control area or geographic region. Furthermore, according to BPA,
the interconnection agreement should require the Interconnection
Customer to abide by any technical requirements established by the
Transmission Provider to govern the safe interconnection of generating
facilities.
201. NARUC offers alternative language laying out the
responsibilities of the Parties, consistent with its Model.
Specifically, NARUC proposes replacing article 2.2 with the following:
Each Party will, at its own cost and expense, operate, maintain,
repair, and inspect, and shall be fully responsible for the facility
or facilities which it now or hereafter may own or lease unless
otherwise specified in Exhibit A. Maintenance of Interconnection
Customer's Small Resource and interconnection facilities shall be
performed in accordance with the applicable manufacturer's
recommended maintenance schedule.
The Parties agree to cause their facilities or systems to be
constructed in accordance with specifications provided by the
National Electrical Safety Code, the National Electric Code, and as
approved by the American National Standards Institute, and
interconnected in accordance with the Institute of Electrical and
Electronics Engineers standards where applicable.
Interconnection Provider and Interconnection Customer shall each
be responsible for the safe installation, maintenance, repair and
condition of their respective lines and appurtenances on their
respective sides of the Point Of Common Coupling. The
Interconnection Provider or the Interconnection Customer, as
appropriate, shall provide interconnection facilities that
adequately protect the Interconnection Provider's distribution
system, personnel, and other persons from damage and injury. The
allocation of responsibility for the design, installation,
operation, maintenance and ownership of the Interconnection
Facilities shall be made part of this agreement as Exhibit C.
202. Avista states that ``the Interconnection Customer should be
required not only to construct its generating facility in accordance
with operating requirements to be set forth in Appendix 4 to the
Proposed SGIA, but also to maintain and operate its [Small Generating
Facility] in accordance with such operating requirements.'' \73\
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\73\ Avista at 14.
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203. Nevada Power asserts that the IEEE 1547 standards referred to
in Proposed SGIA article 2.2.4 were never designed to be applied to
generating facilities larger than 10 MW and that in fact ``there is no
extant national standard that can be reasonably applied to govern the
Interconnection Facilities for Generating Facilities greater than ten
megawatts.'' \74\ Instead, Nevada Power proposes that until a national
standard is developed to address this 10-20 megawatt gap, the
Commission modify article 2.2.4 to read:
---------------------------------------------------------------------------
\74\ Nevada Power at 15.
Interconnection Customer agrees to cause its facilities or
systems to be constructed in accordance with applicable
specifications that meet or exceed those provided by the National
Electrical Safety Code, the American National Standards Institute,
IEEE, Underwriter's Laboratory, Operating Requirements, and, where
the Generating Facility will have a capacity greater than ten
megawatts, the Transmission Provider's applicable Interconnection
Facility standards in effect at the time of construction * *
---------------------------------------------------------------------------
*.[\75\]
\75\ Id. (Emphasis added to show the new language proposed by
Nevada Power.)
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204. PacifiCorp notes that the Proposed SGIA assumes that the
Interconnection Customer and the Transmission Provider are each
responsible for the maintenance of equipment on its side of the point
of change of ownership. But as a practical matter, more flexibility is
needed because non-utility companies cannot usually maintain certain
equipment, such as communications equipment, that is critical to the
protection of the Transmission Provider's electric system. Moreover,
the Transmission Provider often owns and maintains revenue meters on
the customer's side of the point of change of ownership. Therefore,
argues PacifiCorp, the SGIA should clarify that unless provided
otherwise in an attachment, each Party is responsible for the equipment
on its side of the point of change of ownership.
205. Small Generator Coalition requests that the Commission
restrict the ability of the Transmission Provider to impose additional
technical requirements on the Small Generating Facility. Otherwise, it
fears that Interconnection Customers will be subjected to additional
requirements under the guise of reliability rules that make it
difficult to interconnect in a cost-effective manner. On the other
hand, Southern Company contends that the standards for operating in
parallel should be codified in the SGIA. This way, the Transmission
Provider can then confirm that all the requirements are met before
granting the authorization to operate.
206. In its supplemental comments, Joint Commenters recommends
several changes to Proposed SGIA article 2.2. Specifically, Joint
Commenters recommend clarifying that the Transmission Provider must
coordinate with an Affected System operator to complete the
interconnection, but need not negotiate on behalf of the
Interconnection Customer. Joint Commenters also propose changing the
last sentence of proposed article 2.2.4 to read:
Interconnection Customer agrees to design, install, maintain,
and operate, or cause the design, installation, maintenance, and
operation of the Generating Facility and Interconnection Customer
Interconnection Facility so as to reasonably minimize the likelihood
of a disturbance, originating on such equipment affecting or
impairing the system or equipment of Transmission Provider, or
Affected Systems.\76\
\76\ Emphasis added to show the language proposed by the Joint
Commenters.
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[[Page 34210]]
Commission Conclusion
207. We are adopting a version of this provision that is based on
the NARUC Model and Joint Commenters' proposals. Redrafting article 2.2
as requested by commenters clarifies the rights and responsibilities of
the Parties and aids them in better understanding their roles in the
interconnection process.
208. Several commenters also ask the Commission to clarify the
right of the Transmission Provider to include supplemental
``Interconnection Guidelines,'' either in the SGIA or as an attachment
to it. As the Commission stated in Order No. 2003-A, the Transmission
Provider may include supplemental interconnection requirements if (1)
they are authorized by the applicable reliability council and (2) the
Transmission Provider imposes such requirements on itself and all other
Interconnection Customers, including its affiliates.\77\ We see no
reason to depart from this standard. The Commission has consistently
held that an Interconnection Customer must adhere to established
reliability practices within the control area with which it is
interconnecting.\78\ The same would be true for including supplemental
guidelines for generators larger than 10 MW, as requested by Nevada
Power.
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\77\ Order No. 2003-A at P 399.
\78\ See, e.g., Order No. 2003-A at P 44, Order No. 2003 at P
823, and Order No. 888 at 31,770.
---------------------------------------------------------------------------
209. In response to Nevada Power's comments about the applicability
of the IEEE 1547 standard to generating facilities no larger than 10
MW, we note that the SGIA states that this standard is required only
``where applicable.''
210. The SGIA also addresses PacifiCorp's concerns over using the
point of change of ownership as the basis for establishing the Parties'
respective roles and allows the Parties to specify their respective
roles in SGIA Attachment 2.
211. Metering (Proposed SGIA Article 2.4)--Proposed SGIA article
2.4 would specify that the Interconnection Customer is responsible for
the Transmission Provider's reasonable cost for the purchase,
installation, operation, maintenance, testing, repair, and replacement
of any metering and data acquisition equipment. It also would require
that the Interconnection Customer's metering equipment conform to
applicable industry rules and operating requirements.
Comment
212. CA ISO argues that Proposed SGIA article 2.4 should require
any Small Generating Facility larger than 1 MW to provide real-time
telemetry to the Transmission Provider to better maintain reliability
and meet regional requirements.
Commission Conclusion
213. We are not requiring Small Generating Facilities to provide
real-time telemetry because doing so may hamper their development and
we are not convinced that it is necessary in every instance. However,
if regional reliability requirements dictate real-time telemetry for
Small Generating Facilities, we expect the Interconnection Customer to
meet such requirements.
214. Equipment Testing and Inspection (Proposed SGIA Article 3.1)--
Proposed SGIA article 3.1 described the pre-operational testing and
inspection requirements for the Small Generating Facility.
Comments
215. Central Maine argues that the Interconnection Customer should
periodically test the Small Generating Facility and Interconnection
Facilities after they achieve commercial operation and that the
Transmission Provider should be allowed to witness such testing. The
purpose of such testing is to ensure that the Interconnection
Customer's equipment is operating properly. Southern Company argues
that the Interconnection Customer should pay the Transmission
Provider's expenses for such pre-operational testing.
Commission Conclusion
216. We decline to expand the provisions of this article to require
generically that every Interconnection Customer perform periodic
testing of its Small Generating Facility, regardless of circumstances.
To so do would be burdensome on the Interconnection Customer, costly,
and potentially allow a self-interested Transmission Provider to impose
multiple rounds of costly testing on competing generators. However,
should the Transmission Provider believe in good faith that the Small
Generating Facility or the Interconnection Facilities is affecting
safety and reliability, the Transmission Provider may, upon advance
written notice, require the Interconnection Customer to perform
reasonable additional post-operational testing. The Transmission
Provider may witness such testing. The Transmission Provider and the
Interconnection Customer shall be responsible for their own staff,
equipment, and other costs associated with the testing and inspection.
217. Right of Access (Proposed SGIA Article 3.3)--The Proposed SGIA
would give the Transmission Provider access to land owned or controlled
by the Interconnection Customer to construct Interconnection Facilities
or for other specified purposes.
Comment
218. NARUC urges the Commission to adopt the following right of
access provision from its Model:
Upon reasonable notice, the Interconnection Provider may send a
qualified person to the premises of the Interconnection Customer at
or immediately before the time the Small Resource first produces
energy to inspect the interconnection, and observe the commissioning
of the Small Resource (including any required testing), startup, and
operation for a period of up to no more than three days after
initial start-up of the unit. In addition, the Interconnection
Customer shall notify the Interconnection Provider at least seven
days before conducting any on-site Verification Testing of the Small
Resource. Following the initial inspection process described above,
at reasonable hours, and upon reasonable notice, or at any time
without notice in the event of an emergency or hazardous condition,
Interconnection Provider shall have access to Interconnection
Customer's premises for any reasonable purpose in connection with
the performance of the obligations imposed on it by this Agreement
or if necessary to meet its legal obligation to provide service to
its [customers].
Commission Conclusion
219. We largely adopt NARUC's proposal. It uses the concepts found
in the Small Generator Interconnection NOPR, but shortens and
simplifies the provisions. However, we are adding that each Party is
responsible for its own staff, equipment, and other costs in carrying
out this provision.
220. Term of Agreement (Proposed SGIA Article 4.2)--Proposed SGIA
article 4.2 would require that the interconnection agreement remain in
effect for ten years, or longer by request, and that it can be
automatically renewed for each successive one year period thereafter.
Comments
221. BPA argues that the interconnection agreement should remain in
effect as long as the Small Generating Facility remains interconnected,
subject to the termination provision of the SGIA or as agreed to by the
Parties. The article unnecessarily requires the Parties to negotiate a
follow-on agreement after ten years.
222. Central Maine requests that the SGIA terminate after a set
number of
[[Page 34211]]
years agreed to by the Parties. It states that the provision is
unacceptable because it allows the Interconnection Customer to
unilaterally select the term of the interconnection agreement.
Commission Conclusion
223. We deny BPA's and Central Maine's requests to revise the term
of the interconnection agreement. These issues were addressed in Order
No. 2003, and neither commenter raises any new arguments here.\79\
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\79\ Order No. 2003 at P 302-304.
---------------------------------------------------------------------------
224. Termination (Proposed SGIA Article 4.3) and Default (Proposed
SGIA Article 6.17)--Proposed article 4.3.1 would grant the
Interconnection Customer the right to terminate the SGIA at any time by
giving 30 days written notice. Proposed article 4.3.2 would allow the
Transmission Provider to terminate the interconnection agreement if a
material change in law or regulations would either prevent performance
of the interconnection agreement or impose on the Transmission Provider
substantial additional costs that are not reimbursed by another entity.
Proposed article 6.17 described when a Default takes place and the
Parties' right to cure upon notice of a Default. Because these
provisions are closely related, we discuss them together.
Comments
225. Several commenters ask the Commission to grant the
Transmission Provider termination rights comparable to those given the
Interconnection Customer.\80\ PG&E and Southern Company request that
the Transmission Provider have the right to terminate the
interconnection agreement if the Small Generating Facility is either
shut down or abandoned. Southern Company asks that the Transmission
Provider be allowed to terminate the agreement if the Small Generating
Facility either does not begin commercial operation or is inactive for
three years. Absent changes to this provision, the only remedy
available to the Transmission Provider is to file an application to
terminate with the Commission.
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\80\ See, e.g., BPA, Central Maine, PG&E, and Southern Company.
---------------------------------------------------------------------------
226. Central Maine, Joint Commenters, and PacifiCorp ask that if
the Interconnection Customer terminates the SGIA, neither the
Transmission Provider nor its customers should have to pay the costs of
termination, including the cost of site restoration. Central Maine says
these costs should be paid by the Interconnection Customer if it
defaults on the interconnection agreement. PacifiCorp requests that the
SGIA require the Interconnection Customer to pay any outstanding costs
under the SGIP or SGIA during the 30 day notice period, or else
termination shall not become effective. Joint Commenters also propose
including a provision specifying that a Party remains liable for
expenses incurred under the SGIA even after it has terminated. Central
Maine states that certain critical provisions, such as access,
confidentiality, invoicing, limitation of liability, and
indemnification, should survive any expiration or earlier termination
of an agreement.
227. NARUC urges the Commission to adopt its Model interconnection
agreement, which allows the Interconnection Customer to terminate the
agreement for any reason, including default, provided 60 days' written
notice is given. Alternatively, the Transmission Provider may terminate
the agreement if the Small Generating Facility does not generate energy
in parallel with the Transmission Provider's Transmission System by the
later of two years from the date of the agreement or 12 months after
interconnection is completed.
228. NARUC also requests clarification that the Transmission
Provider may terminate the interconnection agreement for Default. Both
NARUC and Joint Commenters propose adding a provision specifying that a
Transmission Provider may terminate the SGIA if there is a material
change in a rule or statute concerning interconnection and parallel
operation of the Small Generating Facility that would impose additional
costs on the Transmission Provider. Finally, the NARUC Model clarifies
that termination does not relieve either Party of its obligations to
the other Party.
229. Central Maine and NYTO ask the Commission to clarify the
difference between ``Default'' and ``Breach,'' as it did in the LGIA.
Specifically, Central Maine states that a Breach, if uncured, becomes a
Default and may result in termination.
Commission Conclusion
230. As Order No. 2003 stated, there is no reason to allow the
Transmission Provider to terminate the interconnection agreement if the
Interconnection Customer has met all its obligations.\81\ As we have
noted elsewhere in this Final Rule, the interests of a Transmission
Provider may be adverse to those of the Interconnection Customer, and
it has an incentive to discriminate against the Interconnection
Customer. The Interconnection Customer's business decision not to
operate its Small Generating Facility for an extended period of time
should not result in the loss of its rights under the SGIA.
---------------------------------------------------------------------------
\81\ Order No. 2003 at P 313.
---------------------------------------------------------------------------
231. We adopt NARUC's proposal that a Party be given 60 calendar
days in which to cure a Default once notified that it is in Default. If
at the end of the 60 calendar days, the Default continues to exist, the
non-defaulting Party may terminate the interconnection agreement. This
is consistent with the Commission's regulations that require an entity
to notify the Commission of the proposed cancellation or termination of
a contract at least 60 calendar days before the cancellation or
termination is proposed to take effect. However, to allow for
situations where 60 calendar days are not sufficient time to cure the
default, the SGIA allows up to six months in which to cure the Default
so long as the Party ``continuously and diligently'' works towards
curing the Default.
232. Joint Commenters and Central Maine propose provisions that
address the cost responsibility of the Parties if the SGIA is
terminated. Both the Termination and Default provisions now clarify
that the Parties' financial obligations and other responsibilities
survive the termination of the SGIA. The SGIA also addresses
PacifiCorp's concern that the Interconnection Customer would be able to
terminate the interconnection agreement and escape financial
responsibility for costs it has already incurred.
233. The Proposed SGIA included a provision allowing the
Transmission Provider to terminate the SGIA should there be a
regulatory change that would impose additional costs on the
Transmission Provider. Consistent with the LGIA, we are not including
such a provision in the SGIA. Should a significant regulatory change
take place, the Transmission Provider may request termination of the
interconnection agreement under section 205 of the FPA.
234. Central Maine and NYTO are correct that the term ``breach''
does not appear in the SGIA. Upon discovering a Default, the non-
defaulting Party gives notice of the Default to the defaulting Party.
The defaulting Party then has time to cure the Default. If it does not
do so, the SGIA may then be terminated. We are revising the SGIA
accordingly.
235. Emergency Conditions (Proposed SGIA Article 4.4.1)--Proposed
SGIA article 4.4.1 would give the Transmission Provider the right to
immediately suspend interconnection service and temporarily disconnect
the
[[Page 34212]]
Small Generating Facility under Emergency Conditions.
Comment
236. SoCal Edison proposes adding the term ``Distribution
Provider's Distribution System'' to each place where the definition of
Emergency Condition says ``Transmission Provider's Transmission
System.'' \82\
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\82\ SoCal Edison does not give any rationale for its proposed
change, only modified tariff sheets.
---------------------------------------------------------------------------
Commission Conclusion
237. The owner of the Commission-jurisdictional facility with which
the Interconnection Customer interconnects is the ``Transmission
Provider'' regardless of how the facility may be classified by the
Transmission Provider. As defined by this Final Rule, ``Transmission
Provider'' means ``the public utility * * * that owns, controls, or
operates transmission or distribution facilities used for the
transmission of electricity in interstate commerce and provides
transmission service under the Tariff'' (emphasis added). The change
suggested by SoCal Edison would be redundant.\83\
---------------------------------------------------------------------------
\83\ If the Small Generatiing Facility is interconntected with
nonjurisdictional lines, then this Final Rule does not reach the
issue of whether a jurisdictional Transmission Provider may
disconnect the Small Generating Facility in an emergency. The
Transmission Provider would have to deal with the non-jurisdictional
utility.
---------------------------------------------------------------------------
238. Temporary Disconnection--Routine Maintenance, Construction,
and Repair (Proposed SGIA Article 4.4.2) and Forced Outages (Proposed
SGIA Article 4.4.3)--Proposed SGIA article 4.4.2 would require that the
Transmission Provider give five Business Days' notice before
interrupting interconnection service, curtailing the output of the
Small Generating Facility, or temporarily disconnecting the Small
Generating Facility for routine maintenance, construction, and repairs.
Proposed SGIA article 4.4.3 would give the Transmission Provider the
right to suspend interconnection service to make repairs during forced
outages. It would also require the Transmission Provider to give the
Interconnection Customer written documentation to explain the
circumstances of the disconnection if prior notice was not given. Both
provisions would require the Transmission Provider to use its best
efforts to coordinate disconnections, curtailments, and forced outages
with the Interconnection Customer.
Comments
239. PG&E states that it has thousands of small solar projects
interconnected with its ``Distribution System'' and requests that the
five Business Day notice requirement be waived for distribution level
generators because it would interfere with a Distribution System
owner's ability to work on its facilities.
240. Empire District argues that it should not take five days to
shut down a Small Generating Facility. If some minimum notice is
required, it should apply only to Small Generating Facilities larger
than 2 MW. Empire District also questions the need for an ``individual
notice'' to every generator and whether it is really necessary to
notify the operators of small certified units under 100 kW in size. If
individual notifications are required, the Interconnection Customer
should have a method in place whereby ``nearly instantaneous, two-way
communication'' (notification and verification of receipt of notice)
can be made within 24 hours.
241. EEI, PacifiCorp, and Southern Company ask that the term
``reasonable efforts'' be used instead of ``best efforts'' in Proposed
SGIA articles 4.4.2 and 4.4.3, noting that ``reasonable efforts'' was
used in the ANOPR consensus document.
242. EEI and PacifiCorp ask the Commission to clarify that the
Transmission Provider must provide written documentation to the
Interconnection Customer only when the latter requests it.
Commission Conclusion
243. We are not convinced that a five Business Day notice is unduly
burdensome to the Transmission Provider or that it should apply only to
Small Generating Facilities larger than 2 MW. Even if PG&E has
thousands of small solar projects interconnected with its Distribution
System subject to an OATT, as it states, it is highly unlikely that it
will ever have to provide notice to all of them simultaneously.
244. We agree that the term ``reasonable efforts'' should be used
instead of ``best efforts'' in the SGIA. We are making this change
throughout the SGIA.
245. Finally, we are persuaded that written documentation need be
provided only upon request by the Interconnection Customer, and the
SGIA reflects this change.
246. Temporary Disconnection--Adverse Operating Effects (Proposed
SGIA Article 4.4.4)--Proposed SGIA article 4.4.4 said that after being
notified that its Small Generating Facility may degrade the reliability
of the Transmission Provider's electric system, the Interconnection
Customer must be given reasonable time to make necessary corrections.
If it does not make the corrections within that time, the Transmission
Provider must provide a second notice to the Interconnection Customer
stating that the Small Generating Facility may be disconnected in five
Business Days.
Comments
247. Several commenters \84\ contend that the five day notice
period is unreasonable, restricts the Transmission Provider's ability
to respond to reliability concerns, and could be misinterpreted to mean
that an Interconnection Customer whose Small Generating Facility is
causing adverse operating conditions has priority over other customers.
---------------------------------------------------------------------------
\84\ E.g., Ameren, EEI, National Grid, PacifiCorp, PG&E, and
Southern Company.
---------------------------------------------------------------------------
248. EEI recommends that the last sentence of Proposed SGIA article
4.4.4 be revised to read: ``Transmission Provider shall provide
Interconnection Customer notice of such disconnection within a
reasonable time period, unless the provisions of article 4.4.1
[Emergency Conditions] apply.''
249. National Grid states that some form of advance notice and the
ability to cure is generally reasonable before disconnection; however,
such steps cannot be mandated all the time. It proposes language giving
the Transmission Provider the right to take unilateral action to avoid
service disruptions to other customers or damage to facilities caused
by the Small Generating Facility.
250. According to Small Generator Coalition, the Transmission
Provider should notify the Interconnection Customer if, based on sound
engineering judgment, it concludes that adverse operating conditions
exist.
Commission Conclusion
251. This article applies only if the Transmission Provider
determines that the Small Generating Facility may adversely affect its
electric system and the Interconnection Customer has failed to take the
necessary remedial action within the time specified by the Transmission
Provider. We are not convinced that the notice period is too long,
could endanger reliability or safety, or unnecessarily expose the
Transmission Provider to liability claims when damage and disruption to
its electric system is imminent. There could be legitimate reasons for
the Interconnection Customer not to make the necessary corrections
within the allotted time (e.g., replacement parts are on back order).
SGIA article 3.4.1 provides that the Transmission Provider
[[Page 34213]]
may declare an emergency and disconnect the Small Generating Facility
if there is an imminent threat to its electric system, which provides
the Interconnection Customer with ample incentive to promptly resolve
any adverse operating effects. Accordingly, we reject the request to
eliminate the notification period from this article. However, we are
revising this provision to specify that no notice is necessary in order
to resolve an Emergency Condition.
252. We agree with Small Generator Coalition that the Transmission
Provider should immediately notify the Interconnection Customer when
operation of the Small Generating Facility may cause disruption or
deterioration of service to other customers and that this finding must
be based on and supported by sound engineering principles. We also
stress that all documentation supporting the problem must be provided
to the Interconnection Customer upon request.
253. Temporary Disconnection--Modification of the Generating
Facility (Proposed SGIA Article 4.4.5)--Proposed SGIA article 4.4.5
would require the Interconnection Customer to secure written
authorization from the Transmission Provider before making any material
modification to the Small Generating Facility, or it can be
disconnected.
Comment
254. EEI recommends that the phrase ``material modification'' be
replaced with ``modification.'' This revised language is used in LGIA
article 5.19.2.
Commission Conclusion
255. We agree with EEI that the term ``material modification''
could be ambiguous. Accordingly, we are revising this article to
provide that Transmission Provider written approval is required before
the Interconnection Customer may modify its Small Generating Facility
in such a way that could materially impact the safety or reliability of
the Transmission Provider's electric system. We are also requiring that
any modifications be done according to Good Utility Practice.
256. Temporary Disconnection--Reconnection (Proposed SGIA Article
4.4.6)--Proposed SGIA article 4.4.6 would require the Parties to
cooperate with each other to restore the Small Generating Facility, the
Interconnection Facilities, and the Transmission Provider's electric
system to their normal operating state as soon as reasonably
practicable following any temporary disconnection.
Comments
257. Southern Company contends that this article should state that
restoration is required only when the events causing the temporary
disconnection are over. Small Generator Coalition asks that the
provision use ``interruption and curtailment'' instead of
``reduction.''
258. In its supplemental comments, Joint Commenters propose the
following alternative language: ``the Parties shall cooperate with each
other to restore the Generating Facility, Interconnection Facilities,
and Transmission Provider's Transmission System to their normal
operating state as soon as reasonably practicable following a temporary
disconnection.''
Commission Conclusion
259. We are adopting the proposed language submitted by Joint
Commenters because it removes unnecessary jargon and simply requires
that the Parties work to restore normal interconnection service as
quickly as possible. This language addresses Southern Company's and
Small Generator Coalition's concerns as well.
260. Financial Security Arrangements (Proposed SGIA Article 5.2)--
Proposed SGIA article 5.2 provided that the Interconnection Customer
provide financial security to the Transmission Provider for the
construction of Interconnection Facilities or Upgrades through a
guarantee, surety bond, letter of credit, or other form of credit that
meets certain standards. The type of financial security arrangement and
issuing entity would have to be reasonably acceptable to the
Transmission Provider and have (1) terms and conditions that guarantee
payment up to an agreed upon amount, (2) a reasonable date of
expiration, (3) be issued at least 20 days before construction, and (4)
be consistent with the Uniform Commercial Code of the jurisdiction
where the Point of Interconnection is located.
Comments
261. PacifiCorp argues that this article does not refer to design
costs. It asserts that this could lead to unnecessary confusion over
whether design costs should be included with procurement, resulting in
the burden of design costs falling on the Transmission Provider and its
customers.
262. Southern Company offers proposed changes to provide protection
for the Transmission Owner and the Transmission Provider. It asks the
Commission to delete any references to surety bonds as an acceptable
form of payment on the grounds that they are not specifically mentioned
in the OATT and are not generally accepted as a form of payment. It
also requests that the SGIA state clearly that the terms of any letter
of credit, guarantee or other security must be reasonably acceptable to
the Transmission Provider.
263. In an effort to avoid fraudulent conveyance issues or problems
with the enforcement of any guarantee through bankruptcy procedures,
Southern Company proposes that the parent of the Interconnection
Customer (if any) serve as the source of any guarantee, specifically
excluding affiliates from proposing any guarantee. Additionally, any
proposed guarantor should have a credit rating of BBB+ to protect
against rapid credit downgrades.
264. Southern Company also argues that the dollar-for-dollar
reduction of security as payments are made to the Transmission Provider
is arbitrary and capricious and imposes risks under bankruptcy and
fraudulent conveyance law upon the Transmission Provider. At a minimum,
the Commission should not require that security be reduced until the
expiration of any potential bankruptcy preference period. Southern
Company also asks the Commission to clarify that credit support is not
to be reduced by payments made to the Transmission Provider that are
unrelated to the actions designated in this article. It also proposes
the expansion of credit to cover all other obligations of the
Interconnection Customer under the interconnection agreement.
265. Finally, NYTO proposes that the Interconnection Customer
demonstrate its creditworthiness in its Interconnection Request.
Commission Conclusion
266. We agree with PacifiCorp that design costs are a part of the
development process that should be covered and are including such a
provision in the SGIA.
267. While Southern Company opposes using surety bonds as an
acceptable form of payment, we are following in this Final Rule the
same approach taken in the LGIA, which states that the Interconnection
Customer has the right to select a form of security that is acceptable
to the Transmission Provider and consistent with commercial
practices.\85\ Because SGIA article 6.3 grants the Transmission
Provider the discretion to reject a form of security (if it is
reasonable to do so), we reject Southern Company's proposal to
eliminate the surety bond as an acceptable form of credit. Giving the
[[Page 34214]]
Interconnection Customer a choice of security is not unreasonable.\86\
Furthermore, granting the Transmission Provider absolute discretion on
what forms of security to allow would provide too great an opportunity
to erect hurdles to new small generation.\87\
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\85\ Order No. 2003 at P 597.
\86\ See Florida Power & Light Company, 98 FERC ] 61,226 at
61,893-94, reh'g granted in part on other grounds, 99 FERC ] 61,318
(2002); Florida Power & Light Company, 98 FERC ] 61,324 at 62,358-59
(noting that the Transmission Provider's practice of limiting
interconnection customers to a letter of credit is unreasonable),
reh'g rejected as moot, 100 FERC ] 61,094 (2002).
\87\ Southwest Power Pool, Inc., 100 FERC ] 61,096 at P 12
(2002).
---------------------------------------------------------------------------
268. For the same reasons, we reject Southern Company's proposals
to (1) limit the source of any guarantee to a parent of the
Interconnection Customer and (2) require any proposed guarantor to have
a credit rating of BBB+. These are hurdles that could be exploited to
discourage Small Generating Facilities. The SGIA grants the
Transmission Provider the discretion to reject a form, source, or
issuing entity of security only if doing so is reasonable. Giving the
Transmission Provider absolute discretion on these choices would create
too great an opportunity for exploitation.
269. We are requiring the reduction of the security amount on a
dollar-for-dollar basis as payments are made because this protects the
Interconnection Customer against providing too much security while
ensuring that the Transmission Provider is sufficiently protected
against its real cost exposure.\88\ We recognize that reducing the
security as the Interconnection Customer pays its bills may cause a
small increase in risk to the Transmission Provider, but the chilling
effect of requiring the Interconnection Customer to maintain the full
security during the length of the interconnection process would
seriously discourage new small generation.
---------------------------------------------------------------------------
\88\ See Order No. 2003 at P 264.
---------------------------------------------------------------------------
270. We clarify that credit support is not to be reduced by
payments made to the Transmission Provider that are unrelated to the
actions listed in this article. In response to NYTO, we note that the
Interconnection Customer is already required to give appropriate
financial guarantees before the Transmission Provider begins
construction. Thus, the Interconnection Customer need not demonstrate
its creditworthiness when it submits its Interconnection Request.
271. Milestones (Proposed SGIA Article 5.3)--Proposed SGIA article
5.3 stated that the Parties are to agree on milestones that each Party
is responsible for meeting. These milestones are part of the
interconnection agreement. Article 5.3 further specified that if either
Party does not meet a milestone, it must compensate the other Party for
its losses (i.e., pay liquidated damages).
Comments
272. Several commenters ask the Commission to remove references to
liquidated damages from the SGIA. Others claim that the Commission
lacks the legal authority to impose liquidated damages.
273. EEI seeks the elimination of this article entirely. The
provision is vague and confusing because conflicting milestone
requirements appear in other areas of the Proposed SGIA and Proposed
SGIP. NYTO contends that Appendix 3 of the Proposed SGIA, which
requires the Parties to list agreed upon milestones, is unnecessary.
274. Midwest ISO requests that the Commission adopt the same
liquidated damages clause as in the LGIA. It states that this will make
the large and small generator tariff provisions consistent.
275. PacifiCorp requests that Proposed SGIA articles 5.3.1 and
5.3.2 be deleted. It contends that the accomplishment of milestones
should be subject to a ``reasonable efforts'' or ``good faith efforts''
standard rather than liquidated damages being applied. As a matter of
policy, good faith efforts should not be penalized, since the
Transmission Provider does not profit from interconnections.
276. In its supplemental comments, Joint Commenters suggest
replacing this provision in its entirety. The proposed replacement
requires the Parties to agree to extend milestone deadlines if the
milestone was missed in ``reasonable good faith.'' However, the Party
affected by the failure to meet a milestone is not required to agree to
an extension if:
(1) It will suffer significant uncompensated economic or
operational harm from the delay and believes that the delay is not
or was not unavoidable, (2) attainment of the same milestone has
previously been delayed, or (3) it has reason to believe that the
delay in meeting the milestone is intentional or unwarranted
notwithstanding the circumstances explained by the party proposing
the amendment.
277. Joint Commenters also suggest making the provision bilateral
and removing the monetary penalty for missing a milestone.
Additionally, Joint Commenters would require the Party missing the
milestone to fully explain to the other Party why the milestone was
missed. Finally, Joint Commenters propose adding a statement that any
dispute as to this provision should be resolved according to the
dispute resolution portions of the SGIA.
Commission Conclusion
278. This Final Rule adopts many concepts proposed by Joint
Commenters, including the notice provisions and the preference that the
Parties agree to extend deadlines instead of declaring that the other
Party has defaulted on the SGIA.
279. Regarding Joint Commenters' proposal to add a statement
regarding dispute resolution, such a statement is not needed because
the SGIA's dispute resolution provision applies to the entire document.
280. We reject PacifiCorp's proposal to delete SGIA milestone
provisions. These provisions provide a single reference to the relevant
milestones. They will assist the Parties and will minimize
disagreements. Removing them would create uncertainty for the Parties.
281. Because we are not imposing in this Final Rule a financial
penalty on the Transmission Provider for missing milestones, there is
no need to discuss commenters' arguments on that issue.
282. Billing and Payment (Proposed SGIA Article 5.4)--Proposed SGIA
article 5.4 would provide that billing and payment obligations are to
be performed under the terms of the SGIA.
Comments
283. PacifiCorp requests that this article be revised to include
billing and payment requirements for Distribution Upgrades or Network
Upgrades. It also states that billing and payment for miscellaneous
costs, such as restudy costs, should be addressed.
Commission Conclusion
284. We agree with PacifiCorp in part and are revising this article
to clarify that billing and payment requirements are for Distribution
Upgrades and Network Upgrades. However, we see no need to identify
specific miscellaneous costs because the obligations listed in SGIA
article 6.1 are for services rendered, which already includes such
costs.
285. Billing Procedure for Interconnection Facilities Construction
(Proposed SGIA Article 5.4.1) and Final Accounting (Proposed SGIA
Article 5.4.2)--Under Proposed SGIA article 5.4.1, the Transmission
Provider would bill monthly for expenditures for the design,
engineering and construction of, or for other charges related to,
Interconnection Facilities. The Interconnection Customer would remit
payment within 30 calendar days after receipt of the bill.
286. Proposed SGIA article 5.4.2 would require that the
Transmission
[[Page 34215]]
Provider submit a final accounting report to the Interconnection
Customer within 45 calendar days after installing the Transmission
Provider's Interconnection Facilities.
Comments
287. PacifiCorp suggests that Proposed SGIA article 5.4.1 also
include procurement costs. Small Generator Coalition argues that
alternative arrangements for payment of the bill should be allowed if
the Parties agree. With respect to Proposed SGIA article 5.4.2,
numerous commenters \89\ argue that 45 calendar days is not enough time
for the Transmission Provider to prepare a final accounting report.
They offer an array of alternative deadlines ranging from 60 Business
Days to 90 days after the Small Generating Facility begins commercial
operation. BPA complains that there is not a similar deadline for any
additional payments owed by the Interconnection Customer. It proposes
that any unpaid bill must be paid within 30 days after the bill is
submitted by the Transmission Provider.
---------------------------------------------------------------------------
\89\ E.g., BPA, Central Maine, NYTO, PGE, and Southern Company.
---------------------------------------------------------------------------
Commission Conclusion
288. We agree with PacifiCorp that procurement costs should be
included. We are also revising the provision to allow the Parties to
make other reasonable payment arrangements should they agree to do so,
as requested by Small Generator Coalition.
289. While we agree with commenters that the proposed deadline for
submitting the final accounting report may be too short, tying it to
commercial operation of the Small Generating Facility is unrealistic
because that event may happen long after construction is complete. A
more realistic deadline, and one that provides sufficient time for the
Transmission Provider to compile the expenditures and process the final
accounting report, is three months from the date construction of the
facilities is completed. We are so revising this provision.
290. BPA is correct that proposed SGIA article 5.4.2 did not
include a deadline for the Interconnection Customer to pay its final
accounting bill. We are including in the SGIA 30 calendar days for the
Interconnection Customer to make payment to the Transmission Provider.
291. Finally, we are consolidating Proposed LGIA articles 5.2, 5.3,
and 5.4 because they are so closely related. The new article is
entitled ``Billing, Payment, Milestones, and Financial Security.''
292. Assignment (Proposed SGIA Article 6.5)--Proposed SGIA article
6.5 would allow the Parties to assign their rights under the
interconnection agreement to others under certain circumstances.
Comments
293. Southern Company contends that the proposed assignment
provision unreasonably allows one Party to freely assign its rights to
an affiliate without consent from the other Party. It argues that this
subjects the Transmission Provider to unnecessary risk from which it
cannot protect itself by requiring that the assignee have a credit
rating equivalent to that of the assignor; Transmission Providers
typically rely on guarantees or letters of credit, which are personal
to the obligor and would likely not cover the assignee. Bureau of
Reclamation emphasizes that its policies allow assignment of an
interconnection agreement only if both Parties agree to the assignment
and the assignor agrees to remain bound by the original terms of the
SGIA.
294. Southern Company also argues that it is unreasonable to make
the Transmission Provider get the Interconnection Customer's agreement
before it can assign the interconnection agreement as collateral, while
at the same time allowing the Interconnection Customer to assign the
interconnection agreement as collateral without the Transmission
Provider's permission. Southern Company contends that such assignments
could unfairly deprive the Transmission Provider of the right to
require the assignee or purchaser in foreclosure to assume the
obligations of the assignor and to fulfill performance. In addition,
the Transmission Provider could lose the right to require collateral
assignees to cure Defaults of the assignor, thereby allowing assignees
or purchasers in foreclosure to gain greater rights under the
interconnection agreement than would have been permitted to the
original Interconnection Customer. The requirement that notice of
collateral assignment be provided by the secured party, trustee, or
mortgagee is unworkable, as there would be no enforceable penalties for
breach of this obligation. Not only do these parties lack contractual
privity with the Transmission Provider, but they are also not typically
subject to Commission jurisdiction.
295. Southern Company contends that this article should provide
Transmission Providers and Transmission Owners indemnification rights
for any losses, costs, and expenses they may incur in connection with
assignments or foreclosures. In addition, Southern Company seeks
clarification of the conditions under which the Transmission Provider
must recognize foreclosure rights and assignments. The provision as
written could expose the Transmission Provider to uncompensated risks,
forcing its native load to bear the costs.
296. Small Generator Coalition requests that this article allow the
Interconnection Customer to assign its rights and obligations under the
interconnection agreement without consent of the Transmission Provider
if the Interconnection Customer sells or transfers the Small Generating
Facility and the real property on which it is located.
297. NARUC urges adoption of its Model interconnection agreement
language, which allows assignment by the Interconnection Customer in
two situations. First, assignment may be made to a corporation or other
limited liability entity upon the consent of the Transmission Provider.
Such consent is not to be withheld unless the Transmission Provider
``can demonstrate that the corporate entity is not reasonably capable
of performing the obligations of the assigning Interconnection
Customer.'' Second, the Interconnection Customer may assign the
interconnection agreement to a person who is either the ``owner,
lessee, or is otherwise responsible for the Small [Generating
Facility].''
298. In its supplemental comments, Joint Commenters recommend two
changes to the Proposed SGIA: (1) Deleting the sentence requiring the
assignee to notify the other Party before exercising its assignment
rights and (2) requiring the assigning Party to give the other Party 15
days to object to an assignment.
Commission Conclusion
299. The assignment provision proposed by Joint Commenters is
similar to the provision in the Small Generator NOPR. However, Joint
Commenters propose two minor changes that we will adopt. First, Joint
Commenters propose to remove a very technical sentence relating to
financing from the provision that is not well suited to smaller
projects. Second, Joint Commenters require that a Party seeking to
assign the SGIA merely inform the other Party of the pending
assignment. Should the Party not object, the assignment may go forward.
If the Party does object, then the remainder of the provision will
apply. Making these changes to the assignment provision should reduce
the administrative
[[Page 34216]]
burden on the Parties without diminishing their substantive rights.
300. In Order No. 2003-A,\90\ the Commission modified the
assignment provision of the LGIA in order to address Southern Company's
concerns relating to protecting native load customers. We make
corresponding changes here, clarifying that (1) an Interconnection
Customer assigning its rights under the SGIA is required to notify the
Transmission Provider of the assignment and (2) an assignee is
responsible for meeting the same insurance and financial security
obligations as a normal Interconnection Customer upon exercising its
right of assignment.\91\ This is in addition to a sentence specifying
that ``an assignment under this provision shall not relieve a Party of
its obligations * * *.'' We also make various editorial changes that
make the provision easier to read. Southern also requests that a
Transmission Provider be allowed to assign the interconnection
agreement as collateral. We reject that request for the same reasons
discussed in Order No. 2003-A.\92\
---------------------------------------------------------------------------
\90\ See Order No. 2003-A at P 470.
\91\ See Id. P 471.
\92\ See Id. P 475.
---------------------------------------------------------------------------
301. Insurance (Proposed SGIA Article 6.16)--In the Small Generator
Interconnection NOPR, the Commission asked whether insurance should be
required for Small Generating Facility interconnections and if so, how
much. While the Proposed SGIA itself contained insurance provisions,
the Commission did not specify dollar amounts and requested proposals
from commenters. The Commission also requested comments on three
specific issues. First, should insurance coverage vary with the size of
the facility? Should, for example, a 20 MW Small Generating Facility be
subject to higher coverage amounts than a 10 MW facility, which itself
would be subject to higher coverage amounts than a 5 MW facility?
Second, should coverage types and amounts vary according to the type of
generator so that, for example, solar or wind facilities would require
different insurance coverage than gas-fired facilities? Third, should
there be a size cutoff that would exempt certain facilities from some
insurance requirements?
Comments
302. The NARUC Model, while not requiring insurance, proposes that
state regulators recommend that every Interconnection Customer
``protect itself with insurance or other suitable financial instrument
sufficient to meet its construction, operating and liability
responsibilities * * *.'' \93\
---------------------------------------------------------------------------
\93\ NARUC Model--Interconnection Agreement at article 7.
---------------------------------------------------------------------------
303. NARUC argues that the Commission's proposal to require seven
different types of insurance is excessive and makes federal
interconnection rules incompatible with state rules. The very act of
requiring insurance would drive up prices because insurance companies
would then have a captive market that must have insurance. Workers'
compensation and automobile insurance are already required by state
law; accordingly, they should not be mandated by the federal
government. NARUC also asserts that state regulators will have more
flexibility to assure low insurance rates if this Final Rule does not
require insurance. Finally, NARUC reports that while California
requires insurance for most projects, the majority of other states
(including New York, Texas, and Ohio) do not. Therefore, requiring
insurance would be inconsistent with the practice in most states.
304. NYPSC reports that its own efforts to establish minimum
insurance requirements were unsuccessful. While it recognizes the risk
Small Generating Facilities pose to the Transmission Provider,
mandatory insurance ``created a substantial barrier to the
proliferation of distributed generation units.'' \94\ The biggest
barrier to entry is not the cost of insurance (though that is a
factor), but the fact that insurance is unavailable at any price in
many situations. Insurance companies are not yet familiar with the
risks posed by the interconnection of Small Generating Facilities and
often will not insure them. NYPSC instead proposes allowing the market
to determine insurance requirements. It reports that the market has at
least partially responded to this need, creating insurance pools to
spread the risk to multiple entities. It also notes that manufacturers
sometimes bundle insurance coverage along with the equipment.
---------------------------------------------------------------------------
\94\ NYPSC at 9.
---------------------------------------------------------------------------
305. ISO New England recognizes that smaller generators generally
pose less risk than larger ones, but argues that the level of risk
should be evaluated on a case-by-case basis. This Final Rule should let
an independent Transmission Provider waive the insurance requirement if
it determines that the project poses little risk to its electric
system. For many smaller facilities, the liability, indemnity, and
insurance requirements typically required of larger facilities may cost
too much. Likewise, MISO supports making the amount of insurance
required a function of the risk of the particular interconnection.
However, MISO also supports establishing minimum standard insurance
requirements (although it does not offer specific amounts).
306. Some Transmission Providers \95\ want the Commission to keep
the proposed insurance limits. Central Maine and NYTO, among others,
point out that most small projects would not have the financial
resources to pay any judgment against them and argue that insurance is
necessary to protect the interests of the Transmission Provider, and
ultimately, its customers. EEI favors using the same insurance limits
as the LGIA.
---------------------------------------------------------------------------
\95\ E.g., AEP, Allegheny Energy, Avista, BPA, Central Maine,
Cinergy, EEI, NRECA, NYTO, and Southern Company.
---------------------------------------------------------------------------
307. AEP also argues that there is no reason why standard insurance
provisions should be different for a 1 MW facility than for a 20 MW
facility. Likewise, Allegheny Energy, Central Maine, NYTO, and others
argue that even a very small generating facility can damage the
Transmission Provider's electric system.
308. Empire District, Nevada Power, NRECA, and PG&E assert that the
amount of insurance required should vary with generator size. As NRECA
puts it, ``a residential consumer installing a 3 kW Small Generating
Facility should not have to acquire $1 million in insurance * * *.''
\96\ Even so, NRECA states that it would oppose any attempt to create a
minimum megawatt threshold below which insurance would not be required.
---------------------------------------------------------------------------
\96\ NRECA at 34.
---------------------------------------------------------------------------
309. PG&E states that California has long required insurance for
all projects larger than 10 kW and that this requirement has not
noticeably dampened the market for on-site Small Generating Facilities.
310. While Nevada Power agrees that solar and wind projects present
less risk than does a traditional gas-fired generator, it opposes
insurance requirements that differ by fuel type. The market already
recognizes these reduced risks by charging proportionately less for
some types of insurance than others. NRECA also opposes distinguishing
between different fuel types, arguing that this is only one of many
factors that determine a project's risk.
311. In contrast, Tangibl supports basing the required amount of
insurance on the type of generator being interconnected. It argues that
the risks posed by Small Generating Facilities are largely
environmental, such as fuel
[[Page 34217]]
spills. Tangibl also argues that Small Generating Facilities pose less
risk than do large generators because the former need smaller amounts
of fuel to be stored on site. This risk is even less for renewable
sources such as wind or solar.
312. Nevada Power says that knowing how much insurance is going to
be required at the outset of the project is important to its success.
313. While AEP supports including standard insurance terms in this
Final Rule, the Parties should be able to negotiate additional terms if
warranted by the physical characteristics of the project. NRECA argues
for permitting the Transmission Provider to determine the necessary
level of insurance on a case-by-case basis.
314. Cinergy also argues for increased flexibility. It would let
the Transmission Provider reduce or eliminate the required insurance
provisions on a case-by-case basis if it believes in good faith that
the full amount of insurance is not required to safeguard its
interests. Cinergy also argues that this Final Rule should provide a
mechanism for dealing with insurance requirements that simply do not
apply to a given generator, such as requiring workers' compensation
insurance for a generator that does not have any on-site employees.
315. National Grid proposes that the Commission not set required
levels of insurance, and instead leave it to the Transmission Provider
and state law. It points out that several states have, or are in the
process of developing, specific insurance requirements for Small
Generating Facilities. The Commission should not second-guess the
attempt of various states to encourage on-site Small Generating
Facilities. Specifically, National Grid points to a proposal developed
by a working group of the Massachusetts Public Utilities Commission
that proposes varying levels of insurance depending on the capacity of
the project.\97\
---------------------------------------------------------------------------
\97\ The proposal requires no insurance for projects smaller
than 10 kW; $500,000 for projects between 10 kW and 100 kW ($500,000
aggregate); $1 million for projects between 100 kW and 1 MW ($1
million aggregate); $2 million for projects larger than 1 MW and no
larger than 5 MW ($5 million aggregate); and $5 million for projects
larger than 5 MW ($5 million aggregate). See National Grid Comments,
Appendix A (citing Tariff to Accompany Proposed Uniform Standards
for Interconnecting Distributed Generation in Massachusetts,
Submitted by the Distributed Generation Interconnection
Collaborative to the Massachusetts Department of Telecommunications
and Energy in Compliance with DTE Order No. 02-38-A (May 15, 2003)).
---------------------------------------------------------------------------
316. NYTO makes a similar request, arguing that the Transmission
Provider should be allowed to fill in specific insurance amounts based
on state law, established local practice or, absent those, its own
business judgment.
317. Avista states that the Parties should be allowed to negotiate
alternative mechanisms such as self-insurance. It argues that even a
Transmission Provider facing financial difficulty can always raise
rates to cover any potential liability. Southern Company also proposes
revisions to clarify the meaning of this article.
318. NRECA, while it supports the Commission's insurance proposal,
opposes making the provision bilateral. It argues that the Transmission
Provider's operation of its electric system does not create any greater
risk to the Interconnection Customer than to any other customer. The
interconnection of the Small Generating Facility, on the other hand,
increases the risks to the Transmission Provider. Furthermore,
according to NRECA, most Transmission Providers are already required to
either self-insure or otherwise carry insurance sufficient to cover any
liability that may arise from operation of their electric systems, so
requiring further insurance is duplicative.
319. Empire District supports requiring the Transmission Provider
to be named as an additional insured for generators larger than 5 or 10
kW, while Avista opposes such a size-related requirement.
320. Avista notes that workers' compensation requirements vary
significantly by state. It argues that the Commission should not
attempt to federally preempt these long-standing practices. According
to Avista and Nevada Power, the interconnection agreement should simply
require compliance by each Party with the applicable state workers'
compensation laws.
321. Cinergy states that while insurance may be a significant
barrier to entry for some Interconnection Customers, the Commission
should heed the insurance market's independent assessment of the risk
of a particular project. Fundamental economic principles require
Interconnection Customers to bear the costs of the risks they impose on
third parties, and there is no sound basis for the Commission to shift
that cost to the Transmission Provider and its customers. Nevada Power
and NRECA make similar arguments. NRECA also argues that if
Interconnection Customers do not have insurance, insurance companies
will be forced to raise the cost of insurance for Transmission
Providers, and that in turn will be paid by all users of the
Transmission System.
322. Small Generator Coalition, like most commenters representing
Small Generating Facilities, argues that purchasing insurance is a
business decision and that the level and nature of the insurance should
be established by each business according to its needs, not mandated by
the federal government. It argues that requiring insurance would create
a major barrier to small generator interconnections and would prevent
utility customers (as opposed to commercial generation projects) from
pursuing interconnection because the administrative and financial
barriers to entry would simply be too great. It asserts that the
insurance requirements for a small wind turbine should be less than for
a nuclear power plant or other large generator. Small Generator
Coalition is particularly vehement in its opposition to insurance
requirements for projects under 2 MW in size. Overall, Small Generator
Coalition supports NARUC's comments and asks the Commission to use the
NARUC Model in lieu of the Proposed SGIA.
323. Small Generator Coalition states that if the Commission does
include insurance requirements in its Final Rule, it should exempt
facilities no larger than 2 MW and require only $1 million in general
liability insurance for projects 2 MW or larger.
324. In general, Transmission Providers support requiring an
insurance regime with larger policy limits and a broad array of
coverage. Interconnection Customers and NARUC generally support
requiring smaller amounts of insurance or none at all. Southern Company
proposes revisions to Proposed SGIA article 6.16.11 to clarify the
conditions under which one Party must notify the other of accidents and
injuries arising out of the interconnection agreement.
325. Central Maine proposes requiring the following policies: $1
million in employer's liability and workers' compensation insurance; $1
million in Commercial General Liability Insurance (with a $2 million
aggregate combined limit); comprehensive automobile liability insurance
of $1 million (with a $2 million aggregate combined limit); and an
additional $1 million in excess public liability insurance (with a $5
million aggregate cap).
326. Nevada Power proposes requiring $1 million in general
liability coverage from projects greater than or equal to 200 kW and
$500,000 if the project is no larger than 200 kW. It also proposes
requiring excess public liability insurance of $10 million if the
facility is greater than or equal to 10 MW in size ($10 million
aggregate); $5
[[Page 34218]]
million for projects between 5 and 10 MW ($5 million aggregate); $2
million for projects between 200 kW and 5 MW ($2 million aggregate);
and none for projects less than 200 kW.
327. Southern Company is in favor of requiring a flat level of
coverage for all Small Generating Facilities, regardless of size, and
proposes requiring $1 million workers' compensation insurance ($1
million aggregate); $2 million general liability insurance ($6 million
aggregate); $2 million comprehensive automobile liability insurance;
and $10 million excess public liability insurance ($10 million
aggregate).
328. Tangibl proposes differing levels of insurance requirements
based on both size and type of the generator. For solar or wind
generators, Tangibl proposes requiring $2 million in insurance for
facilities larger than 10 MW; non-solar or wind facilities larger than
10 MW would maintain $4 million. However, for facilities no larger than
10MW, Tangibl proposes $500,000 in workers' compensation insurance; $1
million Commercial General Liability Insurance ($2 million aggregate);
$1 million comprehensive automobile insurance ($1 million aggregate);
and $5 million excess public liability insurance ($5 million
aggregate).
329. SoCal Edison urges the Commission to adopt the same insurance
requirements that the California Public Utilities Commission (CPUC)
requires, asserting that California's extensive experience with small
generators should serve as a model for the Commission. Specifically,
California's Rule 21 requires general liability coverage in the amount
of $2 million for projects larger than 100 kW; $1 million for projects
larger than 20 kW and no larger than 100 kW; and $500,000 for projects
no larger than 20 kW. Rule 21 also creates a special reduced insurance
requirement of $200,000 for facilities no larger than 10 kW associated
with a retail customer. Rule 21 exempts some classes of solar and wind
generators from its insurance requirements entirely, and provides for
waiver of the insurance requirements for some small residential
interconnections if insurance is not easily obtainable.
330. In its supplemental comments, Joint Commenters propose
requiring the Interconnection Customer to maintain insurance in an
amount ``sufficient to insure against all reasonably foreseeable direct
liabilities given the size and nature of the generating equipment being
interconnected, the interconnection itself, and the characteristics of
the system to which the interconnection is made.'' It also specifies
that the provision shall not require the Interconnection Customer to
obtain additional insurance if the insurance it already has is
sufficient. The Interconnection Customer is required to document its
insurance coverage no later than ten days before the anticipated
commercial operation date of the Small Generating Facility, and
afterwards as requested by the Transmission Provider. The proposed
provision also allows the Interconnection Customer to self insure when
appropriate and requires the Transmission Provider to maintain
insurance ``consistent with the Transmission Provider's commercial
practice.'' While Joint Commenters were able to reach consensus on the
insurance requirement for most Small Generating Facilities, they were
not able to reach consensus on the issue of insurance requirements for
inverter-based generators no larger than 10 kW.
Commission Conclusion
331. The wide range of insurance recommendations points out the
difficulties in establishing a set dollar amount or type of insurance
appropriate to every Small Generating Facility. Insurance can add
significant costs to a Small Generating Facility and may affect the
project's economic feasibility. Nevertheless, a mismanaged
interconnection can harm the Transmission Provider's electric system
and affect power customers, potentially subjecting the Parties to
liability.
332. We adopt in its entirety Joint Commenters' proposal, which
reflects appropriate compromises regarding this diversity of insurance
needs. We are pleased that such a diverse group of stakeholders could
reach consensus on this difficult issue.
333. The level of risk in interconnecting a 50 kW photovoltaic
system with the Transmission Provider's Transmission System is very
different from the risk involved in interconnecting a 10 MW generator.
Mandating that the Interconnection Customer maintain a reasonable
amount of insurance based on the specific characteristics of its
interconnection avoids the one-size-misfits-all problem and addresses
the differing needs of different Interconnection Customers and
Transmission Providers.
334. Joint Commenters, however, could not reach consensus on any
insurance provision for certified inverter-based generators no larger
than 10 kW. Commenters have convinced us that the risk of
interconnecting these small inverter-based generators is low and we
therefore decline to impose a generic insurance requirement in this
Final Rule.\98\ Instead, we adopt the approach proposed by NARUC which
is that each Party be required to ``follow all applicable insurance
requirements imposed by the state in which the Point of Interconnection
is located. All insurance policies must be maintained with insurers
authorized to do business in that state.'' Given that most generators
of this size and type will be interconnecting with state-jurisdictional
facilities, it makes sense to coordinate our approach with the approach
recommended by NARUC. This will also avoid forum shopping. This is also
similar to the approach adopted in Order No. 2003-A, which deferred to
state insurance laws rather than imposing specific dollar amounts for
these types of insurance.\99\
---------------------------------------------------------------------------
\98\ See, e.g., Cinergy, Empire District, ISO New England,
NRECA, NYPSC, PG&E, and Small Generator Coalition. But see, e.g.,
AEP, Central Maine, EEI, NYTO, and Southern Company.
\99\ See Order No. 2003-A at P 462.
---------------------------------------------------------------------------
335. However, because any uninsured risk will fall squarely on the
Transmission Provider's customers, who would effectively subsidize the
costs of the interconnection, we reject proposals that we completely
waive insurance requirement. Several commenters also advise the
Commission to leave the issue of insurance to state regulators. While
this makes sense for small inverter-based generators, for larger Small
Generating Facilities, having insurance requirements vary by state
would hamper our effort to promulgate national small generator
interconnection standards.
336. Cinergy asks that the Transmission Provider be allowed to
waive or reduce insurance requirements for a given project if it
concludes that it poses little risk to its electric system. The
provision proposed by Joint Commenters would allow this type of
flexibility. If the Parties agree that the interconnection is safe,
then they can agree that insurance is not necessary. However,
Transmission Providers must waive or reduce the insurance requirements
on a non-discriminatory basis that does not favor affiliated
facilities.
337. We also clarify that an RTO or ISO may propose additional or
different insurance requirements under the independent entity variation
provision contained in this Final Rule.
338. Reservation of Rights (Proposed SGIA Article 6.20)--Some
commenters pointed out that Proposed SGIA article 6.20 contained a
typographical error, which we are correcting.
339. Signatures and Parties to the SGIA (Proposed SGIA Article 9)--
[[Page 34219]]
Proposed SGIA article 9 required both the Transmission Provider and the
Transmission Owner to sign the interconnection agreement. This is the
same approach taken in Order No. 2003.\100\ In an RTO or ISO where the
Transmission Provider is not the Transmission Owner, the RTO's or ISO's
compliance filing may propose a modified interconnection agreement that
provides the Transmission Provider and Transmission Owner different
rights and obligations.
---------------------------------------------------------------------------
\100\ Order No. 2003 at P 909.
---------------------------------------------------------------------------
Comments
340. ISO New England supports the approach taken in Order No. 2003,
allowing Transmission Owners and Transmission Providers to propose a
modified interconnection agreement when the Transmission Provider is an
entity distinct from the Transmission Owner. It contends that this
approach is necessary if the Commission wishes to establish a single
interconnection agreement for a region encompassed by an RTO or ISO.
341. NYISO argues that the SGIA should assign certain basic
responsibilities to either the Transmission Owner or Transmission
Provider.
342. Midwest ISO asserts that it is the RTO's role as an
independent entity ``to ferret out unnecessary studies or inappropriate
contingencies.''\101\ However, it argues that the ``NOPR's failure to
fully distinguish between a transmission provider and transmission
owner belies the independence of the RTO,'' \102\ and both it and other
commenters \103\ request clarification of the respective roles of the
RTO and the Transmission Owner.
---------------------------------------------------------------------------
\101\ Midwest ISO at 6.
\102\ Id.
\103\ E.g., NYTO and PG&E.
---------------------------------------------------------------------------
343. National Grid argues that defining ``Transmission Provider''
to include both the Transmission Provider and the Transmission Owner
confuses the issue and adds ambiguity into the interconnection process.
The Commission should clearly define the role of each Party. National
Grid also notes that the Small Generator Interconnection NOPR did not
account for the role of stand-alone distribution companies.
344. Central Maine asks the Commission to clarify that the
Transmission Owner (or distribution company, where applicable) must
sign the interconnection agreement and to clarify whether the
Transmission Provider needs to be a Party to the agreement. It asserts
that the division of functions between the Transmission Owner and the
Transmission Provider varies by region and depends on the role that the
RTO or ISO plays in the region. A request for interconnection with a
Distribution System may require that a distribution company be a Party
to the interconnection agreement, in lieu of a Transmission Owner or
Transmission Provider. Central Maine concludes that the standard
interconnection agreement resulting from this proceeding must
ultimately be a contract between the Interconnection Customer and the
entity that owns the Transmission System (i.e., the Transmission Owner
or the distribution company).
345. In RTO or ISO regions, if the Commission determines that the
Transmission Provider must also sign the interconnection agreement,
Central Maine asks the Commission to clarify that, under section 205 of
the FPA, the Transmission Owner has the right to file the agreement,
consistent with Atlantic City Electric Co., et al. v. FERC, 329 F.3d
856, 858-59 (D.C. Cir. 2003) (explaining that while an ISO may have
certain FPA section 205 rights, the individual utility also has FPA
section 205 rights). Central Maine also says that the Transmission
Owner, not the Transmission Provider, has the right to file executed or
unexecuted interconnection agreements.
346. In lieu of requiring the signatures of both the Transmission
Owner and the Transmission Provider, EEI contends that the Commission
should require the signature only of the Transmission Owner.
Additionally, the Commission should encourage ISOs and RTOs with
operational roles that cause this distinction to clearly delineate the
rights and responsibilities in their operations agreements and
protocols. The interconnection agreement can specifically refer to the
OATT already approved by the Commission, thereby eliminating the need
to have both a separate agreement between the Transmission Provider and
the Interconnection Customer and a three-party agreement.
347. PG&E argues that RTOs and ISOs do not need to become Parties
to interconnection agreements for distribution level projects because
such entities only operate transmission systems. These entities have
very little interest in the smallest projects interconnected with
Distribution Systems and therefore, should not be the ones to receive
Interconnection Requests or maintain the queue for distribution level
interconnections. The Commission should designate the distribution
provider to fulfill these roles.
348. NYTO asserts that since an independent RTO or ISO has no right
to bind a Transmission Owner, the RTO or ISO should not sign the
interconnection agreement.
Commission Conclusion
349. As in Order No. 2003, we are requiring three-party agreements
in areas where the Transmission Provider and Transmission Operator are
different entities.\104\ In other regions of the country where the
Transmission Provider and the Transmission Owner are the same entity,
there is no need for a second signature block.\105\
---------------------------------------------------------------------------
\104\ Order No. 2003 at P 909.
\105\ We note that whether a public utility characterizes itself
as a ``transmission'' provider or a ``distribution'' provider does
not matter, since the Transmission Provider is defined to be the
``public utility * * * that owns, controls, or operates transmission
or distribution facilities used for the transmission of electricity
in interstate commerce and provides transmission service under the
Tariff.''
---------------------------------------------------------------------------
350. Given that RTOs and ISOs have distinct characteristics and
challenges, we have permitted each RTO or ISO to propose, on
compliance, an interconnection procedures document and agreement
tailored to its individual needs.\106\ Such proposals should allocate
to each entity the appropriate rights and obligations. As the Order No.
2003 compliance process demonstrated, the Transmission Provider and
Transmission Owner are capable of dividing responsibility among
themselves.
---------------------------------------------------------------------------
\106\ Order No. 2003 at P 909.
---------------------------------------------------------------------------
351. Finally, Central Maine asks the Commission to specify that,
under section 205 of the FPA, the Transmission Owner, not the
Transmission Provider, must file the interconnection agreement. This is
an issue better resolved on a case-by-case basis through the compliance
process. It would be premature to conclude that in all circumstances
the Transmission Owner, and not the Transmission Provider, has the
right to file the interconnection agreement.
352. Liability--In the Proposed SGIA, the Commission proposed
including provisions in the SGIA governing the apportionment of
liability between the Parties. These provisions (indemnity,
consequential damages, and Force Majeure) were similar to the
provisions in the LGIA. The Commission requested comments on whether
Small Generating Facilities should be treated differently from Large
Generating Facilities with respect to liability. We discuss our general
approach to the liability provisions first, followed by a more detailed
discussion of each provision.
[[Page 34220]]
General Approach
Comments
353. In general, Transmission Providers support liability
provisions similar to those in the LGIA, arguing that interconnecting a
Small Generating Facility raises as many safety and reliability issues
as interconnecting a Large Generating Facility.\107\
---------------------------------------------------------------------------
\107\ For instance, AEP, BPA, EEI, and Nevada Power argue that
the LGIA and the SGIA should be consistent. Nevada Power argues that
such provisions would not discourage well-run generators from
interconnecting with the Transmission Provider.
---------------------------------------------------------------------------
354. Small Generator Coalition and NARUC generally argue that these
provisions should be tailored specifically to Small Generating
Facilities, arguing that the Proposed SGIA was simply too complicated
for many Small Generating Facilities. They first argue that a Small
Generating Facility poses less danger to the Transmission Provider's
electric system than a Large Generating Facility. Second, they argue
that imposing liability provisions similar to those in the LGIA on
Small Generating Facilities would be a major financial barrier to entry
and deter the development of new Small Generating Facilities. Third,
they point out that the Transmission Provider has an incentive to
include onerous liability provisions in the SGIA to deter competition.
355. ISO New England similarly argues that Small Generating
Facilities do not present the same risks as do Large Generating
Facilities. It asks the Commission to permit independent entities to
determine, on a case-by-case basis, whether to waive or relax the
liability provisions for individual generators.
356. Avista asks the Commission to follow Midwest Independent
System Operator, Inc., et al., 100 FERC ] 61,144 (2002), which allows
the Parties to propose customized liability limitations. It argues that
the August 14, 2003 Northeast Blackout is evidence of the need for a
comprehensive look at liability limitations. Avista argues that the
interconnection agreement should have a savings clause to let an RTO
conform the liability and dispute resolution provisions (and possibly
others) to the standards and procedures being implemented by the RTO.
Otherwise, the Commission's rule could unnecessarily grandfather
inconsistent provisions.\108\ For example, the Agreement Limiting
Liability Among Western Interconnected Systems (``WIS Agreement'')
\109\ should continue to be an option for generators and utilities.
Avista argues that the SGIA should have a savings clause for the WIS
Agreement.
---------------------------------------------------------------------------
\108\ Avista at 18.
\109\ ``The WIS Agreement * * * is a multi-lateral agreement
among parties in the Pacific Northwest that operates to limit
liability among the signatories.'' Id.
---------------------------------------------------------------------------
Commission Conclusion
357. Many commenters, including NARUC and independent entities like
ISO New England, agree that the Commission should modify the proposed
liability provisions for Small Generating Facilities in this Final
Rule. We agree that the provisions can generally be simplified without
increasing the liability of any Party. The liability provisions adopted
here use many of the proposals made by NARUC and other commenters. They
address the Transmission Provider's need to protect its electric system
while removing unreasonable barriers to entry for Interconnection
Customers.
358. We agree with ISO New England that an independent Transmission
Provider (via the independent entity variation standard) may propose on
compliance to evaluate each Interconnection Request on a case-by-case
basis and fashion liability requirements that are suitable to that
particular entity.
359. We deny Avista's request for caps on the amount of liability
the Transmission Provider may be subject to, or that we allow it to
develop its own liability rules.\110\ The liability rules discussed in
the interconnection context are distinct from the liability rules in
the rest of the OATT.\111\ In the interconnection context, the
indemnity provision is two-sided (or three-sided, in the case of an
independent Transmission Provider). This means that the indemnity
provisions found in the SGIA are very different than the indemnity
provisions found in the OATT. Many of Avista's comments have more to do
with the liability provisions found in the transmission portions of the
OATT than they do with interconnection. While we agree that liability
protection is important, this rulemaking is not the place to decide
such an issue. We also deny Avista's request to insert a savings clause
into the liability provision. Avista has not explained how the
Transmission Provider's participation in the WIS Agreement would be
affected by this Final Rule. If Avista wishes, it may seek to include
such a provision on compliance under the ``consistent with or superior
to'' standard.
---------------------------------------------------------------------------
\110\ In Puget Sound Energy, Inc., 107 FERC ] 61,287 (2004), the
Commission denied a request by Puget Sound to include the WIS
Agreement in its tariff because Puget Sound did not explain why such
inclusion was ``consistent with or superior to'' the pro forma OATT.
However, the Commission did not foreclose the possibility that a WIS
Agreement member may be able to make such a showing in a future
compliance filing.
\111\ Order No. 2003 at P 636 (``Commenters have convinced us
that interconnection presents a greater risk of liability than
exists for the provision of transmission service and that, therfore,
the OATT indemnity provision is not suitable in the interconnection
context.'')
---------------------------------------------------------------------------
Consequential Damages (Proposed SGIA Article 6.19)
360. Proposed SGIA article 6.19 used the LGIA consequential damages
provision, which states that neither Party is liable to the other for
special or consequential damages except as expressly provided for in
the interconnection agreement.
Comments
361. Central Iowa Coop is concerned that the phrase ``[o]ther than
as expressly provided for in this agreement'' could make the Parties
subject to consequential damages when read in conjunction with the
indemnification provision in Proposed SGIA article 6.13. It asks the
Commission to clarify that the bar against consequential damages
applies in all circumstances, except when the Parties have reached an
express agreement to the contrary.
362. Central Maine asks the Commission to clarify that indemnity
payments to a third party are not consequential damages.
363. NARUC proposes that the Commission adopt its Model language,
which is less complicated than the proposed provision. Specifically,
NARUC proposes replacing Proposed SGIA article 6.19 with a generic
statement at the beginning of the liability article:
Each Party's liability to the other Party for any loss, cost,
claim, injury, liability, or expense, including reasonable
attorney's fees, relating to or arising from any act or omission in
its performance of this agreement, shall be limited to the amount of
direct damage actually incurred. In no event shall either Party be
liable to the other Party for any indirect, special, consequential,
or punitive damages of any kind whatsoever.
Commission Conclusion
364. We retain the provision as proposed. This is a contractual
term and no commenter has convinced us that it is necessary to deviate
from the approach taken in Order No. 2003.
365. Several commenters appear to have misunderstood the
relationship between the indemnity and consequential damages provisions
in the Proposed SGIA. The bar against
[[Page 34221]]
consequential damages does not apply in the indemnity context. Instead,
the indemnification of one Party by another is comprehensive, and the
indemnifying Party is responsible for all of the indemnified Party's
costs, regardless of whether those costs are compensatory or punitive.
While the consequential damages provision adopted in this Final Rule
prevents one Party from seeking consequential damages against another
Party, the purpose of the indemnification provision is different; it
protects the indemnified Party from liability to third parties (those
who are not Parties to the interconnection agreement). Requiring the
indemnifying Party to reimburse the indemnified Party for, say, only
compensatory damages and not punitive damages would not make the
indemnified Party whole. We are adding language to the beginning of the
indemnity section to make this clear.
Indemnity (Proposed SGIA Article 6.13)
366. Indemnification is compensating another for a loss suffered
due to a third party's act or default.\112\ The Proposed SGIA contained
indemnity provisions similar to those contained in the LGIA. The
proposal would require the Transmission Provider and the
Interconnection Customer to indemnify each other for any damages,
losses, claims, and obligations by or to third parties arising from
performance of the Transmission Provider's or Interconnection
Customer's obligations under the interconnection agreement on behalf of
the other contracting party. Indemnity protection would include the
amount of the indemnified Party's loss, net of any insurance recovery,
but would not apply where there is gross negligence or intentional
wrongdoing. The proposed provision also set forth detailed procedures
for pursuing an indemnity claim and allowed recovery of legal costs in
some cases.
---------------------------------------------------------------------------
\112\ Black's Law Dictionary 772 (7th ed. 1999).
---------------------------------------------------------------------------
Comments
367. AEP, BPA, Idaho Power, and Nevada Power generally agree that
Small and Large Generating Facilities should be treated consistently
with respect to indemnity protections.
368. Central Iowa Coop, Georgia Transmission, and NYTO request that
the Commission replace the mutual indemnity provision with a one-way
indemnity provision in favor of the Transmission Provider. They argue
that the Transmission Provider receives no benefit from an
interconnection, but does face additional safety, reliability, and
power quality concerns as a result of it. To require the Transmission
Provider to indemnify the Interconnection Customer unfairly shifts the
costs and risks to the Transmission Provider's other customers.
369. Central Maine contends that Proposed SGIA article 6.13 should
not exclude ``insurance or other recovery'' from amounts owed to an
indemnified party. It argues that this is commercially unreasonable and
undermines the very intent of the indemnity provision.
370. ISO New England argues that applying the liability provisions
contained in the LGIA to Small Generating Facilities is unreasonable
because the risks associated with interconnecting the latter are not
comparable to those associated with interconnecting Large Generating
Facilities. The Commission should permit independent entities such as
RTOs and ISOs to determine, on a case-by-case basis, whether a waiver
or relaxation of the indemnity provisions used for Large Generating
Facilities should be permitted based on the actual risk the Small
Generating Facility presents. Permitting this type of flexibility would
minimize the cost of interconnection and ensure adequate protection for
the Transmission Provider.
371. Southern Company argues that the proposed indemnity provision
is not workable. The provision requires each Party to indemnify the
other for damages arising out of such other Party's ``performance of
obligations under this Agreement on behalf of the indemnifying Party.''
\113\ It argues that it is unclear whether the indemnity provision
would ever apply because the Parties do not perform obligations on
behalf of each other at all. It proposes that each Party indemnify the
other from any liabilities or damages resulting from activities on the
indemnifying Party's own side of the point of change of ownership.
Additionally, each Party should indemnify the other for the
indemnifying Party's failure to adhere to operating requirements and
for breaches of the interconnection agreement. Southern Company also
takes issue with the provision's limitation of expenses paid for the
legal defense of an indemnified Party. If an indemnified Party has
additional legal defenses, the proposed article requires the
indemnifying Party to pay for only one attorney.\114\ Southern Company
requests that the Commission revise the provision to require the
payment of the indemnified party's reasonable legal expenses.
---------------------------------------------------------------------------
\113\ Southern Company at 34.
\114\ See Proposed SGIA article 6.13.
---------------------------------------------------------------------------
372. In its Model interconnection agreement, NARUC proposes a
different approach to indemnity. There, the Transmission Provider and
the Interconnection Customer would assume liability and indemnify each
other for claims and expenses resulting from their own negligence as it
relates to the design, construction, and operation of their facilities.
A Party indemnifies the other only for claims brought by claimants who
could directly recover from the Party itself. Indemnity for both
Parties includes monetary losses, reasonable legal fees for defending a
third party action, damages related to the death/injury of a third
party, damages to the Party's property or property of a third party,
and damages for disruption of a third party's business. Neither the
Transmission Provider nor the Interconnection Customer assumes
liability for consequential, special, incidental, or punitive damages,
and neither is responsible for disruption of the other's business or
for the costs and expenses of pursuing legal action against the other.
Commission Conclusion
373. We are adopting a streamlined indemnity provision in this
Final Rule.
374. Several commenters appear to have misunderstood the relation
between the proposed indemnity provision and the bar against
consequential damages provision (now called Limitation of Liability).
We are therefore including in the SGIA an explanation that claims under
the indemnity provision are exempt from the bar against consequential
damages contained in the Limitation of Liability provision.
375. Many of the comments addressing indemnity are identical to
those addressed in Order No. 2003 and do not argue that Small
Generating Facilities should be treated differently from Large
Generating Facilities. We will not repeat the discussion in those
orders. For instance, the Commission addressed comments about the
bilateral nature of the provision in Order No. 2003 at P 637, and
comments on which side of the Point of Interconnection work is
conducted in Order No. 2003 at P 638.
376. Because the purpose of indemnification is to pay another for
actual losses, the exclusion of ``insurance or other recovery'' from
amounts owed to an indemnified Party does not undermine the intent of
this provision, as Central Maine argues. Forcing an indemnifying Party
to pay
[[Page 34222]]
damages already covered under an insurance policy would allow the
indemnified Party to profit at the expense of the indemnifying Party.
Excluding insurance and other recoverable amounts avoids
overcompensating an indemnified Party.
377. In response to Southern Company's request that the provision
cover an indemnifying Party's failure to meet operating requirements or
its breach of the SGIA, we note that it covers damages from actions or
inactions under the interconnection agreement. However, in response to
Southern Company's comments, we are modifying the provision to add:
``arising out of or resulting from the other Party's actions or failure
to meet its obligations under this SGIA.''
Force Majeure (Proposed SGIA Article 6.14)
378. Proposed SGIA article 6.14 provided that no Party is
considered to be in default with respect to contractual obligations,
other than payment of money due, if it is prevented from fulfilling
such obligations by a Force Majeure event. The affected Party is to
exercise due diligence to remove the disability and provide adequate
notice to the other Party. These provisions are consistent with those
in the LGIA. The Commission requested comments concerning whether a
different approach should be taken for Small Generating Facilities.
Comments
379. AEP, BPA, Idaho Power, and Nevada Power generally agree that
all generating facilities should be treated the same with respect to
Force Majeure. AEP argues that because Force Majeure can happen for
either type of interconnection, there is no reason that the contractual
protection should differ according to generator size. Nevada Power
contends that consistent treatment does not interfere with having a
simplified and expedited interconnection process for Small Generating
Facilities.
380. While NARUC's Model and the Proposed SGIA included similar
Force Majeure clauses, NARUC recommends that the Commission remove the
statement that economic hardship is not considered a Force Majeure
Event. It also proposes that the Commission require that an affected
Party use ``reasonable efforts'' instead of ``due diligence'' to resume
its performance as soon as possible. Additionally, NARUC proposes
changing the definition of Force Majeure to include events that ``the
affected Party is unable to prevent or provide against by exercising
reasonable diligence.'' \115\
---------------------------------------------------------------------------
\115\ NARUC Model--Definitions.
---------------------------------------------------------------------------
Commission Conclusion
381. We agree with NARUC that some modification to the Proposed
SGIA is needed and we are adopting a Force Majeure clause that melds
the best aspects of NARUC's and the Commission's proposals. For
instance, this Final Rule provision allows the Party asserting the
Force Majeure Event to call or write to the other Party to make the
required notification. Easy notification ensures that both Parties know
of a Force Majeure Event as soon as possible.
382. We are not adopting all of NARUC's proposals, however. The
NARUC Model would not allow a Party to invoke Force Majeure if it could
have prevented the event through the exercise of ``reasonable
diligence.'' Our SGIA uses the terms ``negligence'' and ``intentional
wrongdoing,'' which are commonly accepted legal terms.
383. Finally, we are moving the definition of Force Majeure Event
to the body of the SGIA from an appendix.
384. Reactive Power--The Proposed SGIA did not include a separate
provision for reactive power; however, the LGIA does.
Comments
385. CA ISO and Southern Company ask the Commission to include a
provision for reactive power in the interconnection agreement. CA ISO
argues that this provision is essential for the reliability of the
Western Interconnection because the entire region is afflicted by
voltage instability. A Small Generating Facility interconnecting at the
transmission level should meet the reactive power requirements of the
CA ISO tariff and abide by reactive power dispatch instructions from
the control area operator. Moreover, a Small Generating Facility
interconnecting at the ``distribution'' level should meet reactive
power requirements specified in the Wholesale Distribution Access
Tariff and abide by any reactive power dispatch instructions from the
Distribution System operator.
386. Southern Company notes that the LGIA has a reactive power
provision and argues that one should be included in the SGIA as well.
Otherwise, a Small Generating Facility could become a burden on the
Transmission Provider's electric system. The Transmission Provider
should be provided real-time information on the status and output of
each generator to ensure safe and reliable operation.
Commission Conclusion
387. We are requiring the Interconnection Customer's Small
Generating Facility to maintain a power factor within the range of 0.95
leading to 0.95 lagging, unless the Transmission Provider establishes
and the Commission approves different requirements that apply to all
similarly situated generators. There is no reactive power requirement
for wind powered Small Generating Facilities.
388. Generator Balancing Requirements--The Proposed SGIA did not
include a separate generator balancing provision.
Comment
389. Southern Company argues that the SGIA should include
provisions for generator balancing service, and presents several
arguments in support of its position.
Commission Conclusion
390. In Order No. 2003-A, the Commission determined that generator
balancing service is more closely related to delivery service than to
interconnection service, and because delivery service requirements are
addressed elsewhere in the OATT, the balancing service requirement need
not appear in the interconnection agreement. On rehearing, the
Commission in Order No. 2003-B did not add a generator balancing
service provision to the LGIA, but it did permit the Transmission
Provider to include a provision for generator balancing service in
individual interconnection agreements. We reach the same conclusion
here.\116\ Any such provision should be tailored to the Parties'
specific circumstances and is subject to Commission approval.
---------------------------------------------------------------------------
\116\ Order No. 2003-B at P 72-75.
---------------------------------------------------------------------------
391. Appendices to the SGIA--The Proposed SGIA included five
appendices (called attachments in the Final Rule SGIA) that set forth
technical and operating information, including: (1) A description and
statement of the costs of the Small Generating Facility,
Interconnection Facilities, and metering equipment; (2) a one-line
diagram depicting the Small Generating Facility, Interconnection
Facilities, metering equipment and Upgrades; (3) project milestones;
(4) additional operating requirements for the Transmission Provider's
electric system and Affected Systems needed to support the
Interconnection Customer's needs; and (5) the Transmission Provider's
[[Page 34223]]
description of its Network Upgrades and Distribution Upgrades and a
best estimate of their costs.
Comments
392. Central Maine and NYTO state that these appendices would
require information that is not needed. They ask that the appendices
include only: (1) Small Generating Facility description, (2) one-line
diagram, (3) description of the Interconnection Facilities, (4)
operation and maintenance (O&M) costs, and (5) operating procedures.
They state that additional operating procedures may have to be
developed with input from the Transmission Owner and the
Interconnection Customer to ensure system integrity and reliability.
Commission Conclusion
393. We are not persuaded that any change in the appendices is
warranted. With the exception of O&M costs, all the items that Central
Maine and NYTO would have us include in the appendices are already
there. We agree with Central Maine and NYTO that additional operating
procedures with input from both the Transmission Provider and the
Interconnection Customer may be needed, and we encourage such efforts.
The treatment of O&M costs is discussed in more detail in Part II.H
below (Responsibility for Operation and Maintenance Costs).
G. The 10 kW Inverter Process
394. In the Small Generator Interconnection NOPR, the Proposed SGIP
included a default interconnection Study Process for Small Generating
Facilities and a simplified procedure that used technical screens for
certified Small Generating Facilities no larger than 2 MW. The Proposed
SGIA, however, would be used for the interconnection of all Small
Generating Facilities, up to and including 20 MW in size. The NOPR did
not include a separate procedures document or interconnection agreement
for very small generators, although some commenters urged, in comments
submitted in response to the ANOPR, that 0-50 kW facilities (especially
facilities that use inverters to convert the direct current output of
the generator to alternating current) need a separate and simpler
process than other generators.
Comments
395. Some commenters argue that the Proposed SGIP and Proposed SGIA
are too complicated for very small Interconnection Customers. Small
Generator Coalition states that unless the Commission is willing to
modify the NOPR in fundamental ways, many of its members believe that
development of Small Generating Facilities would be better served if
the NOPR were simply withdrawn. It claims that, under the Proposed SGIP
and Proposed SGIA, the only method by which even a small photovoltaic
system, say 10 kW, could interconnect with the Transmission Provider is
to follow the same process that would apply to generators 1,000 times
larger. It asks the Commission to ``recognize the simplicity of the
very smallest generators and [to] include an exception for small
inverter-based systems.'' Plug Power, also representing small generator
interests, states that a special process should be adopted for very
small generators because their interconnection requirements are
fundamentally different from those of larger facilities. Moreover,
adopting simpler requirements would foster the growth of ``plug and
play'' equipment.
396. NRECA, which represents a wide variety of cooperative
utilities that interconnect with small generators, states that it has
adopted special procedures for evaluating very small generators because
they generally interconnect at low voltage and have different technical
requirements from larger ones.
397. Some state regulatory authorities already have a simplified
process for very small generators. NJ BPU points out that it has
adopted simplified procedures for qualified very small inverter-based
generators. NARUC, in its updated Model, supports a simplified
Interconnection Request (application) for very small generators.
398. Joint Commenters submits in its supplemental comments a
streamlined process for certified inverter-based generators no larger
than 10 kW. This consists of a simplified Interconnection Request,
simplified procedures, and a brief set of terms and conditions (that is
essentially a highly simplified interconnection agreement )--all
contained in a single document. This Joint Commenter proposal consists
of the following steps: (1) The Interconnection Customer completes an
abbreviated Interconnection Request and signs the terms and conditions
when it submits its Interconnection Request to the Transmission
Provider; (2) the Transmission Provider uses the Fast Track Process
technical screens to evaluate the Interconnection Request; (3) if the
proposed interconnection passes the technical screens, the Transmission
Provider approves the application; (4) once the Interconnection
Customer's equipment has been installed, it sends a certificate of
completion to the Transmission Provider; and (5) the Transmission
Provider then inspects the equipment installation and, if satisfied
that it is safe for operation, authorizes the interconnection.
Commission Conclusion
399. The comments demonstrate a near universal agreement of the
need for special provisions for very small generators, a need that is
being met at least in part by some state regulatory authorities. We
agree with the commenters who state that the Proposed SGIP and Proposed
SGIA are too complicated for very small generators, and we recognize
the desire to accommodate their interconnection needs. However, a
single document tailored for the needs of the smallest generators would
be unsuitable for the interconnection of larger small generators; their
technical evaluations and their legal rights and responsibilities must
be set out in greater detail.
400. We conclude that a balanced response to the comments is to
issue two sets of documents--an SGIP and SGIA that serve the needs of
most small generators, and a simplified document that meets the needs
of very small generators.
401. Joint Commenters' proposed process for the interconnection of
very small generators, which enjoys broad support from a variety of
stakeholder interests, is simple to implement while ensuring the safety
and reliability of the Transmission Provider's electric system.
Accordingly, we are adopting it in this Final Rule with minor
modification under the name ``10 kW Inverter Process.'' The simplified
10 kW Inverter Process consists of an Interconnection Request,
simplified procedures, and a brief set of terms and conditions
applicable to inverter-based 0-10 kW generators. It is included as
Attachment 5 to the SGIP. This ``all-in-one'' document combines the
attributes of both an interconnection procedures document and an
interconnection agreement. We are including it in the SGIP because it
is the SGIP that the Interconnection Customer will first encounter in
the process of interconnecting its Small Generating Facility with the
Transmission Provider. A flowchart showing the 10 kW Inverter Process
may be found in Appendix D of this Final Rule.
402. The 10 kW Inverter Process is user friendly and a
straightforward interconnection should be accomplished in short order.
To accelerate the process, by signing the application at the time of
submission,
[[Page 34224]]
the Interconnection Customer executes what essentially is an
interconnection agreement, in the form of standard terms and conditions
with which it agrees. This eliminates the additional step of signing an
interconnection agreement if the proposed interconnection passes the
screens.
403. The 10 kW Inverter Process, by its very name, applies only to
equipment that is interconnected with the Transmission Provider's
electric system through an inverter. Inverter-based equipment has a
very small likelihood of causing safety and reliability concerns on the
Transmission Provider's electric system because it can quickly
disconnect from the electric system when a disturbance occurs.
Nonetheless, while the 10 kW Inverter Process should facilitate the
interconnection of this class of Small Generating Facilities, the
technical requirements for interconnection are just as rigid as those
for all Small Generating Facilities up to 2 MW in size that elect to
use the Fast Track Process. Specifically, they must be certified by a
Nationally Recognized Testing Laboratory and the proposed
interconnection must pass the technical screens. Consequently,
interconnections will not be permitted if they jeopardize the safety
and reliability of the Transmission Provider's electric system.
404. Although the Interconnection Customer signs an abbreviated set
of terms and conditions when it submits its Interconnection Request
under the 10 kW Inverter Process, it is a legal instrument nonetheless.
Its provisions are consistent with the SGIA. Should a dispute arise, we
encourage the Parties to use this rulemaking for assistance in
interpreting the terms and conditions of the 10 kW Inverter Process.
Moreover, because the intent of the terms and conditions in this
document are the same as those of the SGIA, no separate discussion of
them is necessary here again in this Final Rule.
405. The 10 kW Inverter Process is quick, inexpensive, and user
friendly. Including it in this Final Rule removes barriers to the
development and interconnection of this class of Small Generating
Facilities, both at the federal and state jurisdiction levels. Its
adoption should promote standardization of interconnection rules across
the nation. We encourage states that do not have interconnection
procedures for very small generators to consider using this as a model
for their own rules.
H. Other Significant Issues
406. A number of issues, such as interconnection pricing policy,
variations permitted for independent transmission entities, and legal
issues such as liquidated damages, transcend individual provisions of
the SGIP and SGIA. Accordingly, we address them below.
Pricing/Cost Recovery for Interconnection Facilities and Upgrades
(Proposed SGIA Article 5.1)
407. In the Small Generator Interconnection NOPR, the Commission
proposed to retain its then existing pricing policy for the
interconnection of a Generating Facility with a Transmission System
that is operated by a non-independent entity. That policy, as set forth
in Order No. 2003, was to allocate the costs of the new or upgraded
transmission facilities based on a locational test: Whether they are at
or beyond the Point of Interconnection. Facilities that are on the
Small Generating Facility's side of the Point of Interconnection would
be considered Interconnection Facilities, while those that are at or
beyond the Point of Interconnection would be considered Network
Upgrades. The Interconnection Customer would be directly assigned the
costs of all Interconnection Facilities because they are sole use
facilities. The Interconnection Customer would initially fund the
Network Upgrades required for the interconnection unless the
Transmission Provider chooses to pay for them itself. However, the
Interconnection Customer would be entitled to a refund equal to the
total amount paid to the Transmission Provider and the Affected System
operator, if any, for Network Upgrades, including any tax-related
payments. Order No. 2003 called for these refunds to be paid to the
Interconnection Customer, with interest, as credits on a dollar-for-
dollar basis for the non-usage sensitive portion \117\ of transmission
charges, as payments are made under the Transmission Provider's tariff
and the Affected System's tariff for any transmission services taken by
the Interconnection Customer on the respective systems, whether or not
the Generating Facility is the source of the power being
transmitted.\118\ Order No. 2003 permitted the Interconnection
Customer, Transmission Provider, and Affected System operator to adopt
any alternative payment schedule that is mutually agreeable provided
all amounts paid by the Interconnection Customer for Network Upgrades
are refunded, with interest, within five years of the generating
facility's commercial operation date.\119\ The Interconnection Customer
would be allowed to assign its refund rights to any person.
---------------------------------------------------------------------------
\117\ Non-usage sensitive transmission charges include all
transmission charges except those for items that vary with the
amount of power transmitted, such as congestion charges, line
losses, and Ancillary Services.
\118\ In Order No. 2003-A, this policy was revised to make
credits available only for transmission service that has the
generating facility as the source of the power transmitted.
\119\ The five year refund period was subsequently changed to 20
years in Order No. 2003-B.
---------------------------------------------------------------------------
408. Because a Small Generating Facility may interconnect with a
Transmission Provider's Distribution System subject to an OATT in order
to make a sale of electricity at wholesale in interstate commerce, the
Small Generator Interconnection NOPR also addressed cost recovery for
Distribution Upgrades at or beyond the Point of Interconnection.\120\
Consistent with Order No. 2003, the Commission proposed that the costs
of Distribution Upgrades be directly assigned to the Interconnection
Customer because Distribution Upgrades do not generally benefit all
users.
---------------------------------------------------------------------------
\120\ The costs of all Interconnection Facilities, whether owned
by the Interconnection Customer or the Transmission Provider, are
directly assigned to the Interconnection Customer.
---------------------------------------------------------------------------
409. The Commission sought comments on whether this approach should
also apply to Small Generating Facilities. The Commission also invited
commenters to recount their recent experiences with interconnecting
small generators with the ``Distribution System,'' in particular the
process for determining whether Distribution Upgrades are necessary,
and the cost assignment of those Upgrades.
410. For a Transmission Provider that is an independent entity,
such as an RTO or ISO, the Commission's policy, as adopted in Order No.
2003, is to allow more pricing flexibility, subject to Commission
approval. Also in Order No. 2003, we permitted a Regional State
Committee to establish criteria that an independent entity would use to
determine which Network Upgrades should be subject to ``participant
funding.'' Order No. 2003 also permitted, for a period of transition to
the start of RTO or ISO operations, not to exceed a year, participant
funding to be used for Network Upgrades as soon as an independent
entity has been approved by the Commission and the affected states. In
the Small Generator Interconnection NOPR, the Commission proposed to
adopt the same policies for Small Generating Facilities that
interconnect with a Transmission System operated by an independent
entity. The Commission sought comments on this approach.
[[Page 34225]]
411. In the Small Generator Interconnection NOPR, the Commission
also proposed certain pricing provisions that are consistent with, but
have no direct parallel with, the Order No. 2003 pricing provisions.
The Proposed SGIA provided that costs associated with Interconnection
Facilities could be shared with other entities that may benefit from
such facilities by agreement of the Interconnection Customer, such
other entities, and the Transmission Provider. It also proposed that,
if the Parties agree that the Small Generating Facility benefits the
Transmission Provider's electric system, the Interconnection Customer's
cost responsibility for the Transmission Provider's Interconnection
Facilities or Upgrades would be reduced. The benefits would have to be
measurable and verifiable. Where there are multiple Interconnection
Requests and each requires Network Upgrades, Interconnection Customers
would be assigned costs or benefits separately if effects can be
attributed to different projects. Where such attribution is not
possible, Interconnection Customers would share costs or benefits in
proportion to their projected Small Generating Facility capacities.
Pricing Comments That the Commission Already Addressed in the Large
Generator Interconnection Proceeding
Comments
412. Several commenters object to various features of the
Commission's current interconnection pricing policy, presenting
arguments that the Commission has addressed in Order No. 2003. For
example, Alabama PSC and others argue that prohibiting the direct
assignment of the cost of Network Upgrades means that native load
customers subsidize the cost of Network Upgrades that benefit only the
Interconnection Customer. They argue that this may also cause the
Interconnection Customer to make inefficient siting decisions.
Mississippi PSC objects to the requirement that the Transmission
Provider pay interest on unused credits and that it make a lump sum
payment to the Interconnection Customer for credits that remain unused
after five years. Alabama PSC argues that transmission credits should
be provided only for Network Upgrades that provide a system benefit and
only when the Small Generating Facility is the source of power for the
transaction.
413. NRECA argues that if a merchant generator has not committed to
serve network and native load customers within the Transmission
Provider's footprint on a long-term basis, the generator and the
Transmission Provider's own generators are not comparable. It asserts
that credits are appropriate only where the Small Generating Facility
is committed to customers in the Transmission Provider's footprint.
414. Central Maine requests clarification that transmission credits
should be required only when the Interconnection Customer is taking and
paying for transmission service on the Transmission System on which the
Network Upgrade was made for the output of its facility. Central Maine
also requests clarification that cost responsibility for Network
Upgrades required by an Affected System is consistent with cost
responsibility for Network Upgrades required by the Transmission Owner
with whom an Interconnection Customer is directly interconnecting; that
is, that transmission credits are required only when the
Interconnection Customer takes and pays for transmission service from
the Transmission Owner or Affected System for the output of its
facility. It also asks that the contractual provisions concerning cost
responsibility and payment obligations among Affected Systems and
Interconnection Customers be in a separate agreement, not in the
interconnection agreement.
415. Avista, Alabama PSC, and Mississippi PSC argue that allowing
pricing flexibility to an independent Transmission Provider such as an
RTO or ISO is unduly discriminatory. They state that this policy
penalizes the retail customers of the non-independent Transmission
Provider because it forces them to bear the cost of Network Upgrades
that benefit only the Interconnection Customer. Idaho Power argues that
having different pricing for an independent and a non-independent
Transmission Provider is bad public policy, arbitrary and capricious,
and discriminatory. TAPS states that the NOPR incorrectly proposes
participant funding for Upgrades to a Transmission System operated by
an independent entity.
Commission Conclusion
416. All of the comments summarized above relate to the
Commission's general pricing policy, and each was discussed in Order
No. 2003.\121\ We adopt here the general conclusions adopted in those
orders. However, those orders did not address the specific question of
whether the Commission's general interconnection pricing policy is
suitable for Small Generating Facilities. Several commenters raise this
question, and we address their comments below.
---------------------------------------------------------------------------
\121\ See Order No. 2003 at P 675-750, Order No. 2003-A at P
562-697, and Order No. 2003-B at P 15-57.
---------------------------------------------------------------------------
Applicability of the Commission's Interconnection Pricing Policy to the
Interconnection of Small Generating Facilities
Comments
417. Several commenters support the use of the Commission's current
interconnection pricing policy. Western supports the Commission's
proposal to have the Interconnection Customer initially fund
interconnections and associated Transmission System improvements and
states that this approach is consistent with the budgetary realities
that Western faces. Georgia PSC agrees that Interconnection Facilities
are sole use facilities and, accordingly, should be directly assigned
to (paid for by) the Interconnection Customer.
418. Nevada Power states that interconnection pricing policies must
be consistent for both Small and Large Generating Facilities to avoid
the possibility of pricing manipulation. It opposes credits for
facilities that do not increase transfer capability, but states that
the requirement that the Interconnection Customer initially fund the
Network Upgrade costs is an important safeguard to ensure that the
Transmission Provider and other customers do not subsidize what would
otherwise be an uneconomic project. SoCal Edison states that the Small
Generator Interconnection NOPR correctly mirrors the Large Generator
Final Rule with respect to the pricing policies for Network Upgrades
and sole use Interconnection Facilities. BPA generally supports
consistency between pricing for Small and Large Generating Facility
interconnections, provided the Commission clearly articulates the
physical boundary between Interconnection Facilities and Network
Upgrades.
419. AEP and Midwest ISO agree that an independent Transmission
Provider should be allowed interconnection pricing policy flexibility,
subject to Commission approval. Midwest ISO states that few
circumstances would warrant an approach for Small Generating Facilities
that differs from the approach that an RTO would establish for a Large
Generating Facility. A common approach makes good business sense,
assures comparability and makes the interconnection process more
effective. Also, BPA generally supports RTO pricing flexibility,
provided it does not conflict with an
[[Page 34226]]
RTO's obligations under its governing agreements.
420. Cummins, however, argues that the Commission should adopt
different pricing rules for Small Generating Facilities because the
Commission's current policy gives the Transmission Provider the
discretion to place a huge cost burden on the Small Generating
Facility. These costs may even exceed the installation and operating
costs of a Small Generating Facility, completely destroying project
economics. Cummins argues that this problem can be addressed only by
specific performance standards (which Cummins does not describe) that
only the Commission can establish. Also, if the Interconnection
Customer is deemed to be the only beneficiary of the Upgrade or
interconnection, the five year refund mechanism would be of no benefit,
as the project would not go forward.
421. The Small Generator Interconnection NOPR asked for specific
examples of situations where a Transmission Provider has seemingly
applied excessive fees for Upgrades. Cummins describes two examples
that highlight its concerns:
A manufacturer installed a 300 kW synchronous generator and
cogeneration system, and provided the interconnection equipment
specified by the [Transmission Provider]. The system was approved by
the [Transmission Provider] and went into successful operation. When
the owner decided to expand the facility to include a second 300 kW
generator, they were informed that the distribution system would
need upgrades that would cost in excess of $140,000. On further
investigation, it was learned that the upgrades included only
``block closing'' provisions on a recloser. This device is
effectively a simple voltage sensing relay that would interconnect
into the existing infrastructure at a substation. After intensive
negotiations and investigations, the customer was able to get the
cost reduced to under $50,000, and the project went forward. The
$50,000 cost was still far more than the upgrade should have cost,
but the customer was forced to pay it because the generator was key
to the viability of the customer's business. This represented a 10%
increase in the overall project.
In another case, a customer installed a 2 MW synchronous
generator with equipment that allowed it to parallel with the
utility for 1/10th of a second. The equipment included timer
functions that prevented the machine from staying in parallel for
more than 1 second, as required by local rules. The [Transmission
Provider], unsatisfied with the ``quality'' or ``performance'' of
the relay in the customer's device, forced the customer to install a
new relay costing over $2,000 for the 1 second time function. This
was an excessively expensive piece [of] equipment to perform a
simple operation; however the Interconnection Customer needed the
equipment to operate, and had to pay the price.
422. Small Generator Coalition argues that the Small Generator
Interconnection NOPR's cost allocation provisions appear to guarantee
pancaked wheeling charges on energy produced by Small Generating
Facilities, contrary to the Commission's goal of eliminating such
pancaking.\122\
---------------------------------------------------------------------------
\122\ By ``pancaking,'' we presume that Small Generator
Coalition is referring to the possibility that the Interconnection
Customer may be required to pay for Distribution Upgrades and to
make an up-front payment for Network Upgrades.
---------------------------------------------------------------------------
423. MidAmerican states that a Commission rule requiring a
Transmission Provider to pay any interconnection-related costs could
supersede state policy and also would affect the ability of states to
set retail rates following well-established cost causation principles.
MidAmerican argues that the rules should permit the Transmission
Provider to directly assign all costs to the Interconnection Customer
unless that violates state regulatory policy.
Commission Conclusion
424. We recognize that the Interconnection Facilities, Distribution
Upgrades, and Network Upgrades required to interconnect a generator can
be costly. Indeed, such costs can be a significant portion of the total
project costs. Nevertheless, each Generating Facility, whether large or
small, must bear its fair share of the cost of the facilities and
Upgrades from which it benefits; otherwise, the facility simply does
not make economic sense.
425. To this end, the Small Generator Interconnection NOPR proposed
to apply to Small Generating Facility interconnections the same pricing
policy that the Commission adopted for Large Generating Facilities in
Order No. 2003. Among other things, this means that the Interconnection
Customer must bear the cost of necessary Interconnection Facilities and
Distribution Upgrades. Also, the Interconnection Customer must
initially fund the cost of Network Upgrades, but is entitled to credits
against its charges for transmission delivery service equal to the
amount funded, plus interest. None of the arguments presented here
convinces us that the policies adopted in Order No. 2003 should not
also apply to Small Generating Facility interconnections. In
particular, contrary to the assertions of Cummins and Small Generator
Coalition, we do not view the policy as creating rate pancaking or an
undue burden for the Small Generating Facility. Thus, we adopt the
Order No. 2003 pricing policies for small generator interconnections in
this Final Rule.
426. With regard to Cummins's concern that the Transmission
Provider may be able to force the Small Generating Facility to bear
unreasonable costs, we note that our principal purpose in adopting a
standardized procedures document and agreement for generator
interconnections, and making them part of the Transmission Provider's
tariff, is to eliminate much of the opportunity for the Transmission
Provider to act in this manner. Indeed, adoption of this Final Rule
should greatly reduce the likelihood of the two negative experiences
that Cummins describes, if indeed the cost were unreasonable.
427. In response to MidAmerican, this Final Rule applies only to
generator interconnections that are under the jurisdiction of the
Commission. It does not apply where we do not have jurisdiction.
Although state regulators or other rate-making authorities may model
their own policies after those adopted herein, or the similar NARUC
Model, they are free to establish whatever rules for determining cost
responsibility that they deem reasonable for interconnections under
their jurisdiction.
428. The Commission modified and clarified its pricing policy for
Large Generator Interconnections in Order Nos. 2003-A and 2003-B, which
were issued after the Small Generator Interconnection NOPR in this
proceeding. Upon review of the revisions to the Commission's pricing
policy included in those orders, we conclude that they should apply to
the interconnection of Small Generating Facilities as well. Therefore,
we are revising the Proposed SGIA to reflect our current
interconnection pricing policy as modified by Order Nos. 2003-A and
2003-B. (See articles 4 and 5 of the SGIA).
Implementation of the Interconnection Pricing Policy for Small
Generating Facilities
Comments
429. Midwest ISO notes that Chart 1 of the Proposed SGIP shows a
difference between the Point of Interconnection and the ``point of
common coupling'' \123\ and says that equipment Upgrades may sometimes
be needed between these two points. Midwest ISO asks who is to be
responsible for such Upgrades and whether transmission service credits
will be provided to the Interconnection Customer if it finances the
Upgrades.
---------------------------------------------------------------------------
\123\ The term ``Point of Common Coupling'' is not used in the
SGIP and SGIA.
---------------------------------------------------------------------------
430. Empire District agrees that Upgrades that are directly
assigned,
[[Page 34227]]
such as radial extensions to the generator, should not be paid for (or
reimbursable to the Interconnection Customer) by the Transmission
Provider. In addition, it states that interconnection costs should be
treated in a manner similar to the crediting methods used by the
Southwest Power Pool (which Empire District does not describe).
431. Many commenters support the Commission's proposal to directly
assign the cost of Distribution Upgrades to the Interconnection
Customer.\124\ For example, AEP states that a Distribution Upgrade that
is required to accommodate the proposed generator does not benefit all
users; rather, its sole purpose is to accommodate one customer. AEP
contends, therefore, that it is entirely reasonable for the
Interconnection Customer to be responsible for the cost of the
Distribution Upgrade. Cinergy states that such responsibility follows
from the radial nature of the Distribution System and is consistent
with the LGIA. Baltimore G&E states that the Commission must guarantee
that distribution utilities receive full cost recovery from
interconnecting Small Generating Facilities to avoid subsidization by
retail customers.
---------------------------------------------------------------------------
\124\ See, e.g., AEP, Alabama PSC, Baltimore G&E, Central Maine,
Cinergy, Consumers, MidAmerican, Mississippi PSC, Nevada Power,
NRECA, and SoCal Edison.
---------------------------------------------------------------------------
432. Nevada Power agrees that the cost of Distribution Upgrades
should be directly assigned to the Interconnection Customer, but is
concerned that Proposed SGIA article 5.1.3 does not adequately protect
the Transmission Provider from having to bear such costs. This article
could be construed to say that wholesale transactions by the
Interconnection Customer change the segment of the distribution
facilities to which the Interconnection Customer connects into
transmission facilities. Nevada Power argues that the Proposed SGIA
definition of Transmission System illustrates this concern:
``Transmission System shall mean the facilities owned, controlled or
operated by the Transmission Provider or Transmission Owner that are
used to provide transmission service under the Tariff.'' An inference
can be drawn that what was previously a distribution facility is now a
transmission facility because it provides transmission service, and is
therefore subject to the crediting process. To address this concern,
Nevada Power proposes specific changes to Proposed SGIA article 5.1.3.
433. SoCal Edison notes that in the Small Generator Interconnection
NOPR, Distribution Upgrades and Network Upgrades are both defined as
being at or beyond the Point of Interconnection. Distribution Upgrades
are defined as upgrades to the Distribution System, while Network
Upgrades are defined as upgrades to the Transmission System. However,
``Transmission System'' is defined to include any facility, be it
transmission or distribution, that is subject to an OATT. Therefore,
SoCal Edison contends that because ``Transmission System'' is defined
to include portions of the Distribution System, the definition of
Network Upgrades (in combination with other provisions of the SGIP and
SGIA) is confusing. SoCal Edison argues that keeping the terms
Transmission System and Distribution System distinct is crucial. For
this reason, the definition of Transmission System needs to exclude
distribution facilities, which facilities already are included in the
term Distribution System.
434. In a similar vein, PacifiCorp argues that the definition of
Network Upgrades must be revised to prevent it from being applied to
Upgrades to a Transmission Provider's Distribution System. The Proposed
SGIA's definition of Network Upgrades could be read to include Upgrades
to radial feeders or other facilities that are part of the Transmission
Provider's Distribution System. In PacifiCorp's view, Network Upgrades
should include only Upgrades to networked transmission or sub-
transmission facilities. Any Upgrades to radial feeders or other
facilities that make up the Transmission Provider's Distribution System
should be paid for by the Interconnection Customer without credits.
435. PSE&G states that the definition of Network Upgrades should be
modified as follows: ``[Network Upgrades] shall mean the additions,
modifications and upgrades * * * required (strike out ``at or'') beyond
the point at which the Interconnection Customer interconnects to the
Transmission Provider's or Transmission Owner's or distribution owner's
(strike out ``Transmission'' and add ``Distribution'') System to
accommodate the Generating Facility * * *.''
436. NRECA states that the Commission has an important role in
determining whether facilities are distribution or transmission. The
Commission should apply the seven-factor test where there are disputes
and should not in doing so give undue deference to state or public
utility classifications of facilities. As shown by cases such as
Arkansas Power & Light,\125\ the Commission may conclude that a
facility serves a transmission function even if it is lower voltage and
serves a few end-use customers, if the predominant use of the facility
is to provide wholesale transmission service.
---------------------------------------------------------------------------
\125\ Arkansas Power & Light Co. v. FPC, 368 F. 2d 376 (8th Cir.
1966) (Arkansas Power & Light).
---------------------------------------------------------------------------
437. In addition, NRECA seeks clarification of the NOPR's statement
that ``if a proposed interconnection passes either the super-expedited
screening procedures or the expedited screening procedures, the
Interconnection Customer would have no cost responsibility for
Upgrades.'' NRECA contends that this contradicts article 5.1.3 of the
Proposed SGIA (Distribution Upgrades), and thus is inconsistent with
the Commission's proposal to require Distribution Upgrades to be
directly assigned to the Interconnection Customer. Furthermore, the
statement would shift costs from the Interconnection Customer to
utilities and their other customers. Also, Cummins says that the
proposal runs counter to, or may confuse the application of, screens
that would expedite the interconnection process.
438. Small Generator Coalition states that although Proposed SGIA
article 5.1.5 gives the Interconnection Customer an opportunity to
demonstrate benefits to the Transmission Provider's electric system
that would reduce the Interconnection Customer's costs, the NOPR's
discussion of Distribution Upgrades at P 72 appears to rule out any
cost reductions for Distribution Upgrades. In addition, Small Generator
Coalition argues that ambiguous NOPR provisions may permit Transmission
Owners to require the Interconnection Customer to pay for Network
Upgrades with no compensation to the Interconnection Customer or
consideration of network benefits. Because downstream resources can
benefit system reliability, Small Generator Coalition argues that the
Commission's rule should allocate Upgrade costs according to benefits
to all portions of an affected Transmission System, including
facilities operating at distribution voltages.
439. Alabama PSC and Mississippi PSC argue that distribution
facilities should be directly assigned. However, because the Commission
lacks jurisdiction over distribution facilities, cost responsibility
for Distribution Upgrades is an issue for state regulators to address.
440. Midwest ISO notes that Proposed SGIA article 5.1.5 provides
that if the Parties agree that the Small Generating Facility benefits
the Transmission
[[Page 34228]]
Provider's electric system, the Interconnection Customer's cost
responsibility may be reduced accordingly. The Small Generator
Interconnection NOPR says that, if multiple facilities are involved,
pro rata allocation of the costs or benefits must be made. These
provisions appear to conflict with the NOPR's proposal at P 71, which
allows an RTO flexibility with respect to interconnection pricing.
Commission Conclusion
441. With reference to Chart 1 of the Proposed SGIP, Midwest ISO
asks who is responsible for the cost of Upgrades between the point of
common coupling and the Point of Interconnection. Chart 1 was in error.
The Point of Interconnection is the point identified as the point of
common coupling, which is the point in the diagram where the
Interconnection Facilities connect to the Transmission Provider's
Distribution System subject to an OATT. Thus, the Upgrades to which
Midwest ISO refers are in fact Interconnection Facilities, and their
cost is directly assigned to the Interconnection Customer.
442. In response to Empire District, we confirm that radial
extensions to the Small Generating Facility are to be directly assigned
to the Interconnection Customer if they are Interconnection Facilities;
that is, if the radial line is a sole use facility located between the
Small Generating Facility and the Point of Interconnection, its cost is
directly assigned to the Interconnection Customer. Also, Empire
District recommends that the Commission adopt a crediting policy that
is similar to the methods set forth by the Southwest Power Pool.
However, Empire District does not explain how its recommended methods
differ from or are better than those proposed in the NOPR.
443. In order to eliminate the confusion expressed by Nevada Power,
SoCal Edison and others about the distinction between Distribution
Upgrades and Network Upgrades, we are adding the following sentence to
the definition of Network Upgrades: ``Network Upgrades do not include
Distribution Upgrades.''
444. NRECA seeks clarification of the Small Generator
Interconnection NOPR's statement that ``if a proposed interconnection
passes either the super-expedited screening procedures or the expedited
screening procedures, the Interconnection Customer would have no cost
responsibility for Upgrades.'' The issue of who pays for an Upgrade in
the case of a proposed interconnection passing all the screens is moot
because one of the provisions of SGIP section 2.2.1 is a requirement to
pass a screen that the interconnection must not require an Upgrade.
445. Small Generator Coalition is concerned that the Proposed SGIA
may assign to the Interconnection Customer cost responsibility for
Interconnection Facilities in a way that gives no recognition to the
benefits that the Interconnection Facilities may bring to the
Transmission Provider's electric system. In response, we clarify that
the Interconnection Customer is responsible for the cost of
Interconnection Facilities except when such cost is shared with other
entities that may benefit from the Interconnection Facilities by
agreement of the Interconnection Customer, the other entities, and the
Transmission Provider. This provision for cost sharing is included in
SGIA article 4.1.1.
446. Small Generator Coalition also asks about sharing cost
responsibility for Distribution Upgrades and initial funding
responsibility for Network Upgrades. The Interconnection Customer is
responsible for the upfront funding of Network Upgrades unless the
Transmission Provider elects to provide the upfront funding itself.
This payment option is included in SGIA article 5.2. However, we are
not adopting the explicit cost sharing provisions of Proposed SGIA
article 5.1.5 relating to Distribution Upgrades because they are not
consistent with Order No. 2003 which specified that all Distribution
Upgrades shall be directly assigned to the Interconnection
Customer.\126\
---------------------------------------------------------------------------
\126\ See LGIA article 11.3 (``The Interconnection Customer
shall be responsible for all costs related to Distribution
Upgrades.'')
---------------------------------------------------------------------------
447. In response to Midwest ISO, we clarify that we are allowing
flexibility for the pricing that an independent Transmission Provider
may propose to adopt, subject to Commission approval, under the
``independent entity'' variation. Accordingly, an independent
Transmission Provider may propose a pricing method that differs from
what this Final Rule otherwise requires.
448. Alabama PSC and Mississippi PSC assert that cost
responsibility for Distribution Upgrades is beyond the scope of the
Commission's authority. As explained above, the Commission's assertion
of jurisdiction here is no broader than in Order No. 888. This Final
Rule applies to interconnections with a Transmission System or with a
Distribution System subject to an OATT for the purpose of making
wholesale sales. The Commission's authority over such interconnections
with Distribution Systems, for the purposes of making a wholesale sale
of electricity in interstate commerce, includes allocating the cost of
all of the Transmission Provider's Upgrades needed to effect the
interconnection. Otherwise, the Commission could not ensure that the
costs incurred to provide a jurisdictional service are allocated
appropriately. The pricing policy for Distribution Upgrades directly
assigns costs to the Interconnection Customer so there is no impact on
retail customers of the Distribution System.
Responsibility for Operation and Maintenance Costs
449. Proposed SGIA article 5.1.4 stated that the Interconnection
Customer is responsible for the operating and maintenance costs
associated with the Interconnection Facilities that it owns as well as
those owned by the Transmission Provider. The Proposed SGIA did not
assign responsibility for O&M costs associated with Network Upgrades or
Distribution Upgrades.
Comments
450. Central Maine and NYTO ask the Commission to clarify that the
Interconnection Customer is responsible for ongoing O&M costs
associated with Network Upgrades when the Interconnection Customer does
not take and pay for transmission service for the output of its Small
Generating Facility.
451. Southern Company contends that Proposed SGIA article 5.1.4
contemplates that the Interconnection Customer is responsible for all
reasonable expenses associated with operating and maintaining its own
Interconnection Facilities and the Transmission Provider's
Interconnection Facilities, but it is unclear whether all applicable
O&M costs are covered. It notes that LGIA article 10.5 does not limit
O&M cost recovery to the Transmission Provider's Interconnection
Facilities, but explicitly provides that the Interconnection Customer
is responsible for all reasonable O&M costs. Therefore, Southern
Company proposes to revise article 5.1.4 to include Distribution
Upgrades so as to ensure that all appropriate O&M costs are included.
452. Robert L. Carrey contends that the Interconnection Customer
should pay only the O&M costs of the Interconnection Facilities built
on its behalf. He argues that the Interconnection Customer should not
have to pay for routine O&M costs where no Interconnection Customer and
Transmission Provider share the same poles and rights-of-way.
Commission Conclusion
453. The Commission has long held that O&M costs associated with
Network
[[Page 34229]]
Upgrades cannot be directly assigned to the Interconnection Customer,
because Network Upgrades are part of the integrated transmission system
from which all transmission users benefit.\127\ Therefore, we deny the
requests of Central Maine and NYTO that the Commission require the
Interconnection Customer to pay O&M costs associated with Network
Upgrades.\128\
---------------------------------------------------------------------------
\127\ See, e.g., PJM Interconnection, L.L.C., 109 FERC ] 61,326
(2004) (holding that O&M costs associated with Network Upgrades may
not be directly assigned to the Interconnection Customer). We note,
however, that the Transmission Provider may propose to recover the
cost of Network Upgrades from the Interconnection Customer through
an incremental transmission rate. In that case, the Commission would
entertain a proposal to include in the incremental rate O&M costs
associated with the Network Upgrades. Order No. 2003-B at P 57.
\128\ This issue was discussed at P 421-424 of Order No. 2003-A.
---------------------------------------------------------------------------
454. While the SGIA authorizes the Transmission Provider to collect
O&M costs associated with Interconnection Facilities, this Final Rule
does not contain a rate recovery mechanism for collecting those costs,
because such costs will vary from case to case. Therefore, if a
Transmission Provider wishes, it may propose and justify its rate to
recover such costs under section 205 of the FPA.\129\ In response to
Southern Company, a Transmission Provider may make a similar filing to
recover from the Interconnection Customer an appropriate share of any
Commission-jurisdictional component of the O&M costs of Distribution
Upgrades. Absent Commission approval of such a rate schedule, the
Transmission Provider may not collect Commission-jurisdictional O&M
costs associated with Interconnection Facilities or Distribution
Upgrades.
---------------------------------------------------------------------------
\129\ 16 U.S.C. 824d (2000); see also 18 CFR 35.12 (2004).
---------------------------------------------------------------------------
455. In response to Mr. Carrey, the Transmission Provider is free
to propose to recover these expenses in any manner it sees fit;
however, the Commission will approve the Transmission Provider's
proposed rate if it is shown to be just and reasonable and not unduly
discriminatory or preferential.
Responsibility for the Construction of Upgrades
456. Proposed SGIA article 5.1.2 stated that the Transmission
Provider or Transmission Owner shall design, procure, construct,
install, and own the Network Upgrades.
Comments
457. PacifiCorp states that the Parties should be permitted to
agree that the Network Upgrades will be built by the Interconnection
Customer on its land. This could facilitate a faster interconnection.
In addition, Proposed SGIA article 3.3 should be revised to give the
Transmission Provider the right to inspect, operate, or maintain
Network Upgrades on the Interconnection Customer's land.
458. AMP-Ohio states that, in the region where its members'
Distribution Systems are located, the Transmission Provider would be an
RTO. It notes that Proposed SGIA article 5.1.3 stated that the
``Transmission Provider or Transmission [Owner] shall design, procure,
construct, install, and own the distribution Upgrades * * *'' AMP-Ohio
is concerned that this article could be construed to allow the RTO to
own and operate piecemeal sections of a member's electric system. The
Commission should clarify that one entity cannot assert the right to
own a portion of another's electric system.
Commission Conclusion
459. In response to PacifiCorp, neither Proposed SGIA article 5.1.2
nor article 5.1.3 precluded the Parties from agreeing that the
Interconnection Customer may construct Network Upgrades or Distribution
Upgrades on its own land. Nevertheless, we make this option explicit in
SGIA articles 4.2 and 5.2. PacifiCorp's proposed revisions to Proposed
SGIA article 3.3 are addressed above in our discussion of that article.
460. In response to AMP-Ohio, we clarify that this Final Rule does
not authorize any entity, including the Transmission Provider, to own a
portion of another entity's Transmission System without the permission
of the Transmission Owner.
Miscellaneous Pricing Issues
Comments
461. PacifiCorp notes that Proposed SGIA article 5.1.2.1 would
permit a refund to an Interconnection Customer whose Small Generating
Facility does not achieve commercial operation, if another customer
uses the Network Upgrades for which the first Interconnection Customer
paid. PacifiCorp asks that this provision specify that a refund is
available only if the second Interconnection Customer actually requires
the Network Upgrades for its Small Generating Facility.
462. TAPS states that the NOPR does not make the Transmission
Provider remove its own Interconnection Facilities from rate base.
Commission Conclusion
463. We agree with PacifiCorp that the first Interconnection
Customer should not receive a refund of amounts it has advanced for
Network Upgrades unless the later Interconnection Customer's Small
Generating Facility actually would have required the construction of
the Network Upgrades. However we believe that the SGIA, as written,
makes this clear. To make a change to this provision would imply that
it means something different from the similar provision adopted in the
LGIA, and that is not our intent, therefore we decline to accept
PacifiCorp's proposed modification.
464. With regard to the issue that TAPS raises, the Commission
addressed this matter in Order No. 2003. There the Commission required
the Transmission Provider to remove from transmission rates the costs
of Interconnection Facilities constructed by the Transmission Provider
after March 15, 2000 to interconnect generating facilities owned by the
Transmission Provider on the effective date of the Final Rule in the
Large Generator Interconnection proceeding.\130\ The Commission's
conclusion about the need for the Transmission Provider to remove its
own Interconnection Facilities from rate base was not intended to be
limited to Large Generating Facilities. We clarify here that it applies
to all of the Transmission Provider's Interconnection Facilities,
regardless of the size of the associated generating facility.
---------------------------------------------------------------------------
\130\ See Order No. 2003 at P 744 and Order No. 2003-A at P 663.
---------------------------------------------------------------------------
Commission Jurisdiction Under the Federal Power Act
465. Sections 205 and 206 of the FPA require the Commission to
remedy undue discrimination by public utilities. In Order No. 888, the
Commission found that public utilities owning or controlling
jurisdictional transmission facilities had the incentive to engage in,
and had engaged in, unduly discriminatory practices.\131\ Because
interconnection is an element of transmission service that must be
provided under the OATT, the Commission in Order No. 2003 established
generic interconnection terms and procedures under its authority to
remedy undue discrimination under sections 205 and 206.\132\ The Small
Generator Interconnection NOPR proposed that its jurisdictional reach
would be identical to Order No. 2003.
---------------------------------------------------------------------------
\131\ Order No. 888 at 31,679-84; Order No. 888-A at 30,209-10.
\132\ Order No. 2003 at P 18-20.
---------------------------------------------------------------------------
[[Page 34230]]
Comments
466. NARUC, NRECA, several state regulatory commissions,\133\ and
others \134\ argue that the Small Generator Interconnection NOPR
unlawfully encroaches upon the jurisdiction of the states by proposing
to regulate interconnections with ``local distribution'' facilities.
---------------------------------------------------------------------------
\133\ E.g., Alabama PSC, CPUC, CT PUC, Florida PSC, Iowa
Utilities Board, Mississippi PSC, North Carolina Commission, and
NYPSC.
\134\ E.g., Baltimore G&E, Central Maine, Consumers, EEI, Idaho
Power, PacifiCorp, Progress Energy, and Southern Company.
---------------------------------------------------------------------------
467. Many of the commenters opposing the Commission's exercise of
jurisdiction over facilities used both for Commission-jurisdictional
and for state-jurisdictional transactions (``dual-use'' facilities)
cite Detroit Edison.\135\ They appear to have read Detroit Edison as
forbidding the exercise of federal jurisdiction over any facilities
used to any degree to distribute bundled power to end-users at retail,
regardless of whether those facilities are also used for transactions
that are under the Commission's jurisdiction.\136\ Other commenters,
including Small Generator Coalition and SoCal Edison,\137\ assert that
nothing in Detroit Edison prevents the Commission from asserting
jurisdiction over all interconnections made to facilitate Commission-
jurisdictional activities.
---------------------------------------------------------------------------
\135\ Shortly before comments were due in this docket, the DC
Circuit issued Detroit Edison v. FERC, 334 F.3d 48 (DC Cir. 2003)
(Detroit Edison). Since then, the Commission has issued both Order
Nos. 2003-A (at P 705 et seq.) and 2003-B (at P 14), which discuss
Detroit Edison at length.
\136\ Alabama PSC at 4-5 (citing 16 U.S.C. 824(b) (2003), which
states that ``[t]he Commission * * * shall not have jurisdiction * *
* over facilities used in local distribution * * *.'')
\137\ Id. at 10 (emphasis in original).
---------------------------------------------------------------------------
468. Interconnections with ``distribution'' facilities, argues
Alabama PSC, should be exclusively state-jurisdictional. It argues that
``the Courts have long recognized and enforced the State's primacy over
the regulation of distribution facilities.''\138\ CPUC makes a similar
argument, stating that:
---------------------------------------------------------------------------
\138\ Id. at 5 (citing Southern Co. Services, Inc. v. FCC, 293
F.3d 1338, 1344 (11th Cir. 2002)).
federal law was meant to supplement--and not to supplant--state
regulation of those utilities. The FPA was enacted to fill in gaps
not covered by state regulation, not as a mechanism for avoiding
state regulation of public utilities. In enacting the FPA, Congress
did not purport to exercise all of the authority it might have
exercised under the Commerce Clause, because its intention was to
preserve, not override, state regulatory jurisdiction.\139\
---------------------------------------------------------------------------
\139\ CPUC at 8 (citing Conn. Light & Power Co. v. FPC, 324 U.S.
515, 529-30 (1945)).
469. Alabama PSC, Mississippi PSC, and Southern Company also cite
the preemption doctrine (that federal preemption of state law is not to
be assumed unless Congress expresses a clear intent to do so) as
another reason why the Commission is not permitted to exercise
jurisdiction over ``distribution'' facilities. ``To the contrary,''
Alabama PSC argues, ``the FPA expressly provides that FERC does not
have such jurisdiction.'' \140\
---------------------------------------------------------------------------
\140\ Alabama PSC at 6 (citing 16 U.S.C. 824(b)).
---------------------------------------------------------------------------
470. CT PUC asks the Commission to clarify that this Final Rule
does not preempt state regulatory authority with respect to electric
distribution company regulation, environmental protection (including
Clean Air Act permitting), fire and building safety regulation, etc.,
as these may apply to Small Generating Facility interconnections with
``distribution'' facilities.
471. Idaho Power states that ``[t]he `dual use' theory leaves the
``distribution'' facility owner that is trying to design an efficient
and reliable ``distribution'' system in the untenable position of
having two masters attempting to control the same physical line for
differing purposes.'' \141\
---------------------------------------------------------------------------
\141\ Idaho Power at 3.
---------------------------------------------------------------------------
472. PacifiCorp cites forum shopping concerns and suggests that a
Small Generating Facility interconnecting as a Qualifying Facility (QF)
to a dual use facility could receive different treatment depending on
whether it sells its output to the host utility under the Public
Utility Regulatory Policies Act of 1978 (PURPA)\142\ or to a customer
other than the host utility. In the first instance, the interconnection
would be state-jurisdictional; in the second, Commission-
jurisdictional. PacifiCorp asserts that this is a confusing outcome and
could be avoided if the Commission disclaims jurisdiction over low
voltage and dual use facilities.
---------------------------------------------------------------------------
\142\ 16 U.S.C. 824a-3 (2004).
---------------------------------------------------------------------------
473. Small Generator Coalition argues that not asserting
jurisdiction over all interconnections made to facilitate Commission-
jurisdictional activities means adopting a circuit-by-circuit approach
to jurisdiction. This would be contrary to the Commission's approach
taken in a variety of contexts, including assignment of system losses
\143\ and recovery of fixed costs \144\ on a system-wide basis.
Further, if the Commission allows a Transmission Provider to refuse
interconnections with the low-voltage ``distribution'' portions of its
system not already used for jurisdictional transactions, ``small
resource development would be inhibited if not eliminated.'' \145\
Transmission Providers could ``pick and choose among interconnection
applicants based on any criteria they elected to employ.'' \146\
Finally, Small Generator Coalition argues that the Commission
adequately recognizes state jurisdiction by claiming jurisdiction over
only interconnections with ``distribution'' facilities that are used
for wholesale transactions.
---------------------------------------------------------------------------
\143\ Small Generator Coalition at 37 (citing Northern States
Power Co. v. FERC, 30 F.3d 177 (D. C. Cir. 1994)).
\144\ Id. (citing Fort Pierce Utilities Authority v. FERC, 730
F.2d 778, 782 (DC Cir. 1984)).
\145\ Id. at 39.
\146\ Id. at 39.
---------------------------------------------------------------------------
474. NRECA argues that, as more and more distributed generators
participate in the wholesale market, ``many if not most distribution
facilities will carry a few wholesale electrons.'' \147\ Indeed, ``many
if not most distribution facilities will become subject to Commission
jurisdiction. The jurisdictional divide between the Federal Government
and the States that Congress clearly intended in the FPA will have
collapsed.'' \148\ Baltimore G&E asks the Commission to explain how it
will avoid a ``chicken and egg'' situation where the jurisdictional
status of a particular facility would change after the interconnection
takes place.
---------------------------------------------------------------------------
\147\ NRECA at 41.
\148\ Id.
---------------------------------------------------------------------------
475. Solar Turbines expresses concern that ``[a] utility apparently
need merely deny that a particular line is currently being used for any
transmission of power in interstate commerce or for any sales for
resale, and can then refuse to accept an application for
interconnection to that specific facility'' \149\ and requests that the
Commission clarify what the Interconnection Customer should do if it
finds itself in such a situation.
---------------------------------------------------------------------------
\149\ Solar Turbines at 4.
---------------------------------------------------------------------------
476. MidAmerican asks whether this Final Rule would apply to a net
metering arrangement that allows a Small Generating Facility to net
only a portion of its output and resell the remainder to the host
utility. It also asks what happens if it sells the non-net metered
portion of its output to a third party.
477. Avista asks the Commission to address the effect of Detroit
Edison on an interconnection for a purpose other than to ``engage in
sale for resale in interstate commerce or to transmit electricity in
interstate commerce.'' Avista differentiates ``load interconnections''
from ``generator interconnections,'' which are interconnections made to
export power. It requests clarification that a load
[[Page 34231]]
interconnection to a dual use facility is an exclusively state-
jurisdictional interconnection ``except if and to the extent there is
an OATT on file by the owner of the facilities that makes available new
Commission-jurisdictional service over those facilities.'' \150\ Absent
such a clarification, Avista argues that ``uncontrolled deregulation of
service at the distribution level may occur, since any new load can
seek to characterize its service as `wholesale' by inserting a 'sham
utility' between the customer and the incumbent utility.'' \151\ Avista
states that FPA section 212(h) already prohibits ``sham wholesale
transactions'' \152\ and argues that ``the Commission has determined
that Section 212(h) only applies to transmission orders, not
interconnection requests.'' \153\ Without such a clarification, Avista
fears that load interconnections with dual use facilities could be used
to force otherwise non-Commission-jurisdictional ``distribution''
facilities into Commission-jurisdictional status.
---------------------------------------------------------------------------
\150\ Avista at 9.
\151\ Id. at 9-10 (citing, e.g., Snake River Valley Elec. Ass'n
v. PacifiCorp, 238 F.3d 1189 (9th Cir. 2001)).
\152\ 16 U.S.C. 824k(h) (2000).
\153\ Avista at 9-10 (citing Laguna Irrigation District, 95 FERC
] 61,305 (2001), aff'd sub nom. Pacific Gas & Electric Co. v. FERC,
44 Fed. Appx. 170 (9th Cir. 2002) (unpublished opinion); City of
Corona v. Southern California Edison Co., 101 FERC ] 61,240 at
62,025-026 (2002)).
---------------------------------------------------------------------------
478. USCHPA and Solar Turbines ask the Commission to exert
jurisdiction over all load interconnections. Additionally, many
cogeneration projects, USCHPA asserts, make sporadic sales of power
when the economics favor doing so. Such projects should not be denied
the benefits of standardized interconnection rules simply because their
sales into the wholesale energy marketplace are sporadic. Solar
Turbines argues that the needs of Small Generating Facilities are
different and that there are good reasons to depart from the large
generator precedent in this rulemaking. Specifically, Small Generating
Facilities are more likely to be near to load, while Large Generating
Facilities are more likely to be far from their load.
479. Midwest ISO argues that all interconnections with
``distribution'' facilities within an RTO or ISO to sell power at
wholesale should be processed under a single set of rules. This would
include both state- and Commission-jurisdictional facilities. Midwest
ISO remarks that regardless of ``[w]hether the physical requirements of
the interconnection come under the RTO's purview, the generating
facility's operation will'' come under the RTO's jurisdiction.
Therefore, the RTO should be able to ``evaluate the proposed
interconnection with the generating facility's subsequent operation in
mind.'' \154\
---------------------------------------------------------------------------
\154\ Midwest ISO at 6.
---------------------------------------------------------------------------
480. Finally, several comments address whether the use of a 69 kV
cutoff in the SGIP affects the Commission's jurisdiction.
Commission Conclusion
481. The Commission's assertion of jurisdiction in this Final Rule
is identical to the jurisdiction asserted in Order Nos. 2003 and 888
and upheld by the Supreme Court in New York v. FERC. Just as the
Commission stated in Order No. 2003-A:
There is no intent to expand the jurisdiction of the Commission
in any way; if a facility is not already subject to Commission
jurisdiction at the time interconnection is requested, the Final
Rule will not apply. Thus, only facilities that already are subject
to the Transmission Provider's OATT are covered by this rule. The
Commission is not encroaching on the States' jurisdiction and is not
improperly asserting jurisdiction over ``local distribution''
facilities.[\155\]
---------------------------------------------------------------------------
\155\ Order No. 2003-A at P 700.
482. Many commenters seek clarification of issues (particularly
related to the Detroit Edison case) that were discussed at length in
Order Nos. 2003-A and 2003-B, which were issued after comments on the
Small Generator Interconnection NOPR were due.\156\ Since the
jurisdiction asserted in this Final Rule is identical to that asserted
in Order No. 2003, we adopt here our discussion from those orders
rather than repeat the same information.
---------------------------------------------------------------------------
\156\ See Order No. 2003-A at P 698 et seq. and Order No. 2003-B
at P 12 et seq.
---------------------------------------------------------------------------
483. However, several commenters focused on how the jurisdictional
issues raised by small generator interconnections may differ from those
raised in the Large Generator Interconnection rulemaking. Additionally,
some commenters raised issues in this proceeding that were not
addressed in Order Nos. 2003-A or 2003-B. These issues we discuss in
more detail below.
484. We disagree with Alabama PSC, Mississippi PSC, and Southern
Company that the Commission is evading FPA section 201(b)(1) or
preempting state law. In New York v. FERC, the U.S. Supreme Court
approved the Commission's assertion of jurisdiction in Order No.
888.\157\ The applicability of this Final Rule is identical to the
applicability of Order No. 888.
---------------------------------------------------------------------------
\157\ New York v. FERC, 535 U.S. 1 (2002).
---------------------------------------------------------------------------
485. CT PUC is correct that this Final Rule in no way alters the
permitting and other environmental requirements applicable to
Interconnection Customers. Nor does this Final Rule affect any other
state police powers.
486. NRECA asserts that while there are now relatively few Small
Generating Facility interconnections that are Commission-
jurisdictional, that number will increase as time passes. Small
Generator Coalition complains that the number of lower voltage
Commission-jurisdictional facilities is too small. Ultimately, however,
the Commission's jurisdiction does not rest on how common dual use
facilities may be or how many interconnections are Commission-
jurisdictional.
487. Baltimore G&E asks if the jurisdictional status of a facility
would change after an interconnection takes place. Whether a facility
is subject to this rule depends on whether it is subject to an OATT at
the time the Interconnection Request is filed. The use of a facility
and thus its inclusion in an OATT can change over time. Nothing in this
Final Rule (or Order No. 2003) alters the status of any facility.
488. Avista is correct that some interconnections are made simply
to receive power from the electric system. These ``load
interconnections'' are not subject to this Final Rule.
489. In response to USCHPA's concern over Interconnection Customers
who may wish to make sporadic sales of power into the marketplace, we
clarify that there is no requirement that an Interconnection Customer's
participation in the wholesale marketplace be constant. An
Interconnection Customer is free to request interconnection service and
then wait until the economics are favorable before actually making a
wholesale sale.
490. In response to Midwest ISO's desire to process all
interconnections (whether to Commission-jurisdictional or non-
Commission-jurisdictional facilities) under its tariff, we note that
the Commission does not have the authority to order states to use
Midwest ISO's tariff to process interconnections with state or other
non-jurisdictional facilities. However, we encourage the states and
others to use the Commission's interconnection rule or the NARUC Model
as a starting point for developing their own interconnection rules.
491. Many commenters also address the legality of the Small
Generator Interconnection NOPR's proposed use of 69 kV to determine
whether portions of
[[Page 34232]]
the SGIP would apply. Since the Commission has abandoned this
distinction in this Final Rule, these arguments are moot.
Arguments that the Commission Should Delay or Abandon the Small
Generator Interconnection Rulemaking
492. Several commenters argue that the Proposed SGIP and Proposed
SGIA are too complicated for small entities and would create a barrier
to entry. Some commenters argue that the Commission should delay
issuing a Final Rule and allow the various states and other entities to
develop their own model rules. Others disagree.\158\
---------------------------------------------------------------------------
\158\ CT DPUC at 1 (``The CT DPUC generally supports the effort
by the Commission to initiate standardization of interconnection
agreements and procedures * * * ''); see also Cummins at 1 (``We
strongly support the Commission's continued work in this area.'')
---------------------------------------------------------------------------
493. This Final Rule includes several provisions to address these
concerns. First, we are adopting a separate application/procedures/
terms and conditions document for very small certified inverter-based
Small Generating Facilities. This is a big step in facilitating quick
interconnections at very little cost, as long as they can be made
safely and without harming reliability. We are also simplifying many
SGIA provisions at the request of commenters. This Final Rule borrows
liberally from NARUC's Model interconnection rules, which are simpler
than the Small Generator Interconnection NOPR.
494. We address below specific comments relating to our decision to
proceed with this Final Rule. We have divided commenters' arguments
into three sections: (1) Arguments that the Commission should defer to
the states to deal with small generator interconnections; (2) arguments
that the Commission's NOPR is too complex; and (3) arguments that the
Commission should adopt a policy statement or model rules instead of a
Final Rule.
Arguments in Favor of Deferring to the States on Small Generator
Interconnections
Comments
495. NARUC proposes that the Commission adopt its Model, arguing
that it ``would offer the greatest possibility of consistency between
Federal and State interconnection policies'' \159\ It explains that
``the NARUC Model was developed by melding the best practices of
existing State distributed generation interconnection programs.'' \160\
NARUC argues in its supplemental comments that state programs are
successful and that imposing an unnecessary layer of federal regulation
will be disruptive to small generator developers and customers.
Commission action can only create confusion and impede project
development. Because states have better insight into local operating,
planning, safety, reliability, and adequacy needs and conditions, they
are in the best position to address the interconnection of small
generators, regardless of what those generators may do with the output
from their facilities or where they are interconnected. At bottom,
NARUC urges the Commission to take no action on the Small Generator
Interconnection NOPR. In the alternative, if the Commission implements
small generator interconnection rules, it should grandfather existing
state interconnection programs and the interconnections accomplished
under such programs, and include a mechanism for granting deference to
future state small generator interconnection programs.
---------------------------------------------------------------------------
\159\ NARUC at 18.
\160\ Id. at 8.
---------------------------------------------------------------------------
496. CPUC states that California, New York, Ohio, and Texas all
have interconnection procedures applicable to their state-regulated
utility ``distribution'' systems.\161\ Because one third of the
country's population already lives in states with standard
interconnection rules, there is no need for Commission action. It also
contends that (1) existing California interconnection rules meet the
needs of small generators seeking to connect to state-jurisdictional
utility ``distribution'' systems, (2) California procedures already
provide small generators with one-stop shopping, and (3) there is no
``actual or legitimate need for FERC assistance to cover
interconnections to state-jurisdictional facilities in states where
distributed generation interconnection rules are already in place.''
\162\
---------------------------------------------------------------------------
\161\ Virginia, Massachusetts, and other states also have small
generator interconnection rules.
\162\ CPUC at 16.
---------------------------------------------------------------------------
497. Furthermore, CPUC argues, only state-specific interconnection
rules can account for ``regional practices.'' As an example, CPUC's
rules allow it to exempt small Transmission Providers, but the Small
Generator Interconnection NOPR lacks such needed flexibility.\163\ In
sum, CPUC questions the need for the Commission's proposal and asserts
that ``there is no legitimate public policy basis for the assertion of
FERC jurisdiction over small generators that would result if the FERC
proposal were adopted.'' \164\
---------------------------------------------------------------------------
\163\ Id. at 18.
\164\ Id. at 15.
---------------------------------------------------------------------------
498. In contrast, Cummins argues that the Commission should assert
jurisdiction over all interconnections, regardless of whether the
interconnection is with a Commission-jurisdictional facility. Cummins
argues that, although Small Generating Facilities often connect at the
``distribution'' level, their effects can be felt on the Transmission
System. It explains that, because Small Generating Facilities can
relieve congestion on crowded transmission facilities, the effect of
even on-site Small Generating Facilities is felt beyond the Point of
Interconnection. Thus, it is important that the Commission use all its
jurisdictional authority to apply this rule as broadly as possible.
And, where the Commission does not have jurisdiction, Cummins
encourages state regulators to develop interconnection rules that are
consistent with this Final Rule.
499. Plug Power claims that by not proposing standards applicable
to interconnections with distribution facilities, the Commission's
interconnection rules will not help small generators. Further, the
rules proposed in the NOPR are inferior to those already in place in
several states.
500. EEI urges the Commission to work with states to better define
the state-federal role in small generator interconnections. According
to EEI, this approach would provide both Interconnection Customers and
Transmission Providers with clear guidance as to which rules apply to
which interconnections. Finally, EEI states that, with certain
modifications, the interconnection procedures document and agreement
could be a model for use by both federal and state authorities to
process small generator Interconnection Requests.
501. CT DPUC, while supporting the Commission's efforts, argues
that this Final Rule should not lead to a loss of state jurisdiction.
Commission Conclusion
502. We agree with commenters that general consistency between the
Commission's interconnection procedures document and agreement and
those of the states will be helpful to removing roadblocks to the
interconnection of small generators. To a large extent, this Final Rule
harmonizes state and federal practices by adopting many of the
provisions proposed by NARUC and Joint Commenters. This Final Rule
adopts
[[Page 34233]]
interconnection rules that are largely consistent with the ``best
practices'' interconnection rules proposed by NARUC. By doing so, we
hope to minimize the federal-state division and promote consistent,
nationwide interconnection rules.\165\ We hope that states that do not
currently have interconnection rules for small generators will look to
the documents presented in this Final Rule and the NARUC Model as
guides for their own rules. To grandfather existing state
interconnection programs and grant deference to future state small
generator interconnection programs would not fulfill the Commission's
statutory mandate to regulate jurisdictional activities, of which
generator interconnection is one. However, as discussed elsewhere, the
all-in-one document for certified inverter-based generators no larger
than 10 kW should go a long way towards harmonizing state-federal
interconnection practices for this class of generators.
---------------------------------------------------------------------------
\165\ A particular state's interconnection rules may also differ
from the NARUC Model.
---------------------------------------------------------------------------
503. Our hope is that states may find these interconnection rules
helpful in formulating their own interconnection processes. In
particular, we hope the Fast Track and 10 kW Inverter Processes will
prove helpful as starting points from which to develop their own
procedures and agreements.
504. The concerns of CPUC and several other commenters that the
Commission is claiming jurisdiction over interconnections with non-
Commission jurisdictional facilities are addressed elsewhere in more
detail.
Arguments That the NOPR Is Too Complex
Comments
505. CPUC argues that the Proposed SGIA and Proposed SGIP are too
complicated for small Interconnection Customers, especially the
smallest, to use. Small Generator Coalition argues that unless the
Commission is willing to modify the NOPR in fundamental ways, many of
its members believe that development of Small Generating Facilities
would be better served if the NOPR were simply withdrawn. According to
Small Generator Coalition, the NOPR's framing of
interconnection issues as a competition between maintaining system
reliability and encouraging small resources is wholly inappropriate,
and it gives disproportionate weight to the reliability `concerns'
of transmission/distribution owners with generating units of their
own. That system reliability must not be compromised goes without
saying, but the need for system reliability does not compete with
the goal of encouraging small resource development via affordable
and clear interconnection terms and conditions. The compatibility of
small resources with the grid was proven long ago--there are
literally thousands of such small resources in place and operating
in the United States, safely interconnected with the grid (such as
the solar array on the roof of the Commission's own office
building).[\166\]
---------------------------------------------------------------------------
\166\ Small Generator Coalition at 7-8.
506. Small Generator Coalition says that on-site Small Generating
Facilities actually enhance electric system reliability, and that
complex technical provisions should therefore not be required.
507. Plug Power asserts that unless the Commission adopts a simpler
SGIA, the Commission's rulemaking will not help to reach national
interconnection standards.\167\ Of particular concern to Plug Power are
the Proposed SGIA's insurance requirements and what Plug Power terms
its open-ended cost provisions.
---------------------------------------------------------------------------
\167\ Plug Power at 3.
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508. CT DPUC urges the Commission to adopt rules that are not
unnecessarily complicated to administer.
Commission Conclusion
509. We agree with commenters that the Small Generator
Interconnection NOPR contained some provisions that were overly
complicated for many Small Generating Facility interconnections.
Wherever possible, we have simplified the SGIP and SGIA. And, for very
small certified Small Generating Facilities, this Final Rule includes
the highly simplified 10 kW Inverter Process.
Arguments in Favor of a Non-Binding Model Rule
Comments
510. CPUC states that it would support Commission efforts to
establish non-binding guidelines, or a model rule, for use by states
that have not yet adopted their own standards.
511. NARUC comments that any standard interconnection procedures
document and agreement issued by the Commission that disclaims
jurisdiction over ``local distribution'' facilities has limited
applicability. It also claims that states are better situated to handle
small generator interconnections, and having two competing
interconnection regimes for small generator interconnections would be
confusing. NARUC therefore also urges the Commission to adopt a policy
statement instead of a binding rule.
Commission Conclusion
512. We conclude that as much standardization as possible of the
rates, terms, and conditions of jurisdictional interconnection service
will help eliminate undue discrimination. A non-binding policy
statement would not end this undue discrimination. Further, not
regulating jurisdictional interconnections would leave a regulatory gap
where neither the states nor the Commission held sway. A gap of this
sort would make it more difficult for Interconnection Customers wanting
to interconnect and would in fact, leave them worse off than the owners
of Large Generating Facilities.
513. This Final Rule both fulfills the Commission's duty to remedy
undue discrimination when covered by this rule and, when not covered by
this rule, provides a model that state regulators may wish to use as a
starting point for developing their own procedures and agreement. We
hope that the SGIP and SGIA we adopt in this Final Rule are a step
towards having a seamless interconnection process where
interconnections with federal-jurisdictional facilities and state-
jurisdictional facilities will be handled in a similar fashion. By
doing so, we intend to avoid the very federal-state clashes NARUC
anticipates.
Issues Relating to Qualifying Facilities
514. The NOPR did not address the issue of how QFs would be
impacted by the small generator rulemaking.
Comments
515. EEI and PacifiCorp ask the Commission to clarify that a QF
that is not selling at wholesale, other than to a host utility under
PURPA, should seek interconnection service through state procedures,
not through Commission procedures. PacifiCorp states that the PURPA
regulatory scheme for QFs involves considerable deference to state
regulation with regard to the interconnection of QFs to state-regulated
utilities. The Iowa Utilities Board agrees and asserts that this Final
Rule should say that states have authority to establish standards for
the interconnection of QFs. To avoid confusion, PacifiCorp proposes
that the SGIP state clearly that a Small Generating Facility with QF
status or one seeking such status is not eligible for interconnection
under the Commission's rule. PacifiCorp recommends amending the
Interconnection Request so that the Interconnection Customer must
certify that it does not intend to seek QF status. If it then seeks QF
status, PacifiCorp proposes to require a review of the interconnection
to determine whether it meets state interconnection standards for QFs.
The Interconnection Customer
[[Page 34234]]
would also pay any costs incurred by the Transmission Provider that a
QF would have paid, if such costs would not be recovered by the
Transmission Provider under the SGIP.
Commission Conclusion
516. The Commission has regulations that govern a QF's
interconnection with most electric utilities in the United States,\168\
including normally non-jurisdictional utilities.\169\ When an electric
utility is required to interconnect under section 292.303 of the
Commission's regulations, that is, when it purchases the QF's total
output, the state has authority over the interconnection and the
allocation of interconnection costs.\170\ But when an electric utility
interconnecting with a QF does not purchase all of the QF's output and
instead transmits the QF's power in interstate commerce, the Commission
exercises jurisdiction over the rates, terms, and conditions affecting
or related to such service, such as interconnections.\171\
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\168\ 18 CFR 292.303, 292.306 (2004).
\169\ The absence of interstate commerce in Alaska, Hawaii, and
portions of Texas and Maine, and Puerto Rico is not germane to the
Commission's jurisdiction over QF matters under PURPA. See 16 U.S.C.
2602 (2000).
\170\ See Western Massachusetts Electric Co., 61 FERC ] 61,182
at 61,661-62 (1992), aff'd sub nom. Western Massachusetts Electric
Co. v. FERC, 165 F.3d. 922, 926 (D.C. Cir. 1999).
\171\ Id. at 61,661-62. The Commission further clarified that
``[t]he fact that the facilities used to support the jurisdictional
service might also be used to provide various nonjurisdictional
services, such as back-up and maintenance power for a QF, does not
vest state regulatory authorities with authority to regulate matters
subject to the Commission's exclusive jurisdiction.'' Id. at 61,662.
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517. The Commission thus exercises jurisdiction over a QF's
interconnection if the QF's owner sells any of the QF's output to an
entity other than the electric utility directly interconnected with the
QF. This Final Rule applies when the owner of the QF seeks
interconnection with a facility subject to the OATT to sell any of the
output of the QF to a third party. This applies to a new QF that plans
to sell any of its output to a third party and to an existing QF
interconnected with an electric utility or on-site customer that
decides in the future to sell any of its output to a third party.
States continue to exercise authority over QF interconnections when the
owner of the QF sells the output of the QF only to the interconnected
utility or to on-site customers.
518. PacifiCorp's proposal that the Commission require the
Interconnection Customer to certify that it does not intend to seek QF
status is unnecessary. This Final Rule only applies when the
interconnection is subject to the Commission's jurisdiction. Other
rules apply if the generator seeks to interconnect as a QF. PacifiCorp
has provided no convincing rationale why this proposed amendment is
necessary for this rulemaking.
Taxes
519. The NOPR did not explicitly address the potential taxation of
payments made by the Interconnection Customer to the Transmission
Provider for Interconnection Facilities and Upgrades.
Comments
520. A few commenters urge the Commission to address taxes. They
argue that the Commission should adopt an approach similar to that
taken in the LGIA so that any taxes incurred by the Transmission
Provider are not shifted to its customers.
521. Because payments received for Upgrades by the Transmission
Provider may be taxed, EEI and Ameren ask the Commission to clarify how
the Transmission Provider will recover those tax payments. Further, EEI
argues that additional financial security may be required because such
facilities could be jurisdictional to either the Commission or state
utility commissions. Additional financial security would ensure that
the utility is not forced to recover such costs from its entire
customer base. EEI proposes that the following sentence be added to
Proposed SGIA article 5.2: ``[The] Transmission Provider may request
additional financial security to cover tax liabilities that it may
incur as a result of a transaction being deemed by the Internal Revenue
Service to have been a taxable event, for example, when an
Interconnection Customer terminates a signed Interconnection
Agreement.''
522. Southern Company proposes a tax provision modeled after the
ANOPR consensus documents. Under Proposed SGIA article 5.1.2.1, the
refunds paid to the Interconnection Customer through transmission
credits include ``any tax gross-up or other tax-related payments'' in
connection with Network Upgrades required for interconnection. It
argues that if the Interconnection Customer receives transmission
credits for such payments, all other transmission customers will have
to bear the tax liability created by the Interconnection Customer.
Transmission credits should be provided to the Interconnection Customer
for the cost of installing facilities only if those costs may
facilitate transmission delivery service. Any tax gross-up paid by the
Interconnection Customer would not facilitate transmission delivery
service, but instead would be a tax liability created solely by the
interconnection. Moreover, requiring the refund through credits of
taxes paid, plus interest, would force the Transmission Provider to pay
the full carrying cost of income taxes on the Interconnection
Customer's assets with no means of recouping the expenditure.
Commission Conclusion
523. The commenters are correct that payments received for Upgrades
by the Transmission Provider may be taxed under certain circumstances.
If construction of Upgrades is necessary, any associated taxes are to
be handled consistent with Commission precedent and applicable tax
rules and regulations. In particular, the Parties should then look to
the LGIA's tax framework.\172\ We also reiterate that it is Commission
policy that each Party must cooperate with the other Party to maintain
the Transmission Provider's tax exempt status, where applicable.
---------------------------------------------------------------------------
\172\ See, e.g., LGIA articles 5.17 and 5.18 and Order No. 2003-
A at P 324 et seq.
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OATT Reciprocity Requirements
524. The Small Generator Interconnection NOPR did not propose any
changes to the existing reciprocity policy; accordingly, the Small
Generator Interconnection NOPR did not discuss it.
Comments
525. NRECA states that it ``applauds the Commission's decision to
apply the reciprocity provision in the OATT and the reciprocity policy
articulated in Order No. 888 [and] appreciates the sensitivity the
Commission has demonstrated to the needs of non-jurisdictional service
providers.'' \173\ However, it remains concerned that non-public
utilities may be discouraged from interconnecting new generation out of
fear that such an interconnection will make them subject to the
jurisdiction of the Commission. To avoid this, NRECA advocates the
creation of a safe harbor for non-jurisdictional entities that want to
interconnect new generation, yet maintain their non-jurisdictional
status. NRECA points to several Commission natural gas decisions that
it asserts provide precedent for creating a safe harbor of the type it
proposes. NRECA also states that the Commission could achieve the same
result by ordering an interconnection under section 211 of the FPA.
---------------------------------------------------------------------------
\173\ NRECA at 57.
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526. AMP-Ohio and LADWP ask the Commission to clarify that the
[[Page 34235]]
reciprocity condition applies only to the public utility over whose
system the non-public utility takes transmission service. They also ask
the Commission to clarify that there is no reciprocity obligation on
the part of a non-public utility that owns only distribution
facilities, not transmission facilities. The effect of most small
generators is felt at the distribution level, LADWP argues, and these
interconnections are more likely to affect retail customers. SMUD makes
a similar argument.
527. PacifiCorp requests that the Commission clarify that if a
public utility is forced to offer interconnection service on its
distribution lines to a non-public utility under the reciprocity
condition, then the public utility must be offered similar rights to
interconnect with the non-public utility. PacifiCorp argues that
[b]ecause many non-jurisdictional utilities own distribution systems
that they do not consider `transmission,' even when the
corresponding system of a public utility is considered transmission
by the Commission, the potential for discriminatory impact is real.
At a minimum, the definition of a non-jurisdictional utility's
`transmission facilities' should be modified to include any
distribution facility that would be considered `transmission' if it
were owned by a jurisdictional utility.\174\
---------------------------------------------------------------------------
\174\ PacifiCorp at 2-3.
528. SMUD asks if reciprocity applies when the Interconnection
Customer seeks to connect at distribution voltage to the non-
jurisdictional utility and proposes to engage in sales for resale. It
also asks if reciprocity applies differently for non-jurisdictional
utilities seeking bilateral agreements with public utilities than to
non-jurisdictional utilities seeking approval of safe harbor tariffs.
529. NRECA asks the Commission to clarify that a non-jurisdictional
utility is not required to offer interconnection service if doing so
would jeopardize its tax-exempt status.
530. Finally, Bureau of Reclamation, BPA, and others assert that as
federal agencies, they are not able to comply with all of the
provisions of the Proposed SGIP and SGIA. For instance, BPA says its
contracts must accommodate the Freedom of Information Act and that it
could not comply with all aspects of the Commission's proposed
confidentiality provisions. BPA and Bureau of Reclamation request
clarification that they are not required to comply with these
provisions.
Commission Conclusion
531. Most of the comments focus on whether interconnections with
``distribution'' systems are subject to the reciprocity condition. The
answer is, to satisfy the reciprocity condition of Order No. 888, a
non-public utility must offer to a public utility with an OATT service
comparable to that offered to its own or affiliated Interconnection
Customers.\175\
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\175\ Order No. 2003-A at P 775.
---------------------------------------------------------------------------
532. PacifiCorp is correct that what the facility is termed by its
owner does not affect its jurisdictional status. The reciprocity
condition would apply to any facility used to offer services that would
be Commission-jurisdictional if the non-public utility were a public
utility.
533. The reciprocity requirement in Order No. 888 permits a public
utility to require, as a condition of providing open access service to
a non-public utility that owns, controls, or operates transmission
facilities, that the non-public utility provide reciprocal transmission
service. In Order No. 2003-A, the Commission explained that the
reciprocity provision applies to Interconnection Service in the same
way.\176\
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\176\ See Order No. 2003-A at P 760 et seq.
---------------------------------------------------------------------------
534. There are three ways a non-public utility may satisfy the
reciprocity provision.\177\ First, it may provide service under a
Commission-approved ``safe harbor'' tariff--a tariff that the
Commission has determined offers truly open access service. Second, it
may provide service to a public utility under a bilateral agreement
that satisfies its reciprocity obligation. Third, the non-public
utility may ask the public utility to waive the reciprocity condition.
---------------------------------------------------------------------------
\177\ Id. at P 761.
---------------------------------------------------------------------------
535. A non-public utility that has a ``safe harbor'' tariff that is
modeled on the OATT must add to that tariff an interconnection
procedures document and interconnection agreement that either are
modeled on the OATT interconnection procedures document and agreement
or are otherwise found to offer truly open access service if it wishes
to continue to qualify for ``safe harbor'' treatment.\178\ A non-public
utility that owns, controls, or operates transmission, has not filed
with the Commission a ``safe harbor'' tariff, and seeks transmission
service from a public utility that invokes the reciprocity provision
must either satisfy its reciprocity obligation under a bilateral
agreement or ask the public utility to waive the OATT reciprocity
condition.
---------------------------------------------------------------------------
\178\ Id.
---------------------------------------------------------------------------
536. This Final Rule does not modify the Commission's reciprocity
policy as laid out in Order Nos. 888 and 2003.
537. LADWP also states that there are relatively few Commission-
jurisdictional Small Generating Facility interconnections and urges the
Commission not to apply its reciprocity policy in the small generator
context. The fact that there may be relatively few interconnections
subject to this Final Rule does not justify abandoning long-standing
reciprocity policy.
538. As the Commission determined in Order Nos. 888 \179\ and 2003-
A,\180\ reciprocal service is not required if providing such service
would jeopardize the tax-exempt status or bond status of the non-public
utility.
---------------------------------------------------------------------------
\179\ Order No. 888 at 31,762, n.499.
\180\ Order No. 2003-A at P 782.
---------------------------------------------------------------------------
539. As to BPA and Bureau of Reclamation's comments, we reiterate
that reciprocity does not require federal entities to provide services
or sign contracts that they cannot legally enter into. If such entities
choose to amend their safe harbor tariffs on compliance, they may
propose modifications to the SGIP and SGIA that address their concerns.
540. Finally, we deny NRECA's proposed safe harbor provision. As it
notes, section 211 of the FPA already allows a non-public utility to
safeguard its non-jurisdictional status. We see no need to fix a system
that does not appear to be broken.
Coordination With Affected Systems
541. An Affected System is an electric system other than the
Transmission Provider that may be affected by the proposed
interconnection. In the Small Generator Interconnection NOPR, the
Commission proposed to treat coordination between the Transmission
Provider, Interconnection Customer, and any Affected Systems the same
way as in the LGIA. Order Nos. 2003 and 2003-A required the
Transmission Provider to coordinate with an Affected System. The
Commission requested comments on whether there are any issues specific
to Small Generating Facilities that necessitate a different policy.
Comments
542. While no commenters present any arguments on this issue
specific to the small generator context, some discuss the Affected
System provision in terms of Distribution Systems.
Commission Conclusion
543. We are adopting an Affected System provision comparable to the
one
[[Page 34236]]
in the LGIP and LGIA. Regarding the comments addressing the Affected
System provision in terms of Distribution Systems subject to an OATT,
we note that the definition of Affected System includes not only
transmission facilities. The definition is more inclusive; it is ``an
electric system * * * that may be affected by the proposed
interconnection.'' Thus, an Affected System may be any type of electric
system.\181\
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\181\ We note that, similar to when the Affected System is a
non-jurisdictional entity, the Commission does not have to have
jurisdiction over the Affected System in order for the
interconnection to proceed. See Order No. 2003-A at P 114-115.
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I. Compliance Issues
Amendments to the Transmission Provider's OATT
544. In this Final Rule, we are requiring all public utilities that
own, control, or operate interstate transmission facilities to adopt
the SGIP and SGIA, but are using a process different from the one used
in Order No. 2003. On the effective date of Order No. 2003, the OATT of
each Transmission Provider was deemed to have included the LGIP and
LGIA.\182\ On the effective date of this Final Rule, as in Order No.
2003,\183\ the OATTs of all non-independent Transmission Providers are
deemed revised to include the Final Rule SGIP and SGIA. But unlike the
Order No. 2003 process, where the Commission directed Transmission
Providers to make ministerial filings to include the LGIP and LGIA in
their next filings with the Commission, here the Commission will
require no formal amendment until compliance is due in the Commission's
rulemaking on Electronic Tariff Filings.\184\ This means that a non-
independent Transmission Provider that wishes to adopt the SGIP and
SGIA (without variations) into its OATT need not formally add the
documents to its OATT until it submits a compliance filing in response
to the Commission's pending Electronic Tariff Filings rulemaking. A
non-independent Transmission Provider that decides to take this option
nevertheless must apply the SGIP and SGIA to any request for small
generator interconnection that it receives after the effective date of
this Final Rule, but before it complies with the rulemaking on
Electronic Tariff Filings. The compliance obligation is different for
non-independent Transmission Providers that seek variations from the
Final Rule documents, as discussed further below.
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\182\ Order No. 2003 at P 910.
\183\ See Standardization of Generator Interconnection
Agreements and Procedures, Notice Clarifying Compliance Procedures,
106 FERC ] 61,009 at P 2 (2004).
\184\ Electronic Tariff Filings, Notice of Proposed Rulemaking,
69 FR 43929 (July 23, 2004), FERC Stats. & Regs., Proposed
Regulations, ] 32,575 (July 8, 2004).
---------------------------------------------------------------------------
545. If an RTO or ISO wishes to adopt the SGIP and SGIA into its
OATT, it may also await compliance with the Electronic Tariff Filings
rulemaking before formally adding the documents to its OATT. But the
RTO or ISO should notify the Commission by the effective date of this
Final Rule that it will adopt the Final Rule documents and that
requests for interconnection of Small Generating Facilities will be
subject to the SGIP and SGIA in the interim period. An RTO or ISO that
does not adopt the SGIP and SGIA will have additional time to submit
its compliance filings to allow for the stakeholder process and other
measures that must be taken before an RTO or ISO adopts tariff changes.
Therefore, an RTO or ISO that seeks variations will have an additional
90 days to submit its compliance filing. As in the Order No. 2003
proceeding, until the Commission acts on the compliance filing of an
RTO or ISO that seeks variations, the RTO's or ISO's existing
Commission-approved interconnection procedures and agreement remain in
effect.
Variations From the Final Rule
546. As in Order No. 2003, the Commission will consider two
categories of variations from the Final Rule submitted by a non-
independent Transmission Provider.\185\ First, the Commission will
consider ``regional reliability variations'' that track established
reliability requirements (i.e., requirements approved by the applicable
regional reliability council). Any request for a ``regional reliability
variation'' must be supported by references to established reliability
requirements,\186\ and the text of the reliability requirements must be
provided in support of the variation. If the variation is for any other
reason, the non-independent Transmission Provider must demonstrate that
the variation is ``consistent with or superior to'' the Final Rule
provision. Blanket statements that a variation meets the standard or
clarifies the Final Rule provision are not sufficient. Any request for
application of this standard will be considered under FPA section 205
and must be supported by arguments explaining how each variation meets
the standard.
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\185\ Order No. 2003 at P 824-25.
\186\ See also New York Independent System Operator, Inc., 108
FERC ] 61,159 at P 95 (2004), reh'g pending.
---------------------------------------------------------------------------
547. Requests for regional reliability variations are due on the
effective date of this Final Rule. Requests for ``consistent with or
superior to'' variations may be submitted on or after the effective
date of the Final Rule. We note that the ``consistent with or superior
to'' standard is difficult to meet because the burden of showing that a
variation is ``consistent with or superior to'' the relevant provision
or provisions in the Final Rule document is significant.
548. Any request for a variation should be accompanied by a request
to include the complete SGIP and SGIA into the Transmission Provider's
OATT. The Commission will consider incomplete any request for a
variation that does not also propose to append to the Transmission
Provider's OATT the complete SGIP and SGIA. As explained above, an RTO
or ISO will have 90 additional days (for a total of 150 days) to submit
a compliance filing. That compliance filing must contain all proposed
independent entity variations.
549. With respect to an RTO or ISO, at the time its compliance
filing is made, as explained in Order No. 2003, the Commission will
allow it to seek ``independent entity variations'' from the Final Rule
pricing and non-pricing provisions.\187\ The RTO or ISO should explain
the basis for each variation.
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\187\ Order No. 2003 at P 827.
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550. Finally, for a non-independent Transmission Provider that
belongs to an RTO or ISO, the RTO's or ISO's Commission-approved
standards and procedures are to govern interconnection with its
members' facilities that are under the operational control of the RTO
or ISO. An interconnection with a Commission jurisdictional facility
that is owned by a non-independent Transmission Provider but is not
under the operational control of the RTO or ISO is to be conducted
according to the non-independent Transmission Provider's procedures and
agreement. A non-independent Transmission Provider, even if it belongs
to an RTO or ISO, is not eligible for ``independent entity variations''
for procedures and agreements applicable to interconnection with
facilities that remain within its operational control (and therefore,
are subject to a tariff different from the RTO or ISO's OATT). To
clarify, if a non-independent Transmission Provider belongs to an RTO
or ISO, but keeps operational control of some jurisdictional
facilities, and those facilities are not subject to the interconnection
procedures under the OATT of the RTO or ISO, then the non-independent
Transmission Provider must have a separate set of interconnection
procedures and
[[Page 34237]]
agreement applicable to these facilities. To address the confusion that
may arise from having inconsistent interconnection procedures and
agreements applicable within an RTO or ISO region, we allow a non-
independent Transmission Provider that keeps control over some
jurisdictional facilities to subject these facilities to an RTO- or
ISO-controlled interconnection process. In such instance, the non-
independent Transmission Provider must agree to transfer to the RTO or
ISO control over the significant aspects of the interconnection
process, including the performance of all interconnection studies and
cost determinations applicable to Network Upgrades.\188\
---------------------------------------------------------------------------
\188\ See Order No. 2003-B at P 80.
---------------------------------------------------------------------------
Interconnection Requests Submitted Prior to the Effective Date of This
Final Rule and Grandfathering of Existing Interconnection Agreements
551. The grandfathering of existing agreements was not specifically
addressed in the Small Generator Interconnection NOPR; however, the
Commission did request comments on whether generic Commission policies
applicable to Large Generating Facilities (such as grandfathering)
should be applied to Small Generating Facilities.
Comments
552. American Forest and National Grid seek clarification that
small generators that are already interconnected are not subject to
this rulemaking. To avoid unintended barriers to Small Generating
Facilities, they urge the Commission to follow the Order No. 2003
approach for grandfathering. American Forest states that generators
should not have to undergo this new interconnection process,
particularly where the generating facilities that are already
interconnected have not changed their physical operations.
553. California Wind Energy requests that, as in Order No. 2003,
contract conversion of pre-existing interconnection contracts with
former QFs should not trigger an obligation under this Final Rule to
file an Interconnection Request because a change in contract status
alone does not affect a generator's demand on the electric system. It
also seeks clarification that, when the QF's interconnection agreement
provides for greater capacity than what is to be sold to the
interconnecting utility under the PURPA power purchase contract, upon
contract conversion, the former QF should not have to submit an
Interconnection Request if the transmission requirements are consistent
with those provided for in the prior agreement.
554. Finally, if the Commission adopts the approach used in Order
No. 2003, California Wind Energy requests that the Commission clarify
when a change in a QF's contract status triggers an obligation to file
a new Interconnection Request. It notes that Order No. 2003 states that
the owner of a QF formerly interconnected with a Transmission System
has no obligation to file an Interconnection Request when its contract
status changes if the output of its generator ``will be substantially
the same as before.'' \189\ California Wind Energy asserts that the
term ``output'' leaves ambiguous the effect of the Commission's
criteria on projects that are to be repowered after contract
conversion. It explains that when a QF repowers, it increases energy
production while maintaining its maximum megawatt output. California
Wind Energy seeks clarification that when a small generator increases
energy production as a result of a post-PURPA contract repower, and
there is no meaningful change in the generator's maximum output, there
is no obligation to file a new Interconnection Request.
---------------------------------------------------------------------------
\189\ Order No. 2003 at P 815.
---------------------------------------------------------------------------
Commission Conclusion
555. As in Order No. 2003, the Commission is not requiring changes
to interconnection agreements filed with the Commission before the
effective date of this Final Rule. Interconnection agreements submitted
for approval by the Commission before the effective date of this Final
Rule are grandfathered and will not be rejected outright for failing to
conform to the SGIA. Small Generating Facilities already interconnected
that have not changed their physical operations in such a way as to
require a new Interconnection Request are not subject to this
rulemaking.
556. We also note that the Small Generator NOPR did not address
what happens to Interconnection Customers whose Interconnection
Requests are pending at the time this Final Rule goes into effect. LGIP
section 5 addresses how such interconnections are to be processed, and
we adopt a shortened version of that provision in the SGIP as well. The
new section 1.7 clarifies that nothing in this Final Rule is intended
to affect an Interconnection Customer's Queue Position assigned prior
to the effective date of this rule. It also states that the Parties
shall continue to process any executed interconnection study agreements
(or study agreements that have been filed unexecuted with the
Commission) once this Final Rule becomes effective. However, we will
require that any new interconnection study agreement entered into after
this Final Rule becomes effective follow the pro forma study agreements
contained in the SGIP. Any accommodation needed to process such
Interconnection Requests (i.e., should the pre- and post-Final Rule
study processes be significantly different) should be filed with the
Commission and will be evaluated on a case-by-case basis.
557. If an interconnection agreement has been executed prior to the
effective date of this Final Rule, then no additional steps need to be
taken. We agree with the commenters that an existing Interconnection
Customer whose Small Generating Facility is already interconnected
should not have to undergo a new interconnection process.
558. We also reiterate that a change in an Interconnection
Customer's contract status does not, by itself, trigger an obligation
to file an Interconnection Request. As the Commission noted in Order
Nos. 2003 and 2003-A, a former QF interconnected with a Transmission
System that sells electric energy at wholesale in interstate commerce
need not submit an Interconnection Request if it represents that the
output of the generating facility is substantially the same as
before.\190\ Under the Commission's regulations,\191\ a QF must provide
electric energy to its interconnecting utility much like the
interconnecting utility's other network resources because the utility
must purchase the QF's power to displace its own generation. When the
owner of a QF that was formerly interconnected with a Transmission
System seeks to sell energy at wholesale and represents that the output
of its generator will be substantially the same after conversion, it
would be unreasonable for a Transmission Provider to require the former
QF to join the interconnection queue.
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\190\ Order No. 2003 at P 815.
\191\ 18 CFR 292.303 (2004).
---------------------------------------------------------------------------
559. California Wind Energy also asks the Commission to clarify
that a plant repowering at the time of contract conversion that does
not increase plant capacity will not trigger an obligation to file an
Interconnection Request. We clarify that a contract conversion that
does not affect a generator's demands on the Transmission System does
not trigger an obligation to file. When a QF's existing interconnection
agreement provides for capacity greater than the capacity sold by the
QF to the
[[Page 34238]]
interconnecting utility under the PURPA power purchase contract, the
QF's contract conversion will not trigger an obligation to file an
Interconnection Request if its transmission requirements are consistent
with the capacity provided for in the existing interconnection
agreement.
Order No. 2001 and the Filing of Interconnection Agreements
560. Order No. 2001 \192\ revised how traditional public utilities
and power marketers must satisfy their obligation, under section 205 of
the FPA and Part 35 of the Commission's regulations, to file agreements
with the Commission.\193\ Public utilities that have standard forms of
agreement in their OATTs, cost-based power sales tariffs, or tariffs
for other generally applicable services no longer need to file
conforming service agreements with the Commission. The filing
requirement for conforming agreements (those that follow the standard
form) is now satisfied by filing the standard form of agreement and an
Electronic Quarterly Report. Order No. 2001 also lifted the requirement
that Parties to an expiring conforming agreement file a notice of
cancellation or a cancellation tariff sheet with the Commission. The
public utility may simply remove the agreement from its Electric
Quarterly Report in the quarter after it terminates.
---------------------------------------------------------------------------
\192\ Revised Public Utility Filing Requirements, Order No.
2001, 67 FR 31043 (May 8, 2002), FERC Stats. & Regs. ] 31,127
(2002); reh'g denied, Order 2001-A, 100 FERC ] 61,074 (2002);
reconsideration and clarification denied, Order No. 2001-B, 100 FERC
] 61,342 (2002); further order, Order No. 2001-C, 101 FERC ] 61,314
(2002).
\193\ Order No. 2001 pointed out that Part 35 of the
Commission's regulations does not make a distinction between an
interconnection agreement and other agreements for service that must
be filed under the Commission's regulations. Order No. 2001,
therefore, said that if an interconnection agreement conforms to a
Commission-approved standard form of interconnection agreement, the
utility does not have to file it, but must report it in the Electric
Quarterly Reports. It also stated that the requirement to file
contract data and transaction data begins with the first Electric
Quarterly Report filed after service begins under an agreement, and
continues until the Electric Quarterly Report filed after it expires
or by order of the Commission. However, an interconnection agreement
that does not precisely match the Transmission Provider's approved
interconnection agreement or that is unexecuted must be filed with
the Commission. The Transmission Provider must clearly show where
the agreement does not conform to its standard interconnection
agreement, preferably through red-lining and strike-out.
---------------------------------------------------------------------------
561. Non-conforming agreements, which are agreements for
transmission, cost-based power sales or other generally applicable
services that do not conform to a standard form of agreement in a
public utility's tariff, must continue to be filed with the Commission
for approval before going into effect. This category includes
unexecuted agreements and agreements that do not precisely match the
standard form of agreement.
562. Order No. 2003 explained that, under Order No. 2001, if an
interconnection agreement conforms to a Commission-approved standard
form of interconnection agreement, the Transmission Provider does not
have to file it with the Commission, but must report it in its Electric
Quarterly Reports. The same filing rules will apply to non-conforming
SGIAs as for non-conforming LGIAs. However, an interconnection
agreement that does not precisely match the Transmission Provider's
Commission-approved standard interconnection agreements or that is
unexecuted must be filed in its entirety. The Transmission Provider
shall clearly show where the filed agreement does not conform to its
standard interconnection agreement through red-lining and strike-out
and justify the basis for the nonconformance.
III. Information Collection Statement
563. The Office of Management and Budget (OMB) regulations require
that OMB approve certain reporting and record keeping (collections of
information) imposed by an agency.\194\ The information collection
requirements in this Final Rule are identified under the Commission
data collection, FERC-516A ``Standardization of Small Generator
Interconnection Agreements and Procedures.'' Under section 3507(d) of
the Paperwork Reduction Act of 1995,\195\ the proposed reporting
requirements in the subject rulemaking will be submitted to OMB for
review. Interested persons may obtain information on the reporting
requirements by contacting the Federal Energy Regulatory Commission,
888 First Street, NE., Washington, DC 20426 (Attention: Michael Miller,
Office of the Executive Director, 202-502-8415) or from the Office of
Management and Budget (Attention: Desk Officer for the Federal Energy
Regulatory Commission, fax: 202-395-7285, e-mail: n.;[9
oira_submission@omb.eop.gov).
---------------------------------------------------------------------------
\194\ 5 CFR 1320.11 (2004).
\195\ 44 U.S.C. 3507(d) (2000).
---------------------------------------------------------------------------
564. The ``public protection'' provision of the Paperwork Reduction
Act \196\ requires each agency to display a currently valid OMB control
number and inform respondents that a response is not required unless
the information collection displays a valid OMB control number on each
information collection. This provision has two legal effects: (1) It
creates a legal responsibility for the agency; and (2) it provides an
affirmative legal defense for respondents if the information collection
is imposed on respondents by the Commission through regulation or
administrative means in order to satisfy a legal authority or
responsibility of the Commission. If the Commission should fail to
display an OMB control number, then it is the Commission not the
respondent who is in violation of the law. ``Display'' is defined as
publishing the OMB control number in regulations, guidelines or other
issuances in the Federal Register (for example, in the preamble or
regulatory text for the final rule containing the information
collection).\197\ Therefore, the Commission may not conduct or sponsor,
and a person is not required to respond to a collection of information
unless the information collection displays a valid OMB control number.
---------------------------------------------------------------------------
\196\ 44 U.S.C. 3512; 5 CFR 1320.5(b); 5 CFR 1320.6(a).
\197\ See 1 CFR 21.35 and 5 CFR 1320.3(f)(3).
---------------------------------------------------------------------------
565. Public Reporting Burden: The Commission did not receive
specific comments concerning its burden estimates and uses the same
estimates here in the Final Rule. Comments on the substantive issues
raised in the NOPR are addressed elsewhere in the Final Rule.
----------------------------------------------------------------------------------------------------------------
No. of No. of Hours per Total annual
Data collection respondents responses response hours
----------------------------------------------------------------------------------------------------------------
FERC-516A
SGIPs & SGIAs............................... 238 1 25 5,950
Recordkeeping............................... 238 1 2 476
-----------------
Totals.................................. .............. .............. .............. 6,426
----------------------------------------------------------------------------------------------------------------
[[Continued on page 34239]]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
]
[[pp. 34239-34288]] Standardization of Small Generator Interconnection Agreements and
Procedures
[[Continued from page 34238]]
[[Page 34239]]
Total Annual Hours for Collection: 5,950 (reporting) [238
respondents x 1 x 25 hours] + 476 hours (recordkeeping ) [238 hours x 1
filing x 2 hours to retain interconnection documents] = 6,426.\198\
---------------------------------------------------------------------------
\198\ Adjustments made to reflect an increase in the number of
respondents from the estimate in the Small Generator Interconnection
NOPR.
---------------------------------------------------------------------------
566. Information Collection Costs: The Commission sought comments
about the time needed to comply with these requirements. No comments
were received. Staffing requirements to review and modify existing
hourly rate)]. To be added to this cost are the annualized costs for
rate for recordkeeping] or $8,092)). Total costs of $317,492 for
preparing filings for modification of the OATT and for recordkeeping of
interconnection documents. There will be a one-time start up cost to
comply with these requirements for the procedures and agreements and
then an additional cost to maintain them.\199\
---------------------------------------------------------------------------
\199\ Adjusted figures to reflect an increase in the number of
respondents.
---------------------------------------------------------------------------
Titles: FERC-516A ``Standardization of Small Generator
Interconnection Agreements and Procedures
Action: Revision of Currently Approved Collection of Information
OMB Control Nos: 1902-0203.
Respondents: Business or other for profit.
Frequency of Responses: One occasion.
Necessity of Information: The Final Rule revises the reporting
requirements contained in 18 CFR part 35. The Commission promulgates a
standardized SGIP and SGIA that public utilities must adopt. As noted
in the Final Rule, adopting these procedures and agreement will (1)
reduce interconnection costs and time for the owners of Small
Generating Facilities and Transmission Providers alike; (2) limit
opportunities for Transmission Providers to favor their own generation;
(3) facilitate market entry for generation competitors; and (4)
encourage needed investment in generator and transmission
infrastructure.
567. Interconnection plays a growing, crucial role in bringing
generation into the market to meet the needs of electricity customers.
However, requests for interconnection frequently result in complex
technical disputes about interconnection feasibility, cost and cost
responsibility. The Commission expects that a standardized SGIP and
SGIA will reduce interconnection costs and time for Interconnection
Customers and Transmission Providers, resolve most interconnection
disputes, minimize opportunities for undue discrimination, foster
increased development of economic generation, and improve system
reliability.
568. For information on the requirements, submitting comments on
the collection of information and the associated burden estimates
including suggestions for reducing this burden, please send your
comments to the Federal Energy Regulatory Commission, 888 First Street,
NE., Washington, DC 20426 (Attention: Michael Miller, Office of the
Executive Director, (202) 502-8415) or send comments to the Office of
Management and Budget (Attention: Desk Officer for the Federal Energy
Regulatory Commission, fax: (202) 395-7285, e-mail
oira_submission@omb.eop.gov).
IV. Environmental Impact Statement
569. Commission regulations require that an environmental
assessment or an environmental impact statement be prepared for any
Commission action that may have a significant adverse effect on the
human environment.\200\ No environmental consideration is necessary for
the promulgation of a rule that is clarifying, corrective, or
procedural or does not substantially change the effect of legislation
or regulations being amended,\201\ and also for information gathering,
analysis, and dissemination.\202\ The Final Rule updates part 35 of the
Commission's regulations and does not substantially change the effect
of the underlying legislation or the regulations being revised or
eliminated. In addition, the Final Rule involves information gathering,
analysis, and dissemination. Therefore, this Final Rule falls within
categorical exemptions provided in the Commission's regulations.
Consequently, neither an environmental impact statement nor an
environmental assessment is required.
---------------------------------------------------------------------------
\200\ Regulations Implementing National Environmental Policy
Act, Order No. 486, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs.
] 30,783 (1987).
\201\ 18 CFR 380.4(a)(2)(ii) (2004).
\202\ 18 CFR 380.4(a)(5) (2004).
---------------------------------------------------------------------------
570. While some Small Generating Facilities, such as reciprocating
engines, may produce more pollution, others, such as photovoltaics and
fuel cells, produce significantly less air, water and noise pollution
than do new central station technologies. Others, such as micro-
turbines, provide opportunities to reduce emissions by improving the
efficiency with which energy is consumed, through improved heat rates
and combined heat and power applications. Small Generating Facilities
may eliminate the need to run older, more polluting generating units
and reduce power line losses. As one of the goals of this rule is to
allow interconnection of Small Generating Facilities that can provide
environmental and economic benefits, this rule will benefit customers
by providing alternative generation sources.
V. Regulatory Flexibility Act
571. The Regulatory Flexibility Act (RFA) \203\ requires that a
rulemaking contain either a description and analysis of the effect that
the proposed rule will have on small entities or a certification that
the rule will not have a significant economic impact on a substantial
number of small entities. However, the RFA does not define
``significant'' or ``substantial'' instead leaving it up to any agency
to determine the impacts of its regulations on small entities. In the
NOPR, the Commission stated that the proposed regulations would impose
requirements only on interstate Transmission Providers, which are not
small businesses. The Commission certified that the proposed
regulations would not have a significant adverse impact on a
substantial number of small entities. In making its certification, the
Commission determined that the rule applies only to public utilities
that own, control, or operate facilities for transmitting electric
energy in interstate commerce and not to electric utilities per se.
Small entities that believe this rule will have a significant impact on
them may apply to the Commission for waivers.
---------------------------------------------------------------------------
\203\ 5 U.S.C. 601-612 (2000).
---------------------------------------------------------------------------
Comments
572. NRECA questions this certification. NRECA argues that to
lessen the impact of this rule on small entities, the Commission
should: ``(1) Provide a durable blanket waiver of the NOPR requirements
to all currently FPA-jurisdictional utilities, that qualify as 'small'
public utilities under the Small Business Administration (SBA) utility
size standards, and (2) provide a safe harbor for all `small' non-
jurisdictional providers that want to work with consumers to
interconnect generation, but want to maintain their non-jurisdictional
status.''
Commission Conclusion
573. We are applying the same standards to any entity seeking a
waiver of the requirements of this Final Rule. Because the possible
scenarios under which small entities may seek waivers
[[Page 34240]]
are diverse, they are not susceptible to resolution on a generic basis,
and we are requiring applications and fact-specific determinations in
each instance. The Commission does not have jurisdiction over non-
public utilities' rate, terms and conditions of transmission service
under sections 205 and 206 of the FPA, and Order No. 888 does not
require that non-public utilities file open access transmission
tariffs. In addition, under the waiver provisions of Order No. 888,
small non-public utilities may seek waiver from the reciprocity
provision. This waiver policy follows the SBA definition of a small
utility.\204\ The SBA defines a small electric utility as one that
disposes of 4 MWh or less of electric energy in a given year.\205\
---------------------------------------------------------------------------
\204\ See 5 U.S.C. 601(3) and 601(6) and 15 U.S.C. 632(a).
\205\ See 13 CFR 121.601.
---------------------------------------------------------------------------
574. We disagree with NRECA that this Final Rule will have a
significant economic effect on a substantial number of small entities.
Of the 931 electric cooperatives in the 47 states across the country,
686 receive financial assistance from the U.S. Department of
Agriculture and therefore are not subject to the Commission's
jurisdiction.\206\ Of the 67 members of NRECA who have generation and
transmission facilities, only 34 electric cooperatives are subject to
the Commission's jurisdiction. They are only a small subset of the
entities considered when determining a significant impact on a
substantial number of small entities. Within the subset of 34 entities,
only a few own, control, or operate interstate transmission facilities.
---------------------------------------------------------------------------
\206\ Source: Rural Utilities Service, U.S. Department of
Agriculture, http://www.usdagov.rus/electric/borrowers/index.htm.
April, 2005.
---------------------------------------------------------------------------
575. As NRECA noted in its comments, the Commission has an
important role in determining whether facilities are distribution or
transmission, and as the Commission noted elsewhere in this Final Rule,
the only facilities that are already subject to a Transmission's
Provider's OATT are covered by this rule and apply only to a small
percentage of small generator interconnections. The Commission
recognizes that most small generators will interconnect with facilities
that are not subject to the OATT.
576. However, in drafting this rule the Commission has followed the
provisions of both the RFA and the Paperwork Reduction Act to consider
the potential impact of regulations on small business and other small
entities. Specifically, the RFA directs agencies to consider four
regulatory alternatives to be considered in a rulemaking to lessen the
impact on small entities: Tiering or establishment of different
compliance or reporting requirements for small entities,
classification, consolidation, clarification or simplification of
compliance and reporting requirements, performance rather than design
standards, and exemptions. The Commission has adopted both tiering, and
classification and simplification when developing technical accelerated
procedures to apply to interconnections that will have no adverse
effect on the Transmission Provider's electric system. By the use of
tiering, the Commission is creating three ways to evaluate
Interconnection Requests that can be applied to size and operating
conditions of a small generating facility. As noted earlier, all Small
Generating Facilities are subject to the Study Process, but in order to
expedite the process and reduce the requirements on facilities smaller
than 2 MW, technical screens were developed for certified Small
Generating Facilities no larger than 2 MW (Fast Track) and certified
inverter-based Small Generating Facilities no larger than 10 kW (10 kW
Inverter Process). The latter process was further simplified as it does
not use an SGIA, instead using an all-in-one document that includes the
application form, interconnection procedures, and terms and conditions.
In addition, many provisions of the SGIA are based on the NARUC Model
which in turn is based on the experience of several states for
implementing interconnections.
577. A core issue has been whether standards could be developed
that will allow for a cost effective interconnection solution without
jeopardizing the safety and reliability of the Transmission System. One
study showed that the typical cost of interconnection ranges from $50/
kW-$200/kW depending on the size of the generating facility,
application and utility requirements.\207\ By simplifying both the
interconnection procedures document and interconnection agreement, the
costs of small generating facilities should be reduced, equipment
manufacturers will be able to operate from a single set of technical
specifications, and seamless procedures will be in place that do not
jeopardize the safety and reliability of the Transmission System.
---------------------------------------------------------------------------
\207\ Souce: Arthur D. Little, Distribution Generation: System
Interfaces, Arthur D. Little, Inc., Cambridge, Massachusetts, 1999.
---------------------------------------------------------------------------
VI. Document Availability
578. In addition to publishing the full text of this document in
the Federal Register, the Commission provides all interested persons an
opportunity to obtain this document from the Public Reference Room
during normal business hours (8:30 a.m. to 5 p.m. Eastern Time) at 888
First Street, NE., Room 2A, Washington, DC. The full text of this
document is also available electronically from the Commission's
eLibrary system (formerly called FERRIS) in PDF and Microsoft Word
format for viewing, printing, and downloading. eLibrary may be accessed
through the Commission's Home Page (http://www.ferc.gov). To access
this document in eLibrary, type ``RM02-1-'' in the docket number field
and specify a date range that includes this document's issuance date.
579. User assistance is available for eLibrary and the Commission's
Web site during normal business hours from our Help Line at (202) 502-
8222 or the Public Reference Room at (202) 502-8371 Press 0, TTY (202)
502-8659. E-Mail the Public Reference Room at
public.referenceroom@ferc.gov.
VII. Effective Date And Congressional Notification
580. This Final Rule will take effect on August 12, 2005. The
Commission has determined, with the concurrence of the Administrator of
the Office of Information and Regulatory Affairs of the Office of
Management and Budget, that this rule is not a ``major rule'' within
the meaning of section 251 of the Small Business Regulatory Enforcement
Fairness Act of 1996.\208\ The Commission will submit the Final Rule to
both houses of Congress and the General Accounting Office.\209\
---------------------------------------------------------------------------
\208\ 5 U.S.C. 804(2) (2000).
\209\ 5 U.S.C. 801(a)(1)(A) (2000).
---------------------------------------------------------------------------
List of Subjects in 18 CFR Part 35
Electric power rates, Electric utilities, Reporting and
recordkeeping requirements.
By the Commission.
Linda Mitry,
Deputy Secretary.
0
In consideration of the foregoing, the Commission amends part 35,
Chapter I, Title 18 of the Code of Federal Regulations, as follows.
PART 35--FILING OF RATE SCHEDULES AND TARIFFS
0
1. The authority citation for part 35 continues to read as follows:
Authority: 16 U.S.C. 791a-825r, 2601-2645; 31 U.S.C. 9701; 42
U.S.C. 7101-7352.
0
2. In Sec. 35.28, paragraph (f) is revised to read as follows:
[[Page 34241]]
Sec. 35.28 Non-discriminatory open access transmission tariff.
* * * * *
(f) Standard generator interconnection procedures and agreements.
(1) Every public utility that is required to have on file a non-
discriminatory open access transmission tariff under this section must
amend such tariff by adding the standard interconnection procedures and
agreement contained in Order No. 2003, FERC Stats. & Regs. ] 31,146
(Final Rule on Generator Interconnection) and the standard small
generator interconnection procedures and agreement contained in Order
No. 2006, FERC Stats. & Regs. ]------ (Final Rule on Small Generator
Interconnection), or such other interconnection procedures and
agreements as may be approved by the Commission consistent with Order
No. 2003, FERC Stats. & Regs. ] 31,146 (Final Rule on Generator
Interconnection) and Order No. 2006, FERC Stats. & Regs. ]------ (Final
Rule on Small Generator Interconnection).
(i) The amendment to implement the Final Rule on Generator
Interconnection required by paragraph (f)(1) of this section must be
filed no later than January 20, 2004.
Before Commissioners: Pat Wood, III, Chairman;
(ii) The amendment to implement the Final Rule on Small Generator
Interconnection required by paragraph (f)(1) of this section must be
filed no later than August 12, 2005.
(iii) Any public utility that seeks a deviation from the standard
interconnection procedures and agreement contained in Order No. 2003,
FERC Stats. & Regs. ] 31,146 (Final Rule on Generator Interconnection)
or the standard small generator interconnection procedures and
agreement contained in Order No. 2006, FERC Stats. & Regs. ]---- (Final
Rule on Small Generator Interconnection), must demonstrate that the
deviation is consistent with the principles of either Order No. 2003,
FERC Stats. & Regs. ] 31,146 (Final Rule on Generator Interconnection)
or Order No. 2006, FERC Stats. & Regs. ]---- (Final Rule on Small
Generator Interconnection).
(2) The non-public utility procedures for tariff reciprocity
compliance described in paragraph (e) of this section are applicable to
the standard interconnection procedures and agreements.
(3) A public utility subject to the requirements of this paragraph
pertaining to the Final Rule on Generator Interconnection may file a
request for waiver of all or part of the requirements of this
paragraph, for good cause shown. An application for waiver must be
filed either:
(i) No later than January 20, 2004, or
(ii) No later than 60 days prior to the time the public utility
would otherwise have to comply with the requirements of this paragraph.
(4) A public utility subject to the requirements of this paragraph
pertaining to the Final Rule on Small Generator Interconnection may
file a request for waiver of all or part of the requirements of this
paragraph, for good cause shown. An application for waiver must be
filed either:
(i) No later than August 12, 2005, or
(ii) No later than 60 days prior to the time the public utility
would otherwise have to comply with the requirements of this paragraph.
[The following Appendices will not be published in the Code of Federal
Regulations.]
Appendix A--Commenter Acronyms \1\
---------------------------------------------------------------------------
\1\ This list includes commenters who filed in response to the
request for comments in the Notice of Proposed Rulemaking, the
August 12, 2004 Request for Supplemental Comments, or both.
Commenters who responded to the Request for Supplemental Comments
are also listed separately at the end of this appendix.
---------------------------------------------------------------------------
AEP--American Electric Power System
Alabama PSC--Alabama Public Service Commission
Allegheny Energy--Allegheny Energy Supply Company, LLC and
Allegheny Power
Ameren--Ameren Services Company
American Forest--American Forest & Paper Association and the
Process Gas Consumers Group
AMP-Ohio--American Municipal Power--Ohio, Inc.
Avista--Avista Corp. and Puget Sound Energy, Inc.
Baltimore G&E--Baltimore Gas and Electric Company
BPA--Bonneville Power Administration, U.S. Department of Energy
Bureau of Reclamation--Bureau of Reclamation, U.S. Department of
Interior
CA ISO--California ISO
California Wind Energy--California Wind Energy Association
Capstone--Capstone Turbine Corp.
Central Iowa Coop--Central Iowa Power Cooperative and Corn Belt
Power Cooperative
Central Maine--Central Maine Power Company, New York State
Electric & Gas Corporation, and Rochester Gas & Electric Corporation
Cinergy--Cinergy Services, Inc.
Consumers--Consumers Energy Company
CPUC--California Public Utilities Commission
CT DPUC--Connecticut Department of Public Utility Control
Cummins--Cummins, Inc.
EEI--Edison Electric Institute
Empire District--Empire District Electric Co.
Encorp--Encorp, Inc.
Exelon--Exelon Generation Company, LLC, Commonwealth Edison
Company, PECO Energy Company, and Sithe Energies, Inc.
FERC DRS--Dispute Resolution Service, Federal Energy Regulatory
Commission
Florida PSC--Florida Public Service Commission
Garwin McNeilus--Mr. Garwin McNeilus
Georgia PSC--Georgia Public Service Commission
Georgia Transmission--Georgia Transmission Corporation
Idaho Power--Idaho Power Company
Iowa Utilities Board--Iowa Utilities Board
ISO New England--ISO New England
Joint Commenters--National Association of Regulatory Utility
Commissioners, Small Generator Coalition (members listed below),
American Public Power Association (who did not participate in the
filing of supplemental comments), National Rural Electric
Cooperative Association, and Edison Electric Institute
LADWP--Los Angeles Department of Water and Power
Massachusetts DTE--Massachusetts Department of
Telecommunications and Energy
MidAmerican--MidAmerican Energy Company
Midwest ISO--Midwest Independent Transmission System Operator,
Inc.
Minnesota PUC--Minnesota Public Utilities Commission and the
Minnesota Department of Commerce
Mississippi PSC--Mississippi Public Service Commission
NARUC--National Association of Regulatory Utility Commissioners
National Grid--National Grid USA
NEMA--National Electrical Manufacturers Association
NEPOOL Participants--New England Power Pool Participants
Committee
Nevada Power--Nevada Power Company and Sierra Pacific Power
Company
NJ BPU--New Jersey Board of Public Utilities
North Carolina Commission--North Carolina Utilities Commission
and the Public Staff of the North Carolina Utilities Commission
NorthWestern Energy--NorthWestern Energy
NRECA--National Rural Electric Cooperative Association
NYISO--New York Independent System Operator, Inc.
NYPSC--New York State Public Service Commission
NYTO--Central Hudson Gas and Electric Corp., Consolidated Edison
Company of New York, Inc., Long Island Power Authority, New York
Power Authority, New York State Electric and Gas Corp., Orange and
Rockland Utilities, Inc., and Rochester Gas and Electric Corp.
Ohio PUC--Public Utilities Commission of Ohio
PacifiCorp--PacifiCorp
PG&E--Pacific Gas and Electric Company
PJM--PJM Interconnection, L.L.C.
Plug Power--Plug Power, Inc.
Progress Energy--Progress Energy, Inc., Carolina Power and Light
Co., and Florida Power Corp.
PSE&G--Public Service Electric and Gas Company
[[Page 34242]]
Robert L. Carey--Mr. Robert L. Carey
RW Beck--R.W. Beck, Inc.
Small Generator Coalition--American Council for an Energy
Efficient Economy; American Solar Energy Society; American Wind
Energy Association; BP Solar; Citizens Action Coalition of Indiana;
Coffman Electrical Equipment; Cummins Power Generation; Elliott
Energy Systems; Encorp; Environmental Law & Policy Center; Kyocera
Solar, Inc.; MAN Turbomachinery, Inc.; Natural Resources Defense
Council; Northeast-Midwest Institute; Northwest Energy Coalition;
Pace Energy Program; Pennsylvania Energy Project; Plug Power, Inc.;
Power Equipment Associates; PowerLight Corporation; RWE SCHOTT
Solar, Inc.; Shepherd Advisors; Solar Energy Industries Association;
Spire Solar, Inc.; U.S. Combined Heat and Power Association; and
University of Oregon Solar Radiation Monitoring Laboratory.
SMUD--Sacramento Municipal Utility District
SoCal Edison--Southern California Edison Company
Solar Turbines--Solar Turbines, Inc.
Southern Company--Southern Company Services, Inc.
SW TDU Group--Southwest Transmission Dependent Utility Group
(Aguila Irrigation District, Ak-Chin Electric Utility Authority,
Buckeye Water Conservation and Drainage District, Central Arizona
Water Conservation District, Electrical District No. 3, Electrical
District No. 4, Electrical District No. 5, Electrical District No.
6, Electrical District No. 7, Electrical District No. 8, Harquahala
Valley Power District, Maricopa County Municipal Water District No.
1, McMullen Valley Water Conservation and Drainage District, City of
Needles, Roosevelt Irrigation District, City of Safford, Tonopah
Irrigation District, Wellton-Mohawk Irrigation and Drainage
District)
Tangibl--Tangibl, LLC
TAPS--Transmission Access Policy Study Group
TDU Systems--Transmission Dependent Utility Systems (Alabama
Electric Cooperative, Inc.; Arkansas Electric Cooperative
Corporation; Golden Spread Electric Cooperative; Kansas Electric
Power Cooperative, Inc.; Old Dominion Electric Cooperative; and
Seminole Electric Cooperative, Inc.)
USCHPA--U.S. Combined Heat and Power Association
Western--Western Area Power Administration
Commenters Who Filed in Response to the Commission's Request for
Supplemental Comments
CT DPUC--Connecticut Department of Public Utility Control
FERC DRS--Dispute Resolution Service, Federal Energy Regulatory
Commission
Joint Commenters--National Association of Regulatory Utility
Commissioners, Small Generator Coalition (members listed above),
National Rural Electric Cooperative Association, and Edison Electric
Institute (American Public Power Association did not participate in
the filing of supplemental comments)
Massachusetts DTE--Massachusetts Department of
Telecommunications and Energy
Minnesota PUC--Minnesota Public Utilities Commission and the
Minnesota Department of Commerce
National Grid--National Grid USA
NJ BPU--New Jersey Board of Public Utilities
North Carolina Commission--North Carolina Utilities Commission
and the Public Staff of the North Carolina Utilities Commission
NRECA--National Rural Electric Cooperative Association
Ohio PUC--Public Utilities Commission of Ohio
PJM--PJM Interconnection, L.L.C.
Small Generator Coalition (members listed above)
USCHPA--U.S. Combined Heat and Power Association
BILLING CODE 6717-01-U
[[Page 34243]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.000
[[Page 34244]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.001
[[Page 34245]]
Appendix D--Flow Chart for Interconnecting a Certified Inverter-Based
Small Generating Facility No Larger Than 10 kW Using the ``10 kW
Inverter Process''
[GRAPHIC] [TIFF OMITTED] TR13JN05.002
BILLING CODE 6717--01--C
[[Page 34246]]
Appendix E to the Small Generator Interconnection Final Rule
SMALL GENERATOR INTERCONNECTION PROCEDURES (SGIP) (For Generating
Facilities No Larger Than 20 MW)
Table of Contents
Section 1. Application
1.1 Applicability
1.2 Pre-Application
1.3 Interconnection Request
1.4 Modification of the Interconnection Request
1.5 Site Control
1.6 Queue Position
1.7 Interconnection Requests Submitted Prior to the Effective
Date of the SGIP
Section 2. Fast Track Process
2.1 Applicability
2.2 Initial Review
2.2.1 Screens
2.3 Customer Options Meeting
2.4 Supplemental Review
Section 3. Study Process
3.1 Applicability
3.2 Scoping Meeting
3.3 Feasibility Study
3.4 System Impact Study
3.5 Facilities Study
Section 4. Provisions That Apply to All Interconnection Requests
4.1 Reasonable Efforts
4.2 Disputes
4.3 Interconnection Metering
4.4 Commissioning
4.5 Confidentiality
4.6 Comparability
4.7 Record Retention
4.8 Interconnection Agreement
4.9 Coordination With Affected Systems
4.10 Capacity of the Small Generating Facility
Attachment 1--Glossary of Terms
Attachment 2--Small Generator Interconnection Request
Attachment 3--Certification Codes and Standards
Attachment 4--Certification of Small Generator Equipment
Packages
Attachment 5--Application, Procedures, and Terms and Conditions
for Interconnecting a Certified Inverter-Based Small Generating
Facility No Larger Than 10 kW (``10 kW Inverter Process'')
Attachment 6--Feasibility Study Agreement
Attachment 7--System Impact Study Agreement
Attachment 8--Facilities Study Agreement
Section 1. Application
1.1 Applicability
1.1.1 A request to interconnect a certified Small Generating
Facility (See Attachments 3 and 4 for description of certification
criteria) no larger than 2 MW shall be evaluated under the section 2
Fast Track Process. A request to interconnect a certified inverter-
based Small Generating Facility no larger than 10 kW shall be
evaluated under the Attachment 5 10 kW Inverter Process. A request
to interconnect a Small Generating Facility larger than 2 MW but no
larger than 20 MW or a Small Generating Facility that does not pass
the Fast Track Process or the 10 kW Inverter Process, shall be
evaluated under the section 3 Study Process.
1.1.2 Capitalized terms used herein shall have the meanings
specified in the Glossary of Terms in Attachment 1 or the body of
these procedures.
1.1.3 Neither these procedures nor the requirements included
hereunder apply to Small Generating Facilities interconnected or
approved for interconnection prior to 60 Business Days after the
effective date of these procedures.
1.1.4 Prior to submitting its Interconnection Request
(Attachment 2), the Interconnection Customer may ask the
Transmission Provider's interconnection contact employee or office
whether the proposed interconnection is subject to these procedures.
The Transmission Provider shall respond within 15 Business Days.
1.1.5 Infrastructure security of electric system equipment and
operations and control hardware and software is essential to ensure
day-to-day reliability and operational security. The Federal Energy
Regulatory Commission expects all Transmission Providers, market
participants, and Interconnection Customers interconnected with
electric systems to comply with the recommendations offered by the
President's Critical Infrastructure Protection Board and best
practice recommendations from the electric reliability authority.
All public utilities are expected to meet basic standards for
electric system infrastructure and operational security, including
physical, operational, and cyber-security practices.
1.1.6 References in these procedures to interconnection
agreement are to the Small Generator Interconnection Agreement
(SGIA).
1.2 Pre-Application
The Transmission Provider shall designate an employee or office
from which information on the application process and on an Affected
System can be obtained through informal requests from the
Interconnection Customer presenting a proposed project for a
specific site. The name, telephone number, and e-mail address of
such contact employee or office shall be made available on the
Transmission Provider's Internet web site. Electric system
information provided to the Interconnection Customer should include
relevant system studies, interconnection studies, and other
materials useful to an understanding of an interconnection at a
particular point on the Transmission Provider's Transmission System,
to the extent such provision does not violate confidentiality
provisions of prior agreements or critical infrastructure
requirements. The Transmission Provider shall comply with reasonable
requests for such information.
1.3 Interconnection Request
The Interconnection Customer shall submit its Interconnection
Request to the Transmission Provider, together with the processing
fee or deposit specified in the Interconnection Request. The
Interconnection Request shall be date- and time-stamped upon
receipt. The original date- and time-stamp applied to the
Interconnection Request at the time of its original submission shall
be accepted as the qualifying date- and time-stamp for the purposes
of any timetable in these procedures. The Interconnection Customer
shall be notified of receipt by the Transmission Provider within
three Business Days of receiving the Interconnection Request. The
Transmission Provider shall notify the Interconnection Customer
within ten Business Days of the receipt of the Interconnection
Request as to whether the Interconnection Request is complete or
incomplete. If the Interconnection Request is incomplete, the
Transmission Provider shall provide along with the notice that the
Interconnection Request is incomplete, a written list detailing all
information that must be provided to complete the Interconnection
Request. The Interconnection Customer will have ten Business Days
after receipt of the notice to submit the listed information or to
request an extension of time to provide such information. If the
Interconnection Customer does not provide the listed information or
a request for an extension of time within the deadline, the
Interconnection Request will be deemed withdrawn. An Interconnection
Request will be deemed complete upon submission of the listed
information to the Transmission Provider.
1.4 Modification of the Interconnection Request
Any modification to machine data or equipment configuration or
to the interconnection site of the Small Generating Facility not
agreed to in writing by the Transmission Provider and the
Interconnection Customer may be deemed a withdrawal of the
Interconnection Request and may require submission of a new
Interconnection Request, unless proper notification of each Party by
the other and a reasonable time to cure the problems created by the
changes are undertaken.
1.5 Site Control
Documentation of site control must be submitted with the
Interconnection Request. Site control may be demonstrated through:
1.8.1 Ownership of, a leasehold interest in, or a right to
develop a site for the purpose of constructing the Small Generating
Facility;
1.8.2 An option to purchase or acquire a leasehold site for such
purpose; or
1.8.3 An exclusivity or other business relationship between the
Interconnection Customer and the entity having the right to sell,
lease, or grant the Interconnection Customer the right to possess or
occupy a site for such purpose.
1.6 Queue Position
The Transmission Provider shall assign a Queue Position based
upon the date- and time-stamp of the Interconnection Request. The
Queue Position of each Interconnection Request will be used to
determine the cost responsibility for the Upgrades necessary to
accommodate the interconnection. The Transmission Provider shall
maintain a single queue per geographic region. At the Transmission
Provider's option, Interconnection Requests may be studied serially
or in clusters for the purpose of the system impact study.
[[Page 34247]]
1.7 Interconnection Requests Submitted Prior to the Effective Date
of the SGIP
Nothing in this SGIP affects an Interconnection Customer's Queue
Position assigned before the effective date of this SGIP. The
Parties agree to complete work on any interconnection study
agreement executed prior the effective date of this SGIP in
accordance with the terms and conditions of that interconnection
study agreement. Any new studies or other additional work will be
completed pursuant to this SGIP.
Section 2. Fast Track Process
2.1 Applicability
The Fast Track Process is available to an Interconnection
Customer proposing to interconnect its Small Generating Facility
with the Transmission Provider's Transmission System if the Small
Generating Facility is no larger than 2 MW and if the
Interconnection Customer's proposed Small Generating Facility meets
the codes, standards, and certification requirements of Attachments
3 and 4 of these procedures, or the Transmission Provider has
reviewed the design or tested the proposed Small Generating Facility
and is satisfied that it is safe to operate.
2.2 Initial Review
Within 15 Business Days after the Transmission Provider notifies
the Interconnection Customer it has received a complete
Interconnection Request, the Transmission Provider shall perform an
initial review using the screens set forth below, shall notify the
Interconnection Customer of the results, and include with the
notification copies of the analysis and data underlying the
Transmission Provider's determinations under the screens.
2.2.1 Screens.
2.2.1.1 The proposed Small Generating Facility's Point of
Interconnection must be on a portion of the Transmission Provider's
Distribution System that is subject to the Tariff.
2.2.1.2 For interconnection of a proposed Small Generating
Facility to a radial distribution circuit, the aggregated
generation, including the proposed Small Generating Facility, on the
circuit shall not exceed 15% of the line section annual peak load as
most recently measured at the substation. A line section is that
portion of a Transmission Provider's electric system connected to a
customer bounded by automatic sectionalizing devices or the end of
the distribution line.
2.2.1.3 For interconnection of a proposed Small Generating
Facility to the load side of spot network protectors, the proposed
Small Generating Facility must utilize an inverter-based equipment
package and, together with the aggregated other inverter-based
generation, shall not exceed the smaller of 5% of a spot network's
maximum load or 50 kW.\1\
---------------------------------------------------------------------------
\1\ A spot Network is a type of distribution system found within
modern commercial buildings to provide high reliability of service
to a single customer. (Standard Handbook for Electrical Engineers,
11th edition, Donald Fink, McGraw Hill Book Company).
---------------------------------------------------------------------------
2.2.1.4 The proposed Small Generating Facility, in aggregation
with other generation on the distribution circuit, shall not
contribute more than 10% to the distribution circuit's maximum fault
current at the point on the high voltage (primary) level nearest the
proposed point of change of ownership.
2.2.1.5 The proposed Small Generating Facility, in aggregate
with other generation on the distribution circuit, shall not cause
any distribution protective devices and equipment (including, but
not limited to, substation breakers, fuse cutouts, and line
reclosers), or Interconnection Customer equipment on the system to
exceed 87.5% of the short circuit interrupting capability; nor shall
the interconnection proposed for a circuit that already exceeds
87.5% of the short circuit interrupting capability.
2.2.1.6 Using the table below, determine the type of
interconnection to a primary distribution line. This screen includes
a review of the type of electrical service provided to the
Interconnecting Customer, including line configuration and the
transformer connection to limit the potential for creating over-
voltages on the Transmission Provider's electric power system due to
a loss of ground during the operating time of any anti-islanding
function.
------------------------------------------------------------------------
Type of
interconnection
Primary distribution line type to primary Result/ criteria
distribution line
------------------------------------------------------------------------
Three-phase, three wire......... 3-phase or single Pass screen.
phase, phase-to-
phase.
Three-phase, four wire.......... Effectively- Pass screen.
grounded 3 phase
or Single-phase,
line-to-neutral.
------------------------------------------------------------------------
2.2.1.7 If the proposed Small Generating Facility is to be
interconnected on single-phase shared secondary, the aggregate
generation capacity on the shared secondary, including the proposed
Small Generating Facility, shall not exceed 20 kW.
2.2.1.8 If the proposed Small Generating Facility is single-
phase and is to be interconnected on a center tap neutral of a 240
volt service, its addition shall not create an imbalance between the
two sides of the 240 volt service of more than 20% of the nameplate
rating of the service transformer.
2.2.1.9 The Small Generating Facility, in aggregate with other
generation interconnected to the transmission side of a substation
transformer feeding the circuit where the Small Generating Facility
proposes to interconnect shall not exceed 10 MW in an area where
there are known, or posted, transient stability limitations to
generating units located in the general electrical vicinity (e.g.,
three or four transmission busses from the point of
interconnection).
2.2.1.10 No construction of facilities by the Transmission
Provider on its own system shall be required to accommodate the
Small Generating Facility.
2.2.2 If the proposed interconnection passes the screens, the
Interconnection Request shall be approved and the Transmission
Provider will provide the Interconnection Customer an executable
interconnection agreement within five Business Days after the
determination.
2.2.3 If the proposed interconnection fails the screens, but the
Transmission Provider determines that the Small Generating Facility
may nevertheless be interconnected consistent with safety,
reliability, and power quality standards, the Transmission Provider
shall provide the Interconnection Customer an executable
interconnection agreement within five Business Days after the
determination.
2.2.4 If the proposed interconnection fails the screens, but the
Transmission Provider does not or cannot determine from the initial
review that the Small Generating Facility may nevertheless be
interconnected consistent with safety, reliability, and power
quality standards unless the Interconnection Customer is willing to
consider minor modifications or further study, the Transmission
Provider shall provide the Interconnection Customer with the
opportunity to attend a customer options meeting.
2.3 Customer Options Meeting
If the Transmission Provider determines the Interconnection
Request cannot be approved without minor modifications at minimal
cost; or a supplemental study or other additional studies or
actions; or at significant cost to address safety, reliability, or
power quality problems, within the five Business Day period after
the determination, the Transmission Provider shall notify the
Interconnection Customer and provide copies of all data and analyses
underlying its conclusion. Within ten Business Days of the
Transmission Provider's determination, the Transmission Provider
shall offer to convene a customer options meeting with the
Transmission Provider to review possible Interconnection Customer
facility modifications or the screen analysis and related results,
to determine what further steps are needed to permit the Small
Generating Facility to be connected safely and reliably. At the time
of notification of the Transmission Provider's determination, or at
the customer options meeting, the Transmission Provider shall:
2.3.1 Offer to perform facility modifications or minor
modifications to the Transmission Provider's electric system (e.g.,
changing meters, fuses, relay settings) and provide a non-binding
good faith estimate of the limited cost to make such modifications
to the Transmission Provider's electric system; or
2.3.2 Offer to perform a supplemental review if the Transmission
Provider concludes that the supplemental review might determine that
the Small Generating Facility could continue to qualify for
interconnection pursuant to the Fast Track Process, and provide a
non-binding good faith estimate of the costs of such review; or
2.3.3 Obtain the Interconnection Customer's agreement to
continue evaluating the Interconnection Request under the section 3
Study Process.
[[Page 34248]]
2.4 Supplemental Review
If the Interconnection Customer agrees to a supplemental review,
the Interconnection Customer shall agree in writing within 15
Business Days of the offer, and submit a deposit for the estimated
costs. The Interconnection Customer shall be responsible for the
Transmission Provider's actual costs for conducting the supplemental
review. The Interconnection Customer must pay any review costs that
exceed the deposit within 20 Business Days of receipt of the invoice
or resolution of any dispute. If the deposit exceeds the invoiced
costs, the Transmission Provider will return such excess within 20
Business Days of the invoice without interest.
2.4.1 Within ten Business Days following receipt of the deposit
for a supplemental review, the Transmission Provider will determine
if the Small Generating Facility can be interconnected safely and
reliably.
2.4.1.1 If so, the Transmission Provider shall forward an
executable an interconnection agreement to the Interconnection
Customer within five Business Days.
2.4.1.2 If so, and Interconnection Customer facility
modifications are required to allow the Small Generating Facility to
be interconnected consistent with safety, reliability, and power
quality standards under these procedures, the Transmission Provider
shall forward an executable interconnection agreement to the
Interconnection Customer within five Business Days after
confirmation that the Interconnection Customer has agreed to make
the necessary changes at the Interconnection Customer's cost.
2.4.1.3 If so, and minor modifications to the Transmission
provider's electric system are required to allow the Small
Generating Facility to be interconnected consistent with safety,
reliability, and power quality standards under the Fast Track
Process, the Transmission Provider shall forward an executable
interconnection agreement to the Interconnection Customer within ten
Business Days that requires the Interconnection Customer to pay the
costs of such system modifications prior to interconnection.
2.4.1.4 If not, the Interconnection Request will continue to be
evaluated under the section 3 Study Process.
Section 3. Study Process
3.1 Applicability
The Study Process shall be used by an Interconnection Customer
proposing to interconnect its Small Generating Facility with the
Transmission Provider's Transmission System if the Small Generating
Facility (1) is larger than 2 MW but no larger than 20 MW, (2) is
not certified, or (3) is certified but did not pass the Fast Track
Process or the 10 kW Inverter Process.
3.2 Scoping Meeting
3.2.1 A scoping meeting will be held within ten Business Days
after the Interconnection Request is deemed complete, or as
otherwise mutually agreed to by the Parties. The Transmission
Provider and the Interconnection Customer will bring to the meeting
personnel, including system engineers and other resources as may be
reasonably required to accomplish the purpose of the meeting.
3.2.2 The purpose of the scoping meeting is to discuss the
Interconnection Request and review existing studies relevant to the
Interconnection Request. The Parties shall further discuss whether
the Transmission Provider should perform a feasibility study or
proceed directly to a system impact study, or a facilities study, or
an interconnection agreement. If the Parties agree that a
feasibility study should be performed, the Transmission Provider
shall provide the Interconnection Customer, as soon as possible, but
not later than five Business Days after the scoping meeting, a
feasibility study agreement (Attachment 6) including an outline of
the scope of the study and a non-binding good faith estimate of the
cost to perform the study.
3.2.3 The scoping meeting may be omitted by mutual agreement. In
order to remain in consideration for interconnection, an
Interconnection Customer who has requested a feasibility study must
return the executed feasibility study agreement within 15 Business
Days. If the Parties agree not to perform a feasibility study, the
Transmission Provider shall provide the Interconnection Customer, no
later than five Business Days after the scoping meeting, a system
impact study agreement (Attachment 7) including an outline of the
scope of the study and a non-binding good faith estimate of the cost
to perform the study.
3.3 Feasibility Study
3.3.1 The feasibility study shall identify any potential adverse
system impacts that would result from the interconnection of the
Small Generating Facility.
3.3.2 A deposit of the lesser of 50 percent of the good faith
estimated feasibility study costs or earnest money of $1,000 may be
required from the Interconnection Customer.
3.3.3 The scope of and cost responsibilities for the feasibility
study are described in the attached feasibility study agreement.
3.3.4 If the feasibility study shows no potential for adverse
system impacts, the Transmission Provider shall send the
Interconnection Customer a facilities study agreement, including an
outline of the scope of the study and a non-binding good faith
estimate of the cost to perform the study. If no additional
facilities are required, the Transmission Provider shall send the
Interconnection Customer an executable interconnection agreement
within five Business Days.
3.3.5 If the feasibility study shows the potential for adverse
system impacts, the review process shall proceed to the appropriate
system impact study(s).
3.4 System Impact Study
3.4.1 A system impact study shall identify and detail the
electric system impacts that would result if the proposed Small
Generating Facility were interconnected without project
modifications or electric system modifications, focusing on the
adverse system impacts identified in the feasibility study, or to
study potential impacts, including but not limited to those
identified in the scoping meeting. A system impact study shall
evaluate the impact of the proposed interconnection on the
reliability of the electric system.
3.4.2 If no transmission system impact study is required, but
potential electric power Distribution System adverse system impacts
are identified in the scoping meeting or shown in the feasibility
study, a distribution system impact study must be performed. The
Transmission Provider shall send the Interconnection Customer a
distribution system impact study agreement within 15 Business Days
of transmittal of the feasibility study report, including an outline
of the scope of the study and a non-binding good faith estimate of
the cost to perform the study, or following the scoping meeting if
no feasibility study is to be performed.
3.4.3 In instances where the feasibility study or the
distribution system impact study shows potential for transmission
system adverse system impacts, within five Business Days following
transmittal of the feasibility study report, the Transmission
Provider shall send the Interconnection Customer a transmission
system impact study agreement, including an outline of the scope of
the study and a non-binding good faith estimate of the cost to
perform the study, if such a study is required.
3.4.4 If a transmission system impact study is not required, but
electric power Distribution System adverse system impacts are shown
by the feasibility study to be possible and no distribution system
impact study has been conducted, the Transmission Provider shall
send the Interconnection Customer a distribution system impact study
agreement.
3.4.5 If the feasibility study shows no potential for
transmission system or Distribution System adverse system impacts,
the Transmission Provider shall send the Interconnection Customer
either a facilities study agreement (Attachment 8), including an
outline of the scope of the study and a non-binding good faith
estimate of the cost to perform the study, or an executable
interconnection agreement, as applicable.
3.4.6 In order to remain under consideration for
interconnection, the Interconnection Customer must return executed
system impact study agreements, if applicable, within 30 Business
Days.
3.4.7A deposit of the good faith estimated costs for each system
impact study may be required from the Interconnection Customer.
3.4.8 The scope of and cost responsibilities for a system impact
study are described in the attached system impact study agreement.
3.4.9 Where transmission systems and Distribution Systems have
separate owners, such as is the case with transmission-dependent
utilities (``TDUs'')--whether investor-owned or not--the
Interconnection Customer may apply to the nearest Transmission
Provider (Transmission Owner, Regional Transmission Operator, or
Independent Transmission Provider) providing transmission service to
the TDU to request project coordination. Affected Systems shall
participate in the study and
[[Page 34249]]
provide all information necessary to prepare the study.
3.5 Facilities Study
3.5.1 Once the required system impact study(s) is completed, a
system impact study report shall be prepared and transmitted to the
Interconnection Customer along with a facilities study agreement
within five Business Days, including an outline of the scope of the
study and a non-binding good faith estimate of the cost to perform
the facilities study. In the case where one or both impact studies
are determined to be unnecessary, a notice of the fact shall be
transmitted to the Interconnection Customer within the same
timeframe.
3.5.2 In order to remain under consideration for
interconnection, or, as appropriate, in the Transmission Provider's
interconnection queue, the Interconnection Customer must return the
executed facilities study agreement or a request for an extension of
time within 30 Business Days.
3.5.3 The facilities study shall specify and estimate the cost
of the equipment, engineering, procurement and construction work
(including overheads) needed to implement the conclusions of the
system impact study(s).
3.5.4 Design for any required Interconnection Facilities and/or
Upgrades shall be performed under the facilities study agreement.
The Transmission Provider may contract with consultants to perform
activities required under the facilities study agreement. The
Interconnection Customer and the Transmission Provider may agree to
allow the Interconnection Customer to separately arrange for the
design of some of the Interconnection Facilities. In such cases,
facilities design will be reviewed and/or modified prior to
acceptance by the Transmission Provider, under the provisions of the
facilities study agreement. If the Parties agree to separately
arrange for design and construction, and provided security and
confidentiality requirements can be met, the Transmission Provider
shall make sufficient information available to the Interconnection
Customer in accordance with confidentiality and critical
infrastructure requirements to permit the Interconnection Customer
to obtain an independent design and cost estimate for any necessary
facilities.
3.5.5 A deposit of the good faith estimated costs for the
facilities study may be required from the Interconnection Customer.
3.5.6 The scope of and cost responsibilities for the facilities
study are described in the attached facilities study agreement.
3.5.7 Upon completion of the facilities study, and with the
agreement of the Interconnection Customer to pay for Interconnection
Facilities and Upgrades identified in the facilities study, the
Transmission Provider shall provide the Interconnection Customer an
executable interconnection agreement within five Business Days.
Section 4. Provisions That Apply to All Interconnection Requests
4.1 Reasonable Efforts
The Transmission Provider shall make reasonable efforts to meet
all time frames provided in these procedures unless the Transmission
Provider and the Interconnection Customer agree to a different
schedule. If the Transmission Provider cannot meet a deadline
provided herein, it shall notify the Interconnection Customer,
explain the reason for the failure to meet the deadline, and provide
an estimated time by which it will complete the applicable
interconnection procedure in the process.
4.2 Disputes
4.2.1 The Parties agree to attempt to resolve all disputes
arising out of the interconnection process according to the
provisions of this article.
4.2.2 In the event of a dispute, either Party shall provide the
other Party with a written Notice of Dispute. Such Notice shall
describe in detail the nature of the dispute.
4.2.3 If the dispute has not been resolved within two Business
Days after receipt of the Notice, either Party may contact FERC's
Dispute Resolution Service (DRS) for assistance in resolving the
dispute.
4.2.4 The DRS will assist the Parties in either resolving their
dispute or in selecting an appropriate dispute resolution venue
(e.g., mediation, settlement judge, early neutral evaluation, or
technical expert) to assist the Parties in resolving their dispute.
DRS can be reached at 1-877-337-2237 or via the internet at http://www.ferc.gov/legal/adr.asp
.
4.2.5 Each Party agrees to conduct all negotiations in good
faith and will be responsible for one-half of any costs paid to
neutral third-parties.
4.2.6 If neither Party elects to seek assistance from the DRS,
or if the attempted dispute resolution fails, then either Party may
exercise whatever rights and remedies it may have in equity or law
consistent with the terms of this Agreement.
4.3 Interconnection Metering
Any metering necessitated by the use of the Small Generating
Facility shall be installed at the Interconnection Customer's
expense in accordance with Federal Energy Regulatory Commission,
state, or local regulatory requirements or the Transmission
Provider's specifications.
4.4 Commissioning
Commissioning tests of the Interconnection Customer's installed
equipment shall be performed pursuant to applicable codes and
standards. The Transmission Provider must be given at least five
Business Days written notice, or as otherwise mutually agreed to by
the Parties, of the tests and may be present to witness the
commissioning tests.
4.5. Confidentiality
4.5 Confidentiality information shall mean any confidential and/
or proprietary information provided by one Party to the other Party
that is clearly marked or otherwise designated ``Confidential.'' For
purposes of this Agreement all design, operating specifications, and
metering data provided by the Interconnection Customer shall be
deemed confidential information regardless of whether it is clearly
marked or otherwise designated as such.
4.5.2 Confidential Information does not include information
previously in the public domain, required to be publicly submitted
or divulged by Governmental Authorities (after notice to the other
Party and after exhausting any opportunity to oppose such
publication or release), or necessary to be divulged in an action to
enforce this Agreement. Each Party receiving Confidential
Information shall hold such information in confidence and shall not
disclose it to any third party nor to the public without the prior
written authorization from the Party providing that information,
except to fulfill obligations under this Agreement, or to fulfill
legal or regulatory requirements.
4.5.2.1 Each Party shall employ at least the same standard of
care to protect Confidential Information obtained from the other
Party as it employs to protect its own Confidential Information.
4.5.2.2 Each Party is entitled to equitable relief, by
injunction or otherwise, to enforce its rights under this provision
to prevent the release of Confidential Information without bond or
proof of damages, and may seek other remedies available at law or in
equity for breach of this provision.
4.5.3 Notwithstanding anything in this article to the contrary,
and pursuant to 18 CFR 1b.20, if FERC, during the course of an
investigation or otherwise, requests information from one of the
Parties that is otherwise required to be maintained in confidence
pursuant to this Agreement, the Party shall provide the requested
information to FERC, within the time provided for in the request for
information. In providing the information to FERC, the Party may,
consistent with 18 CFR 388.112, request that the information be
treated as confidential and non-public by FERC and that the
information be withheld from public disclosure. Parties are
prohibited from notifying the other Party to this Agreement prior to
the release of the Confidential Information to FERC. The Party shall
notify the other Party to this Agreement when it is notified by FERC
that a request to release Confidential Information has been received
by FERC, at which time either of the Parties may respond before such
information would be made public, pursuant to 18 CFR 388.112.
Requests from a state regulatory body conducting a confidential
investigation shall be treated in a similar manner if consistent
with the applicable state rules and regulations.
4.6 Comparability
The Transmission Provider shall receive, process and analyze all
Interconnection Requests in a timely manner as set forth in this
document. The Transmission Provider shall use the same reasonable
efforts in processing and analyzing Interconnection Requests from
all Interconnection Customers, whether the Small Generating Facility
is owned or operated by the Transmission Provider, its subsidiaries
or affiliates, or others.
4.7 Record Retention
The Transmission Provider shall maintain for three years
records, subject to audit, of all Interconnection Requests received
under these procedures, the times required to complete
Interconnection Request approvals and disapprovals, and
justification for the actions taken on the Interconnection Requests.
[[Page 34250]]
4.8 Interconnection Agreement
After receiving an interconnection agreement from the
Transmission Provider, the Interconnection Customer shall have 30
Business Days or another mutually agreeable timeframe to sign and
return the interconnection agreement, or request that the
Transmission Provider file an unexecuted interconnection agreement
with the Federal Energy Regulatory Commission. If the
Interconnection Customer does not sign the interconnection
agreement, or ask that it be filed unexecuted by the Transmission
Provider within 30 Business Days, the Interconnection Request shall
be deemed withdrawn. After the interconnection agreement is signed
by the Parties, the interconnection of the Small Generating Facility
shall proceed under the provisions of the interconnection agreement.
4.9 Coordination With Affected Systems
The Transmission Provider shall coordinate the conduct of any
studies required to determine the impact of the Interconnection
Request on Affected Systems with Affected System operators and, if
possible, include those results (if available) in its applicable
interconnection study within the time frame specified in these
procedures. The Transmission Provider will include such Affected
System operators in all meetings held with the Interconnection
Customer as required by these procedures. The Interconnection
Customer will cooperate with the Transmission Provider in all
matters related to the conduct of studies and the determination of
modifications to Affected Systems. A Transmission Provider which may
be an Affected System shall cooperate with the Transmission Provider
with whom interconnection has been requested in all matters related
to the conduct of studies and the determination of modifications to
Affected Systems.
4.10 Capacity of the Small Generating Facility
4.10.1 If the Interconnection Request is for an increase in
capacity for an existing Small Generating Facility, the
Interconnection Request shall be evaluated on the basis of the new
total capacity of the Small Generating Facility.
4.10.2 If the Interconnection Request is for a Small Generating
Facility that includes multiple energy production devices at a site
for which the Interconnection Customer seeks a single Point of
Interconnection, the Interconnection Request shall be evaluated on
the basis of the aggregate capacity of the multiple devices.
4.10.3 The Interconnection Request shall be evaluated using the
maximum rated capacity of the Small Generating Facility.
Attachment 1--Glossary of Terms
10 kW Inverter Process--The procedure for evaluating an
Interconnection Request for a certified inverter-based Small
Generating Facility no larger than 10 kW that uses the section 2
screens. The application process uses an all-in-one document that
includes a simplified Interconnection Request, simplified
procedures, and a brief set of terms and conditions. See SGIP
Attachment 5.
Affected System--An electric system other than the Transmission
Provider's Transmission System that may be affected by the proposed
interconnection.
Business Day--Monday through Friday, excluding Federal Holidays.
Distribution System--The Transmission Provider's facilities and
equipment used to transmit electricity to ultimate usage points such
as homes and industries directly from nearby generators or from
interchanges with higher voltage transmission networks which
transport bulk power over longer distances. The voltage levels at
which Distribution Systems operate differ among areas.
Distribution Upgrades--The additions, modifications, and
upgrades to the Transmission Provider's Distribution System at or
beyond the Point of Interconnection to facilitate interconnection of
the Small Generating Facility and render the transmission service
necessary to effect the Interconnection Customer's wholesale sale of
electricity in interstate commerce. Distribution Upgrades do not
include Interconnection Facilities.
Fast Track Process--The procedure for evaluating an
Interconnection Request for a certified Small Generating Facility no
larger than 2 MW that includes the section 2 screens, customer
options meeting, and optional supplemental review.
Interconnection Customer--Any entity, including the Transmission
Provider, the Transmission Owner or any of the affiliates or
subsidiaries of either, that proposes to interconnect its Small
Generating Facility with the Transmission Provider's Transmission
System.
Interconnection Facilities--The Transmission Provider's
Interconnection Facilities and the Interconnection Customer's
Interconnection Facilities. Collectively, Interconnection Facilities
include all facilities and equipment between the Small Generating
Facility and the Point of Interconnection, including any
modification, additions or upgrades that are necessary to physically
and electrically interconnect the Small Generating Facility to the
Transmission Provider's Transmission System. Interconnection
Facilities are sole use facilities and shall not include
Distribution Upgrades or Network Upgrades.
Interconnection Request--The Interconnection Customer's request,
in accordance with the Tariff, to interconnect a new Small
Generating Facility, or to increase the capacity of, or make a
Material Modification to the operating characteristics of, an
existing Small Generating Facility that is interconnected with the
Transmission Provider's Transmission System.
Material Modification--A modification that has a material impact
on the cost or timing of any Interconnection Request with a later
queue priority date.
Network Upgrades--Additions, modifications, and upgrades to the
Transmission Provider's Transmission System required at or beyond
the point at which the Small Generating Facility interconnects with
the Transmission Provider's Transmission System to accommodate the
interconnection with the Small Generating Facility to the
Transmission Provider's Transmission System. Network Upgrades do not
include Distribution Upgrades.
Party or Parties--The Transmission Provider, Transmission Owner,
Interconnection Customer or any combination of the above.
Point of Interconnection--The point where the Interconnection
Facilities connect with the Transmission Provider's Transmission
System.
Queue Position--The order of a valid Interconnection Request,
relative to all other pending valid Interconnection Requests, that
is established based upon the date and time of receipt of the valid
Interconnection Request by the Transmission Provider.
Small Generating Facility--The Interconnection Customer's device
for the production of electricity identified in the Interconnection
Request, but shall not include the Interconnection Customer's
Interconnection Facilities.
Study Process--The procedure for evaluating an Interconnection
Request that includes the section 3 scoping meeting, feasibility
study, system impact study, and facilities study.
Transmission Owner--The entity that owns, leases or otherwise
possesses an interest in the portion of the Transmission System at
the Point of Interconnection and may be a Party to the Small
Generator Interconnection Agreement to the extent necessary.
Transmission Provider--The public utility (or its designated
agent) that owns, controls, or operates transmission or distribution
facilities used for the transmission of electricity in interstate
commerce and provides transmission service under the Tariff. The
term Transmission Provider should be read to include the
Transmission Owner when the Transmission Owner is separate from the
Transmission Provider.
Transmission System--The facilities owned, controlled or
operated by the Transmission Provider or the Transmission Owner that
are used to provide transmission service under the Tariff.
Upgrades--The required additions and modifications to the
Transmission Provider's Transmission System at or beyond the Point
of Interconnection. Upgrades may be Network Upgrades or Distribution
Upgrades. Upgrades do not include Interconnection Facilities.
BILLING CODE 6717-01-U
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BILLING CODE 6717-01-C
[[Page 34264]]
Attachment 3--Certification Codes and Standards
IEEE1547 Standard for Interconnecting Distributed Resources with
Electric Power Systems (including use of IEEE 1547.1 testing
protocols to establish conformity)
UL 1741 Inverters, Converters, and Controllers for Use in
Independent Power Systems
IEEE Std 929-2000 IEEE Recommended Practice for Utility Interface of
Photovoltaic (PV) Systems
NFPA 70 (2002), National Electrical Code
IEEE Std C37.90.1-1989 (R1994), IEEE Standard Surge Withstand
Capability (SWC) Tests for Protective Relays and Relay Systems
IEEE Std C37.90.2 (1995), IEEE Standard Withstand Capability of
Relay Systems to Radiated Electromagnetic Interference from
Transceivers
IEEE Std C37.108-1989 (R2002), IEEE Guide for the Protection of
Network Transformers
IEEE Std C57.12.44-2000, IEEE Standard Requirements for Secondary
Network Protectors
IEEE Std C62.41.2-2002, IEEE Recommended Practice on
Characterization of Surges in Low Voltage (1000V and Less) AC Power
Circuits
IEEE Std C62.45-1992 (R2002), IEEE Recommended Practice on Surge
Testing for Equipment Connected to Low-Voltage (1000V and Less) AC
Power Circuits
ANSI C84.1-1995 Electric Power Systems and Equipment--Voltage
Ratings (60 Hertz)
IEEE Std 100-2000, IEEE Standard Dictionary of Electrical and
Electronic Terms
NEMA MG 1-1998, Motors and Small Resources, Revision 3
IEEE Std 519-1992, IEEE Recommended Practices and Requirements for
Harmonic Control in Electrical Power Systems
NEMA MG 1-2003 (Rev 2004), Motors and Generators, Revision 1
Attachment 4--Certification of Small Generator Equipment Packages
1.0 Small Generating Facility equipment proposed for use
separately or packaged with other equipment in an interconnection
system shall be considered certified for interconnected operation if
(1) it has been tested in accordance with industry standards for
continuous utility interactive operation in compliance with the
appropriate codes and standards referenced below by any Nationally
Recognized Testing Laboratory (NRTL) recognized by the United States
Occupational Safety and Health Administration to test and certify
interconnection equipment pursuant to the relevant codes and
standards listed in SGIP Attachment 3, (2) it has been labeled and
is publicly listed by such NRTL at the time of the interconnection
application, and (3) such NRTL makes readily available for
verification all test standards and procedures it utilized in
performing such equipment certification, and, with consumer
approval, the test data itself. The NRTL may make such information
available on its website and by encouraging such information to be
included in the manufacturer's literature accompanying the
equipment.
2.0 The Interconnection Customer must verify that the intended
use of the equipment falls within the use or uses for which the
equipment was tested, labeled, and listed by the NRTL.
3.0 Certified equipment shall not require further type-test
review, testing, or additional equipment to meet the requirements of
this interconnection procedure; however, nothing herein shall
preclude the need for an on-site commissioning test by the parties
to the interconnection nor follow-up production testing by the NRTL.
4.0 If the certified equipment package includes only interface
components (switchgear, inverters, or other interface devices), then
an Interconnection Customer must show that the generator or other
electric source being utilized with the equipment package is
compatible with the equipment package and is consistent with the
testing and listing specified for this type of interconnection
equipment.
5.0 Provided the generator or electric source, when combined
with the equipment package, is within the range of capabilities for
which it was tested by the NRTL, and does not violate the interface
components' labeling and listing performed by the NRTL, no further
design review, testing or additional equipment on the customer side
of the point of common coupling shall be required to meet the
requirements of this interconnection procedure.
6.0 An equipment package does not include equipment provided by
the utility.
7.0 Any equipment package approved and listed in a state by that
state's regulatory body for interconnected operation in that state
prior to the effective date of these small generator interconnection
procedures shall be considered certified under these procedures for
use in that state.
Attachment 5--Application, Procedures, and Terms and Conditions for
Interconnecting a Certified Inverter-Based Small Generating Facility No
Larger Than 10 kW (``10 kW Inverter Process'')
1.0 The Interconnection Customer (``Customer'') completes the
Interconnection Request (``Application'') and submits it to the
Transmission Provider (``Company'').
2.0 The Company acknowledges to the Customer receipt of the
Application within three Business Days of receipt.
3.0 The Company evaluates the Application for completeness and
notifies the Customer within ten Business Days of receipt that the
Application is or is not complete and, if not, advises what material
is missing.
4.0 The Company verifies that the Small Generating Facility can
be interconnected safely and reliably using the screens contained in
the Fast Track Process in the Small Generator Interconnection
Procedures (SGIP). The Company has 15 Business Days to complete this
process. Unless the Company determines and demonstrates that the
Small Generating Facility cannot be interconnected safely and
reliably, the Company approves the Application and returns it to the
Customer. Note to Customer: Please check with the Company before
submitting the Application if disconnection equipment is required.
5.0 After installation, the Customer returns the Certificate of
Completion to the Company. Prior to parallel operation, the Company
may inspect the Small Generating Facility for compliance with
standards which may include a witness test, and may schedule
appropriate metering replacement, if necessary.
6.0 The Company notifies the Customer in writing that
interconnection of the Small Generating Facility is authorized. If
the witness test is not satisfactory, the Company has the right to
disconnect the Small Generating Facility. The Customer has no right
to operate in parallel until a witness test has been performed, or
previously waived on the Application. The Company is obligated to
complete this witness test within ten Business Days of the receipt
of the Certificate of Completion. If the Company does not inspect
within ten Business Days or by mutual agreement of the Parties, the
witness test is deemed waived.
7.0 Contact Information--The Customer must provide the contact
information for the legal applicant (i.e., the Interconnection
Customer). If another entity is responsible for interfacing with the
Company, that contact information must be provided on the
Application.
8.0 Ownership Information--Enter the legal names of the owner(s)
of the Small Generating Facility. Include the percentage ownership
(if any) by any utility or public utility holding company, or by any
entity owned by either.
9.0 UL1741 Listed--This standard (``Inverters, Converters, and
Controllers for Use in Independent Power Systems'') addresses the
electrical interconnection design of various forms of generating
equipment. Many manufacturers submit their equipment to a Nationally
Recognized Testing Laboratory (NRTL) that verifies compliance with
UL1741. This ``listing'' is then marked on the equipment and
supporting documentation.
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BILLING CODE 6717-01-C
[[Page 34272]]
Terms and Conditions for Interconnecting an Inverter-Based Small
Generating Facility No Larger Than 10kW
1.0 Construction of the Facility
The Interconnection Customer (the ``Customer'') may proceed to
construct (including operational testing not to exceed two hours)
the Small Generating Facility when the Transmission Provider (the
``Company'') approves the Interconnection Request (the
``Application'') and returns it to the Customer.
2.0 Interconnection and Operation
The Customer may operate Small Generating Facility and
interconnect with the Company's electric system once all of the
following have occurred:
2.1 Upon completing construction, the Customer will cause the
Small Generating Facility to be inspected or otherwise certified by
the appropriate local electrical wiring inspector with jurisdiction,
and
2.2 The Customer returns the Certificate of Completion to the
Company, and
2.3 The Company has either:
2.3.1 Completed its inspection of the Small Generating Facility
to ensure that all equipment has been appropriately installed and
that all electrical connections have been made in accordance with
applicable codes. All inspections must be conducted by the Company,
at its own expense, within ten Business Days after receipt of the
Certificate of Completion and shall take place at a time agreeable
to the Parties. The Company shall provide a written statement that
the Small Generating Facility has passed inspection or shall notify
the Customer of what steps it must take to pass inspection as soon
as practicable after the inspection takes place; or
2.3.2 If the Company does not schedule an inspection of the
Small Generating Facility within ten business days after receiving
the Certificate of Completion, the witness test is deemed waived
(unless the Parties agree otherwise); or
2.3.3 The Company waives the right to inspect the Small
Generating Facility.
2.4 The Company has the right to disconnect the Small Generating
Facility in the event of improper installation or failure to return
the Certificate of Completion.
2.5 Revenue quality metering equipment must be installed and
tested in accordance with applicable ANSI standards.
3.0 Safe Operations and Maintenance
The Customer shall be fully responsible to operate, maintain,
and repair the Small Generating Facility as required to ensure that
it complies at all times with the interconnection standards to which
it has been certified.
4.0 Access
The Company shall have access to the disconnect switch (if the
disconnect switch is required) and metering equipment of the Small
Generating Facility at all times. The Company shall provide
reasonable notice to the Customer when possible prior to using its
right of access.
5.0 Disconnection
The Company may temporarily disconnect the Small Generating
Facility upon the following conditions:
5.1 For scheduled outages upon reasonable notice.
5.2 For unscheduled outages or emergency conditions.
5.3 If the Small Generating Facility does not operate in the
manner consistent with these Terms and Conditions.
5.4 The Company shall inform the Customer in advance of any
scheduled disconnection, or as is reasonable after an unscheduled
disconnection.
6.0 Indemnification
The Parties shall at all times indemnify, defend, and save the
other Party harmless from, any and all damages, losses, claims,
including claims and actions relating to injury to or death of any
person or damage to property, demand, suits, recoveries, costs and
expenses, court costs, attorney fees, and all other obligations by
or to third parties, arising out of or resulting from the other
Party's action or inactions of its obligations under this agreement
on behalf of the indemnifying Party, except in cases of gross
negligence or intentional wrongdoing by the indemnified Party.
7.0 Insurance
The Parties each agree to maintain commercially reasonable
amounts of insurance.
8.0 Limitation of Liability
Each party's liability to the other party for any loss, cost,
claim, injury, liability, or expense, including reasonable
attorney's fees, relating to or arising from any act or omission in
its performance of this Agreement, shall be limited to the amount of
direct damage actually incurred. In no event shall either party be
liable to the other party for any indirect, incidental, special,
consequential, or punitive damages of any kind whatsoever, except as
allowed under paragraph 6.0.
9.0 Termination
The agreement to operate in parallel may be terminated under the
following conditions:
9.1 By the Customer
By providing written notice to the Company.
9.2 By the Company
If the Small Generating Facility fails to operate for any
consecutive 12 month period or the Customer fails to remedy a
violation of these Terms and Conditions.
9.3 Permanent Disconnection
In the event this Agreement is terminated, the Company shall
have the right to disconnect its facilities or direct the Customer
to disconnect its Small Generating Facility.
9.4 Survival Rights
This Agreement shall continue in effect after termination to the
extent necessary to allow or require either Party to fulfill rights
or obligations that arose under the Agreement.
10.0 Assignment/Transfer of Ownership of the Facility
This Agreement shall survive the transfer of ownership of the
Small Generating Facility to a new owner when the new owner agrees
in writing to comply with the terms of this Agreement and so
notifies the Company.
[[Page 34273]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.024
WHEREAS, Interconnection Customer has requested the Transmission
Provider to perform a feasibility study to assess the feasibility of
interconnecting the proposed Small Generating Facility with the
Transmission Provider's Transmission System, and of any Affected
Systems;
NOW, THEREFORE, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated or the
meanings specified in the standard Small Generator Interconnection
Procedures.
2.0 The Interconnection Customer elects and the Transmission
Provider shall cause to be performed an interconnection feasibility
study consistent with the standard Small Generator Interconnection
Procedures in accordance with the Open Access Transmission Tariff.
3.0 The scope of the feasibility study shall be subject to the
assumptions set forth in Attachment A to this Agreement.
4.0 The feasibility study shall be based on the technical
information provided by the Interconnection Customer in the
Interconnection Request, as may be modified as the result of the
scoping meeting. The Transmission Provider reserves the right to
request additional technical information from the Interconnection
Customer as may reasonably become necessary consistent with Good
Utility Practice during the course of the feasibility study and as
designated in accordance with the standard Small Generator
Interconnection Procedures. If the Interconnection Customer modifies
its Interconnection Request, the time to complete the feasibility
study may be extended by agreement of the Parties.
5.0 In performing the study, the Transmission Provider shall
rely, to the extent reasonably practicable, on existing studies of
recent vintage. The Interconnection Customer shall not be charged
for such existing studies; however, the Interconnection Customer
shall be responsible for charges associated with any new study or
modifications to existing studies that are reasonably necessary to
perform the feasibility study.
6.0 The feasibility study report shall provide the following
analyses for the purpose of identifying any potential adverse system
impacts that would result from the interconnection of the Small
Generating Facility as proposed:
6.1 Initial identification of any circuit breaker short circuit
capability limits exceeded as a result of the interconnection;
6.2 Initial identification of any thermal overload or voltage
limit violations resulting from the interconnection;
6.3 Initial review of grounding requirements and electric system
protection; and
6.4 Description and non-bonding estimated cost of facilities
required to interconnect the proposed Small Generating Facility and
to address the identified short circuit and power flow issues.
7.0 The feasibility study shall model the impact of the Small
Generating Facility regardless of purpose in order to avoid the
further expense and interruption of operation for reexamination of
feasibility and impacts if the Interconnection Customer later
changes the purpose for which the Small Generating Facility is being
installed.
8.0 The study shall include the feasibility of any
interconnection at a proposed project site where there could be
multiple potential Points of Interconnection, as requested by the
Interconnection Customer and at the Interconnection Customer's cost.
9.0 A deposit of the lesser of 50 percent of good faith
estimated feasibility study costs or earnest money of $1,000 may be
required from the Interconnection Customer.
10.0 Once the feasibility study is completed, a feasibility
study report shall be prepared and transmitted to the
Interconnection Customer. Barring unusual circumstances, the
feasibility study must be completed and the feasibility study report
transmitted within 30 Business Days of the Interconnection
Customer's agreement to conduct a feasibility study.
11.0 Any study fees shall be based on the Transmission
Provider's actual costs and will be invoiced to the Interconnection
Customer after the study is completed and delivered and will include
a summary of professional time.
12.0 The Interconnection Customer must pay any study costs that
exceed the deposit without interest within 30 calendar days on
receipt of the invoice or resolution of any dispute. If the deposit
exceeds the invoiced fees, the Transmission Provider shall refund
such excess within 30 calendar days of the invoice without interest.
IN WITNESS WHEREOF, the Parties have caused this Agreement to be
duly executed
[[Page 34274]]
by their duly authorized officers or agents on the day and year
first above written.
BILLING CODE 6717-01-U
[GRAPHIC] [TIFF OMITTED] TR13JN05.025
[[Page 34275]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.026
[[Page 34276]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.027
Recitals
WHEREAS, the Interconnection Customer is proposing to develop a
Small Generating Facility or generating capacity addition to an
existing Small Generating Facility consistent with the
Interconnection Request completed by the Interconnection Customer
on----------; and
WHEREAS, the Interconnection Customer desires to interconnect
the Small Generating Facility with the Transmission Provider's
Transmission System;
WHEREAS, the Transmission Provider has completed a feasibility
study and provided the results of said study to the Interconnection
Customer (This recital to be omitted if the Parties have agreed to
forego the feasibility study.); and
WHEREAS, the Interconnection Customer has requested the
Transmission Provider to perform a system impact study(s) to assess
the impact of interconnecting the Small Generating Facility with the
Transmission Provider's Transmission System, and of any Affected
Systems;
NOW, THEREFORE, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated or the
meanings specified in the standard Small Generator Interconnection
Procedures.
2.0 The Interconnection Customer elects and the Transmission
Provider shall cause to be performed a system impact study(s)
consistent with the standard Small Generator Interconnection
Procedures in accordance with the Open Access Transmission Tariff.
3.0 The scope of a system impact study shall be subject to the
assumptions set forth in Attachment A to this Agreement.
4.0 A system impact study will be based upon the results of the
feasibility study and the technical information provided by
Interconnection Customer in the Interconnection Request. The
Transmission Provider reserves the right to request additional
technical information from the Interconnection Customer as may
reasonably become necessary consistent with Good Utility Practice
during the course of the system impact study. If the Interconnection
Customer modifies its designated Point of Interconnection,
Interconnection Request, or the technical information provided
therein is modified, the time to complete the system impact study
may be extended.
5.0 A system impact study shall consist of a short circuit
analysis, a stability analysis, a power flow analysis, voltage drop
and flicker studies, protection and set point coordination studies,
and grounding reviews, as necessary. A system impact study shall
state the assumptions upon which it is based, state the results of
the analyses, and provide the requirement or potential impediments
to providing the requested interconnection service, including a
preliminary indication of the cost and length of time that would be
necessary to correct any problems identified in those analyses and
implement the interconnection. A system impact study shall provide a
list of facilities that are required as a result of the
Interconnection Request and non-binding good faith estimates of cost
responsibility and time to construct.
6.0 A distribution system impact study shall incorporate a
distribution load flow study, an analysis of equipment interrupting
ratings, protection coordination study, voltage drop and flicker
studies, protection and set point coordination studies, grounding
reviews, and the impact on electric system operation, as necessary.
7.0 Affected Systems may participate in the preparation of a
system impact study, with a division of costs among such entities as
they may agree. All Affected Systems shall be afforded an
opportunity to review and comment upon a system impact study that
covers potential adverse system impacts on their electric systems,
and the Transmission Provider has 20 additional Business Days to
complete a system impact study requiring review by Affected Systems.
8.0 If the Transmission Provider uses a queuing procedure for
sorting or prioritizing projects and their associated cost
responsibilities for any required Network Upgrades, the system
impact study shall consider all generating facilities (and with
respect to paragraph 8.3 below, any identified Upgrades associated
with such higher queued interconnection) that, on the date the
system impact study is commenced--
8.1 Are directly interconnected with the Transmission Provider's
electric system; or
8.2 Are interconnected with Affected Systems and may have an
impact on the proposed interconnection; and
[[Page 34277]]
8.3 Have a pending higher queued Interconnection Request to
interconnect with the Transmission Provider's electric system.
9.0 A distribution system impact study, if required, shall be
completed and the results transmitted to the Interconnection
Customer within 30 Business Days after this Agreement is signed by
the Parties. A transmission system impact study, if required, shall
be completed and the results transmitted to the Interconnection
Customer within 45 Business Days after this Agreement is signed by
the Parties, or in accordance with the Transmission Provider's
queuing procedures.
10.0 A deposit of the equivalent of the good faith estimated
cost of a distribution system impact study and the one half the good
faith estimated cost of a transmission system impact study may be
required from the Interconnection Customer.
11.0 Any study fees shall be based on the Transmission
Provider's actual costs and will be invoiced to the Interconnection
Customer after the study is completed and delivered and will include
a summary of professional time.
12.0 The Interconnection Customer must pay any study costs that
exceed the deposit without interest within 30 calendar days on
receipt of the invoice or resolution of any dispute. If the deposit
exceeds the invoiced fees, the Transmission Provider shall refund
such excess within 30 calendar days of the invoice without interest.
IN WITNESS THEREOF, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.
BILLING CODE 6717-01-U
[GRAPHIC] [TIFF OMITTED] TR13JN05.028
[[Page 34278]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.029
[[Page 34279]]
[GRAPHIC] [TIFF OMITTED] TR13JN05.030
BILLING CODE 6717-01-C
[[Page 34280]]
Recitals
WHEREAS, the Interconnection Customer is proposing to develop a
Small Generating Facility or generating capacity addition to an
existing Small Generating Facility consistent with the
Interconnection Request completed by the Interconnection Customer
on----------; and
WHEREAS, the Interconnection Customer desires to interconnect
the Small Generating Facility with the Transmission Provider's
Transmission System;
WHEREAS, the Transmission Provider has completed a system impact
study and provided the results of said study to the Interconnection
Customer; and
WHEREAS, the Interconnection Customer has requested the
Transmission Provider to perform a facilities study to specify and
estimate the cost of the equipment, engineering, procurement and
construction work needed to implement the conclusions of the system
impact study in accordance with Good Utility Practice to physically
and electrically connect the Small Generating Facility with the
Transmission Provider's Transmission System.
NOW, THEREFORE, in consideration of and subject to the mutual
covenants contained herein the Parties agreed as follows:
1.0 When used in this Agreement, with initial capitalization,
the terms specified shall have the meanings indicated or the
meanings specified in the standard Small Generator Interconnection
Procedures.
2.0 The Interconnection Customer elects and the Transmission
Provider shall cause a facilities study consistent with the standard
Small Generator Interconnection Procedures to be performed in
accordance with the Open Access Transmission Tariff.
3.0 The scope of the facilities study shall be subject to data
provided in Attachment A to this Agreement.
4.0 The facilities study shall specify and estimate the cost of
the equipment, engineering, procurement and construction work
(including overheads) needed to implement the conclusions of the
system impact study(s). The facilities study shall also identify (1)
the electrical switching configuration of the equipment, including,
without limitation, transformer, switchgear, meters, and other
station equipment, (2) the nature and estimated cost of the
Transmission Provider's Interconnection Facilities and Upgrades
necessary to accomplish the interconnection, and (3) an estimate of
the time required to complete the construction and installation of
such facilities.
5.0 The Transmission Provider may propose to group facilities
required for more than one Interconnection Customer in order to
minimize facilities costs through economies of scale, but any
Interconnection Customer may require the installation of facilities
required for its own Small Generating Facility if it is willing to
pay the costs of those facilities.
6.0 A deposit of the good faith estimated facilities study costs
may be required from the Interconnection Customer.
7.0 In cases where Upgrades are required, the facilities study
must be completed within 45 Business Days of the receipt of this
Agreement. In cases where no Upgrades are necessary, and the
required facilities are limited to Interconnection Facilities, the
facilities study must be completed within 30 Business Days.
8.0 Once the facilities study is completed, a facilities study
report shall be prepared and transmitted to the Interconnection
Customer. Barring unusual circumstances, the facilities study must
be completed and the facilities study report transmitted within 30
Business Days of the Interconnection Customer's agreement to conduct
a facilities study.
9.0 Any study fees shall be based on the Transmission Provider's
actual costs and will be invoiced to the Interconnection Customer
after the study is completed and delivered and will include a
summary of professional time.
10.0 The Interconnection Customer must pay any study costs that
exceed the deposit without interest within 30 calendar days on
receipt of the invoice or resolution of any dispute. If the deposit
exceeds the invoiced fees, the Transmission Provider shall refund
such excess within 30 calendar days of the invoice without interest.
IN WITNESS WHEREOF, the Parties have caused this Agreement to be
duly executed by their duly authorized officers or agents on the day
and year first above written.
BILLING CODE 6717-01-U
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BILLING CODE 6717-01-C
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Appendix F to the Small Generator Interconnection Final Rule
Small Generator Interconnection Agreement (SGIA) (For Generating
Facilities No Larger Than 20 MW)
Table of Contents
Article 1. Scope and Limitations of Agreement
1.5 Responsibilities of the Parties
1.6 Parallel Operation Obligations
1.7 Metering
1.8 Reactive Power
Article 2. Inspection, Testing, Authorization, and Right of Access
2.1 Equipment Testing and Inspection
2.2 Authorization Required Prior to Parallel Operation.
2.3 Right of Access
Article 3. Effective Date, Term, Termination, and Disconnection
3.1 Effective Date
3.2 Term of Agreement
3.3 Termination
3.4 Temporary Disconnection
3.4.1 Emergency Conditions
3.4.2 Routine Maintenance, Construction, and Repair
3.4.3 Forced Outages
3.4.4 Adverse Operating Effects
3.4.5 Modification of the Small Generating Facility
3.4.6 Reconnection
Article 4. Cost Responsibility for Interconnection Facilities and
Distribution Upgrades
4.1 Interconnection Facilities
4.2 Distribution Upgrades
Article 5. Cost Responsibility for Network Upgrades
5.1 Applicability
5.2 Network Upgrades
5.2.1 Repayment of Amounts Advanced for Network Upgrades
5.3 Special Provisions for Affected Systems
5.4 Rights Under Other Agreements
Article 6. Billing, Payment, Milestones, and Financial Security
6.1 Billing and Payment Procedures and Final Accounting
6.2 Milestones.
6.3 Financial Security Arrangements
Article 7. Assignment, Liability, Indemnity, Force Majeure,
Consequential Damages, and Default
7.1 Assignment
7.2 Limitation of Liability
7.3 Indemnity
7.4 Consequential Damages
7.5 Force Majeure.
7.6 Default
Article 8. Insurance
Article 9. Confidentiality
Article 10. Disputes
Article 11. Taxes
Article 12. Miscellaneous
12.1 Governing Law, Regulatory Authority, and Rules
12.2 Amendment
12.3 No Third-Party Beneficiaries
12.4 Waiver
12.5 Entire Agreement
12.6 Multiple Counterparts.
12.7 No Partnership
12.8 Severability
12.9 Security Arrangements
12.10 Environmental Releases
12.11 Subcontractors
12.12 Reservation of Rights
Article 13. Notices
13.1 General
13.2 Billing and Payment
13.3 Alternative Forms of Notice
13.4 Designated Operating Representative
13.5 Changes to the Notice Information
Article 14. Signatures
Attachment 1--Glossary of Terms
Attachment 2--Description and Costs of the Small Generating
Facility, Interconnection Facilities, and Metering Equipment
Attachment 3--One-line Diagram Depicting the Small Generating
Facility, Interconnection Facilities, Metering Equipment, and
Upgrades
Attachment 4--Milestones
Attachment 5--Additional Operating Requirements for the Transmission
Provider's Transmission System and Affected Systems Needed to
Support the Interconnection Customer's Needs
Attachment 6--Transmission Provider's Description of its Upgrades
and Best Estimate of Upgrade Costs
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In consideration of the mutual covenants set forth herein, the
Parties agree as follows:
Article 1. Scope and Limitations of Agreement
1.1 This Agreement shall be used for all Interconnection
Requests submitted under the Small Generator Interconnection
Procedures (SGIP) except for those submitted under the 10 kW
Inverter Process contained in SGIP Attachment 5.
1.2 This Agreement governs the terms and conditions under which
the Interconnection Customer's Small Generating Facility will
interconnect with, and operate in parallel with, the Transmission
Provider's Transmission System.
1.3 This Agreement does not constitute an agreement to purchase
or deliver the Interconnection Customer's power. The purchase or
delivery of power and other services that the Interconnection
Customer may require will be covered under separate agreements. The
Interconnection Customer will be responsible for separately making
all necessary arrangements (including scheduling) for delivery of
electricity with the applicable Transmission Provider.
1.4 Nothing in this Agreement is intended to affect any other
agreement between the Transmission Provider and the Interconnection
Customer.
1.5 Responsibilities of the Parties
1.5.1 The Parties shall perform all obligations of this
Agreement in accordance with all Applicable Laws and Regulations,
Operating Requirements, and Good Utility Practice.
1.5.2 The Interconnection Customer shall construct,
interconnect, operate and maintain its Small Generating Facility and
construct, operate, and maintain its Interconnection Facilities in
accordance with the applicable manufacturer's recommended
maintenance schedule, in accordance with this Agreement, and with
Good Utility Practice.
1.5.3 The Transmission Provider shall construct, operate, and
maintain its Transmission System and Interconnection Facilities in
accordance with this Agreement, and with Good Utility Practice.
1.5.4 The Interconnection Customer agrees to construct its
facilities or systems in accordance with applicable specifications
that meet or exceed those provided by the National Electrical Safety
Code, the American National Standards Institute, IEEE, Underwriter's
Laboratory, and Operating Requirements in effect at the time of
construction and other applicable national and state codes and
standards. The Interconnection Customer agrees to design, install,
maintain, and operate its Small Generating Facility so as to
reasonably minimize the likelihood of a disturbance adversely
affecting or impairing the system or equipment of the Transmission
Provider or Affected Systems.
1.5.5 Each Party shall operate, maintain, repair, and inspect,
and shall be fully responsible for the facilities that it now or
subsequently may own unless otherwise specified in the Attachments
to this Agreement. Each Party shall be responsible for the safe
installation, maintenance, repair and condition of their respective
lines and appurtenances on their respective sides of the point of
change of ownership. The Transmission Provider and the
Interconnection Customer, as appropriate, shall provide
Interconnection Facilities that adequately protect the Transmission
Provider's Transmission System, personnel, and other persons from
damage and injury. The allocation of responsibility for the design,
installation, operation, maintenance and ownership of
Interconnection Facilities shall be delineated in the Attachments to
this Agreement.
1.5.6 The Transmission Provider shall coordinate with all
Affected Systems to support the interconnection.
1.6 Parallel Operation Obligations
Once the Small Generating Facility has been authorized to
commence parallel operation, the Interconnection Customer shall
abide by all rules and procedures pertaining to the parallel
operation of the Small Generating Facility in the applicable control
area, including, but not limited to; 1) the rules and procedures
concerning the operation of generation set forth in the Tariff or by
the system operator for the Transmission Provider's Transmission
System and; 2) the Operating Requirements set forth in Attachment 5
of this Agreement.
1.7 Metering
The Interconnection Customer shall be responsible for the
Transmission Provider's reasonable and necessary cost for the
purchase, installation, operation, maintenance, testing, repair, and
replacement of metering and data acquisition equipment specified in
Attachments 2 and 3 of this Agreement. The Interconnection
Customer's metering (and data acquisition, as required) equipment
shall conform to applicable industry rules and Operating
Requirements.
1.8 Reactive Power
1.8.1 The Interconnection Customer shall design its Small
Generating Facility to maintain a composite power delivery at
continuous rated power output at the Point of Interconnection at a
power factor within the range of 0.95 leading to 0.95 lagging,
unless the Transmission Provider has established different
requirements that apply to all similarly situated generators in the
control area on a comparable basis. The requirements of this
paragraph shall not apply to wind generators.
1.8.2 The Transmission Provider is required to pay the
Interconnection Customer for reactive power that the Interconnection
Customer provides or absorbs from the Small Generating Facility when
the Transmission Provider requests the Interconnection Customer to
operate its Small Generating Facility outside the range specified in
article 1.8.1. In addition, if the Transmission Provider pays its
own or affiliated generators for reactive power service within the
specified range, it must also pay the Interconnection Customer.
1.8.3 Payments shall be in accordance with the Interconnection
Customer's applicable rate schedule then in effect unless the
provision of such service(s) is subject to a regional transmission
organization or independent system operator FERC-approved rate
schedule. To the extent that no rate schedule is in effect at the
time the Interconnection Customer is required to provide or absorb
reactive power under this Agreement, the Parties agree to
expeditiously file such rate schedule and agree to support any
request for waiver of the Commission's prior notice requirement in
order to compensate the Interconnection Customer from the time
service commenced.
1.9 Capitalized terms used herein shall have the meanings
specified in the Glossary of Terms in Attachment 1 or the body of
this Agreement.
Article 2. Inspection, Testing, Authorization, and Right of Access
2.1 Equipment Testing and Inspection
2.1.1 The Interconnection Customer shall test and inspect its
Small Generating Facility and Interconnection Facilities prior to
interconnection. The Interconnection Customer shall notify the
Transmission Provider of such activities no fewer than five Business
Days (or as may be agreed to by the Parties) prior to such testing
and inspection. Testing and inspection shall occur on a Business
Day. The Transmission Provider may, at its own expense, send
qualified personnel to the Small Generating Facility site to inspect
the interconnection and observe the testing. The Interconnection
Customer shall provide the Transmission Provider a written test
report when such testing and inspection is completed.
2.1.2 The Transmission Provider shall provide the
Interconnection Customer written acknowledgment that it has received
the Interconnection Customer's written test report. Such written
acknowledgment shall not be deemed to be or construed as any
representation, assurance, guarantee, or warranty by the
Transmission Provider of the safety, durability, suitability, or
reliability of the Small Generating Facility or any associated
control, protective, and safety devices owned or controlled by the
Interconnection Customer or the quality of power produced by the
Small Generating Facility.
2.2 Authorization Required Prior to Parallel Operation
2.2.1 The Transmission Provider shall use Reasonable Efforts to
list applicable parallel operation requirements in Attachment 5 of
this Agreement. Additionally, the Transmission Provider shall notify
the Interconnection Customer of any changes to these requirements as
soon as they are known. The Transmission Provider shall make
Reasonable Efforts to cooperate with the Interconnection Customer in
meeting requirements necessary for the Interconnection Customer to
commence parallel operations by the in-service date.
2.2.2 The Interconnection Customer shall not operate its Small
Generating Facility in parallel with the Transmission Provider's
Transmission System without prior written authorization of the
Transmission Provider. The Transmission Provider will provide such
authorization once the Transmission Provider receives notification
that the Interconnection Customer has complied with
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From the Federal Register Online via GPO Access [wais.access.gpo.gov]
]
[[pp. 34289-34301]] Standardization of Small Generator Interconnection Agreements and
Procedures
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all applicable parallel operation requirements. Such authorization
shall not be unreasonably withheld, conditioned, or delayed.
2.3 Right of Access
2.3.1 Upon reasonable notice, the Transmission Provider may send
a qualified person to the premises of the Interconnection Customer
at or immediately before the time the Small Generating Facility
first produces energy to inspect the interconnection, and observe
the commissioning of the Small Generating Facility (including any
required testing), startup, and operation for a period of up to
three Business Days after initial start-up of the unit. In addition,
the Interconnection Customer shall notify the Transmission Provider
at least five Business Days prior to conducting any on-site
verification testing of the Small Generating Facility.
2.3.2 Following the initial inspection process described above,
at reasonable hours, and upon reasonable notice, or at any time
without notice in the event of an emergency or hazardous condition,
the Transmission Provider shall have access to the Interconnection
Customer's premises for any reasonable purpose in connection with
the performance of the obligations imposed on it by this Agreement
or if necessary to meet its legal obligation to provide service to
its customers.
2.3.3 Each Party shall be responsible for its own costs
associated with following this article.
Article 3. Effective Date, Term, Termination, and Disconnection
3.1 Effective Date
This Agreement shall become effective upon execution by the
Parties subject to acceptance by FERC (if applicable), or if filed
unexecuted, upon the date specified by the FERC. The Transmission
Provider shall promptly file this Agreement with the FERC upon
execution, if required.
3.2 Term of Agreement
This Agreement shall become effective on the Effective Date and
shall remain in effect for a period of ten years from the Effective
Date or such other longer period as the Interconnection Customer may
request and shall be automatically renewed for each successive one-
year period thereafter, unless terminated earlier in accordance with
article 3.3 of this Agreement.
3.3 Termination
No termination shall become effective until the Parties have
complied with all Applicable Laws and Regulations applicable to such
termination, including the filing with FERC of a notice of
termination of this Agreement (if required), which notice has been
accepted for filing by FERC.
3.3.1 The Interconnection Customer may terminate this Agreement
at any time by giving the Transmission Provider 20 Business Days
written notice.
3.3.2 Either Party may terminate this Agreement after Default
pursuant to article 7.6.
3.3.3 Upon termination of this Agreement, the Small Generating
Facility will be disconnected from the Transmission Provider's
Transmission System. The termination of this Agreement shall not
relieve either Party of its liabilities and obligations, owed or
continuing at the time of the termination.
3.3.4 This provisions of this article shall survive termination
or expiration of this Agreement.
3.4 Temporary Disconnection
Temporary disconnection shall continue only for so long as
reasonably necessary under Good Utility Practice.
3.4.1 Emergency Conditions--``Emergency Condition'' shall mean a
condition or situation: (1) That in the judgment of the Party making
the claim is imminently likely to endanger life or property; or (2)
that, in the case of the Transmission Provider, is imminently likely
(as determined in a non-discriminatory manner) to cause a material
adverse effect on the security of, or damage to the Transmission
System, the Transmission Provider's Interconnection Facilities or
the Transmission Systems of others to which the Transmission System
is directly connected; or (3) that, in the case of the
Interconnection Customer, is imminently likely (as determined in a
non-discriminatory manner) to cause a material adverse effect on the
security of, or damage to, the Small Generating Facility or the
Interconnection Customer's Interconnection Facilities. Under
Emergency Conditions, the Transmission Provider may immediately
suspend interconnection service and temporarily disconnect the Small
Generating Facility. The Transmission Provider shall notify the
Interconnection Customer promptly when it becomes aware of an
Emergency Condition that may reasonably be expected to affect the
Interconnection Customer's operation of the Small Generating
Facility. The Interconnection Customer shall notify the Transmission
Provider promptly when it becomes aware of an Emergency Condition
that may reasonably be expected to affect the Transmission
Provider's Transmission System or other Affected Systems. To the
extent information is known, the notification shall describe the
Emergency Condition, the extent of the damage or deficiency, the
expected effect on the operation of both Parties' facilities and
operations, its anticipated duration, and the necessary corrective
action.
3.4.2 Routine Maintenance, Construction, and Repair--The
Transmission Provider may interrupt interconnection service or
curtail the output of the Small Generating Facility and temporarily
disconnect the Small Generating Facility from the Transmission
Provider's Transmission System when necessary for routine
maintenance, construction, and repairs on the Transmission
Provider's Transmission System. The Transmission Provider shall
provide the Interconnection Customer with five Business Days notice
prior to such interruption. The Transmission Provider shall use
Reasonable Efforts to coordinate such reduction or temporary
disconnection with the Interconnection Customer.
3.4.3 Forced Outages--During any forced outage, the Transmission
Provider may suspend interconnection service to effect immediate
repairs on the Transmission Provider's Transmission System. The
Transmission Provider shall use Reasonable Efforts to provide the
Interconnection Customer with prior notice. If prior notice is not
given, the Transmission Provider shall, upon request, provide the
Interconnection Customer written documentation after the fact
explaining the circumstances of the disconnection.
3.4.4 Adverse Operating Effects--The Transmission Provider shall
notify the Interconnection Customer as soon as practicable if, based
on Good Utility Practice, operation of the Small Generating Facility
may cause disruption or deterioration of service to other customers
served from the same electric system, or if operating the Small
Generating Facility could cause damage to the Transmission
Provider's Transmission System or Affected Systems. Supporting
documentation used to reach the decision to disconnect shall be
provided to the Interconnection Customer upon request. If, after
notice, the Interconnection Customer fails to remedy the adverse
operating effect within a reasonable time, the Transmission Provider
may disconnect the Small Generating Facility. The Transmission
Provider shall provide the Interconnection Customer with five
Business Day notice of such disconnection, unless the provisions of
article 3.4.1 apply.
3.4.5 Modification of the Small Generating Facility--The
Interconnection Customer must receive written authorization from the
Transmission Provider before making any change to the Small
Generating Facility that may have a material impact on the safety or
reliability of the Transmission System. Such authorization shall not
be unreasonably withheld. Modifications shall be done in accordance
with Good Utility Practice. If the Interconnection Customer makes
such modification without the Transmission Provider's prior written
authorization, the latter shall have the right to temporarily
disconnect the Small Generating Facility.
3.4.6 Reconnection--The Parties shall cooperate with each other
to restore the Small Generating Facility, Interconnection
Facilities, and the Transmission Provider's Transmission System to
their normal operating state as soon as reasonably practicable
following a temporary disconnection.
Article 4. Cost Responsibility for Interconnection Facilities and
Distribution Upgrades
4.1 Interconnection Facilities
4.1.1 The Interconnection Customer shall pay for the cost of the
Interconnection Facilities itemized in Attachment 2 of this
Agreement. The Transmission Provider shall provide a best estimate
cost, including overheads, for the purchase and construction of its
Interconnection Facilities and provide a detailed itemization of
such costs. Costs associated with Interconnection Facilities may be
shared with other entities that may benefit from such facilities by
agreement of the Interconnection Customer, such other entities, and
the Transmission Provider.
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4.1.2 The Interconnection Customer shall be responsible for its
share of all reasonable expenses, including overheads, associated
with (1) owning, operating, maintaining, repairing, and replacing
its own Interconnection Facilities, and (2) operating, maintaining,
repairing, and replacing the Transmission Provider's Interconnection
Facilities.
4.2 Distribution Upgrades
The Transmission Provider shall design, procure, construct,
install, and own the Distribution Upgrades described in Attachment 6
of this Agreement. If the Transmission Provider and the
Interconnection Customer agree, the Interconnection Customer may
construct Distribution Upgrades that are located on land owned by
the Interconnection Customer. The actual cost of the Distribution
Upgrades, including overheads, shall be directly assigned to the
Interconnection Customer.
Article 5. Cost Responsibility for Network Upgrades
5.1 Applicability
No portion of this article 5 shall apply unless the
interconnection of the Small Generating Facility requires Network
Upgrades.
5.2 Network Upgrades
The Transmission Provider or the Transmission Owner shall
design, procure, construct, install, and own the Network Upgrades
described in Attachment 6 of this Agreement. If the Transmission
Provider and the Interconnection Customer agree, the Interconnection
Customer may construct Network Upgrades that are located on land
owned by the Interconnection Customer. Unless the Transmission
Provider elects to pay for Network Upgrades, the actual cost of the
Network Upgrades, including overheads, shall be borne initially by
the Interconnection Customer.
5.2.1 Repayment of Amounts Advanced for Network Upgrades
The Interconnection Customer shall be entitled to a cash
repayment, equal to the total amount paid to the Transmission
Provider and Affected System operator, if any, for Network Upgrades,
including any tax gross-up or other tax-related payments associated
with the Network Upgrades, and not otherwise refunded to the
Interconnection Customer, to be paid to the Interconnection Customer
on a dollar-for-dollar basis for the non-usage sensitive portion of
transmission charges, as payments are made under the Transmission
Provider's Tariff and Affected System's Tariff for transmission
services with respect to the Small Generating Facility. Any
repayment shall include interest calculated in accordance with the
methodology set forth in FERC's regulations at 18 CFR
35.19a(a)(2)(iii) from the date of any payment for Network Upgrades
through the date on which the Interconnection Customer receives a
repayment of such payment pursuant to this subparagraph. The
Interconnection Customer may assign such repayment rights to any
person.
5.2.1.1 Notwithstanding the foregoing, the Interconnection
Customer, the Transmission Provider, and Affected System operator
may adopt any alternative payment schedule that is mutually
agreeable so long as the Transmission Provider and Affected System
operator take one of the following actions no later than five years
from the Commercial Operation Date: (1) Return to the
Interconnection Customer any amounts advanced for Network Upgrades
not previously repaid, or (2) declare in writing that the
Trans