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Enron Mail |
FYI.
----- Forwarded by Jeff Dasovich/NA/Enron on 04/11/2001 10:25 AM ----- Christi L Nicolay@ECT 04/11/2001 09:21 AM To: Susan J Mara/NA/Enron@ENRON, Alan Comnes/PDX/ECT@ECT, Jeff Dasovich/NA/Enron@Enron, Steve Walton/HOU/ECT@ECT cc: James D Steffes/NA/Enron@Enron Subject: Cal ISO interconnection proc. Amend 39 I reviewed the Cal ISO filings below (in Sue's note) to determine general consistency with FERC orders on interconnection procedures. Potential issues are identified below and you all can decide if Enron should protest/intervene (the West Developers may want to review this too). Since I am not familiar with the Cal ISO procedures, I cannot determine whether protest is necessary (for example, PJM, NY, and NEPOOL have certain interconnection policies that would not be acceptable outside the pool, but that work ok for the pool). The TOs have also filed Amend. 39 interconnection procedures, but I have not looked at those to see if they mirror these. Maybe one of the paralegals could check that. In addition, one of you should review the filing letter and procedures to make sure that the statements made by Cal ISO are correct. (Filing letter) The Cal ISO states that these procedures are filed in response to FERC's orders and that the Cal ISO and Market Participants are examining policies that will ensure that the ISO Controlled Grid is expanded to support competitive markets. It also states that it would have liked to propose complementary changes to its long-term planning and expansion process, but other priorities have prevented it from doing so. Discusses the two previously methodologies regarding interconnection procedures -- "No Grandfathering of Transmission Rights" and "Advance Congestion Cost Mitigation" (which was apparently rejected last year. (Filing Letter at 10) -- Cal ISO does not propose a method of sharing upgrade costs, but states that the procedures do not preclude such a provision. This is one we have used in other Inter. Agreements: If required by law or if the Parties mutually agree to allow one or more third parties to use the Interconnection Facilities or any part thereof (whether by transfer of the Interconnection Facilities to an RTO or otherwise) and such use decreases the capacity of the Interconnection Facilities available to TO or the Facility or otherwise causes any detriment to TO or the Facility or benefits any party (including TO) other than Generator, or if TO is compensated for the costs of the Interconnection Facilities (in whole or in part) for any reason, Generator will be entitled to compensation from TO based upon the pro rata use of the Interconnection Facilities by TO, all third party users, and Generator, for the greater of (i) whatever costs Generator incurred in connection with the Interconnection Facilities, plus interest at the Interest Rate from the date of Generator's payment of the costs in connection with the Interconnection Facilities and (ii) the value that TO receives for the Interconnection Facilities. Notwithstanding the foregoing sentence, the Parties may use any other mutually agreed upon methodology to determine such compensation. 3.3 If one or more third parties are to use the Interconnection Facilities in accordance with Section ___, Generator's obligation to reimburse TO for the operation and maintenance costs incurred by TO in connection with the Interconnection Facilities shall be based on the pro rata use of the Interconnection Facilities by TO, all third parties users, and Generator, or on some other mutually agreed upon methodology; provided, however, that, under no circumstances shall Generator's share of TO's operation and maintenance costs be greater than its pro rata use of the Interconnection Facilities. (Procedures) The timelines for submitting applications and responding to system impact studies (SIS) and facilities study (FS) are fine, per previous FERC orders (in fact, Cal ISO asks for 60 days to complete the Facilities Study -- PGE just filed requesting 90 days). 5.7.3.1.1.© I would add "on a non-discriminatory basis" after "unless otherwise agreed by the ISO, and the Interconnecting PTO" 5.7.4.2 allows the generator to perform its own SIS and FS, subject to review by the Cal ISO and TO (this is a good provision that has not been adopted by many utilities). 5.7.4.2.1 -- The SIS will identify adverse impact on "Encumbrances" (undefined). Someone needs to check this provision since I am not familiar with this Cal ISO rule. 5.7.4.2.2 -- A New Facility Operator is entitled to amend its Completed Application once without losing its queue spot. Other utilities allow amendments as long as the change is not "material", which has only been defined by the utility and approved by FERC in several cases. This Cal ISO proposed provision could be problematic to other generators in the queue if it is not limited to "material", (unless Enron is making the one time change!) In any event, check with West Developers on this provision. 5.7.4.3 -- This provision requiring a New Facility Operator to execute (or have filed unsigned at FERC) an Interconnection Agreement within 10 days (if no upgrades) or within 30 days (if upgrades) can be a problem. Cal ISO does not file a pro forma Interconnection Agreement in these procedures. If Cal ISO tenders a poor interconnection agreement draft (which happens all the time with other utilities), then there is no way that Enron would typically want to execute it within those time limits. For example, Duke did not file an pro forma interconnection agreement, but does allow 90 days for negotiation. In my experience, the negotiation of the interconnection agreement can take a long time. It would be advisable for the Cal ISO to file a pro forma at FERC, then you can protest, if necessary, and at least there will be a fairly decent interconnection agreement to use. 5.7.4.4.1(a) -- The Queuing Milestones appear to be fairly rigid and quick: require the New Facility Operator to comply with the ISO tariff and the TO tariff and within 6 months of its Completed Application Date, satisfy all applicable Data Adequacy Requirements of state and local siting and other regulatory authorities. I don't know that 6 months is achievable. FERC has approved milestones in other cases, but most contain language requiring reasonable movement toward the milestones. For example in Duke ER01-794 Section 41.5: (Transmission Provider may reasonably extend any such milestone dates in the event of delays not caused by the Generation Interconnection Customer, such as unforeseen regulatory or construction delays that could not be remedied by Gen. Int. Customer through the exercise of due diligence, and may also reasonably extend milestone dates to which the Gen. Int. Customer has not agreed and which the Gen. Int. Customer has challenged at the Commission pending a Commission determination as to the reasonableness of such dates.) In addition, the Cal ISO only allows one extension of 30 days -- probably not enough. 5.7.4.4.1 (b) -- requires a New Facility License within 15 months after satisfying the Data Adequacy Requirements. 5.7.5 -- does not provide for transmission credits for "network upgrades" (upgrades other than the costs of interconnection). The Cal ISO recognized this exclusion in its filing letter at 11, but thinks that such issues are appropriately addressed as part of the process to revise the ISO's long-term grid planning process. Enron has argued and won at FERC for transmission credits in other utility cases, but I don't know what is appropriate under Cal ISO system, so please check this carefully. ---------------------- Forwarded by Christi L Nicolay/HOU/ECT on 04/11/2001 08:02 AM --------------------------- Susan J Mara@ENRON 04/05/2001 03:18 PM To: Christi L Nicolay/HOU/ECT@ECT cc: Subject: RE: FERC FIlings I complained to the ISO Webmaster and Voila! I guess I was looking in the wrong spot Sue Mara Enron Corp. Tel: (415) 782-7802 Fax:(415) 782-7854 ----- Forwarded by Susan J Mara/NA/Enron on 04/05/2001 01:14 PM ----- WebMaster <WebMaster@caiso.com< 04/05/2001 01:11 PM To: "Mara, Sue" <smara@enron.com< cc: Subject: RE: FERC FIlings Its under Public Info, FERC Filings and Rulings, Tariff Amendments. Here's the direct link http://www2.caiso.com/docs/2001/04/02/200104021630021868.html -----Original Message----- From: smara@enron.com [mailto:smara@enron.com] Sent: Thursday, April 05, 2001 1:05 PM To: webmaster@caiso.com Cc: webmaster@caiso.com Subject: FERC FIlings I am looking for the ISO's FERC filing that was made on April 2 -- of Amendment No. 39 on the New Facility Interconnection procedures.
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