Innovations and Efficiencies in Generator Interconnection Workshop (Day 1 of 2)

Welcome and Opening Remarks

Innovations Panel 1:  Integrated Transmission Planning and Generator Interconnection

This panel will discuss the extent to which transmission planning and generator interconnection processes may be further integrated beyond the reforms adopted in Order No. 1920.[1]  This panel will explore ideas to more efficiently and proactively plan for and interconnect new generation with increased cost certainty.

Questions 

1. Can efficiencies be gained through closer integration of generator interconnection processes with transmission planning processes? If so, how?  What considerations need to be taken into account?  What are the advantages/disadvantages, including impacts on consumers, to closer integration of these processes?
2. How might transmission providers more proactively, rather than reactively, identify zones where new transmission capacity could most efficiently accommodate proposed generating facilities?
3. What mechanisms may be appropriate for transmission providers to use to determine the cost responsibility for such proactively planned network upgrades?  Is it appropriate for any such costs to be allocated to load and if so, why?  If it is appropriate, how should such costs be allocated between load and interconnection customers both: a) in regions that use participant funding, i.e., where interconnection customers are directly assigned network upgrade costs and b) in regions that do not use participant funding, i.e., where load is assigned network upgrade costs?   What are the advantages/disadvantages, including impacts on consumers, of varying approaches to cost responsibility?
4. Where the costs exceed estimates for such proactively planned network upgrades, what are some approaches transmission providers could use to address concerns regarding ensuring adequate funding?  For any given approaches proposed to ensure adequate funding, would these mechanisms increase or decrease the time and/or costs required to interconnect new resources, and how would this impact interconnection customers? 

Panelists:

• Beth Garza – Senior Fellow, R Street Institute
• Arash Ghodsian – Vice President, Transmission & Policy, Invenergy
• John Michael Haggerty – Principal, The Brattle Group
• Natasha Henderson – Senior Director of Grid Asset Utilization, Southwest Power Pool
• Aubrey Johnson – Vice President of System Planning, Midcontinent Independent System Operator, Inc.
• David Mindham – Director of Regulatory and Market Affairs, EDP Renewables North America
• Zach Smith – Senior Vice President, System Resource Planning, New York Independent System Operator

Innovations Panel 2: Exploring Different Approaches to Processing and Studying Generator Interconnection Requests

This panel will focus on the viability and utility of different approaches to organizing, processing, and studying generator interconnection requests.  Examples include a “connect and manage” process where interconnection requests for Energy Resource Interconnection Service (ERIS) may be interconnected more quickly and at lower cost than interconnection requests for Network Resource Interconnection Service (NRIS), the use of competitive mechanisms (such as an auction process) to allocate scarce capacity or to resolve competition for the same point of interconnection, as well as other potential approaches. 

Questions: 

1. Please discuss the advantages and disadvantages of making ERIS, which requires the proposed generating facility to mitigate overloads through network upgrades to allow the generating facility to operate at full output (albeit without the deliverability analysis that NRIS entails), more like the approach used in the region managed by the Electricity Reliability Council of Texas (ERCOT), sometimes referred to as a “connect and manage” approach, which curtails the generating facility in the study model when needed to minimize network upgrades at the cost of risking real-time curtailments and subsequently identifies necessary network upgrades through the transmission planning process.
2. How could elements of the ERCOT “connect and manage” approach be incorporated into the current structure of Commission-jurisdictional markets and pro forma generator interconnection procedures and agreements?  
   1. Could customers interconnecting under this type of approach eventually increase their deliverability or reduce curtailments, such as by later converting to NRIS?  How would this conversion be accomplished?
   2. In the context of RTO/ISO markets, how would an RTO/ISO account for resources’ differing levels of interconnection service (e.g., “connect and manage” versus NRIS or its equivalent) and any associated capacity rights when dispatching resources pursuant to security-constrained economic dispatch? 
3. What other approaches could build on the pro forma generator interconnection procedures and agreements adopted in Order No. 2023 to more efficiently organize interconnection queues and process interconnection requests? 
   1. Should transmission providers proactively identify zones where there is currently available transmission capacity or new transmission capacity due to planned transmission facilities and provide information on these zones to interconnection customers?  If so, how should transmission providers identify these zones and how should they communicate that information to interconnection customers?
   2. If transmission providers identify zones, as described in (a) above, should auctions be used to assign queue positions or allocate excess transmission capacity in those zones?  What other approaches could be considered?
   3. How could such procedures ensure that generator interconnection service is consistent with open access principles and is provided in a manner that is not unduly discriminatory or preferential?

Panelists:

• Liz Delaney – Vice President of Utility-Scale Policy and Business Development,  New Leaf Energy, Inc.
• Jennifer Galaway – Senior Manager of Regional Transmission Development & Interconnection Services, Portland General Electric
• Warren Lasher – President, Lasher Energy Consulting LLC
• Tyler H. Norris – James B. Duke Fellow & Ph.D. Student, Duke University  
• Matt Picardi – Vice President of Regulatory Affairs, Shell Energy North America
• Aaron Vander Vorst – Head of Growth Strategy and Transmission, Enel North America
• Andy Witmeier – Director of Resource Utilization, Midcontinent Independent System Operator, Inc.

Innovations Panel 3: Prioritizing Certain Generator Interconnection Requests

This panel will examine whether certain proposed generator interconnection requests may be prioritized in the interconnection queue without undue discrimination, building on the use of first-ready, first-served cluster window deadlines and readiness milestones as adopted by Order No. 2023.   

Questions:

1. Are there any viable, not unduly discriminatory methods for further prioritization of interconnection requests to increase queue efficiency and ensure just and reasonable rates? 
2. Would prioritization of interconnection requests selected in open competitive resource solicitations over other interconnection requests that are not similarly selected add efficiency to the generator interconnection process?  How would this type of prioritization affect the alignment of transmission planning, resource solicitation, and generator interconnection processes?  Under such a prioritization, must an open competitive solicitation process meet certain requirements to avoid infringing on the Commission’s open access transmission requirements?
3. Should interconnection requests for new generating facilities submitted to replace existing generating facilities at existing points of interconnection (replacement generation) have priority in the transmission provider’s processing of its interconnection queue over the interconnection of new generating facilities at new points of interconnection?  If so, are there conditions that should be required for such prioritization of replacement generation, for example, a finding by the transmission provider that the replacement generation allows for a faster or lower-cost interconnection as compared to the interconnection of new generating facilities at new points of interconnection? 
4. Should interconnection requests from proposed new generating facilities that meet certain resource adequacy or reliability needs have priority over other interconnection requests for new generating facilities?

Panelists:

• Ian Black – Chief Development Officer, ENGIE North America, Inc.
• Eric Blank – Chairman, Colorado Public Utilities Commission
• Joshua Burkholder -- Managing Director of Integrated Resource Planning, American Electric Power Company, Inc.
• Jason Burwen – Vice President of Policy and Strategy, GridStor
• Mike Calviou – Senior Vice President of US Policy & Regulation, National Grid
• Adrien Ford – Wholesale Market Development Director, Constellation Energy Generation, LLC
• Danielle Osborn Mills – Principal of Infrastructure Policy Development, California ISO