Comprehensive Interconnection Process Improvements

Transcription

1 Comprehensive Interconnection Process Improvements Thinh Nguyen Manager, Interconnection Projects Business Issues Committee August 9, 2017 Operating Committee August 10, 2017

2 Agenda Background Objectives List of Proposed Process Changes Administrative Process Improvements Class Year Study Process Improvements Other Study Process Improvements Clarifications Regarding SDUs and Incremental TCCs for SDUs Other Clarifications and Updates Targeted Schedule Appendix Additional detailed slides regarding all proposals describing the current rules, details, rationale and proposed effective dates for each proposal, and references to tariff sections that NYISO proposes to revise 2

3 Background Date Working Group/Committee Discussion Points Aug. 1, 2016 Jan. 30, 2017 Feb. 17, 2017 Mar. 2, 2017 Transmission Planning Advisory Subcommittee (TPAS) Joint TPAS/Interconnection Issues Task Force (IITF) Joint TPAS/IITF Discussions regarding proposed improvements to the NYISO s interconnection process Presentation regarding proposed revisions to the Transmission Expansion & Interconnection Manual ( TE&I Manual ), in part, to implement proposed process improvements Presentation regarding proposed process improvements (Issue Nos administrative process improvements, Class Year Study process improvements and Optional Feasibility Study proposal) April 3, 2017 Joint TPAS/IITF Presentation regarding proposed process improvements identified in Issue Nos ; additional details regarding Issue Nos. 1-2 May 9, 2017 May 23, 2017 June 2, 2017 June 14, 2017 June 15, 2017 June 23, 2017 June 30, 2017 July 21, 2017 Joint TPAS/IITF Market Issues Working Group (MIWG) Joint MIWG/Installed Capacity Working Group (ICAPWG) Business Issues Committee Operating Committee Joint TPAS/IITF/MIWG/ICAPWG Presentation and discussion regarding all proposed process improvements and tariff revisions/manual revisions for same; recommendation that OC approve manual revisions Additional discussions regarding proposed revisions to the TE&I Manual; MIWG recommendation that BIC approve manual revisions Presentation and further discussions regarding proposed process improvements and tariff revisions for same Approval of TE&I Manual revisions implementing certain proposed process improvements Presentation and further discussions regarding proposed process improvements and tariff revisions for same Aug. 1, 2017 Joint TPAS/IITF Presentation and further discussions regarding proposed process improvements and tariff revisions related to Issue Nos. 2 and 4 3 3

4 Objectives Improve the efficiency of the interconnection process while maintaining necessary reliability evaluations and ensuring the equitable treatment of Developers, specifically: Increase administrative efficiency Expedite the interconnection study process Allow Developers to proceed through entire process more quickly, particularly the Class Year Study, while allowing as much flexibility as possible Clarify and update existing practices/procedures other than the Transmission Interconnection Procedures (TIP), which is still pending FERC acceptance Utilize varying effective dates to implement process improvements as soon as practicable For proposals requiring tariff revisions, unless otherwise specified, the proposed effective date for a specific proposal is the date of the FERC order accepting the NYISO s proposed tariff revisions NYISO is proposing effective dates and transition rules to allow projects currently in the interconnection process to benefit from the proposed changes to the extent possible 4

5 List of Proposed Process Improvements See also Queue Improvement Overview Chart posted with meeting materials that contains specific tariff sections related to each of the following issues Administrative Process Improvements Issue No. 1: Electronic Form Submission Issue No. 2: Expedited Study Agreement Processing Issue No. 3: Format of Study Reports Issue No. 4: Roles & Responsibilities of Parties in the Interconnection Study Process Issue No. 5: Interconnection Requests with Multiple Voltage Levels Issue No. 6: Clarification of Withdrawal Procedure Class Year Study Process Improvements Issue No. 7: Additional Class Year Start Dates Issue No. 8: Additional Opportunity to Withdraw from a Class Year Issue No. 9: Bifurcated Class Year Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations Other Study Process Improvements Issue No. 11: Optional Feasibility Study Issue No. 12: Requirement that SISs and SRISs Move Forward to TPAS and OC Issue No. 13: Revisions to Modeling Data Requirements Issue No. 14: Updates to Small Generator Deposits & Application Fee Issue No. 15: Clarification of Base Case Inclusion Rules Issue No. 16: Revisions to Tracking of In-Service Dates & Commercial Operation Dates 5

6 List of Proposed Process Improvements Other Study Process Improvements, cont. Issue No. 17: Outstanding Invoices for Withdrawn Projects Issue No. 18: Clarification of Process for Evaluation of Alternative POIs in the Small Generator Interconnection Procedures Issue No. 19a: Scope of Studies for Uprate Projects Issue No. 19b: Winter CRIS Determinations Issue No. 20: PMU Requirement Issue No. 21: Clarification of Clustering for Small Generator Studies Issue No. 22: Stakeholder Review of Changes in TO Planning Criteria Issue No. 23a: Clarification of MIS Methodology for Transfer Limit Impacts Issue No. 23b: Transmission Upgrades Identified by the NYISO in Affected System Studies Clarifications regarding cost recovery for SDUs and Incremental TCCs for SDUs Issue No. 24: Offset of SDU Costs Issue No. 25: Highway Facilities Charge Issue No. 26: Incremental TCCs for SDUs Other Tariff/Manual Clarifications/Updates Issue No. 27: Post-Class Year Studies Issue No. 28: Clarifications of Security Provisions Issue No. 29: Affected System EPC Agreements Issue No. 30: Tax Provisions in Pro Forma LGIA Issue No. 31: Insurance Provisions in Pro Forma LGIA Issue Nos : Ministerial and Other Edits 6

7 Administrative Process Improvements. 7

8 Administrative Process Improvements Issue No. 1: Electronic Form Submission Increase efficiency of form submission and routing for Interconnection Requests and Study Agreements, among other things, by providing fillable.pdfs with drop down boxes (where possible) that can be completed and signed electronically and ed directly to a designated NYISO mailbox Issue No. 2: Expedited Study Agreement Processing Revise Attachment X and Attachment Z to require 3-party study agreements only for Facilities Studies by eliminating the separate FES, SRIS, and SIS Agreements and incorporating such terms and conditions into the Interconnection Request Connecting TO will indicate its agreement with the FES, SRIS, and SIS scopes by signing them prior to review by TPAS and OC Shorten Developer deadlines for submission of deposits and data for FES/SIS/SRIS Proposed Effective Dates: Interconnection Requests submitted after the date of the FERC Order will be subject to the new rules and new Interconnection Request form. If an FES, SRIS or SIS 3-party study agreement has been tendered but is not fully executed before the date of the FERC Order, Developer has the option to proceed with the execution of the tendered agreement or submit a revised Interconnection Request using the new form Revised execution deadlines for Facilities Study Agreements (FSAs) will only apply to FSAs tendered after the date of the FERC Order 8

9 Administrative Process Improvements Issue No. 3: Format of Study Reports Develop a more standardized study report format/template for NYISO and its consultants to use Present a transmission map for SIS and SRIS study scopes going to TPAS and OC, showing projects locations Issue No. 4: Roles and Responsibilities of Parties in the Interconnection Study Process NYISO proposes, through additional provisions in Attachments X and Z and at the Scoping Meeting, to reinforce the roles and responsibilities of all parties in the interconnection process, such as: Requiring Developers to provide data requested during study and be present for TPAS and OC where study scope and report is discussed Requiring the Connecting TO and Affected TOs to review and comment on contingency lists, one-line diagrams and study reports Requiring the Connecting TO and Affected TOs to provide input regarding proposed Point(s) of Interconnection and configurations These revisions will complement recent revisions to the TE&I Manual reinforcing these roles and responsibilities 9

10 Administrative Process Improvements Issue No. 5: Interconnection Requests with Multiple Voltage Levels Revise Attachment X to require only one Interconnection Request for a generator with 3-winding transformer w/legs to two different voltage level lines or a combined cycle with a GT and ST connected at two different voltage levels Proposed Effective Date: Interconnection Requests submitted on or after the date of the FERC Order would be subject to this new rule; pending Interconnection Requests for one facility at multiple voltage levels would be permitted to consolidate the two queue positions into one as of the date of the FERC Order Issue No. 6: Clarification of Withdrawal Procedure Clarify the withdrawal procedures with respect to deadlines that cannot be extended via the 15 Business Day withdrawal cure period e.g., deadline by which a project must execute study agreement and submit deposit for Class Year Study 10

11 Class Year Study Process Improvements. 11

12 Class Year Process Improvements Issue No. 7: Additional Class Year Start Dates Currently there are only 3 possible Class Year Start Dates within a calendar year: Class Year Study currently starts on the first of the following dates after completion of the prior Class Year Study: March 1, June 1 or September 1 Proposal would revise Attachment S to provide more possible Class Year Start Dates by allowing a Class Year to start on the first Business Day after 30 days after completion (i.e., settlement and posting of Security) of the prior Class Year Proposed Effective Date: Class Year beginning after Class Year 2017 Issue No. 8: Additional Opportunities for a Class Year Project to Withdraw from a Class Year Currently, unless additional SDU studies are required and notice of such is provided to Class Year members, there is no opportunity for a project to withdraw from the Class Year Study until the decision rounds at the end of the Class Year This proposal would allow a project to withdraw from the Class Year Study prior to the completion of the ATBA study cases Proposed Effective Date: Class Year beginning after Class Year

13 Class Year Process Improvements Issue No. 9: Bifurcated Class Year Currently, all projects in a Class Year Study must wait to complete the decision and settlement process together, and such process may, under certain circumstances, not occur until after additional SDU studies are completed (if such studies are required) In order to allow projects that do not require additional SDU studies to complete the Class Year early, NYISO proposes this bifurcated Class Year structure allowing projects various options to complete the Class Year Proposed Effective Date: Will apply to Class Year 2017 if FERC s Order accepting the tariff revisions pre-dates the decision and settlement phase of Class Year 2017 Proposal involves two separate decision/settlement phases when bifurcated one phase in Class Year X-1 and another in Class Year X-2 X = the year of the Class Year Start Date (e.g., CY17-1 and CY17-2) Both Class Years X-1 and X-2 would required OC approval and would essentially be treated as two separate Class Years Next Class Year Study will not begin until after all Class Year evaluations, including the additional SDU studies are completed, and Class Year X-2 has completed its decision/ settlement period 13

14 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, continued At the stage in the Class Year Study when the need for additional SDUs is identified, NYISO will issue a Notice of SDUs Requiring Additional Study to all Class Year Projects NYISO will then issue a notice to those Class Year Projects for which NYISO has identified SDUs requiring additional studies This triggers the Preliminary SDU Decision Period Projects receiving this notice must respond within 10 Business Days as to whether they want to proceed to Class Year X-2 with additional studies or whether they want to forego additional studies and proceed as part of the Class Year X-1 decision process If, as a result of the election(s) made in the Preliminary SDU Decision Period, NYISO determines that the Class Year Study will be bifurcated: NYISO will issue a Bifurcation Notice to members of the ISO s Interconnection Projects Facilities Study Working Group that will serve to bifurcate the Class Year Study into Class Year X-1 and Class Year X-2, triggering a Bifurcated Decision Period NYISO will provide Class Year X-1 Project Cost Allocations for SUFs and SDUs, excluding Project Cost Allocations for SDUs requiring additional studies in Class Year X-2 14

15 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, continued Within 30 Calendar Days from a Bifurcation Notice, each Class Year Project other than a Class Year Project that elected in the Preliminary SDU Decision Period to proceed with additional SDU studies, must make one of the following elections: Project may elect to settle the Class Year early in Class Year Decision/Settlement as part of Class Year X-1 (see the various settlement options in the proposed revisions in Section of Attachment S); or Project may proceed as a member of Class Year X-2, with no changes to ERIS or CRIS requests; or Project may proceed as a member of Class Year X-2 as ERIS only (i.e., withdrawing its CRIS request); or Project may proceed as a member of Class Year X-2 with ERIS and/or CRIS requests, but electing to have no SDUs identified to make the project deliverable at its level of requested CRIS (i.e., proceed as a member of Class Year X-2 with the option of accepting or not accepting all of its requested ERIS MW and only its Deliverable MW for CRIS); or Project may withdraw from the Class Year entirely 15

16 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, continued Example 1: New rules applying bifurcation to CY15 potential for Class Year X-1 projects to shorten process by 9 months 16

17 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, continued Example 2: New rules applying bifurcation and CY Start Date to CY15 with CY completion date of 3/5/2017 potential to expedite CY17 start by 2 months 17

18 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, continued Security posting implications If a Class Year Project that elects to settle in Class Year X-1 shares a cost allocation for SUFs or Headroom with a Class Year Project that elects to remain in the Class Year through Class Year X-2, the project electing to settle in Class Year X-1 will be required to post security equal to its highest possible Project Cost Allocation Calculated by assuming all, none or any combination of other Class Year projects drop out or accepts their Project Cost Allocations i.e., the highest amount it might possibly be required to post under any Class Year decision and settlement scenario At the end of the Class Year X-1 cost allocation decisions and also, in the Class Year X-2 cost allocation process, NYISO would recalculate the security requirements for each project that settled in Class Year X-1, potentially requiring the CTO to refund excess security resulting from this recalculation 18

19 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal For a Class Year that is not bifurcated and for Class Year X-2, as under the current BSM process, prior to the commencement of the Initial Decision Period, the NYISO will provide initial BSM determinations for all Examined Facilities Those determinations will identify the determination and Offer Floor under the Part A Test and Part B Test, and Self Supply Exemption. They will also identify whether an Examined Facility that requested a Renewable Exemption or a Competitive Entry Exemption ( CEE ) qualifies for that exemption. Concurrent with the issuance of the determinations at the time of the Initial Decision Period, the NYISO will post on its website the quantity of MW of Examined Facilities in the Class Year that had requested a renewable exemption and the quantity determined to the eligible for a Renewable Exemption. 19

20 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. If under OATT Section NYISO issues a notice that any Class Year Project requires SDUs for which additional System Deliverability Upgrade studies are required, NYISO will provide to any such units that are in a Mitigated Capacity Zone, a preliminary Unit Net CONE and Part A Test and Part B Test exemption or Offer Floor determination, and if applicable, a Self Supply or CEE exemption determination, or Renewable Exemption qualification determination. If the Class Year bifurcates, prior to the commencement of the Bifurcated Decision Period, NYISO will issue the determination for each Examined Facility under Part A Test, the Part B Test, and for those that requested it, a determination of exempt or not exempt under CEE and Self Supply, and whether it is qualified for a Renewable Exemption. NYISO will have posted the quantity of MW that requested a Renewable Exemption and, at this time, will post the quantity of MW that were determined to be eligible for a Renewable Exemption» Class Year X-1 NYISO will issue a final BSM determination for Examined Facilities that settle in Class Year X-1 and are allocated CRIS (even if it is a quantity of CRIS MW that is different than the original CRIS request; e.g., it accepts deliverable MW and rejects MW with SDUs), and that posts security in accordance with Attachment S and remain in Class Year X-1 at the time of its completion 20

21 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont.» Class Year X-1, cont. The BSM determination will be the exact same as the determination issued prior to the Bifurcated Decision Period. It will be applied to the quantity of CRIS the Examined Facility received in Class Year X-1 at the time of its completion. The Part A Test and Part B Test will not be recalculated; that is, the calculation will not be updated if there is any change in the MW of CRIS The Examined Facilities that had requested a renewable exemption and were determined to be qualified will receive an exemption based on the total quantity of X-1 MW determined to be eligible, less the MW that received an exemption under the Part A Test, the Part B Test or a Self Supply Exemption. (Note: The pending tariff filing provides that an Examined Facility can request a Self Supply Exemption and a Renewable Exemption in the same Class Year, but cannot also request a CEE in that same Class Year) Examples are presented on a following slide The NYISO will post on its website the X-1 exempt and non-exempt determinations for each X-1 Examined Facility, and will identify whether the facility received a CEE, Self Supply or Renewable Exemption, and the total quantity of renewable exempt MW allocated, and those that remain available for Class Year X-2 (i.e., the difference between the 1000 MW cap and the renewable exempt MW in Class Year X-1) The Class Year X-1 Examined Facilities BSM determinations will not be revised; e.g., for updated SDU estimates, after Class Year X-2 is completed, or any other reason 21

22 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. If the Class Year bifurcates» Class Year X-2 The NYISO will recalculate the Part A Test and Part B Test determinations prior to the Initial Decision Period and during the X-2 Project Cost Allocation process decisional rounds of X-2, as per the current rules Treat the projects that remained in Class Year X-1 at the time of its completion in the same manner as Examined Facilities that remained in a prior Class Year at the time of its completion BSM Determinations become final for these facilities as per the current rules; i.e., provided they remain in Class Year X-2 at the time of its completion 22

23 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. Renewable Exemption The 1000 MW cap will apply to the Class Year regardless of whether it bifurcates If more than 1000 MW request a renewable exemption and are determined to be qualified The 1000 MW would be allocated to X-1 projects first. The allocation would be determined at the time Class Year X-1 is completed As provided under the proposed renewable/self supply filing, if a project requests and is determined to be exempt under the Part A Test or Part B Test, or a self supply exemption, and eligible for a renewable exemption, it would be exempt under such Test or self supply. The MW of such project would not affect the MW available under the cap 23

24 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. Renewable Exemption, cont. Examples of Examined Facilities that request a renewable exemption and are determined to be eligible for it:» These examples assume that projects eligible for a Part A Test, Part B Test or self supply exemptions, receive that exemption, as described above» If there are 700 MW of Qualified Renewable Exemptions exiting in X-1, and 400 MW of Renewables electing to remain in X-2, all 700 MW of X-1 projects will be exempt (leaving 300 MW of potential exempt MW for X-2 projects) In this example, should all 400 MW of X-2 projects remain in the Class Year, each of these projects would receive 75% of their Renewable Exemption request» If there are more than 1,000 MW of Qualified Renewable Exemptions in X-1, then the MW receiving the exemption will be determined by prorating amongst these projects. 24

25 Class Year Process Improvements Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations Currently, NYISO tenders the Interconnection Agreement (IA) on the earlier of completion of the Class Year in which the project accepted cost allocation/posted Security, or upon the Developer s request, if Developer has executed a Class Year Facilities Study Agreement (which allows the Part 1 Facilities Study to commence) After completion of the Part 1 Study, even if that Class Year Study has not formally begun, the parties can finalize and execute the IA An IA executed prior to completion of the project s Class Year Study requires the Developer to accept the costs of any additional SUFs that are identified in the remaining portions of the Class Year study or any modifications to the SUFs or costs estimates for SUFs identified prior to execution of the IA A project seeking to go in-service prior to the completion of required upgrades may request a Limited Operations study to determine whether and the extent to which the project can reliably to interconnect on a provisional basis; however, this option is only set forth in the pro forma Interconnection Agreement NYISO proposes to memorialize the steps above in detail in the tariff and to include a specific provision permitting a Developer to request a Limited Operations study prior to execution of an IA, as long as such evaluation is not an evaluation of an entirely new interim configuration Proposed Effective Date: For the Limited Operations proposal, effective date would be date of FERC Order unless the Developer, NYISO and Connecting TO mutually agree to pre- Interconnection Agreement Limited Operations studies. Other processes described above are already effective. 25

26 Other Study Process Improvements. 26

27 Other Study Process Improvements Issue No. 11: Optional Feasibility Study Proposal to revise Attachments X and Z to make the Feasibility Study optional at the Developer s election Election would not be subject to NYISO s and/or Connecting TO s approval If Developer opts to forego Feasibility Study, required evaluations will be addressed in the SRIS/SIS Scope of Optional Feasibility Study may include any of the following, at the option of the Developer/Customer and study schedule depends on options elected: For $10,000 Study Deposit: Development of conceptual breaker-level one-line diagram how to integrate the project into the existing system; and/or Review of feasibility/constructability of conceptual breaker-level one-line diagram for compliance with local transmission owner planning criteria and other Applicable Reliability Standards of the proposed interconnection For $60,000 Study Deposit ($30,000 for Small Gens): Above analyses as well as one of more of the following:» Preliminary review of local protection, communication, grounding issues associated with the proposed interconnection» Power flow, short circuit, and/or bus flow analyses» Identification of Network Upgrades with non-binding good faith estimate of cost responsibility and non-binding good faith estimated time to construct Proposed Effective Date: Available for projects for which a Feasibility Study Agreement has not been fully executed on the date of the FERC Order 27

28 Other Study Process Improvements Issue No. 12: Requirement that SISs and SRISs move forward to TPAS Proposal to revise OATT 3.7, OATT 3.9, OATT 4.5 and Attachment X to require all SISs and SRISs to move forward to TPAS within 3 months of completion of the study report and move to the next OC following TPAS review and recommendation (or subsequent TPAS review and recommendation if initial TPAS revise requests revisions) Issue No. 13: Revisions to Modeling Data Requirements Proposal to revise the Interconnection Request forms such that dynamic modeling data is not required until the SRIS/SIS stage, to make the Interconnection Request data forms easier to complete, and to permit Developers to provide generic dynamic models (with project-specific parameters and adequate manufacturer documentation) Proposed Effective Date: Interconnection Requests submitted after date of FERC Order 28

29 Other Study Process Improvements Issue No. 14: Updates to Small Generator Deposits and Application Fee Proposal to modify Small Generator fees and deposits Small Generator Interconnection Request application fee of $1,000 to be nonrefundable Increase the Feasibility Study deposit from $1,000 to $10,000 (if project elects more limited study scope) or $30,000 (if projects elects more detailed scope) Decrease the System Impact Study deposit from the full study cost estimate (approx. $75,000 to $100,000) to $50,000 Overall, this proposal would reduce the fees/deposits required for Small Generators from the Interconnection Request through the beginning of the SIS from approx. $77,000 to as low as $51,000 Proposed Effective Date: For application fee, new rules apply to Interconnection Requests submitted on or after FERC Order For study deposits, new deposits will apply to Interconnection Requests submitted on or after the date of the FERC Order 29

30 Other Study Process Improvements Issue No. 15: Clarification of Base Case Inclusion Rules NYISO provided more explanation in the recent revisions to the Transmission Expansion & Interconnection (TE&I) Manual on developing and updating base cases NYISO also proposes to revise Class Year base case inclusion rules as follows: TIP project that is an Attachment Y project must have met the following milestones to be included in a Class Year ATBA base case: Triggered under the RPP, selected under the PPTPP, or approved by beneficiaries under the CARIS; and Completed a System Impact Study; and Have an Article VII deemed complete (if applicable); and Are making reasonable progress under the applicable Attachment Y planning process TIP project that is not an Attachment Y project must have met the following milestones to be included in a Class Year ATBA base case: Completed a Facilities Study; and Posted Security for Network Upgrade Facilities; and Have an Article VII deemed complete (if applicable) Proposed Effective Date: ATBA case developed on or after the date of the FERC Order 30

31 Other Study Process Improvements Issue No. 16: Revisions to Tracking of In-Service Dates, Initial Synchronization Dates and Commercial Operation Dates Require Developers (Large Facilities and Small Generators) to provide proposed Initial Synchronization Date whenever they are required to provide proposed In-Service Date and COD and require updates to proposed In- Service Dates, Initial Synchronization Dates and CODs on a quarterly basis once Developer has executed a Facilities Study Agreement Issue No. 17: Outstanding Invoices for Withdrawn Projects Require outstanding invoices from TOs, Affected System Operators and consultants to be provided within 60 days after completion of the subject study For withdrawn projects, study deposits must be trued up with all outstanding invoices before deposits are refunded Proposed Effective Date: Date of the FERC Order; provided, however, invoices outstanding on date of the FERC Order must be submitted to NYISO within 60 days from date of the FERC Order 31

32 Other Study Process Improvements Issue No. 18: Clarification of Process for evaluation of alternative POIs in the Small Generator Interconnection Procedures Clarify that projects proposing alternative POIs must be evaluated in a Feasibility Study (i.e., removing the option to forego a Feasibility Study for such projects) Clarify that a project requesting alternative POIs must select one POI before moving to the Facilities Study Proposed Effective Date: Applies to Small Generator Interconnection Requests submitted on or after the date of the FERC Order Issue No. 19a: Scope of Studies for Uprate Projects Specify in the tariff that the parties may customize the scope of an SRIS upon mutual agreement Proposed Effective Date: SRIS scopes not yet approved by the OC on the date of the FERC Order 32

33 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations Currently, Attachment S requires NYISO to maintain the same proportion of CRIS to ERIS in the Winter as the facility has in the Summer If the facility is fully deliverable, the Summer CRIS/ERIS ratio will be 100% and the facility s Winter CRIS cap is equal to Winter ERIS A facility is fully deliverable if it was (1) grandfathered for CRIS, evaluated for CRIS in a CY and found fully deliverable or paid Security for SDUs to make if fully deliverable; and (2) has not materially increased its capability NYISO currently determines a Winter CRIS cap for all projects that are not fully deliverable Winter CRIS is calculated through the following formula: NYISO implements the Winter CRIS cap in the ICAP AMS by applying a limiting percentage to the facility s Winter DMNC Under the current process, this percentage needs to be updated manually for every DMNC change 33

34 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations, cont. Rather than manually calculate the applicable percentage of the Winter DMNC for each DMNC update, NYISO proposes to maintain fixed values for Winter CRIS NYISO proposes to specify in Attachment S that for the purpose of calculating the fixed Winter CRIS value, NYISO will use the following formula in which X = the fixed Winter CRIS MW Summer CRIS MW = X MW per Temperature Curve at 90 MW per Temperature Curve at 10 In no case will the Winter CRIS value be lower than Summer CRIS CRIS values will only change upon approved increased CRIS requests NYISO has posted a chart using the 2017 GoldBook existing generator table with a new column with the preliminary fixed Winter CRIS value calculated pursuant to this proposal using existing data. NYISO proposes to include as a 2018 project, software modifications to this project; therefore if this proposal would post-date deployment of the required software modifications (i.e., no earlier than Winter 2018/2019) 34

35 Other Study Process Improvements Issue No. 20: PMU Requirement Proposal to require a PMU for proposed new Large Generating Facilities and Merchant Transmission Facility 100 MW and new substations (230kV or above) A PMU requirement is common in other ISOs/RTOs (e.g., PJM requires PMUs for generators of 100 MVA and above; ERCOT requires PMUs for 20 MVA and above) Issue No. 21: Clarification of Clustering for Small Generator Studies NYISO clarified in the recent revisions to the TE&I Manual the manner in which it performs clustering studies for Small Generators NYISO also proposes to add similar tariff language to: Clarify that Small Generating Facilities moving forward in the same time frame that contribute to Local System Upgrade Facilities will be studied collectively to determine their pro rata cost responsibility for such Local System Upgrade Facilities Clarify that Small Generating Facilities evaluated in a cluster study that trigger non- Local System Upgrade Facilities must be evaluated in a Class Year Interconnection Facilities Study Proposed Effective Date: Immediately (tariff revisions simply clarify existing practice) 35

36 Other Study Process Improvements Issue No. 22: Stakeholder Review of Changes in TO Planning Criteria Proposal to require TOs to present changes to planning criteria to TPAS before such changes will be recognized as Applicable Reliability Requirements or Applicable Reliability Standards Issue No. 23a: Clarification of MIS Methodology for Transfer Limit Impacts Under the Minimum Interconnection Standard, projects require upgrades if the adverse reliability impact cannot be mitigated by normal operating procedures NYISO clarified in the recent revisions to the TE&I Manual, which is currently effective, that under the Minimum Interconnection Standard: Large Facilities interconnecting to the NYCA must mitigate the adverse impact, above 25 MW, on NYISO s external interfaces (essentially creates a 25 MW de minimis) In the CY Study and clustered TIP studies, the 25 MW de minimis is collective, not per-project Issue No. 23b: Evaluation of Transmission Upgrades Identified by the NYISO in Affected System Studies NYISO added language to the TE&I Manual, which is currently effective, to allow transmission upgrades in the NYCA identified by NYISO in Affected System Studies (for projects interconnecting to neighboring regions) to proceed directly from the other region s SIS to a Facilities Study under the TIP 36

37 Clarifications regarding Cost Recovery for SDUs and Incremental TCCs for SDUs. 37

38 SDUs and Incremental TCCs Issue No. 24: Offset of SDU Costs Section of Attachment S provides that if the NYISO identifies a Reliability Need under Attachment Y requiring a Highway facility to be constructed earlier than would be required under Attachment S, funds collected from Class Year Developers for the Highway facility will be used to cover a portion of the regulated solution costs to the extent the upgrades are actually constructed by the regulated solution Section further provides that to the extent this tariff provision applies, the Class Year Developer funds that had been contributed to the Highway SDU will be used as an offset to the total reliability solution upgrade cost, with the remainder of the upgrade cost to be allocated per the requirements of Attachment Y NYISO proposes to expand the allowed offset of SDU costs in Section of Attachment S to provide that SDU funds could be used to cover a portion of the costs of other regulated solutions (not just those triggered by Reliability Needs), including regulated solutions in CARIS and PPTPP Proposed Effective Date: For ROS Highway SDUs for which construction has not yet commenced, date of the FERC Order accepting the proposed revisions. Issue No. 25: Highway Facilities Charge Under Attachment S, if Class Year Developers have posted Security for at least 60% of the total cost allocation of a ROS Highway SDU, construction is triggered. Once constructed, the actual cost of the ROS Highway SDU, above that paid for by Class Year Developers, will be funded by Load Serving Entities, using the rate mechanism contained in Rate Schedule 12 of the OATT NYISO proposes to revise Rate Schedule 12 to clarify the formula and procedures for cost recovery of ROS Highway SDU costs and to address treatment of declined or terminated Incremental TCCs 38

39 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Attachment S provides that for Class Year Developers that contribute to an SDU, once the SDU is built, any resulting Incremental TCCs will be distributed to the Developers in proportion to their funding of the SDU Attachment S also provides that a subsequent Developer paying for use of Headroom on SDUs will receive the corresponding Incremental TCCs NYISO proposes to require the Connecting TO(s) who constructed the SDU to be responsible for requesting Incremental TCCs for the SDU Proposed tariff revisions clarify that each CY Developer (or subsequent CY Developer making a Headroom payment) that elects to receive their portion of any Incremental TCCs will be the Primary Holder thereof and subject to the requirements of Section 19.7 of Attachment M of the OATT (including registering as a Customer and meeting the applicable credit requirements see MST, Attachment K) Proposed tariff revisions clarify the ability of CY Developers (or subsequent CY Developers making Headroom payments) to decline their portion of any Incremental TCCs at the time offered or subsequently terminate any accepted Incremental TCCs in accordance with Section of Attachment M of the OATT 39

40 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs, continued Proposed tariff revisions clarify that any Incremental TCCs declined or subsequently terminated by CY Developers that initially contributed to an SDUwill be deemed reserved to the extent necessary to facilitate transfers to subsequent Developers that pay for Headroom created by the SDU Incremental TCCs previously deemed reserved that are transferred to a subsequent Developer will become effective on the first day of the Capability Period that commences following the next Centralized TCC Auction conducted after the subsequent Developer makes the necessary Headroom payment and elects to receive its proportionate share of Incremental TCCs Attachment S provides that Incremental TCCs attributable to LSE funding will be credited to the LSEs in proportion to their funding of the Highway SDU in accordance with Rate Schedule 12 Proposed tariff revisions clarify that in cases where LSEs have funded a portion of a Highway SDU, any Headroom payments by subsequent CY Developers will be made to the Connecting TO(s) who constructed the SDU and be credited to the LSEs that funded a portion of the SDU Proposed tariff revisions clarify that all Incremental TCCs related to SDUs will not be eligible for sale in NYISO-administered TCC auctions or secondary markets regardless of the entity holding the Incremental TCCs. Primary Holders of these Incremental TCCs will receive congestion payments pursuant to Section of Attachment N of the OATT 40

41 Other Clarifications and Updates. 41

42 Other Clarifications and Updates Issue No. 27: Post-Class Year Studies NYISO clarified in the recent revisions to TE&I Manual the manner in which such studies are conducted and coordinated (e.g., detailed design studies, SSR and protection coordination studies) NYISO proposes to further clarify in Attachment S how the results of such studies may impact actual costs of upgrades for the project Issue No. 28: Clarifications of Security Provisions NYISO proposes to revise Attachment S to: Provide that the Security reduction provisions apply equally to Affected TOs and Connecting TO(s) Clarify the Security forfeiture provisions regarding the extent to which Security must be forfeited to defray the costs of SUFs and SDUs required for other projects Issue No. 29: Affected System EPC Agreements Proposal to require Developer, Connecting TO, NYISO, and any Affected TO to enter into an EPC agreement for the construction of triggered SUFs 42

43 Other Clarifications and Updates Issue Nos. 30 and 31: Tax and Insurance Provisions in Pro Forma LGIA Revise/update tax and insurance provisions in the pro forma Large Generator Interconnection Agreement (LGIA) Issue Nos : Ministerial and Other Edits Refer to Class Year Start Date (vs. March 1) in Section of the MST Clarify baseline ERIS for a project that does not go forward with part of project studied in the interconnection process Simplify language regarding the 30-day deadline for execution of the Facility Study Agreement in Section of Attachment X Add language to Section of Attachment X consistent with regulatory milestone tariff revisions that the requirement applies prior to the execution of an Interconnection Agreement In pro forma Interconnection Request form, add applicable requirements for solar and energy storage projects Streamline Interconnection Request form and eliminate the need for Developers to provide data unnecessary at the initial stage of the interconnection study process Delete Appx. G from the pro forma LGIA per Order No. 827 Other clarifying and ministerial edits (e.g., changing NYISO to ISO as appropriate, to be consistent with the rest of the OATT) 43

44 Targeted Schedule August 30, 2017 Management Committee September 2017 Queue Reforms to Board of Directors September 2017 File with FERC as soon as possible after Board approval. 44

45 Questions?. 45

46 Appendix -Additional detailed slides regarding all proposals describing the current rules, details, rationale and proposed effective dates for each proposal, and references to tariff sections that NYISO proposes to revise. 46

47 Proposed Process Improvements Administrative Process Improvements Issue No. 1: Electronic Form Submission Slide 50 Issue No. 2: Expedited Study Agreement Processing Slide 52 Issue No. 3: Format of Study Reports Slide 61 Issue No. 4: Roles & Responsibilities of Parties in the Interconnection Study Process Slide 64 Issue No. 5: Interconnection Requests with Multiple Voltage Levels Slide 67 Issue No. 6: Clarification of Withdrawal Procedure Slide 68 Class Year Study Process Improvements Issue No. 7: Additional Class Year Start Dates Slide 71 Issue No. 8: Additional Opportunity to withdraw from a Class Year Slide 73 Issue No. 9: Bifurcated Class Year Slide 76 Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations Slide 87 Other Study Process Improvements Issue No. 11: Optional Feasibility Study Slide 92 Issue No. 12: Requirement that SISs and SRISs move forward to TPAS and OC Slide 95 Issue No. 13: Revisions to Modeling Data Requirements Slide 97 Issue No. 14: Updates to Small Generator Deposits and Application Fee Slide 99 Issue No. 15: Clarification of Base Case Inclusion Rules Slide 102 Issue No. 16: Revisions to Tracking of In-Service Dates and Commercial Operation Dates Slide

48 Proposed Process Improvements, cont. Other Study Process Improvements, cont. Issue No. 17: Outstanding Invoices for Withdrawn Projects Slide 106 Issue No. 18: Clarification of Process for evaluation of alternative POIs in the Small Generator Interconnection Procedures Slide 107 Issue No. 19a: Scope of Studies for Uprate Projects Slide 108 Issue No. 19b: Winter CRIS Determinations Slide 109 Issue No. 20: PMU Requirement Slide 114 Issue No. 21: Clarification of Clustering for Small Generator Studies Slide 116 Issue No. 22: Stakeholder Review of Changes in TO Planning Criteria Slide 118 Issue No. 23a: Clarification of MIS Methodology for Transfer Limit Impacts Slide 119 Issue No. 23b: Transmission Upgrades Identified by the NYISO in Affected System Studies Slide 121 Clarifications regarding cost recovery for SDUs and Incremental TCCs for SDUs Issue No. 24: Offset of SDU Costs Slide 123 Issue No. 25: Highway Facilities Charge Slide 125 Issue No. 26: Incremental TCCs for SDUs Slide 126 Other Tariff/Manual Clarifications/Updates Issue No. 27: Post-Class Year Studies Slide 132 Issue No. 28: Clarifications of Security Provisions Slide 133 Issue No. 29: Affected System EPC Agreements Slide 135 Issue No. 30: Tax Provisions in Pro Forma LGIA Slide 136 Issue No. 31: Insurance Provisions in Pro Forma LGIA Slide 137 Issue Nos : Ministerial and Other Edits Slide

49 Administrative Process Improvements. 49

50 Administrative Process Improvements Issue No. 1: Electronic Form Submission Current Practice Most forms and study agreements must be downloaded or printed, completed, signed, scanned and ed to the NYISO Proposal Increase efficiency of form submission and routing for forms such as the Interconnection Request forms, pre-application request forms, and Study Agreements by providing fillable.pdfs with drop down boxes (where possible) that can be completed and signed electronically and ed directly to a NYISO mailbox Rationale for NYISO s Proposal NYISO aims to makes it easier for developers to complete the necessary paperwork required in the interconnection process Electronic fillable.pdfs with drop down boxes and allowing for electronic signatures makes this process quicker and easier for all parties involved, particularly the developer 50

51 Administrative Process Improvements Issue No. 1: Electronic Form Submission, cont. Details This proposal does not require tariff revisions NYISO has already begun converting pro forma study agreements into fillable.pdfs, most recently with the Class Year 2017 Facilities Study Agreements and data forms Proposed 2018 project in the 2018 Project Prioritization Process would further automate interconnection form and data submissions Proposed Effective Date: in progress, with additional electronic form submission as part of a proposed 2018 project 51

52 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing Current Practice/Rule Each project must typically have 3 study agreements to proceed through the interconnection process FESA, SRISA/SISA and FSA Most study agreements are pro forma agreements contained in the OATT that require 3+ parties for execution: Developer, NYISO and each Connecting TO Proposal Revise Attachment X and Attachment Z to require study agreements only Facilities Studies (i.e., eliminate FES, SRIS, and SIS Agreements) Key provisions from FES/SRIS/SIS study agreements re: study obligations to be inserted into the Interconnection Request forms in Attachments X and Z signed by Developer 52

53 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing Proposal, continued Scopes for each study will be provided to the Developer, Connecting TO and Affected TOs for review and comment. Once the CTO has indicated agreement of the study scope, the NYISO will provide the final scope to the CTO, Affected TOs (if identified at the time) and Developer CTO to indicate its agreement by promptly signing it and returning it to the NYISO Affected TOs If the interconnection process reveals an Affected TO of facilities electrically adjacent to the Point of Interconnection and that have design criteria, operational criteria or other local planning criteria applicable to either the substation to which the Developer proposes to interconnect or that will be required to be built to accommodate the interconnection, such an Affected TO will be included in all communications and meetings regarding the project and will have the opportunity to review and comment on all study scopes and study report drafts The NYISO shall include in the appropriate interconnection study proposed additional studies requested by such an Affected Transmission Owner, to the extent such studies are reasonably justified in accordance with Good Utility Practice Attachment X (Large Facility) SRIS scopes will continue to be reviewed with TPAS and subject to approval by the OC All references to SRIS in this proposal include Optional SRIS Similar revisions to be proposed in Attachment P after Attachment P is accepted by FERC 53

54 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, Cont. Proposal, cont. NYISO also proposes to maintain execution deadlines for all parties Facilities Study agreements and to shorten Developer deadlines for submission of deposits and data for other studies (e.g., FES, SRIS) Developer will have 30 Calendar Days to execute Facilities Study agreements, but NYISO and CTO will have 10 Business Days to execute agreement after receipt of executed agreement from Developer, together with required deposits and sufficient technical data For all other interconnection studies, Developer must submit deposits and required data 15 Business Days after notice from NYISO re: good faith cost estimate for study cost NYISO proposes to retain the 30 day deadline for execution of the Small Gen FSA (but change the deadline to 30 Calendar Days vs. the current deadline of 30 Business Days) and Class Year FSA and submission of required FSA data and Class Year deposits however, NYISO proposes that failure to execute Class Year FSA or submit any required Class Year deposits will be a non-curable deficiency NYISO to issue withdrawal notice upon failure to execute Class Year FSA, failure to submit required Class Year FSA data, or failure to submit any required Class Year deposits (study deposit or deposits in lieu of regulatory milestone) Withdrawal on this basis cannot be cured (see Issue 6) 54

55 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Rationale for NYISO s Proposal Execution of multiple study agreements requires time and resources that could be more efficiently used to perform the studies themselves Elimination of study agreements can substantially decrease initial study administration time Study timelines would likely be much more predictable Increased transparency re: status of studies 55

56 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Details Incorporate key terms re: study obligations from FES, SRIS and SIS Agreements into the Interconnection Request Forms Revise or delete tariff references to the FES, SRIS and SIS Agreements Revise execution deadline for NYISO and CTO for Class Year FSA and Small Gen FSA NYISO and CTO must execute upon receipt of executed copy with required deposit and sufficient technical data from Developer, not later than 10 Business Days from receipt 56

57 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Details, continued For all studies other than Facilities Studies, NYISO to use the following milestone in lieu of tender of study agreement: notice from the NYISO to Developer and CTO with good faith estimate of study costs and timeframe for completing the study» NYISO to send such after receipt of 5 day letter from Developer indicating Developer s intent to move forward to the respective study ( 5 day letter from Developer precedes each study and confirms POI)» Such triggers the 15 Business Day deadline for Developer to provide required study deposit and sufficient technical data For all studies other than Facilities Studies, NYISO to use the following milestone in lieu of study agreement execution for study commencement: notice from the NYISO after receipt of study deposit and required technical data» This will identify commencement of the study» This notice requirement is included in the proposed tariff revisions» NYISO to post study commencement date for each of these studies on the Interconnection Queue 57

58 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Details, continued Example of timeline under NYISO s proposal Scoping Meeting Study Scope developed in parallel with other tasks Developer sends study deposit and data within 15 Business Days Developer sends "5-day letter" NYISO s good faith estimate of study cost NYISO sends to commence study 58

59 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Details, continued Proposed Effective Date: NYISO proposes that revised execution deadlines for Facilities Study Agreements apply only to agreements tendered after the date of FERC Order New Interconnection Requests will be subject to the new rules and new Interconnection Request form If the NYISO has already tendered an FES, SRIS or SIS 3- party study agreement and that agreement is not fully executed before the date of the FERC Order, the Developer may opt to proceed to execute the tendered agreements or submit a revised Interconnection Request form containing the key obligations from the prior pro forma FES/SRIS/SIS agreements 59

60 Administrative Process Improvements Issue No. 2: Expedited Study Agreement Processing, cont. Specific tariff sections NYISO proposes to revise: Attachment X, Section Coordination with Affected Systems Attachment X, Section 30.6 Large Facility Feasibility Study (FES) Attachment X, Section 30.7 Large Facility System Reliability Impact Study (SRIS) Attachment X, Section Large Facility Facilities Study/Class Year Study Attachment X, Section Large Facility Optional Interconnection Study Attachment Z, Section Small Gen Scoping Meeting Attachment Z, Section Small Gen FES Attachment Z,Section Small Gen System Impact Study (SIS) Attachment Z,Section Small Gen Facilities Study Attachment Z, Section Coordination with Affected Systems Pro Forma Study Agreements» Attachment X, Section 30.14, Appx. 2 (Large Facility FES Agreement)» Attachment X, Section 30.14, Appx. 3 (Large Facility SRIS Agreement)» Attachment X, Section 30.14, Appx. 4 and 4A (Class Year Facilities Study Agreements)» Attachment X, Section 30.14, Appx. 5 (Optional Interconnection SRIS Agreement)» Attachment Z, Section 32.5, Appx. 6 (Small Gen FES Agreement)» Attachment Z, Section 32.5, Appx. 7 (Small Gen SIS Agreement)» Attachment Z, Section 32.5, Appx. 8 (Small Gen Facilities Study Agreement) Other required revisions in Attachments X and Z to reflect that FES/SRIS/SIS agreements no longer exist and to reflect alternative milestones for agreement execution 60

61 Administrative Process Improvements Issue No. 3: Format of Study Reports Current Practice NYISO either performs an interconnection study in-house or uses a consultant to perform the study The study reports all contain the same types of analyses, but depending upon the entity preparing the report, the format can be different NYISO also provides a brief NYISO Review Report presented to TPAS and the OC that follows a standardized format Proposal & Details Develop a more standardized study report format/template for both NYISO and its consultants to use, specifically, the general framework provided on the following slides NYISO proposes to present a transmission map for SIS and SRIS study scopes going to TPAS and OC, showing the location of each project Proposed Effective Date: immediately Rationale for NYISO s Proposal This was requested by developers for the SRIS A more standardized format may enable parties reviewing the report to review it more quickly and provide comments on a shorter turn-around A more standardized format may enable both developers and TPAS/OC members to more easily review the study reports 61

62 Administrative Process Improvements Issue No. 3: Format of Study Reports, cont. Outline for FES Study Reports Executive Summary Introduction Project Description POI configuration Modeling data Study Methodology Steady State N-0 & N-1 Analysis Short Circuit Analysis Interconnection Cost Estimates CTOAFs and Local SUFs SUFs Conclusions Appendices 62

63 Administrative Process Improvements Issue No. 3: Format of Study Reports, cont. Outline for SRIS Study Reports Executive Summary Introduction Project Description POI configuration Modeling data Study Methodology Steady State N-0 & N-1 Analysis Steady State N-1-1 Analysis Transfer Limit Analysis Thermal Transfer Results Voltage Transfer Results Stability Transfer Results Dynamic Analysis Normal, Extreme Contingencies Critical Clearing Time Short Circuit Analysis Extreme Contingency Analysis Steady State Analysis Dynamic Analysis NPCC A-10 Steady State Analysis Dynamic Analysis Interconnection Cost Estimates CTOAFs and Local SUFs SUFs Conclusions Appendices 63

64 Administrative Process Improvements Issue No. 4: Roles and Responsibilities of Parties in the Interconnection Study Process Current Rule Each parties obligations are set forth in the tariff and study agreements Proposal Reinforce the roles and responsibilities of all parties in the interconnection process through additional provisions in Attachments X and Z, and through the Scoping Meeting Similar revisions to be proposed in Attachment P after the compliance filing created Attachment P is accepted by FERC Rationale for NYISO s Proposal It is helpful, particularly to parties new to the NYISO s interconnection process, to explain each parties role in the process. This helps set realistic expectations at the outset. Even for parties that frequent the interconnection study process, such reminders can be helpful with respect to recent tariff changes 64

65 Administrative Process Improvements Issue No. 4: Roles and Responsibilities of Parties in the Interconnection Study Process, cont. Details NYISO is already reinforcing this in Scoping Meetings NYISO also proposes to add language to the tariff and TE&I Manual reinforcing these obligations, e.g.: Requiring Developers to provide data requested during study and be present for TPAS and OC where study scope and report is discussed Requiring Connecting and Affected TOs to review and comment on contingency lists, one-line diagrams and study reports Requiring Connecting and Affected TOs to provide input regarding proposed Point(s) of Interconnection and configurations Proposed Effective Date: date of FERC Order 65

66 Administrative Process Improvements Issue No. 4: Roles and Responsibilities of Parties in the Interconnection Study Process, cont. Specific tariff sections NYISO proposes to revise: Attachment X, Section Scoping Meeting Attachment X, Section Large Facility FES Procedures Attachment X, Section and Large Facility SRIS Procedures Attachment X, Section Class Year Study Procedures Attachment Z, Section Jurisdictional Determination Attachment Z, Section Small Gen FES Attachment Z, Section Small Gen SIS Attachment Z, Section Small Gen Facilities Study 66

67 Administrative Process Improvements Issue No. 5: Interconnection Requests with Multiple Voltage Levels Current Rule Attachment X provides that an Interconnection Request for one site at two different voltage levels shall require two Interconnection Requests Pending tariff revisions in an Order 1000 compliance filing revised this language such that it only applies to generation facilities Proposal Revise Attachment X to require only one interconnection request for a generator with 3-winding transformer w/legs to two different voltage level lines and for a combined cycle with a GT and ST connected at different voltage levels Rationale for NYISO s Proposal Unnecessary administrative burden to developers to submit separate Interconnection Request for one site at two different voltage levels It is more efficient to evaluate such a facility in a single study Details See proposed tariff revisions to Attachment X, Section Proposed Effective Date: Interconnection Requests submitted on or after the date of the FERC Order would be subject to this new rule; pending Interconnection Requests for one facility at multiple voltage levels would be permitted to consolidate the two queue positions into one as of the date of the FERC Order 67

68 Administrative Process Improvements Issue No. 6: Clarification of Withdrawal Procedure Current Rule The withdrawal provision in Section of Attachment X provides for a 15 Business Day cure period, but specifies that the cure period does not apply to certain deadlines in Attachments S and X (e.g., the deadline by which to accept Project Cost Allocations in the Class Year) One of the deadlines referenced in Section is the deadline to notify the NYISO re: a project s regulatory milestone, even if the project is not entering a Class Year Study The obligation to notify the NYISO re: a project s regulatory milestone status is in Section of Attachment S. Proposal Delete the reference to the deadline in Section from the withdrawal provision in Section of Attachment X and delete the consequence of withdrawal as mandatory from Section (i.e., failure to respond to a request for regulatory milestone status may trigger withdrawal) 68

69 Administrative Process Improvements Issue No. 6: Clarification of Withdrawal Procedure, cont. Rationale for NYISO s Proposal With the recently approved revisions to the regulatory milestone requirement, a project is eligible for CY entry once it has an OC-approved SRIS it is less critical that the NYISO know when a regulatory milestone is met Details See proposed tariff revisions in the following sections: Attachment S, Section Attachment X, Section Proposed Effective Date: date of FERC Order 69

70 Class Year Study Process Improvements. 70

71 Class Year Process Improvements Issue No. 7: Additional Class Year Start Dates Current Rule Class Year Study will start on the first of the following dates after completion of the prior Class Year Study: March 1, June 1 or September 1 Only 3 possible Class Year Start Dates within a calendar year Proposal Revise Attachment S to provide more possible Class Year Start Dates than the existing process by allowing the next Class Year to start on the first Business Day after 30 days after completion (i.e. settlement and posting of Security) of the prior Class Year Proposed Effective Date: Class Year beginning after the completion of Class Year

72 Class Year Process Improvements Issue No. 7: Additional Class Year Start Dates, cont. Rationale for NYISO s Proposal It is unnecessary to wait 3-6 months to start a new Class Year once a Class Year has completed NYISO only needs approximately 30 days between Class Year studies 30 days is the minimum amount of time the NYISO requires to notify potential Class Year projects, confirm eligibility and determine whether projects have met the regulatory milestone (while not required, failure to meet this milestone changes the Class Year entry requirements with respect to the deposit in lieu of regulatory milestone) Details See proposed tariff revisions to Attachment S, Section

73 Class Year Process Improvements Issue No. 8: Additional Opportunities for a Class Year Project to Withdraw from Class Current Rule Unless additional SDU studies are required, and notice of such is provided to Class Year members, there is no opportunity to withdraw from the Class Year Study until the decision rounds Proposal Revise Attachment S and the pro forma Class Year Facilities Study Agreement in Attachment X to allow a project to withdraw from the Class Year Study prior to the completion of the ATBA study cases A Class Year that a project enters and from which it withdraws will still count as one of 2 Class Years a project may enter Proposed Effective Date: Class Year beginning after Class Year

74 Class Year Process Improvements Issue No. 8: Additional Opportunities for a Class Year project to withdraw from Class, cont. Rationale for NYISO s Proposal Developers would like additional opportunities to withdraw from a Class Year Study NYISO proposes only one additional withdrawal opportunity in order to avoid the potential for project withdrawals to delay the completion of the Class Year Study Allowing a project to withdraw from the Class Year Study prior to the completion of the ATBA study cases would have minimal impact on the Class Year schedule 74

75 Class Year Process Improvements Issue No. 8: Additional Opportunities for a Class Year project to withdraw from Class, cont. Details See proposed tariff revisions to the following sections: Attachment S, Section (NYISO obligation to notify CY Members re: ATBA study case schedule) Attachment X, Section (providing for additional opportunity to withdraw from the Class Year Study prior to completion of ATBA study cases) Attachment S, Section (providing that projects that take advantage of this additional withdrawal opportunity use one of their two Class Year entry opportunities) Attachment X, Section and Attachment S, Section (providing for refund of deposits in lieu of regulatory milestones if a project withdraws from the Class Year Study) 75

76 Class Year Process Improvements Issue No. 9: Bifurcated Class Year Current Rule All projects in a Class Year Study must wait to complete the decision and settlement process together, and such process may, under certain circumstances, not occur until after additional SDU studies are completed (if such studies are required) Proposal Allow any Class Year project to settle cost allocation and complete the CY Study (see next slides for additional details) Proposed Effective Date: Class Year 2017, if not completed when FERC issues Order Rationale In two recent Class Years the need to perform additional SDU studies required additional Class Year study time unrelated to the upgrades and cost allocation for a majority of the Class Year projects in those Class Year Studies In order to allow projects ready to move forward to complete the Class Year, NYISO proposes this bifurcated Class Year structure allowing projects various options to complete the Class Year 76

77 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Details Proposal involves two separate decision/settlement phases: CY X-1 and CY X-2 X = the year of the Class Year Start Date (e.g., CY17-1 and CY17-2) Both Class Year X-1 and X-2 would required OC approval essentially treating Class Year as two separate Class Years At the stage in Class Year Study when the need for additional SDUs is identified, NYISO would first issue a notice to the Class Year projects if SDUs requiring additional studies have been identified Such projects will have 10 Business Days to confirm whether they want to proceed to X-2 with additional studies or whether they want to be a part of the X-1 decision process As soon as practicable after the NYISO receives the decisions from the projects requiring additional SDU studies, NYISO will issue a notice to all Class Year projects informing them either: (1) All projects requiring additional SDU studies have elected not to have such SDUs evaluated in X-2 (in which case, the NYISO proceeds to the normal Class Year decision and settlement process); or (2) There will be a Bifurcated Class Year 77

78 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Details Under a Bifurcated Class Year, all projects except the Additional SDU project(s) that elected to move to X-2 will have the following options during the Bifurcated Decision Period: Project may elect to settle the Class Year early in Class Year Decision/Settlement as part of Class Year X-1 (see the various settlement options in the proposed revisions in Section of Attachment S) Project may proceed as a member of Class Year X-2, with no changes to ERIS or CRIS requests; Project may proceed as a member of Class Year X-2 as ERIS only (i.e., withdrawing its CRIS request); Project may proceed as a member of Class Year X-2 with ERIS and/or CRIS requests, but electing to have no System Deliverability Upgrades identified to make the project deliverable at its level of requested CRIS (i.e., proceed as a member of Class Year X-2 with the option of accepting or not accepting all of its requested ERIS MW and only its Deliverable MW for CRIS); or Project may withdraw from the Class Year entirely 78

79 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Details, continued Security posting implications If a project that elects to settle in Class Year X-1 shares a cost allocation for SUFs or Headroom with a project that elects to remain in the Class Year Study through Class Year X-2:» The project electing to settle in Class Year X-1 will be required to post security equal to its highest possible Project Cost Allocation, assuming all, none or any combination of other Class Year projects drop out or accepts their Project Cost Allocations» In other words, if a project that elects to settle in Class Year X-1 shares a cost allocation for System Upgrade Facilities, System Deliverability Upgrades or Headroom with a project that elects to proceed as a member of Class Year X-2, the project electing to settle in Class Year X-1 will be required to post Security equal to the highest amount it might possibly be required to post under any Class Year decision and settlement scenario. At the end of the Class Year X-1 cost allocation decisions and also, in the Class Year X-2 cost allocation process, the NYISO would recalculate the security requirements for each project that settled in Class Year X-1, potentially requiring the CTO to refund excess security resulting from this recalculation 79

80 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Details, continued Next Class Year Study could not begin until after all Class Year evaluations, including the additional SDU studies are completed, and Class Year X-2 has completed its decision/ settlement period Interconnection Base Case Implications ATBA would not be updated to reflect projects that accepted cost allocation and posted Security until Class Year X-2 has completed Interconnection studies (e.g., SRISs) performed after the completion of Class Year X-1 may reflect those projects that accepted cost allocation and posted Security in Class Year X-1 80

81 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Details, continued Buyer Side Mitigation Proposal For a Class Year that is not bifurcated and for Class Year X-2, as under the current BSM process, prior to the commencement of the Initial Decision Period, the NYISO will provide initial BSM determinations for all Examined Facilities» Those determinations will identify the determination and Offer Floor under the Part A Test and Part B Test, and Self Supply Exemption. They will also identify whether an Examined Facility that requested a Renewable Exemption or a Competitive Entry Exemption ( CEE ) qualifies for that exemption.» Concurrent with the issuance of the determinations at the time of the Initial Decision Period, the NYISO will post on its website the quantity of MW of Examined Facilities in the Class Year that had requested a renewable exemption and the quantity determined to the eligible for a Renewable Exemption. 81

82 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. If under OATT Section NYISO issues a notice that any Class Year Project requires SDUs for which additional System Deliverability Upgrade studies are required, NYISO will provide to any such units that are in a Mitigated Capacity Zone, a preliminary Unit Net CONE and Part A Test and Part B Test exemption or Offer Floor determination, and if applicable, a Self Supply or CEE exemption determination, or Renewable Exemption qualification determination. If the Class Year bifurcates, prior to the commencement of the Bifurcated Decision Period, NYISO will issue the determination for each Examined Facility under Part A Test, the Part B Test, and for those that requested it, a determination of exempt or not exempt under CEE and Self Supply, and whether it is qualified for a Renewable Exemption. NYISO will have posted the quantity of MW that requested a Renewable Exemption and, at this time, will post the quantity of MW that were determined to be eligible for a Renewable Exemption» Class Year X-1 NYISO will issue a final BSM determination for Examined Facilities that settle in Class Year X-1 and are allocated CRIS (even if it is a quantity of CRIS MW that is different than the original CRIS request; e.g., it accepts deliverable MW and rejects MW with SDUs), and that posts security in accordance with Attachment S and remain in Class Year X-1 at the time of its completion 82

83 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont.» Class Year X-1, cont. The BSM determination will be the exact same as the determination issued prior to the Bifurcated Decision Period. It will be applied to the quantity of CRIS the Examined Facility received in Class Year X-1 at the time of its completion. The Part A Test and Part B Test will not be recalculated; that is, the calculation will not be updated if there is any change in the MW of CRIS The Examined Facilities that had requested a renewable exemption and were determined to be qualified will receive an exemption based on the total quantity of X-1 MW determined to be eligible, less the MW that received an exemption under the Part A Test, the Part B Test or a Self Supply Exemption. (Note: The pending tariff filing provides that an Examined Facility can request a Self Supply Exemption and a Renewable Exemption in the same Class Year, but cannot also request a CEE in that same Class Year) Examples are presented on a following slide The NYISO will post on its website the X-1 exempt and non-exempt determinations for each X- 1 Examined Facility, and will identify whether the facility received a CEE, Self Supply or Renewable Exemption, and the total quantity of renewable exempt MW allocated, and those that remain available for Class Year X-2 (i.e., the difference between the 1000 MW cap and the renewable exempt MW in Class Year X-1) The Class Year X-1 Examined Facilities BSM determinations will not be revised; e.g., for updated SDU estimates, after Class Year X-2 is completed, or any other reason 83

84 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. If the Class Year bifurcates» Class Year X-2 The NYISO will recalculate the Part A Test and Part B Test determinations prior to the Initial Decision Period and during the X-2 Project Cost Allocation process decisional rounds of X-2, as per the current rules Treat the projects that remained in Class Year X-1 at the time of its completion in the same manner as Examined Facilities that remained in a prior Class Year at the time of its completion BSM Determinations become final for these facilities as per the current rules; i.e., provided they remain in Class Year X-2 at the time of its completion 84

85 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. Renewable Exemption The 1000 MW cap will apply to the Class Year regardless of whether it bifurcates If more than 1000 MW request a renewable exemption and are determined to be qualified The 1000 MW would be allocated to X-1 projects first. The allocation would be determined at the time Class Year X-1 is completed As provided under the proposed renewable/self supply filing, if a project requests and is determined to be exempt under the Part A Test or Part B Test, or a self supply exemption, and eligible for a renewable exemption, it would be exempt under such Test or self supply. The MW of such project would not affect the MW available under the cap 85

86 Class Year Process Improvements Issue No. 9: Bifurcated Class Year, cont. Buyer Side Mitigation Proposal, cont. Renewable Exemption, cont. Examples of Examined Facilities that request a renewable exemption and are determined to be eligible for it:» These examples assume that projects eligible for a Part A Test, Part B Test or self supply exemptions, receive that exemption, as described above» If there are 700 MW of Qualified Renewable Exemptions exiting in X-1, and 400 MW of Renewables electing to remain in X-2, all 700 MW of X-1 projects will be exempt (leaving 300 MW of potential exempt MW for X-2 projects) In this example, should all 400 MW of X-2 projects remain in the Class Year, each of these projects would receive 75% of their Renewable Exemption request» If there are more than 1,000 MW of Qualified Renewable Exemptions in X-1, then the MW receiving the exemption will be determined by prorating amongst these projects. 86

87 Class Year Process Improvements Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations Current Practice/Rule NYISO tenders the Interconnection Agreement on the earlier of completion of the Class Year in which the Developer accepted cost allocation/posted required Security or upon the Developer s request, if Developer has executed a Class Year Facilities Study Agreement Prior to executing an Interconnection Agreement, a Developer may request and the CTO shall offer an E&P Agreement (See Attachment X, Section 30.9) Work Required Prior to Execution of an IA Upon execution of the Class Year Facilities Study Agreement, the NYISO begins work on the Part 1 Study Once the NYISO has identified all required CTO AFs and Local SUFs, even if that Class Year Study has not formally begun, the parties can execute the Interconnection Agreement An Interconnection Agreement executed prior to completion of the project s Class Year Study will require the Developer to accept the costs of any additional SUFs that are identified in the remaining portions of the Class Year study or any modifications to the SUFs or costs estimates for SUFs identified prior to execution of the Interconnection Agreement Under the Interconnection Agreement, if the projects wishes to go in-service prior to the completion of required upgrades, it may request a Limited Operations study under which the NYISO and CTO determine whether and the extent to which the facility can reliably interconnection on a provisional basis 87

88 Class Year Process Improvements Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations, continued Proposal NYISO proposes to describe all of the steps required for a project to go in-service prior to completing a Class Year in the tariff/manual, including a defined end date to Limited Operations NYISO proposes to include a specific provision in the tariff permitting a Developer to request a Limited Operations study prior to execution of an Interconnection Agreement, as long as such evaluation is of the facility prior to completion of required upgrades (i.e., not evaluation of an entirely new interim configuration) Proposed Effective Date: Pre-CY Interconnection Agreements: immediately (tariff revisions simply memorialize existing practice) Limited Operations: date of FERC Order, unless the Developer, NYISO and Connecting TO mutually agree to pre-ia Limited Operations studies 88

89 Class Year Process Improvements Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations, continued Rationale for NYISO s Proposal NYISO is seeing an increase in the number of projects that desire to go into service prior to completion of a Class Year Study To increase transparency and provide a detailed description of the process and limitations applicable to such facilities, NYISO believes that tariff revisions are appropriate 89

90 Class Year Process Improvements Issue No. 10: Pre-Class Year Interconnection Agreements & Limited Operations, continued Details NYISO proposes to renumber Sections and , and insert into Section , a new section, entitled, Interconnection Agreement Pre-Dating Completion of the Large Facility s Class Year Study This new section to contain a detailed description of the process for requesting, negotiating and executing an Interconnection Agreement prior to completing a Class Year Study This new section to also describe the applicable limitations (e.g., a facility must accept its Project Cost Allocation for SUFs; a facility cannot sell CRIS requested in a Class Year until the project completes the Class Year and posts Security for any SDUs) NYISO also proposes to add a new Section (similar to Article 5.9 of the pro forma LGIA) to provide for a limited operations analysis for projects that wish to go in-service prior to completion of all required upgrades (CTO Attachment Facilities and System Upgrade Facilities) 90

91 Other Study Process Improvements. 91

92 Other Study Process Improvements Issue No. 11: Optional Feasibility Study Current Rules Attachments X and Z require an Interconnection Feasibility Study for Large Facilities and Small Generating Facilities Feasibility Study may be waived if the NYISO, Connecting TO and Developer all agree Proposal Revise Attachments X and Z to make the Feasibility Study optional Available at the Developer s option not subject to NYISO and/or Connecting TO approval Study schedule for optional Feasibility Study to depend on options elected by proposing entity If Developer opts to forego Feasibility Study, required evaluations will be addressed in the SIS/SRIS 92

93 Other Study Process Improvements Issue No. 11: Optional Feasibility Study, cont. Rationale for NYISO s Proposal Analyses that are required can easily be folded into the SIS or SRIS without the need to develop separate FES scopes, study agreements and study reports This would allow a project developer to complete the interconnection process in less time Details NYISO proposes to revise Attachments X and Z to make the FES optional (see following slides for specific tariff revisions proposed) NYISO proposes to rename the Interconnection Feasibility Study throughout Attachments X and Z as the Optional Interconnection Feasibility Study NYISO also proposes to rename the Optional Interconnection Study in Attachment X to the Optional Interconnection System Reliability Impact Study (to distinguish this study from the Optional Interconnection Feasibility Study) Proposed Effective Date: the Feasibility Study will be optional for projects for which a Feasibility Study Agreement has not been fully executed on the date of the FERC Order 93

94 Other Study Process Improvements Issue No. 11: Optional Feasibility Study, cont. NYISO proposes to revise Attachment X, Section and Attachment Z, Section to specify that the Scope of Optional Feasibility Study may include any of the following, at the option of the Developer/Customer: For $10,000 Study Deposit: Development of conceptual breaker-level one-line diagram of existing system where project proposes to interconnect (i.e., how to integrate the project into the existing system); and/or Review of feasibility/constructability of conceptual breaker-level one-line diagram for compliance with local transmission owner planning criteria and other Applicable Reliability Standards of the proposed interconnection (e.g., space for additional breaker bay in existing substation or identification of cable routing concerns inside existing substation) For $60,000 Study Deposit ($30,000 for Small Gens): Above analyses as well as one of more of the following:» Preliminary review of local protection, communication, grounding issues associated with the proposed interconnection» Power flow, short circuit, and/or bus flow analyses» Identification of Network Upgrades with non-binding good faith estimate of cost responsibility and non-binding good faith estimated time to construct Similar revisions to be proposed in Attachment P after the compliance filing created Attachment P is accepted by FERC 94

95 Other Study Process Improvements Issue No. 12: Requirement that SISs and SRISs move forward to TPAS Current Rules Currently, there is no requirement that a project with a completed SIS or SRIS move forward to TPAS and the OC for review and approval of such reports within a specified time The only rules that would impact such studies concern Large Facilities subject to a Class Year process Large Facilities (i.e., Large Generating Facilities and Merchant Transmission Facilities) are subject to withdrawal if they do not enter a Class Year within 3 Class Year Start Dates after OC approval of the SRIS (Section of Attachment S) No such rules apply to the other studies subject to OC approval SISs performed under OATT 3.7, OATT 3.9 or Attachment P 95

96 Other Study Process Improvements Issue No. 12: Requirement that SISs and SRISs move forward to TPAS, cont. Proposal & Details Revise OATT 3.7, OATT 3.9, OATT 4.5 and Attachment X to require all SISs and SRISs to move forward to TPAS within 3 months of completion of the study report and move to the next OC following TPAS review and recommendation (or subsequent TPAS review and recommendation if initial TPAS revise requests revisions) Completion to be defined as the point at which a final draft study report has been issued by the NYISO Similar revisions to be proposed in Attachment P after the compliance filing created Attachment P is accepted by FERC Proposed Effective Date: date of FERC Order SISs and SRISs completed as of date of FERC Order will have 3 months from FERC Order date Rationale for NYISO's Proposal Allowing a project with a completed SRIS or SIS to wait to proceed to TPAS and the OC for up to 3 Class Years can lead to studies coming to the OC for approval even though modeling assumptions, analyses and study conclusions may be stale Members of the TPAS and OC have expressed significant concerns regarding this practice 96

97 Other Study Process Improvements Issue No. 13: Revisions to Modeling Data Requirements Current Practice The Interconnection Request form requires detailed, project-specific dynamic modeling data Proposal & Details Revise the Interconnection Request forms in Attachment X and Z such that dynamic modeling data is not required until the SRIS/SIS stage and also to make the forms easier to complete. Attachment X, Section 30.14, Appx. 1 (Large Facility Interconnection Request form) Attachment Z, Section 32.5, Appx. 2 (Small Gen Interconnection Request form) Permit Developers to provide generic dynamic models (with project-specific parameters and adequate manufacturer documentation) Proposed Effective Date: Interconnection Requests submitted after date of FERC Order 97

98 Other Study Process Improvements Issue No. 13: Revisions to Modeling Data Requirements, cont. Rationale for NYISO's Proposal The level of detail currently required in the Interconnection Request form with regard to dynamic modeling data is not necessary at the outset of the interconnection process. Such information is not required to validate an Interconnection Request, nor is it required for the Feasibility Study Such information can be submitted as part of the eligibility requirements for an SRIS Generic dynamic models can be accommodated if such models contain project specific parameters and adequate manufacturer documentation 98

99 Other Study Process Improvements Issue No. 14: Updates to Small Generator Deposits and Application Fee Current Provisions Small Generator Interconnection Request requires an application fee of $1,000 The Small Generator Feasibility Study (FES) requires a deposit of the lesser of 50% of the good faith estimated FES costs or $1,000 The Small Generator System Impact Study (SIS) requires a deposit of the good faith estimated costs, which is typically $75,000 99

100 Other Study Process Improvements Issue No. 14: Updates to Small Generator Deposits and Application Fee, cont. Proposal & Details Revise Section of Attachment Z to make the Small Generator Interconnection Request application fee of $1,000 a non-refundable fee Revise Section of Attachment Z to increase the Small Generator FES deposit from $1,000 to $10,000 (if project elects more limited FES scope) or $30,000 (if projects elects more detailed FES scope) Revise Section of Attachment Z to decrease the Small Generator SIS deposit from the full study cost estimate (approx. $75,000 to $100,000) to $50,000 Proposed Effective Date: For application fee, new deposit structure applicable to applications submitted on or after FERC Order For study deposits, new deposits will apply to studies for which the study agreement is tendered on or after the date of the FERC Order 100

101 Other Study Process Improvements Issue No. 14: Updates to Small Generator Deposits and Application Fee, cont. Rationale for NYISO's Proposal Overall, this proposal would reduce the fees/deposits required for Small Generators from the Interconnection Request through the beginning of the SIS from approx. $77,000 to $61,000 (or as low as $51,000 if no FES) Rational for application fee being non-refundable: Processing of Interconnection Requests requires administrative work by both the NYISO and Connecting TO that needs to be covered by the application fee Like the application fee for the Large Facility Interconnection Request, this application fee should be non-refundable to cover such costs in the event the project ultimately withdraws or its Interconnection Request is found deficient 101

102 Other Study Process Improvements Issue No. 15: Clarification of Base Case Inclusion Rules Current Provisions Attachment S provides detailed base case inclusion rules for the Class Year Study (Section ) Attachment X provides the following description of Base Cases: The power flow, short circuit and stability data bases, hereinafter referred to as Base Cases, provided shall be those that the NYISO is using in the Annual Transmission Baseline Assessment then in progress, or if such data bases are not available, the data bases from the last completed Annual Transmission Reliability Assessment conducted pursuant to Attachment S of the OATT prior to the request. In the case of a request from a Developer considering Capacity Resource Interconnection Service, the power flow data bases provided shall include the Annual Transmission Reliability Assessment case from the most recently completed Class Year Deliverability Study. 102

103 Other Study Process Improvements Issue No. 15: Clarification of Base Case Inclusion Rules, cont. Proposal & Details Provide more explanation in the Transmission Expansion & Interconnection Manual regarding the manner in which base cases are created and updated Revise the Class Year base case inclusion rules for the ATBA in Attachment S, Section with respect to the milestone for TIP projects to be included: TIP project that is an Attachment Y project must have met the following milestones to be included in a Class Year ATBA base case:» Triggered under the RPP, selected under the PPTPP, or approved by beneficiaries under the CARIS; and» Completed a System Impact Study; and» Have an Article VII deemed complete (if applicable); and» Are making reasonable progress under the applicable Attachment Y planning process TIP project that is not an Attachment Y project must have met the following milestones to be included in a Class Year ATBA base case:» Completed a Facilities Study; and» Posted Security for Network Upgrade Facilities; and» Have an Article VII deemed complete (if applicable) Revisions to be proposed (and discussed with stakeholders) regarding appropriate revisions in Attachment P after the compliance filing created Attachment P is accepted by FERC Proposed Effective Date: next ATBA case developed on or after the date of the FERC Order 103

104 Other Study Process Improvements Issue No. 15: Clarification of Base Case Inclusion Rules, cont. Rationale for NYISO's Proposal Stakeholders have requested clarification regarding how and when interconnection studies are updated NYISO believes more specific details will provide increased transparency to participants in the interconnection study process TIP projects fall in 2 distinct groups (Att. Y projects and others) that necessarily require different base case inclusion rules For Att. Y, selection under the applicable Att. Y process, together with the other milestones required is a good indication of firmness For non-att. Y projects, they should (like Class Year projects) not be included in base cases for other projects before they have posted Security for their Network Upgrade Facilities 104

105 Other Study Process Improvements Issue No. 16: Revisions to Tracking of In-Service Dates, Initial Synchronization Dates and Commercial Operation Dates Current Provisions Projects must specify a proposed In-Service (I/S) Date and Commercial Operation Date (CODs) in the Interconnection Request Updates to these dates must be included in the Class Year Facilities Study Agreement data sheet and in the Interconnection Agreement Proposal & Details Add tariff language to Section of Attachment X and Section of Attachment Z to require Developers (Large Facilities and Small Generators) to provide updates to proposed I/S Dates, Initial Synchronization Dates and CODs on a quarterly basis once they have executed a Facilities Study Agreement Add tariff language requiring Developers to provide proposed Initial Synchronization Date any time they are required to provide proposed I/S Date and proposed COD Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal Stakeholders believe proposed I/S Dates and CODs are often unrealistic and request that Developers be required to update them on a more frequent basis based on the project status 105

106 Other Study Process Improvements Issue No. 17: Outstanding Invoices for Withdrawn Projects Current Practice Consistent with FERC precedent, upon withdrawal, all deposits are payable with interest Proposal & Details Add tariff language to Section of Attachment X to require outstanding invoices from TOs, Affected System Operators and Consultants to be provided within a specific timeframe, e.g., 60 days after completion of the subject study Add tariff language to Section of Attachment X to require, for withdrawn projects, that study deposits be trued up with all outstanding invoices before deposits are refunded in the event of withdrawal Proposed Effective Date: date of FERC Order Invoices outstanding on date of FERC Order must be submitted to the NYISO within 60 days from date of FERC Order Rationale for NYISO's Proposal Unfair windfall to a withdrawn project to receive study deposit refunds with interest, when such refunds have not been trued up against outstanding invoices 106

107 Other Study Process Improvements Issue No. 18: Clarification of Process for evaluation of alternative POIs in the Small Generator Interconnection Procedures Current Provisions The Small Generator FES Agreements and SIS Agreement both refer to alternative POIs, appearing to contemplate that a Small Generator may request evaluation of an alternative POI, however there are no provisions in Attachment Z explaining the evaluation of alternative POIs Proposal & Details Revise Section of Attachment Z to clarify the process for electing the evaluation of alternative POIs in the Small Generator Interconnection Procedures Revise Section of Attachment Z to require alternative POIs to be evaluated in a Feasibility Study (for both Large and Small Facilities) i.e., a project that requests alternative POIs may not opt to forego a Feasibility Study Revise Section of Attachment Z to clarify that a project requesting alternative POIs must select one POI before moving to the Facilities Study Proposed Effective Date: Small Generator Interconnection Requests submitted on or after date of FERC Order Rationale for NYISO's Proposal The Small Generator procedures are silent on how an alternative POI can be requested and evaluated. NYISO proposes to add such provisions to provide needed clarity. 107

108 Other Study Process Improvements Issue No. 19a: Scope of Studies for Uprate Projects Current Practice Currently, uprate projects may, with the NYISO s and Connecting TO s agreement, be able to forego a FES and may have a more narrow study scope for the SRIS than a typical new facility Proposal & Details Eliminate requirement that Developer obtain consent from the Connecting TO and NYISO to forego a FES (See proposed tariff revisions associated with Issue No. 11) Continue to customize the scope of an SRIS, as appropriate, for uprates and specifically recognize in Section of Attachment X and Section of Attachment Z that the parties may do so upon mutual agreement Proposed Effective Date: SRIS scopes not yet approved by the Operating Committee on the date of FERC Order Rationale for NYISO's Proposal Uprates to an existing facility may not require all of the same evaluations that a new facility requires 108

109 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations Current Provisions Section of Attachment S requires the NYISO to maintain the same proportion of CRIS to ERIS in the Winter as the facility has in the Summer Since the CRIS level assigned to a facility under Attachment S is a Summer value, this tariff language extends a CRIS value to the Winter If the facility is fully deliverable, the Summer CRIS/ERIS ratio will be 100% and the facility s Winter CRIS cap is equal to Winter ERIS A facility is fully deliverable if it was (1) grandfathered for CRIS, evaluated for CRIS in a CY and found fully deliverable or paid Security for SDUs to make if fully deliverable; and (2) has not materially increased its capability 109

110 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations, cont. Current Practice NYISO currently determines a Winter CRIS cap for all projects that are not fully deliverable E.g., Projects that elected to take only partial Summer CRIS in a Class Year Winter CRIS is calculated through the following formula: NYISO implements the Winter CRIS cap in the ICAP AMS by applying a limiting percentage to the facility s Winter DMNC This percentage needs to be updated manually for every DMNC change 110

111 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations, cont. Proposal Rather than manually calculate the applicable percentage of the Winter DMNC for each DMNC update, NYISO proposes to maintain fixed values for Winter CRIS Details NYISO proposes to revise Section of Attachment S clarifying the manner in which it will calculate the fixed Winter CRIS values NYISO proposes to specify that for the purpose of calculating the fixed Winter CRIS value, NYISO will use the following formula in which X = the fixed Winter CRIS MW Summer CRIS MW = X MW per Temperature Curve at 90 MW per Temperature Curve at 10 In no case will the Winter CRIS value be lower than Summer CRIS CRIS values will only change upon approved increased CRIS requests (i.e., 2 MW permissible lifetime increase, CRIS received through a same location CRIS transfer, or CRIS received through a Class Year Deliverability Study) NYISO has posted a chart with the 7/21 meeting materials using the 2017 GoldBook existing generator table with a new column with the fixed Winter CRIS value using existing data 111

112 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations, cont. Details, continued NYISO proposes to include as a 2018 project, software modifications to: Modify the ICAP AMS to add a field for a fixed Winter CRIS value while maintaining historical Winter CRIS % in AMS; and Modify calculations inside AMS to use new fixed Winter CRIS value Implementation of this proposal would post-date deployment of the required software modifications (i.e., no earlier than Winter 2018/2019) Proposed Effective Date: Winter Capability Period commencing after software is deployed no earlier than Winter 2018/

113 Other Study Process Improvements Issue No. 19b: Winter CRIS Determinations, cont. Rationale With the rule added to Attachments X and Z providing for nonmaterial increases in output that can be permitted without an Interconnection Request, the NYISO is seeing an increase in such ERIS increases Determining fixed Winter CRIS values is preferable to manually updating percentages to be applied to a facility s Winter DMNC each time a DMNC is updated NYISO s proposal provides transparency and predictability for market participants while maintaining the original intent of Attachment S 113

114 Other Study Process Improvements Issue No. 20: PMU Requirement Current Provisions Currently there are no PMU requirements for facilities interconnection to the New York State Transmission System Proposal & Details Add tariff language to the pro forma LGIA in a new Article 9.10 to require a PMU for proposed new Large Generating Facilities and Merchant Transmission Facility 100 MW and new substations (230kV or above) Proposed Effective Date: date of FERC Order Projects that have signed Facilities Studies prior to FERC Order date will be exempt from this requirement Rationale for NYISO's Proposal A PMU requirement is common in other ISOs/RTOs PJM requires PMUs for generators of 100 MVA and above ERCOT requires PMUs for 20 MVA and above 114

115 Other Study Process Improvements Issue No. 20: PMU Requirement, cont. Rational for NYISO s Proposal, cont. System-wide situational awareness Faster diagnosis of operational issues For example, if operators identify power swings at a plant and have to order it off-line, PMU data can help identify the root-cause of the issue and allow the plant be brought back on-line sooner Supports NERC MOD-026, MOD-027 and MOD-033 NERC requires generating plants to validate their stability models Since recording equipment is already required by NERC, NYISO s additional requirement would be only to transfer the phasor measurements back to the control center in real-time 115

116 Other Study Process Improvements Issue No. 21: Clarification of Clustering for Small Generator Studies Current Practice Section of Attachment Z provides that, Interconnection Requests may be studied serially or in clusters for the purpose of the system impact study. For Small Generators that could potentially impact each other or that could collectively impact system conditions so as to require shared upgrade facilities, such projects are evaluated in a clustered SIS If a cluster study identifies non-local SUFs, projects triggering such upgrades must enter a Class Year Proposal & Details Explain in the TE&I Manual the manner in which NYISO performs clustering studies for Small Generators Add tariff language to Section of Attachment Z to explain that Small Generating Facilities moving forward in the same time frame that contribute to Local System Upgrade Facilities will be studied collectively to determine their pro rata cost responsibility for such Local System Upgrade Facilities. Add tariff language to Section clarifying that Small Generating Facilities evaluated in a cluster study that trigger non-local System Upgrade Facilities must be evaluated in a Class Year Interconnection Facilities Study pursuant to Section of this Attachment Z. Proposed Effective Date: immediately (tariff revisions simply clarify existing practice) 116

117 Other Study Process Improvements Issue No. 21: Clarification of Clustering for Small Generator Studies Rationale for NYISO's Proposal NYISO is seeing a significant influx of Small Generating Facilities in the Interconnection Queue, many in close proximity to each other, that require evaluation of their collective impacts in order to ensure reliability To increase transparency, NYISO believes it will be helpful to provide more details regarding the manner in which clustered studies are performed and the implications for cost allocation 117

118 Other Study Process Improvements Issue No. 22: Stakeholder Review of Changes in TO Planning Criteria Current Practice TOs provide updates to their local planning criteria in the annual FERC 715 report While NYISO requests TOs review changes with TPAS and the OC, stakeholders have requested that TOs have a more firm obligation to present changes to stakeholders for review and comment Proposal & Details Add tariff requirements to Section of Attachment S to require TOs to present changes to planning criteria to TPAS before such changes will be recognized as Applicable Reliability Requirements or Applicable Reliability Standards Similar revisions to be proposed in Attachment P after the compliance filing created Attachment P is accepted by FERC Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal Increased transparency Opportunity for affected parties to review and comment on proposed changes 118

119 Other Study Process Improvements Issue No. 23a: Clarification of MIS Methodology for Transfer Limit Impacts Current Provisions Attachment P and OATT 3.7 specifically provide that transmission projects evaluated under those procedures are responsible for upgrades if the projects degrades transfer capability by > 25 MW While Attachment S and X currently do not specify the specific levels of transfer degradation that require mitigation under the MIS, they do require upgrades under the MIS if the adverse reliability impact cannot be mitigated by normal operating procedures Transfer limit degradations can cause adverse reliability impacts that cannot always be mitigated by normal operating procedures 119

120 Other Study Process Improvements Issue No. 23a: Clarification of MIS Methodology for Transfer Limit Impacts, cont. Proposal & Details NYISO proposes to clarify in Section of the TE&I Manual, that under the MIS evaluation Large Facilities interconnecting to the NYCA must mitigate the adverse impact, above a specified threshold 25 MW on NYISO s external interfaces NYISO proposes to clarify in Section of the TE&I Manual that in the CY Study and clustered TIP studies, the 25 MW permissible transfer limit degradation is collective, not per-project Proposed Effective Date: date of approval of TE&I manual revisions Studies commenced on or after date of approved revisions to TE&I Manual will be subject to the 25 MW proposed de minimis value Prior to approved revisions to TE&I Manual, NYISO will continue to identify upgrades required to mitigate transfer limit degradations that adversely impact reliability and cannot be mitigated via normal operating procedures Rationale for NYISO's Proposal Beneficial to potential project developers to understand the specific threshold of transfer limit degradation that can be accommodated under the MIS without triggering upgrades 120

121 Other Study Process Improvements Issue No. 23b: Evaluation of Transmission Upgrades Identified by the NYISO in Affected System Studies Current Provisions Tariff currently requires that transmission upgrades identified by the NYISO in an Affected System Study be evaluated in the NYISO s TIP process, which includes an optional FES, an SIS and a Facilities Study Proposal & Details Add language to the TE&I Manual to allow transmission upgrades in the NYCA identified by the NYISO in Affected System Studies (for projects interconnecting to neighboring regions) to proceed directly from the other region s SIS to a NYISO s TIP Facilities Study Proposed Effective Date: date of approval of TE&I manual revisions Rationale for NYISO's Proposal The NYISO s identification of such upgrades is part of the SIS for another region and involves the same analyses the NYISO would perform in a TIP SIS 121

122 Clarifications regarding Cost Recovery for SDUs and Incremental TCCs for SDUs. 122

123 SDUs and Incremental TCCs Issue No. 24: Offset of SDU Costs Current Provisions Section of Attachment S provides that if the NYISO Comprehensive Reliability Planning Process ( CRPP ) identifies a Reliability Need requiring a Highway facility to be constructed earlier than would be required under Attachment S, funds collected from Class Year Developers will be used to cover a portion of the regulated solution costs to the extent such funds were collected for SDUs that are actually constructed by the regulated solution Section further provides that to the extent this tariff provision applies, the Class Year Developer funds that had been contributed to the Highway SDU will be used as an offset to the total reliability solution upgrade cost, with the remainder of the upgrade cost to be allocated per the requirements of the CRPP 123

124 SDUs and Incremental TCCs Issue No. 24: Offset of SDU Costs, cont. Proposal & Details Expand the allowed offset of SDU costs in Section of Attachment S to provide that SDU funds could be used to cover a portion of the costs of other regulated solutions (not just those triggered by Reliability Needs), including regulated solutions in CARIS and PPTPP Clarify that what would constitute the same upgrade for these purposes is a facility providing the exact amount of transfer capability the Highway SDU provides or a facility that provides transfer capability equal to or greater than the Highway SDU Clarify how CY Developers share of SDU costs would be allocated to regulated solution vis-à-vis SDU allocation See proposed tariff revisions in Section of Attachment S Proposed Effective Date: date of FERC Order, but only applicable to ROS Highway SDUs for which construction has not yet commenced Rationale for NYISO's Proposal This provision in Attachment S predated the current Attachment Y processes that include the PPTPP. NYISO believes it should be updated to apply to CARIS and PPTPP as well as Reliability Needs 124

125 SDUs and Incremental TCCs Issue No. 25: Highway Facilities Charge Current Provisions Under Attachment S, if Class Year Developers have posted Security for at least 60% of the total cost allocation of a ROS Highway SDU, construction is triggered Attachment S further provides that once constructed, the actual cost of the ROS Highway SDU, above that paid for by Class Year Developers, will be funded by Load Serving Entities, using the rate mechanism contained in Rate Schedule 12 of the NYISO OATT Proposal & Details Clarify the formula and procedures for cost recovery of ROS Highway SDU costs in Rate Schedule 12 See proposed tariff revisions in Section of the OATT Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal As NYISO prepares to implement Rate Schedule 12 for the Leeds-Hurley SDU, it believes the language and formula in RS 12 could benefit from clarification and additional detail 125

126 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Current Provisions Attachment S provides that for Class Year Developers that contribute to an SDU, once the SDU is built, any resulting Incremental TCCs will be distributed to the Developers in proportion to their funding of the SDU Attachment S also provides that a subsequent Developer paying for use of Headroom on SDUs will receive the corresponding Incremental TCCs Attachment S provides that Incremental TCCs attributable to LSE funding will be credited to the LSEs in proportion to their funding of the Highway SDU in accordance with Rate Schedule

127 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Proposal & Details Require the Connecting TO(s) who constructed the SDU to be responsible for requesting Incremental TCCs for the SDU Clarify that each CY Developer (or subsequent CY Developer making a Headroom payment) that elects to receive their portion of any Incremental TCCs will be the Primary Holder thereof and subject to the requirements of Section 19.7 of Attachment M of the OATT (including registering as a Customer and meeting the applicable credit requirements see MST, Attachment K) Clarify the ability of CY Developers (or subsequent CY Developers making Headroom payments) to decline their portion of any Incremental TCCs at the time offered or subsequently terminate any accepted Incremental TCCs in accordance with Section of Attachment M of the OATT 127

128 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Details, cont. Clarify that any Incremental TCCs declined or subsequently terminated by CY Developers that initially will be deemed reserved to the extent necessary to facilitate transfers to subsequent Developers that pay for Headroom created by the SDU Maintains equitable allocation among eligible entities based on funding obligations, while facilitating re-allocation to subsequent CY Developers paying for use of Headroom on a SDU Capacity associated with declined/terminated Incremental TCCs will be made available to support the sale of TCCs in TCC auctions Clarify the procedures for re-allocating previously awarded Incremental TCCs to subsequent CY Developers paying for use of Headroom on an SDU Incremental TCCs previously deemed reserved that are transferred to a subsequent Developer will become effective on the first day of the Capability Period that commences following the next Centralized TCC Auction conducted after the subsequent Developer makes the necessary Headroom payment and elects to receive its proportionate share of Incremental TCCs Clarify that in cases where LSEs have funded a portion of a Highway SDU, any Headroom payments by subsequent CY Developers will be made to the Connecting TO(s) who constructed the SDU and be credited to the LSEs that funded a portion of the SDU 128

129 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Details, cont. Clarify that all Incremental TCCs related to SDUs will not be eligible for sale in NYISOadministered TCC auctions or secondary markets regardless of the entity holding the Incremental TCCs. Primary Holders of these Incremental TCCs will receive congestion payments pursuant to Section of Attachment N of the OATT Clarify how the congestion value of any Incremental TCCs held by the Connecting TO(s) who constructed an SDU will be accounted for either pursuant to Rate Schedule 12 (for Highway SDUs that include LSE funding) or Attachment H of the OATT (for all other SDUs) Proposed Effective Date: date of FERC Order See proposed tariff revisions in: Sections and of Rate Schedule 12 (HFC Cost Recovery) Section of Attachment M of the OATT (Incremental TCCs for SDUs) Section of Attachment S of the OATT (Incremental TCCs for Byway and Highway SDUs) Sections and of Attachment S of the OATT (Incremental TCCs for Highway SDUs) Sections and of Attachment S of the OATT (Incremental TCCs associated with Headroom on Highway SDUs) 129

130 SDUs and Incremental TCCs Issue No. 26: Incremental TCCs for SDUs Rationale for NYISO's Proposal An SDU is unique in that it can potentially have numerous holders for any Incremental TCCs resulting therefrom: TO(s) who constructed it; Class Year Developers who contributed to it LSEs who paid for a portion of it under Rate Schedule 12; and Subsequent Developers who use Headroom on the SDU Certain of these entities may not be Customers at the time the SDU goes In-Service and any Incremental TCCs associated therewith become effective As such, the NYISO would have no way to administer the Incremental TCCs vis-à-vis such entities These unique aspects of Incremental TCCs for SDUs require specific rules regarding how they will be administered 130

131 Other Tariff/Manual Clarifications/Updates. 131

132 Other Clarifications and Updates Issue No. 27: Post-Class Year Studies Current Practice Currently, certain detailed design studies are performed within the scope of the Class Year Facilities Study (e.g., EMTP studies) while others are performed under engineering work required by the Interconnection Agreement (e.g., SSR studies) Proposal & Details Clarify in the TE&I Manual and in Section of Attachment S the manner in which such studies are conducted and coordinated (e.g., detailed design studies, SSR and protection coordination studies) and how the results of such studies may impact actual costs of upgrades for the project Similar revisions to be proposed in Attachment P after the compliance filing created Attachment P is accepted by FERC Proposed Effective Date: date of approval of TE&I manual revisions Rationale for NYISO's Proposal NYISO seeks to create consistency in the manner in which such studies are performed and provide transparency to Developers regarding how such studies can impact actual costs 132

133 Other Clarifications and Updates Issue No. 28: Clarifications of Security Provisions Current Provisions Section of Attachment S provides for Connecting TOs to reduce Security they hold as discrete portions of the System Upgrade Facilities have been completed by the Transmission Owner and paid for by the Developer, on a dollar-for-dollar basis Section also provides for the circumstances under which Security is forfeited by terminated projects and is used to defray the cost of SUFs and SDUs for other projects Proposal & Details NYISO proposes to revise Attachment S to provide that the Security reduction provisions apply equally to Affected TOs and Connecting TO(s) NYISO proposes to clarify the Security forfeiture provisions regarding the extent to which Security must be forfeited to defray the costs of SUFs and SDUs required for other projects NYISO proposes to revise the TIP process to provide additional details regarding Security following a FERC order accepting the compliance filing that resulted in the creation of the TIP process 133

134 Other Clarifications and Updates Issue No. 28: Clarifications of Security Provisions, cont. Proposal & Details, continued NYISO proposes to revise Attachment S to provide that the Security reduction provisions apply equally to Affected TOs and Connecting TO(s) NYISO proposes to clarify the Security forfeiture provisions regarding the extent to which Security must be forfeited to defray the costs of SUFs and SDUs required for other projects Proposed Effective Date: date of FERC Order 134

135 Other Clarifications and Updates Issue No. 29: Affected System EPC Agreements Current Practice While not specifically required by Attachment S, NYISO has been a party to EPC agreements among the Developer, Connecting TO, and Affected TO for SUFs and SDUs required on Affected TO facilities Proposal & Details Revise Section of Attachment X to require Developer, Connecting TO, the NYISO, and any Affected Transmission Owner to enter into an EPC agreement for the construction of triggered SUFs Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal This would memorialize current practice and would be consistent with language in Attachment S, Section for EPCs required for SDUs 135

136 Other Clarifications and Updates Issue No. 30: Tax Provisions in Pro Forma LGIA Current Provisions Section 5.17 of the pro forma LGIA provides a number of tax provisions related to interconnection facilities Proposal & Details Revise/update tax provisions in the pro forma Large Generator Interconnection Agreement as necessary See proposed revisions to Articles and of the pro forma LGIA Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal Parties to recent Interconnection Agreements have identified concerns with language in the existing pro forma tax provisions that require updating 136

137 Other Clarifications and Updates Issue No. 31: Insurance Provisions in Pro Forma LGIA Current Provisions Section 18.3 of the pro forma LGIA requires minimum insurance coverages for Developers and Connecting TOs Section requires that within 10 days after execution of the IA, Developer and Connecting TO provide certification of all insurance required in the IA Proposal & Details Update insurance language in the pro forma LGIA See proposed revisions in Section 30.14, Appx. 6 (Article 18.3) of the LGIA in Attachment X Proposed Effective Date: date of FERC Order Rationale for NYISO's Proposal Insurance language in the pro forma LGIA needs to be updated 137

138 Other Clarifications and Updates Issue Nos : Ministerial and Other Edits Ministerial Edits to Services Tariff, Section 5 Remove the March 1 reference in Section of the Services Tariff refer to Class Year Start Date instead Proposed Effective Date: date of FERC Order Ministerial and Other Edits to Attachments P and X Remove Standard from remaining Att. X references to Standard LFIP and use LGIA acronym where appropriate (e.g., Section 30.11) In Sections , clarify baseline ERIS for project that doesn t go forward with part of project studied in the interconnection process Simplify the language regarding the 30 day deadline for execution of the FSA in Section Add language to Section consistent with regulatory milestone tariff revisions re: regulatory milestone requirement prior to IA execution Other clarifying and ministerial edits (e.g., changing NYISO to ISO as appropriate, to be consistent with the rest of the OATT) Ministerial edits to Attachment P will be proposed after a FERC Order accepting the compliance filing that created Attachment P Proposed Effective Date: date of FERC Order 138

139 Other Clarifications and Updates Issue Nos : Ministerial and Other Edits, cont. Ministerial Edits to Attachment X Agreements In pro forma Interconnection Request form, add applicable requirements for solar and energy storage projects Streamline Interconnection Request form and eliminate the need for Developers to provide data unnecessary at the initial stage of the interconnection study process In pro forma Facilities Study Agreement, make the following revisions: Change Large Facility to facility as appropriate, to accommodate Small Generators and non-ferc jurisdictional interconnections that enter a Class Year only for CRIS Make the following edit to Article 6.5: Developer or NYISO may terminate this Agreement upon the withdrawal of the Developer s withdrawal project from the Interconnection Facilities Study pursuant to Section of Attachment S. In External CRIS FSA, revise winder to winter Delete Appx. G from the pro forma LGIA as it is no longer needed in light of Order No. 827 Proposed Effective Date: date of FERC Order 139

140 Other Clarifications and Updates Issue Nos : Ministerial and Other Edits, cont. Ministerial Edits to Attachment Z In Sections and , clarify baseline ERIS for project that doesn t go forward with part of project studied in the interconnection process Correct reference to FSA in Section to refer to the Class Year FSA, which is required for CRIS requests by Small Generators. Proposed Effective Date: date of FERC Order 140

141 The Mission of the New York Independent System Operator, in collaboration with its stakeholders, is to serve the public interest and provide benefits to consumers by: Maintaining and enhancing regional reliability Operating open, fair and competitive wholesale electricity markets Planning the power system for the future Providing factual information to policy makers, stakeholders and investors in the power system 141