Several wind generation developers came together to protest proposed tariff revisions that the Southwest Power Pool Inc. had submitted to initiate a FERC docket. EDF Renewable Energy Inc., EDP Renewables North America LLC, E.ON Climate & Renewables North America LLC and Enel Green Power North America Inc. filed the protest on July 21 with FERC.
The developers are members of the American Wind Energy Association and the Wind Coalition, which are submitting joint comments in the same docket. The developers said they support the AWEA/TWC comments and urge the commission to grant the relief they request.
They wrote: “Wind Generation Developers file this Protest to identify further items that bear directly on SPP performing a just and reasonable integrated transmission planning process, but are not addressed in its proposed Tariff revisions.The items we discuss herein should be additions to SPP’s Tariff and should not be relegated to SPP’s ITP Manual. The items we discuss herein bear directly on whether SPP is performing just and reasonable transmission planning and transmission development and thus directly on whether SPP’s resulting rates for transmission service and energy are just and reasonable.”
This protest filing had its genesis in Docket No. ER17-300, where SPP asked the commission to waive the tariff requirement for SPP to engage in the next successive ITP-20 because SPP intended to revamp how it plans for transmission.
The developers, through AWEA and TWC, said they supported the need to revise how transmission is planned, but urged that the proper course of action should be for SPP to seek a waiver to perform ITP-20 in January 2017 so it may perform ITP-10 in its place.
ITP-20 determines system needs 20 years out, focuses on extra-high voltage transmission solutions and includes an assessment of economic upgrade needs, the developers noted. On the other hand, ITP-10 identifies system needs over a 10-year period, focuses on facilities 100 kV and above and includes an assessment of economic, reliability and public policy upgrade needs.
The commission had previously granted SPP a waiver in 2014 to not perform the regularly scheduled ITP-20 and instead advanced the performance of ITP-10. The results of that advanced ITP-10 were scheduled to be provided in January 2017.
AWEA and TWC explained that there was a vital need for SPP to immediately perform another ITP-10 so its assessment of the need for economic upgrades on the SPP grid would not go unaddressed for the next several years, the developers added. The commission granted SPP’s request to forgo the ITP-20 and did not heed AWEA and TWC’s request for SPP to perform an ITP-10 while it decides how to revamp its ITP process.
The developers wrote further: “Thus, SPP has not undertaken any economic and public policy long-term transmission planning since its last study was concluded earlier this year. Moreover, it is our understanding that some of the assumptions used to formulate that ITP-10 were not realistic in many respects (see discussion below), thus leading to insufficient results. Further, SPP has approved very little new transmission (and especially for economic needs) from its ITP process in the last several years and the amount continues to decline.”
They added: “$58 million in economic upgrades for the entire SPP region was approved in the most recent ITP-10. This amount of approved transmission for economic upgrades is dwarfed by what other neighboring RTO are doing. Yet, conditions on SPP’s grid demonstrate a severe need. Because these studies underestimated wind development, SPP has not properly examined the impact of the changing grid and thus has not adequately assessed the negative impact to consumers of failing to build transmission.
“With the submission in this docket, if SPP adheres to its proposed timetable, it will not complete its next review of economic and public policy needs until sometime in 2019, after which it will then be years for approved transmission projects to be completed. This is a significant gap. This means SPP’s grid will continue to experience unnecessary congestion and curtailment for many years into the future that is costly to consumers. At the end of March 2017, SPP had close to 37 GW of wind projects in various stages of development.
“SPP is in a unique position to integrate low-cost wind to benefit consumers, but significant transmission build is needed. (SPP’s Tariff has “stop gap” means that the Board can use in the interim by directing High Priority Studies for ‘one-off transmission solutions,’ but it is uncertain whether that will occur.)
“Given the gap that exists and the severe need, it is imperative that the next ITP process and study be sufficiently robust and study all appropriate needs. That will not occur with the Tariff submission that SPP has submitted in this docket. There are vital details that are missing and if not hard-coded into SPP’s Tariff, will result in an under-planned grid. SPP proposes to list these details in its ITP Manual. The issues that AWEA and TWC present in their comments and the issues we address below need to be in SPP’s Tariff, not in the ITP Manual. Indeed, there is not even a guarantee that SPP will follow-though and include these issues in its ITP Manual or if they are included, that they will be defined and applied reasonably. These issues are too important to have them hide in SPP’s ITP Manual with no Commission review.”