Addressing Concerns in Rule 21 NEM Interconnection
Resolving technical and operational gaps in Rule 21 Large-Scale Net Energy Metering projects for improved coordination, visibility, and controllability. Issues include lack of required coordination, gaps in technical requirements, and visibility and controllability challenges in system and market operations.
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Presentation Transcript
Rule 21 Interconnection Discussion Forum Large-Scale Net Energy Metering Rule 21 Interconnection Projects BA Concerns Jeffrey Billinton Director, Transmission Infrastructure Planning Jill Powers Infrastructure & Regulatory Policy Manager June 24, 2020 CAISO PUBLIC CAISO PUBLIC
Concerns: Planning/Technical Interconnection/Operational CAISO PUBLIC CAISO PUBLIC
Planning Concerns/Issues Concerns with current lack of required coordination on large- scale NEM projects during study process 1. Currently no obligation to be notified of projects studied under Rule 21 interconnection 2. No tariff obligation to share study results to ensure system will see no harm from interconnection. 3. CAISO unable to advise or inform PTOs on the studies until they are complete or until NEM generation is operational 4. Lack of participation within CAISO coordination regarding affected systems CAISO PUBLIC Page 3
Technical Interconnection Concerns/Issues Gaps between CAISO s Generator Interconnection Agreements (GIA) and Rule 21 Interconnection Agreements 1. NEM generators would not be subject to CAISO GIAs o Although transmission-connected o Potential for large capacity generation on transmission system 2. Not subject to CAISO s requirements for inverter-based resources : o Frequency ride-through and loss of synchronism o Voltage control and reactive current requirements o Voltage ride-through and momentary cessation ride-through requirements o Diagnostic equipment and data retention requirements o Anti-islanding provisions o Plant controller/inverter control coordination 3. Potential additional technical requirement gaps with these projects interconnecting under Rule 21 CAISO PUBLIC Page 4
System and Market Operation Concerns/Issues Lack of visibility and controllability of real-time operation of the NEM generator and exported generation 1. NEM generators would not be subject to CAISO Resource Interconnection or New Resource Implementation (NRI) processes o Are not identified in the Resource Interconnection Management System (RIMS) 2. Not subject to CAISO s telemetry or metering requirements for operational visibility or situational awareness of large capacity generator 3. Unknown level of NEM generation controllability (if needed) o BA-to-TOP communication needed if shutdown required 4. Unable to forecast generation or its impact 5. Inability to model appropriately o Load or gen? At what value? 6. Impact of daily dynamic operation of NEM generator to transmission reliability and market operations CAISO PUBLIC Page 5
Resolving current Rule 21 NEM interconnection technical gaps Apply applicable interconnection and operational requirements based on voltage level of the interconnection Opportunity exists to align IEEE 1547 (2018) requirements being adopted with what is in best interest of the grid, both transmission and distribution CAISO PUBLIC Page 6
