1. PLWG Review 6.9 and the Interconnection process

2. ROS Directive:
“Direct PLWG to review 6.9 and the Interconnection process and recommend PG changes or other appropriate action”
Source: Brittney Albracht notes from March 3, 2016 ROS Meeting

3. Planning Guide Section 6.9 Review

4. Current Requirements of Section 6.9(1)

5. Exploring Possible Solutions to address these concerns
Modify the RARF data requirement in PG Section 6.9 and use “preliminary” RARF data for modeling purposes for modeling in the SSWG cases
Review data requirements needed for modeling in the DWG and SPWG cases
Modify the outreach effort in order to help educate IE’s in importance of timely RARF submittals and clarify the data requirement is for ‘As Planned’ at this stage.

6. New Language Proposal for PG 6.9 (1)
6.9 Addition of Proposed Generation Resources to the Planning Models
(1) ERCOT will include a proposed Generation Resource in the base cases created and maintained by the Steady State Working Group (SSWG), the System Protection Working Group (SPWG), and the Dynamics Working Group (DWG), once each of the following has occurred:
The Interconnecting Entity (IE) provides all data required in the Resource Registration Glossary Screening Study (FIS if available);
(b) – (d) Unchanged
Add New Bullet (2)
(2) Upon meeting the requirements of 6.9 (1), the IE shall provide the required data with 60 days for modeling the proposed Generation Resource in the bases cases created and maintained by the System Protection Working Group (SPWG) and the Dynamics Working Group (DWG), as requested by ERCOT as well as the remaining data for SSWG.
Renumber current (2) to new (3)
Notwithstanding paragraph (1) of this Section, ERCOT will not require an IE proposing to interconnect a Generation Resource powered by wind or photovoltaic solar energy to provide notification of receiving an air permit or a Declaration of Adequate Water Supplies as a condition for including the Generation Resource in the base cases described in paragraph (1). However, ERCOT will not include such a Generation Resource in the base cases unless the IE has provided all data required by Paragraph (1)(a) and an agreement or letter as described in Paragraph (1)(d).
Delete redundant language in current (3)
(3) The IE shall provide to ERCOT the data necessary to model the Generation Resource in the base cases created and maintained by SSWG, SPWG, and the DWG, as directed by ERCOT.
(4) Once the IE has met these requirements, ERCOT will notify the SSWG, SPWG, and the DWG, and the proposed Generation Resource will be included in the base cases created and maintained by these working groups.
Consider adding PG 6.9 must be met before resource registration RARF will be accepted.

7. Additional Steps
Have DWG and SPWG determined the necessary modeling data in order to incorporate the proposed Generation Resource in the DWG and SPWG cases
Modify the outreach effort to notify the IE of meeting PG 6.9(1) and send a data request basis of the step above. Ensure the data request clearly communicates that the required data is ‘as planned’ data.

8. Review the Interconnection process and recommend PG changes or other appropriate action

9. PG Section 5 Review and Discussion Possible changes to interconnection process
5.5.1 Standard Generation Interconnection Agreement
(2) Before an SGIA is signed, all studies included in the FIS scope must be completed, unless mutually agreed by the IE and the TSP . In the event the IE and the TSP agree to sign an SGIA prior to the completion of all studies  included in the FIS scope, the TSP shall notify ERCOT. The IE and TSP must meet and maintain compliance with all North American Electric Reliability Corporation (NERC) Reliability Standards, Protocols, and the requirements of this Planning Guide and the Operating Guides concerning interconnection.
Why does TSP agree to this?
Why does IE agree to this?
Is RARF used for IE data submittal to TSP for FIS?

10. PG Section 5 Review and Discussion Possible changes to interconnection process
5.7.1 Generation Resource Data Requirements
 (4) While the duty to update data may require additional information, at a minimum, the IE shall submit the following data and information to be provided to ERCOT at each step of the process:
Application and Security Screening Study …
FIS …
Meeting PG 6.9(1) (new section)
Add requirement to submit remaining planning data within 60 days of meeting PG 6.9(1)
Add meeting PG 6.9 required for resource registration RARF to be accepted. The reason for this is that there is a requirement to go into the planning model but no similar requirement for entry into the Network Operations Model.
Prior to start of construction

11. PG Section 5 Review and Discussion Possible changes to interconnection process
5.1 Introduction
Provide accurate initial  data about the proposed Generation Resource to ERCOT to ensure that ERCOT and stakeholders have the information necessary for planning purposes.
5.3.1 Full Interconnection Study Submission Requirements
(7) The planning submissions of the Resource Registration data  are considered planning data and shall accurately  reflect the design of the facility. Please note this process does not satisfy the Resource Registration submissions requirements contained in the Protocols, but the use of this format is intended to facilitate the preparation of the data required for that process and the continuity of data between the interconnection study process and the data submitted for Resource Registration. 
 Sync with NOG 5.1 and mention representative data is allowed (next slide)

12. PG Section 5 Review and Discussion Possible changes to interconnection process
 NOG 5.1
5.1 System Modeling Information
(d) Typical or representative information may be provided for planned facility additions or modifications for use in the SSWG, DWG, and SPWG base cases, but such information shall be revised using actual design or construction information in accordance with the time line for Network Operations Model changes outlined in Protocol Section , Time Line for Network Operations Model Changes.

13. PG Section 5 Review and Discussion Possible changes to interconnection process
5.3.2 Modifications to Request Declarations of Resource Data Accuracy
(6) Within ten Business Days, the IE shall notify  ERCOT and the relevant TSP(s) of any change in ownership and shall provide conclusive documentary evidence of the ownership change (such as a purchase/sale agreement or a document executed by both parties confirming the transaction).
Add failure to notify could delay project energization.

14. NP Section 16.5 Review and Discussion Possible changes to interconnection process
16.5 Registration of a Resource Entity
(3) Following ERCOT’s receipt of a new or amended Standard Generation Interconnection Agreement (SGIA) or a letter from a duly authorized official from the Municipally Owned Utility (MOU) or Electric Cooperative (EC), ERCOT shall review the description of the proposed All-Inclusive Generation Resource in Exhibit “C” (or similar exhibit) to the SGIA and the data submitted pursuant to Planning Guide Section 6.8.2, to assess whether the Resource, as proposed, would violate any operational standards established in the Protocols, Planning Guide, Nodal Operating Guides, and Other Binding Documents. ERCOT must provide its determination to the Transmission Service Provider (TSP) and the owner of the proposed Resource within 60 days of the date ERCOT receives the new or amended SGIA or letter from a duly authorized official from the MOU or EC.
Issue: If FIS not complete before SGIA, this review triggered by SGIA
Results in many reviews having “Pending”, “Almost”, “Fail”, “TBA”, “Incomplete”, “Missing” items in checklist

15. Questions