Hello, Cindy -
Here are a few short
comments from the California Wind Energy Association (CalWEA) on the latest ISO
Location-Constrained Resource Interconnection Facility (LCRIF)
proposal.
We are encouraged, based on
the conference call last Friday, that the ISO has apparently adopted many
of our earlier suggestions, listed below, though we recommend that
you state them more clearly and explicitly in the upcoming
tariff-language proposal:
> Ability of parties to
submit problems needing investigation, or more general solutions, in the
transmission-planning Open Season process, rather then full-blown LCRIF
proposals;
> Requirement that LCRIF
proponents study transmission alternatives (at least 3
recommended);
> Provision that the ISO
will include potential Network Upgrade alternatives in its assessment of LCRIF
proposals, if the proponent has not thoroughly studied such altermatives;
and
> Ability of projects in out-of-state areas (and in-state areas currently outside the
ISO Control Area) to qualify for LCRIF treatment as long as their first
interconnection point with the electricity grid is an ISO-controlled
facility.
We also support your stated
intention to examine all likely generation projectsin the area in sizing and designing LCRIFs; this will ensure that the most rational
project is built and prevent location-constrained generation from being
displaced by other local projects afterwards. That requirement should also
be reflected in proposed tariff language.
Finally, we encourage the ISO to preserve its ability to
consider LCRIFs in areas outside state-designated ERAs that meet the other
criteria and are found to be the optimal interconnection method, e.g., where an
ISO cluster study indicates that this would be the least-cost
interconnection and/or where one of the two state agencies favors an ERA
designation but the other does not. You could provide that Board approval
would be required, as in the the pre-ERA interim methodology. We
understand that you would need to investigate why the area wasn't designated as
an ERA in determining whether an LCRIF is warranted, but it does not seem wise
to curtail the ISO's discretion where it believes that a project is otherwise
worthy.
Thank you for the
opportunity to offer these comments - please call me with any
questions.
- Susan Schneider
Phoenix Consulting
(916) 804-9514