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NPRR703

Summary

Title: Clarification of Disclosure Requirements for GINR Study Information
Next Group:
Next Step:
Status: Approved on 08/11/2015
Effective Dates:
12/10/2015

Action

Date Gov Body Action Taken Next Steps
08/11/2015 BOARD Approved
07/30/2015 TAC Recommended for Approval Revision Request Consideration
07/16/2015 PRS Recommended for Approval Revision Request Consideration
06/11/2015 PRS Recommended for Approval Impact Analysis Consideration
05/14/2015 PRS Deferred/Tabled Language Consideration

Voting Record

Date Gov Body Motion Result
08/11/2015 BOARD To approve NPRR703 as recommended by TAC in the 7/30/15 TAC Report. Passed
07/30/2015 TAC To recommend approval of NPRR703 as recommended by PRS in the 7/16/15 PRS Report. Passed
07/16/2015 PRS To endorse and forward to TAC the 6/11/15 PRS Report and Impact Analysis for NPRR703. Passed
06/11/2015 PRS To recommend approval of NPRR703 as amended by the 5/13/15 CenterPoint Energy comments. Passed
05/14/2015 PRS To table NPRR703 and refer the issue to ROS. Passed

Vote tallies here reflect individual votes, not the weight of the votes by market segment. Affirmative votes are not recorded in these vote tallies. For additional details on the voting record, please consult the Recommendation or Action Report, or the official vote tally if available, as posted in the key documents.

Background

Status: Approved
Date Posted: Apr 29, 2015
Sponsor: ERCOT
Urgent: No
Sections: 1.3.1.1, 1.3.1.2, 1.3.3, 2.1, 2.2
Description: As part of the process of interconnecting a new All-Inclusive Generation Resource, Interconnecting Entities are required to obtain a Full Interconnection Study (FIS) from the interconnecting Transmission Service Provider (TSP). The FIS typically includes a dynamic and transient stability study (“stability study”) and may include a subsynchronous oscillation (SSO) study. Stability studies and SSO studies often contain data and descriptions of unique generator characteristics that may credibly be considered “Resource-specific . . . design [or] engineering data” under paragraph (m) of Protocols Section 1.3.1.1, Items Considered Protected Information, and thus protected from disclosure. However, paragraph (l) in this same section provides that the “Protected Information status of [information related to generation interconnection requests] shall expire when the generation interconnection agreement is executed or a financial arrangement for transmission construction is completed with a [TSP]”). Given the unclear interplay of these two provisions, ERCOT submits this Nodal Protocol Revision Request (NPRR) and an associated Planning Guide Revision Request (PGRR) to clarify ERCOT’s disclosure obligations concerning FIS studies. Until recently, ERCOT’s practice had been to post all generator interconnection study information (including the FIS and the initial Resource Asset Registration Form) to the Planning and Operations Information website, which was accessible by any entity that had been granted access to the site. However, in October 2014, ERCOT decommissioned this website and, pursuant to new Section 7.1 of the Planning Guide, began posting generator interconnection information only to the Market Information System (MIS) Certified Area for each TSP. While the use of the MIS has given ERCOT the ability to precisely control access to generation interconnection information, some Market Participants have expressed concerns about these restrictions. A number of developers and consultants have raised a concern that the more limited availablility of FIS studies impedes their ability to evaluate potential project locations. Additionally, some participants at the April 23, 2015 meeting of the Congestion Management Working Group (CMWG) expressed concerns that withholding broader access to FIS studies might give Interconnecting Entities an unfair market advantage if those studies provide information that has not already been made public. Given these concerns, ERCOT recognizes a need for prompt stakeholder discussion of this issue so that the appropriate scope of disclosure can be determined as soon as possible. As proposed, this NPRR would allow disclosure of all FIS studies except stability studies and SSO studies. However, ERCOT understands that stakeholders may ultimately have a different view of this issue and that there may be other ways to safeguard this information short of restricting all public access to these studies. ERCOT therefore requests its stakeholders’ thoughtful and candid input on this proposal. Additionally, this NPRR proposes revisions to Sections 1.3.1.1(5), 1.3.1.2(3), and 1.3.3(5) to eliminate inconsistency and reduce duplication of language. This NPRR also proposes a definition of “Full Interconnection Study.” Finally, this NPRR proposes revisions to Section 1.3.3(4)—regarding information to be posted after an FIS is requested—to clarify that the information should be posted to the MIS Public Area rather than the MIS Certified Area.
Reason: Regulatory requirements and enhancements to Market efficiencies.

Key Documents

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