PROPOSED RULES FOR ENERGY STORAGE RESOURCES IN GENERATOR INTERCONNECTION STUDIES GI Improvement Task Force

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PROPOSED RULES FOR ENERGY STORAGE RESOURCES IN GENERATOR INTERCONNECTION STUDIES Published October 19, 2018 By SPP

REVISION HISTORY DATE OR VERSION NUMBER AUTHOR CHANGE DESCRIPTION COMMENTS September 19, 2018 SPP GI Dept. Initial Draft September 26, 2018 GIITF Amended pursuant to discussion. Approved. October 16, 2018 SPP GI Dept. Approved by MOPC.

CONTENTS 1 Purpose... 1 2 Background... 2 3 Proposed Rules... 3 3.1 Applicability... 3 3.2 Process... 3 3.2.1 Discharge Mode... 3 3.2.2 Charge Mode... 3

1 PURPOSE This document describes proposed rules for processing and evaluating interconnection requests for energy storage resources ( ESRs ) under SPP s Generator Interconnection Procedures ( GIP ). This proposal was developed by the Generator Interconnection Improvement Task Force ( GIITF ) in response to its mandate to address new requirements arising from FERC rulemaking initiatives. The GIITF was created by and reports to the Markets and Operations Policy Committee (MOPC) of SPP. The purpose of this document is (a) to document and explain in sufficient detail the recommended rules to the MOPC for its ultimate approval, (b) to provide guidance for those drafting and reviewing applicable governing document language necessary to implement the recommendations, and (c) to provide general information to interested stakeholders wishing to understand the recommendations in more detail. If this document does not identify a change to an existing provision of the GIP, then those provisions should be considered to remain unchanged, unless modified by an independent recommendation or separate revision effort. When unspecified, days refers to calendar days. If not otherwise defined in this document, capitalized terms have the definition contained in the SPP tariff. Proposed ESR Rules for GI 1

2 BACKGROUND In Order 845, FERC changed the definition of Generating Facility to include devices for the production and/or storage for later injection of electricity identified in the Interconnection Request. SPP has seen increased interest in energy storage resources in its queue requests and through customer inquiries. Order 841, although focused on treatment of energy storage resources in the market, has raised the profile and interest in storage resources generally. SPP s current tariff and business practices do not address some of the unique aspects of storage that may require clarification. Proposed ESR Rules for GI 2

3 PROPOSED RULES 3.1 APPLICABILITY A request to interconnect an ESR to the SPP Transmission System shall be treated as an Interconnection Request under the GIP. A request to add an ESR to an existing Generating Facility may be made as a new request for Interconnection Service or as a new request for Surplus Interconnection Service. 3.2 PROCESS ESRs will be evaluated for reliability impacts to the SPP Transmission System in both discharging mode (as a generator) and charging mode (as a load). The evaluation of both modes of operation will be conducted as part of the applicable Interconnection Study under the GIP. The application will accommodate the specific needs of ESR requests. 3.2.1 DISCHARGE MODE When evaluating the interconnection of an ESR as a generator, the ESR will be dispatched in the GI cluster study models in the following ways: Steady-State Power Flow Analysis As an Energy Resource in the high variable energy resource (HVER) cases When Network Resource Interconnection Service (NRIS) is requested, in the NR cases. In all seasons at 100% of requested capacity. Dynamic Simulation In the same way as other non-storage resources. Short-Circuit Analysis As a source with characteristic impedance of the device. 3.2.2 CHARGE MODE Evaluation of the ESR in charging mode will be conducted as follows: The load will be modeled in the latest ITPNT Base Reliability model set, and a contingency scan will be performed. Thermal and voltage impacts will be identified in accordance with NERC TPL requirements. Seasons evaluated will include Year 1 or 2 system peak and off-peak, Year 5 system peak and offpeak, and Year 10 system peak. The additional load will be supplied following the rules for generation shortfall specified in the MDWG manual. The charging capacity may be specified less than the nameplate capacity. The evaluation of the impact of the ESR in charging mode may be waived if the application meets these requirements: Proposed ESR Rules for GI 3

The application for interconnection service stipulates that the Generating Facility will never take energy from the Transmission System when operating in charging mode, by either Self-Dispatch or at the direction of SPP. The application for interconnection service includes a description of the monitoring and control equipment that will be used to ensure that the Generating Facility never takes energy from the Transmission System when operating in charging mode. Normal auxiliary load required solely for the operation of the ESR is exempted from this requirement. Proposed ESR Rules for GI 4