NPRR703  Clarification of Disclosure Requirements for GINR Study Information

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.