Withdrawals
Do affected systems Network Upgrades count towards the 25%/100% upgrades increase clause in Section 3.7.1?
The applicable costs are only those identified in the Cluster Study or Restudy Report. Affected systems Network Upgrades are not captured in those studies and reports, so they are not included.
Study Costs & Deposits
How are actual study costs calculated?
Actual study costs are determined by the time spent to complete the cluster study. The study costs will be allocated to those in the cluster area pursuant to the ratio provided in LGIP section 13.3 of Idaho Power’s LGIP compliance filing.
Site Control
What is the definition of exclusive site control?
The definition of Site Control is included in Section 1 of Idaho Power’s compliance filing.
Do we need to have site control for our gen-tie?
Per FERC Order 2023 paragraph 604, site control demonstration applies only to the land needed for the Generating Facility and does not apply to interconnection facilities or gen-ties. The gen-tie site control will need to be obtained after LGIA execution during construction.
When does Idaho Power intend to issue for review its site control business practice?
Idaho Power has posted the site control business practice to the Idaho Power OASIS site.
What is the 90% threshold for site control for projects entering the initial cluster in 2025?
For future cluster studies not including the transitional study process, the 90% threshold is measured by the interconnection customer demonstrating exclusive site control for 90% of the minimum acreage requirements to site the size and fuel type of the generating facility that it is requesting to interconnect to Idaho Power’s transmission or distribution system. For the avoidance of doubt, the 90% threshold is not a measure of interconnection customer’s progress through a negotiation process for site control.
I am researching a site for a proposed project in Idaho, who should I reach out to for assistance and questions regarding energy and mineral information?
The Idaho Governor’s Office of Energy and Mineral Resources (OEMR) serves as the first point of contact for energy and mineral information in Idaho and can assist a proponent in identifying state agencies that may have regulatory and technical expertise over resources that may be affected by a proposed project. To help avoid or minimize potential unintended project effects, OEMR recommends that the proponent contact its staff for assistance identifying agencies and potential project issues early in the proponent’s planning process.
Modeling
Is a PSLF generic library RMS dynamic model sufficient for the application submission, or is a User Defined Dynamic Model (UDM) mandatory as well?
Attachment A to Appendix 1 of the LGIP states “Models for Non-Synchronous Generators” require both a validated user-defined root mean squared (RMS) positive sequence dynamics model (UDM) AND an appropriately parameterized generic library RMS positive sequence dynamics model, including model block diagram of the inverter control and plant control systems, as defined by the selection in Table 1 or a model otherwise approved by the Western Electricity Coordinating Council, that corresponds to Interconnection Customer’s Large Generating Facility.
Can the User Defined Dynamic Model (UDM) be submitted in PSSE format?
Yes, UDMs are acceptable in PSSE format.
Is the PSCAD electromagnetic transient model (ETM) required at the time of submission?
Given the likelihood of technological changes, Idaho Power has determined that the PSCAD model can be submitted at the Cluster Facility Study Phase, unless otherwise requested at an earlier date.
Where can I access Idaho Power’s Base Case Model?
Submit a request to the Generator Interconnection team to initiate a NDA request to be granted access to this program. Please be aware to provide consistent, accurate data free from conversion discrepancies, Idaho Power provides the Base Case Data in PowerWorld format; it will not be offered in other formats (including .raw).
How are models set up prior to running the analysis of projects prior to the Facilities Study?
Power flow analysis requires WECC base cases to reliably balance under peak load conditions the aggregate of generation in the local area, with the Generating Facility at full output, to the aggregate of the load in the Transmission Provider’s Transmission System. However, Idaho Power’s balancing authority area has proposed generation in the interconnection queue that far surpasses projected load. To reliably balance the power flow case, it is necessary to assume some portion of other resources are displaced by the current project(s) under study and that some generation is being transferred regionally through the transmission system in order to assess the impact of new interconnections. As part of an NRIS interconnection request Idaho Power will stress the powerflow case to represent the full utilization of pertinent WECC Paths. The path rating is, among other things, established based on the maximum amount of powerflow prior to a thermal or voltage issue. Please see WECC’s website for additional information on WECC Paths WECC – Western Electricity Coordinating Council.
Dates
When does the initial Cluster Request Window open?
Per Section 3.4.1 of Idaho Power’s LGIP, the Initial Cluster Request Window is proposed to open on March 1, 2025, and successive Cluster Request Windows shall open annually every March 1 thereafter. Please review the LGIP for the study timelines associated with the cluster study process following completion of the transition.
RFP Impacts
Is Idaho Power planning to conduct a resource solicitation cluster for projects that are successful in the 2026 RFP?
Idaho Power does not currently have any proposed processes that include a resource solicitation cluster.
General Communication
Do the Idaho and Oregon Public Utility Commissions need to approve this filing before it can be implemented?
The cluster study process required under FERC Order 2023 applies to FERC-jurisdictional projects that are processed under Attachment M of Idaho Power’s Open Access Transmission Tariff (OATT). Idaho Power’s OATT is not under state jurisdiction; therefore, Idaho Power does not need approval from the IPUC and/or OPUC to implement this FERC order for FERC-jurisdictional projects.
Transitional Cluster
When does the withdrawal penalty apply in the Transition Process?
Per Section 5.1.1, 5.1.1.1, and 5.1.1.2 of the LGIP and FERC Order 2023 paragraph 865, up until the execution of the Transitional Agreement, you have the opportunity to withdraw with no withdrawal penalty. Consistent with the definition of Transitional Withdrawal Penalty, a withdrawal penalty will be assessed for any project that withdraws, is deemed withdrawn, or otherwise does not reach commercial operation at any point after commencement of the Transitional Cluster Study.
Why is the withdrawal penalty for transition projects 9x actual study costs? Do the withdrawal costs in section 3.7 apply as well?
In Order 2023, FERC defined the withdrawal penalty for projects participating in the transitional study process as 9x the study costs. FERC states in paragraph 860 of the order that, “The withdrawal penalty plays an important role in deterring speculative interconnection requests in both the standard cluster study and the transition process. We disagree with commenters that call for a lower penalty to apply during the transition process, given that the risk of withdrawals is heightened during the transition process.” The withdrawal penalty of 9x the study cost—inclusive of all studies performed during both the serial and transitional processes—is the withdrawal penalty for projects that choose to proceed in the transitional study process; therefore, the withdrawal penalty calculations in section 3.7 do not apply to these projects.
Which Commercial Readiness deposits are required for the transition process?
Projects that enter the transitional cluster study are not subject to the commercial readiness deposits required under 7.5.1 and 8.1(3) because the transitional cluster study is a combined system impact and facilities study, so those sections do not apply. Per the final paragraph of Idaho Power’s compliance filing section 5.1.1.2, following receipt of the final transitional cluster study report, the interconnection customer shall proceed pursuant to section 11. Therefore, the deposit required in 11.3 is applicable to projects in the transitional study process.
What amount of this deposit is refundable if we withdraw after entering the transitional process?
Per Section 5.1.1.1 and Section 5.1.1.2, if the Interconnection Customer withdraws, or otherwise does not reach Commercial Operation, Transmission Provider shall refund the remaining deposit after the final invoice for study costs and Withdrawal Penalty is settled.
How will the actual study costs be deducted during the Transitional Process if a Letter of Credit is used as the required deposit?
If the deposit is in the form of a Letter of Credit, the projects will be invoiced monthly for the work performed.
Can we conduct a Limited Operations Study in conjunction with the Transitional Cluster Study?
A Limited Operations Study may be requested at the time the draft final Transitional Cluster Study Report is issued, i.e., 360 Calendar Days after the Commission Approved Effective Date.
Can a project entering the Transition Study Process satisfy Site Control via a deposit in situations where the IC can demonstrate that Site Control is unobtainable due to regulatory limitations?
While the Order and Idaho Power’s compliance filing include language regarding regulatory limitations, such regulatory limitations would not be available to Interconnection Customers until the initial cluster study that would commence following completion of the transitional study process. FERC has stated that the transitional study process requires 100% site control for proposed generating facilities to ‘provide further assurance that such interconnection customers are ready to proceed to construction’ (Order 2023 paragraph 870).
When did you communicate this compliance filing? Why weren’t we directly notified when it was submitted?
Idaho Power submitted its compliance filing with FERC Order 2023 on October 2, 2023, and posted to OASIS and to the Generation Interconnection website notice of the compliance filing on October 2, 2023, to meet the requirement to provide notice to all interconnection customers simultaneously and in the same manner. Per Idaho Power’s standards of conduct, we are unable to notify individual interconnection customers of the filing outside of the public postings to avoid actual or perceived preferential treatment.
What are the benefits of entering the Transition Process over waiting for the initial cluster process?
Idaho Power cannot speak to the benefits of entering into the transitional cluster study as opposed to waiting to enter the initial cluster in 2025; the pros and cons of each are unique to each project and are up to the interconnection customer to define for themselves.
Will Idaho Power include the suspended projects in the Transition Cluster Steady-State Study?
Yes, suspended projects are included.
Additional FAQs
Where can I find detailed information on the current status of the queue?
Please visit Idaho Power’s OASIS; there you can view our Generation Interconnection Queue and sort by the active projects’ size, fuel type, and Point of Interconnection.
Can I increase/decrease the electrical output (MW) as a modification during the Transition Process?
As per Section 4.4.1 of the LGIP of FERC Order 2023, prior to the execution of the Transitional Cluster Study Agreement, a decrease of up to 60% of electrical output (MW) of the proposed project, through either a decrease in plant size or a decrease in Interconnection Service level will be allowed. As per Section 4.4.2, prior to the execution of the Transitional Facilities Study Agreement, a decrease of up to 15% of electrical output of the proposed project through either a decrease in plant size or a decrease in Interconnection Service level will be allowed. As per Section 4.4.1, for any increase in electrical output, these will be considered as a new application and thus can be submitted during the next Cluster Study Window.
Will Gateway West be open to submit an Interconnection Request to starting in 2025? Additionally, which entity will serve as the Transmission Provider for this line to submit applications to, Idaho Power or another utility?
As of now, the project is not yet far enough along for us to be able to provide the answers to this question. The ownership arrangements are still being determined which would determine the answers to this question.
Will SWIP-North be open to submit an Interconnection Request starting in 2025? Additionally, which entity will serve as the Transmission Provider for this line to submit applications to, Idaho Power or another utility?
Idaho Power is not accepting Interconnection Requests for the SWIP-North at this time. Updates will be publicly posted on OASIS once the area becomes available.