Earlier, FERC approved Southwest Power Pool (SPP)’s High Impact Large Load (HILL) Proposal. The proposal defined HILLs as new loads of 50 megawatts (MW) or more interconnected about 69kV, or 10 MW interconnected at 69kV or lower, and created “enhanced” study requirements for the HILLs, detailed in SPP’s new Tariff attachment BA. 

More interestingly, SPP added a new generator interconnection service called “HILLGA.” This process is in addition to the Definitive Interconnection System Impact Study (DISIS) Process. The HILLGA process allows for generators associated with a HILL to apply for interconnection using the HILLGA process. Generators must be located no more than two substations away from the HILL associated with and are capped at the requested MW load amount of the associated HILL. SPP will accept HILLGA requests at any time, including while a generator is proceeding through the DISIS Process. HILLGA requests must include: 

1. Executed HILLGA Study Agreement and HILL Delivery Point Study (HDPS) Agreement
2. $20,000 application fee
3. Study Deposit
   1. $250,000 for requests up to 500 MW
   2. $500,000 for requests greater than 500 MW
4. Demonstration of Site Control
5. Definitive Point of Interconnection (POI)
6. Defined resource traits
   1. Nameplate Capacity
   2. Maximum Injection capability
   3. Network resource deliverability of the generation facility
7. Security Deposit equal to $8,000/MW of the requested Max. Injection Capability
8. Evidence of satisfaction of development milestones, for example, applications for land use permits, presence in a state resource plan, executed contracts,
9. Other applicable information depending on facility type. 

All proposed HILLGAs must be proposed to be operational within 5 years of the execution date of the HILLGA study agreement. HILLGA Customers can support multiple HILLs assuming there are “no more than 5 substations” involved 

Under the HILLGA process, SPP studies whether any network upgrades are needed to accommodate the generator’s injection into the local area and post the system impact study report in90 calendar days. SPP will send a HILL Generator Interconnection Agreement (HILLGIA) to the HILLGA Customer at the same time it creates the system impact study report. 

The “Secret Sauce,” as Commissioner David Rosner calls it, of SPP’s proposal is the interconnection service offered, called the “Load Limited Resource Interconnection Service (LLRIS)program. LLRIS allows the maximum economic capacity operating limits of the HILLGA Generating facility not exceeding the hourly load forecast value of the supported HILL, except when directed by SPP for reliability or as otherwise specified in the HILLGIA. After 5 years, the HILLGIA will terminate and also terminate LLRIS, at which time the generation must interconnect through the DISIS program. 

The HILL and HILLGA Requirements are located in the newly created Attachments BA and BB of the SPP Open Access Transmission Tariff (OATT).

Please contact me if you have any questions about SPP’s proposal or potential future tariff and business practice modifications.