2024-INT 00011 Published On: 09/06/2024
Question: Understanding that FERC jurisdictional projects (80MW+) will be allowed to submit into the RFP via the UOT bid track only, will this also mean that FERC jurisdictional projects (80MW+) would be allowed to submit for an interconnection queue position during this RSC window?
Answer: No, the Resource Solicitation Cluster is open for Solar and Solar plus Storage projects participating in the 2024 RFP. The next opportunity to participate in the Definitive Interconnection System Impact Study (DISIS) begins January 1, 2025.
2024-INT 00010 Published On: 08/22/2024
Question: For FERC-Jurisdictional IRs, is there a requirement for ERIS vs NRIS? And if we choose NRIS on the IR, will there be a chance to switch to ERIS after Phase 1?
Answer: ERIS and NRIS are terms that are only applicable to the FERC-Jurisdictional generator interconnection study process. Market Participants submitting FERC-Jurisdictional bids (UOT only) into the 2024 RFP are required to request NRIS (Network Resource Interconnection Service) to deliver their full capacity and energy output to serve native load customers. The Large Generator Interconnection Procedures allow for a FERC customer to request both NRIS and ERIS studies, but the FERC-jurisdictional UOT winner(s) that proceed in the RSC and RFP will be required to have NRIS service.
2024-INT 00009 Published On: 08/09/2024
Question: Are Asset Transfer Proposals that are also bidding into the PPA track the only Asset Transfer projects that can submit State-Jurisdictional interconnection requests? Or could an Asset Transfer Proposal that is not also bidding into the PPA track follow the same path of going through the whole State-Jurisdictional process, terminating the State-Jurisdictional Interconnection Agreement, and then executing an LGIA?
Answer: Pursuant to Section IV.B of the RFP, PPA Track proposals must be sized over 20 MWac in DEC or over 40 MWac in DEP and up to and including 80 MWac, among other things. If a project is bidding a proposal into both the UOT Track and the PPA Track, and the project size is therefore between 20-80 MWac, the interconnection request (IR) submitted should be a state jurisdictional IR. Pursuant to Section IV.A of the RFP, projects bidding UOT-Track only and not also PPA Track must have a FERC-jurisdictional interconnection request under the Companies’ FERC Joint OATT Attachment K Large Generator Interconnection Procedures.
2024-INT 00008 Published On: 08/09/2024
Question: If an Asset Transfer Proposal were to be selected with a State-Jurisdictional IR, would the Market Participant be able to terminate the associated State-Jurisdictional Interconnection Agreement and execute the necessary LGIA without going through a re-study? Can you explain the process of converting the State-Jurisdictional IA to an LGIA?
Answer: If an Asset Transfer Proposal were to be selected with a State-Jurisdictional IR, the Market Participant would first work with the Utility Ownership Team to execute a letter of intent, followed by the definitive agreement (Asset Purchase Agreement (“APA”)). Then per the APA, the Market Participant is responsible for completing all interconnection studies and execution of an interconnection agreement (“IA”). The Market Participant will execute a State-Jurisdictional IA, which coinciding with closing under the APA, will be terminated and the Market Participate will execute a FERC-Jurisdictional IA. The FERC IA is then assigned to DEC or DEP at APA closing. The conversion of a State-IA to a FERC-IA must be commensurate with the sale of the project assets to the utility and is highly coordinated between the Renewable Integration Team, the Utility Ownership Team and the Market Participant. The Renewable Integration Team is the best resource for questions related to the interconnection agreement.
2024-INT 00007 Published On: 07/23/2024
Question: We reviewed the recently posted Locational Guidance document, which was very helpful. In the document, Duke stated that any additional generation in the Brunswick County region would cause additional, unacceptable limitations in the operation of the Brunswick nuclear generators. Moreover, the transmission solutions to fix these limitations would cost +$100 million. Can you confirm a rough radius of this region? If projects are +50 miles away, would they still trigger these upgrades?
Answer: The Brunswick limitation is for new generation connected directly to any of the 8 transmission lines connected to / coming out of Brunswick Plant. It is not a mileage radius around the plant.
2024-INT 00006 (revised 07/24/2024) Published On: 07/23/2024
Question: The 2024 RFP is scheduled to extend past Duke Energy's FERC O2023-A compliance filing effective date i.e. 11/1/2025. Will this RSC process be affected by these planned tariff changes? What are the changes expected for this RSC process?
Answer: If FERC approves the Order 2023-A Compliance filing with effective date 11/1/2025, FERC interconnection customers would have 60 days to comply with the order. If the 2024 Resource Solicitation Cluster (RSC) follows the same schedule as the 2023 RSC and a Phase 3 restudy is not required, then the 2024 RSC Phase 2 study would likely end in early November, 2025. The readiness requirements to move to Facilities Study would therefore be administered pursuant to the new Large Generator Interconnection Procedures (LGIP) effective 11/1/2025. The Order 2023-A Compliance filing includes a readiness requirement of 15% of the facility’s assigned Network Upgrade costs in order to move to the Facilities Study phase in the form of an irrevocable letter of credit, cash, a surety bond, or other form of security that is reasonably acceptable to Duke Energy. This financial readiness requirement is based upon a different calculation than the calculation included in the currently-effective LGIP.
2024-INT 00005 Published On: 06/27/2024
Question: If an MP is bidding SPS into the 2024 RFP, should they submit a Solar-Only interconnection request to the RSC including the SPS configuration documents (SLDs, site layouts, etc.) as attachments, or should they submit an SPS interconnection request including the Solar-Only configuration documents as attachments?
Answer: The MP should submit an SPS Interconnection Request during the Open Enrollment Window into the Resource Solicitation Cluster (RSC). The Interconnection Request submitted into the RSC must be for one generating facility and the facility can elect to bid as both solar only and SPS. One facility cannot bid multiple solar only and multiple SPS sizes or configurations. For additional information related to submitting an Interconnection Request in the RSC, please see Appendix O, Section I – “New Interconnection Request during 2024 RSC Bid Window”.
2024-INT 00004 Published On: 06/03/2024
Question: Will projects with an interconnection agreement from a previous DISIS be able to participate [in the 2024 RFP] without participating in the resource solicitation cluster? Or is the RSC required for all participants regardless of Interconnection status?
Answer: For eligibility requirements for the 2024 RFP, please see Section V. RFP Process, D. 2024 RFP-Specific Resource Solicitation Cluster of the RFP document, available at www.dukeenergyrfpcarolinas.com/2024-RFP-Documents.
2024-INT 00003 Published On: 05/20/2024
Question: In the 2024 draft RFP, under section B. Requirements specific to Solar Only Facilities, part (a) states that a project qualifies for the RFP if it has a “fully executed Interconnection Agreement with DEC or DEP and have participated in the serial interconnection study process.” Since a DISIS has been completed and projects might have an IA executed under that process, will the 2024 RFP amend the current language to include projects from earlier DISIS processes?
Answer: The Companies are not accepting projects in the 2024 RFP that have an executed Interconnection Agreement under a prior cluster study process.
2024-INT 00002 Published On: 04/19/2024
Question: Can you please confirm that projects planning to participate in the upcoming 2024 RFP and associated RSC should not enter into DISIS at this time?
Answer: Projects that plan to participate in the upcoming 2024 RFP will be required to participate in the 2024 Resource Solicitation Cluster (opening in August) and not the 2024 DISIS.
2024-INT 00001 Published On: 04/19/2024
Question: In the upcoming 2024 RFP if my project is selected as a finalist, but the RSC Phase 1 report indicates it would not able to reach commercial operation until after the RFP’s target time (presumably 11/30/2029), can my proposal decline the offer and have our proposal security refunded?
Answer: As currently contemplated, the Commercial Operation Date for 2024 RFP Winning Bids is November 30, 2029. Under the current version of the proposed 2024 RFP, a bidder may decline a winning bid offer and have their proposal security released if the 2024 RSC Phase 1 report indicates the project would have an online date past the assumed RFP target date (11/30/2029) due to network upgrade, contingent facilities, and interconnection facilities construction.