2024-INT 00031 Published On: 10/30/2024
Question: If the Transmission Provider’s cost for the estimated network upgrades specified in the completed, executable version of the Interconnection Agreement is greater than 125% of the estimated cost of these network upgrades calculated during Phase 1 of the Resource Solicitation Cluster (the “Excess Network Upgrade Costs”), and the Buyer (Duke) exercises the right to terminate the PPA under Section 20.1.2, what happens to the pre-COD deposit posted by the Seller? What is the process including number of days to refund it to the Seller?
Answer: Pre-COD performance security for a PPA project is typically in the form of cash or a letter of credit. This security will be released by Duke Energy in the event the PPA is terminated due to excess network upgrade cost. The form of security will impact the timeline for its release. The companies will sign a Mutual Termination Agreement, and the release will be part of the MTA. Duke Energy will endeavor to return the security as soon as reasonably possible after the contract termination, but in no event later than the end of the Security Period set forth in Section 5.7 of the PPA.
As an estimate, a letter of credit release takes about 10 business days; a cash refund will take about 30 days.
2024-INT 00030 Published On: 10/14/2024
Question: If a market participant is shortlisted for Step 2, then the MP has to pay the proposal security and an M1 initial security deposit. The M1 Security is equal to $50,000 plus $1/KWAC for project size > 50 KWAC, and is paid by a market participant prior to the 2024 RSC Phase 1 Study. How does the market participant get this M1 security deposit back? In cash or is it applied towards other payments? When?
Answer: The RFP Document explains that all third party MPs that are invited to the “short list” and elect to move into Step 2 of the evaluation process must post Step 2 Proposal Security and that the M1 security applies to the calculation of the Step 2 Proposal Security. Section J(3) of the RFP Document explains the release of this security under a number of factual scenarios.
2024-INT 00029 Published On: 10/14/2024
Question: A study deposit of $50,000 plus $1/KWAC for project size > 50 KWAC is paid by a market participant as part of the application for 2024 RSC Interconnection Request. How does the market participant get this deposit back? In cash or applied towards other payments? When?
Answer:
2024-INT 00028 Published On: 10/08/2024
Question: For an MP with a PPA track bid participating in the 2024 RSC, are the estimated POI related network upgrades such as Switching Equipment and Modify Relay and Communication Equipment to be included in the Part A/C or Part B/D bid price? The 2023 RSC Study Reports break out the network upgrades into several categories, POI, Remote End, Telecommunications, and Power-Flow Thermal; are only the Power-Flow Thermal Network Upgrades reimbursable through the Part B/D pricing or the Total Network Upgrades estimate from the study report?
Answer: Switching Equipment and Relay and Communication Equipment are considered network upgrades in most cases. For standard cost estimates please see “DEC DEP Standard Interconnection Cost Estimates” document posted June 28, 2024 at 2024-RFP-Documents (dukeenergyrfpcarolinas.com). The standard interconnection facilities costs do not include the network upgrade costs. Part B/D covers all items identified as network upgrades, not just thermal network upgrades. Accordingly, please include costs for System Equipment and Modify Relay and Communication Equipment in the Part B/D bid price. Please also see "DEC DEP 2024 RFP Document," Section VI.A (Proposal Pricing and Bidding - Controllable PPA Proposal Pricing), available here: 2024-RFP-Documents (dukeenergyrfpcarolinas.com).
2024-INT 00027 (revised 09/27/2024) Published On: 09/27/2024
Question: In the document “DEC/DEP Standard Interconnection Cost Estimates,” it states: "Estimates do not include financial multipliers or applicable sales tax. The Interconnection Agreement will identify the Customer's selection of financial arrangement—Monthly Charge or Total Prepayment—and the estimated costs for the financial arrangement." Our question pertains to the financial arrangements mentioned, specifically the Monthly Charge or Total Prepayment options. Based on our experience with LGIAs from prior procurement cycles, we’ve encountered the following scenarios:
For DEC:
For DEP:
This means the interconnection costs will be approximately 1.6 times than the provided estimated facilities costs. While this information has been included in Appendix 2 of previous LGIAs we've signed, we have not found this specific detail in any public documents related to this procurement. Given the significant financial impact this has on bidders' pricing, we believe it is crucial to have clear and up-to-date guidance.
We are confident that both Duke Energy and Charles River Associates aim to ensure all bids are submitted in good faith and based on consistent information. To that end, could Duke please provide Market Participants with the current and complete guidance on the available financial arrangements for both DEC and DEP?
Answer: Please see “Summary of Extra Facilities (2024 RFP).pdf” included on the 2024 FAQ Documents webpage. It provides the relevant interconnection facilities charge payment options that are currently available to NC and SC Interconnection Customers in DEC and DEP under applicable service regulations. The effective interconnection facilities charge payment options will be reflected in Appendix 2 of executed Interconnection Agreements. Please note that these payment options are subject to change based on order of the jurisdiction’s governing body (the North Carolina Utilities Commission or South Carolina Public Service Commission) and the payment options applicable to a Market Participant/Interconnection Customer will be based on the payment options that are effective at the time the Interconnection Agreement is tendered.
2024-INT 00026 Published On: 09/26/2024
Question: One question on RSC application. Is the “site control verification form” required for the application? All the GLAs of the project are valid and currently in diligence period, available to be uploaded.
Answer: Yes, site control verification is one of the requirements for the Interconnection Request to be considered complete. This is required by the close of the 2024 RFP bid window on September 30, 2024, see DEC DEP RFP Document, “Section V. RFP PROCESS, D. 2024 RFP-SPECIFIC RESOURCE SOLICITATION CLUSTER” available in the 2024 RFP Documents.
2024-INT 00025 Published On: 09/25/2024
Question: I am unable to identify in the SC Duke DISIS appendix of the transmission tariff, what contsitutes a material modifcation to a project. Specifically, are reductions allowed without penalty between Phase 1 and Phase 2 of the DISIS as non material modifications? Or at other stages?
Answer: Material Modification is defined in Appendix CS as follows:
A modification to machine data or equipment configuration or to the interconnection site of the Generating Facility that has a material impact on the cost, timing or design of any Interconnection Facilities or Upgrades. Material Modifications include project revisions proposed at any time after receiving notification by the Utility of a complete Interconnection Request pursuant to Section 1.3.3 that 1) alters the size or output characteristics of the Generating Facility from its Utility-approved Interconnection Request submission; 2) may adversely impact other Interconnection Requests with higher Queue Numbers, or may adversely impact another Interconnection Customer who is part of the same Cluster where the utility is implementing the Definitive Interconnection Study Process. In addition to the list of modifications to an Interconnection Request identified in the SC GIP that are not indicia of a Material Modification, a change in the point of interconnection to a new location or new voltage level, where requested by the Utility and agreed to by the Interconnection Customer pursuant to Section 5.3.6, is not a Material Modification.
Further information on what does and does not constitute a Material Modification can be found in Attachment 1 of the South Carolina Interconnection Procedures Glossary of Term’s definition of Material Modification.
2024-INT 00024 Published On: 09/23/2024
Question: For projects offered as Asset Transfer with an executed Interconnection Agreement, will Duke reimburse spent Interconnection costs outside of the offered Asset Transfer price or should these be included in the offer?
Answer: An Asset Transfer proposal with an executed Interconnection Agreement will be solely responsible for the cost of any Interconnection Facilities and System Upgrades assigned to it under its Interconnection Agreement and shall bid accordingly as participation in the 2024 RFP will not alter any contractual obligations included in the MP’s executed Interconnection Agreement.
The bid Asset Purchase Price should account for the bidder’s financial obligations under the Interconnection Agreement and the bidder should disclose how much of the bid Asset Purchase Price includes Interconnection Agreement costs, so that the Utility Ownership Team does not double count costs between the bid Asset Purchase Price and expected project costs for Interconnection Facilities and System Upgrades. Pursuant to the LOI and form Asset Purchase Agreement, yes, the bidder does get reimbursed for costs incurred under the Interconnection Agreement (i.e. cash deposits made to the Transmission Provider).
2024-INT 00023 Published On: 09/23/2024
Question: My question is about the generator power flow model in PSSE for a new large generation interconnection application with an inverter-based system. Should the PSSE load flow model be a test case (a simplified model provided by the inverter manufacturer), or should it represent the actual power plant we are submitting the application for?
Answer: Please see responses to FAQs 2024-INT 00015, 2024-INT 00019 and 2024-INT 00021.
2024-INT 00022 Published On: 09/23/2024
Question: Can you provide support on the RSC application? My main query is once I log in the portal, I am not sure which option to select within the Interconnection request for a SPS project. Should it be “NC/SC Distribution Greater then 20Kw”? Generally, which information is required in the application? Below are all the steps I have done so far. 1 Portal https://dukeenergy.my.site.com/ 2 Section “Interconnection Request” https://dukeenergy.my.site.com/s/interconnection-request 3 As application Type, which should it be? “NC/SC Distribution Greater then 20Kw” Or The other options available? 4 In general, what information is required for this application?
Answer: Please see the slides provided at the Pre-Solicitation Bidders Conference, they are located in the Stakeholder Materials (dukeenergyrfpcarolinas.com), starting at slide 14 there are screenshots to guide you through the RSC application on the Interconnection Portal.
2024-INT 00021 (revised 10/24/2024) Published On: 09/20/2024
Question: For a new large generation interconnection application with an inverter-based system, I found on your website that we need to submit the inverter and power plant controller models in PSS/E (*.dyr file). Could you please confirm if a plant model (*.raw or *.sav file) is also required?
Answer: A sample implementation test case shall be included.
2024-INT 00020 (revised 09/19/2024) Published On: 09/19/2024
Question: What do you want us to select below in the Battery Operation section in the Interconnection Application for an SPS project? Considering the fact that Duke on the offtake side is the one that controls the battery operations?
Answer: These fields are not relevant for projects in the RFP. Our recommendation is to “Dispatch” for the Modes of Operation and “Other” for the Control Narrative.
2024-INT 00019 Published On: 09/19/2024
Question: Do we need to submit a generator power flow model for each interconnection request?
Answer: Yes, PSSE models are required. For projects bidding as both SPS and Solar only, both PSSE models are needed. See 2024-INT 00015.
2024-INT 00018 Published On: 09/16/2024
Question: Can you confirm that if FERC approves the Order 2023-A Compliance filing, the readiness requirement to get into the Facilities Study (15% Network Upgrades) and the readiness requirement at IA execution (20% Network Upgrades) both need to be included in the price of the UOT proposal. Can you also confirm whether Duke accepts surety bonds as an acceptable form of credit for these readiness requirements? The Order 2023-A Compliance Filing seems to allow surety bonds, but the Duke Energy Policy on Security for FERC Generators on OASIS seems to contradict that.
Answer: As provided in 2024-GEN 00011 and 2024-INT 00013, all UOT proposals will also be responsible for completing the interconnection study process, including providing any study deposits (such as M4) and executing and maintaining an Interconnection Agreement, as well as providing any additional securities that may be required under such Interconnection Agreement, until the Interconnection Agreement is assigned to DEC/DEP at closing. If Duke Energy’s FERC Order No. 2023-A compliance filing is approved, FERC Interconnection Customers may provide surety bonds to meet the referenced readiness requirements as long as the surety bond is in a form reasonably acceptable to Duke Energy. To maximize the efficiency of this process, Duke Energy has developed a form of surety bond that is reasonably acceptable and will be provided to customers upon request. The Duke Energy Policy on Security for FERC Generators on OASIS is applicable to FERC Generators that progress through the interconnection process (after readiness referenced is provided) to LGIA execution. Please see 2024-INT 00006 for information on the readiness requirements.
2024-INT 00017 Published On: 09/16/2024
Question: As a follow up to FAQ 2024-GEN 00020, if the Seller makes the M4 payment deposit under the RSC process with DEP Transmission within 10 days after receiving the Facilities Study results. Following which, if the System Upgrade Costs in the executable version of the Interconnection Agreement are greater than 125% of the System Upgrade Cost (SUC) estimate in the RSC Phase I Study results, and Duke exercises the right to terminate the PPA under Section 20.1.2, what happens to the Interconnection Application under the RSC process? Does it continue under the RSC, and can the Seller proceed to execute the Interconnection Agreement? a. If yes, what are the potential offtake alternatives for the Seller? PURPA PPA and Corporate PPA sleeved through Duke's potential Green Source Advantage Choice. Any other alternatives? b. If no, will the project get withdrawn from the RSC as well and in that case, will the Seller get full refund of the M1 and M4 deposits made under the RSC?
Answer: In the unlikely event that Duke exercises the right to terminate the PPA under Section 20.1.2 subject to the facts provided in the question, then the Generating Facility cannot continue in the Resource Solicitation Cluster. In accordance with Section 4.4.2 of the NCIP and Section 5.3.2 of the SCGIP, where a Generating Facility is rejected in a Resource Solicitation Cluster Process administered separately from a Definitive Interconnection System Impact Study Cluster, the Generating Facility shall lose the Queue Position it held as part of the Competitive Resource Solicitation. Again, Duke believes such an event to be very unlikely. If such situation does arise, Duke will address refundability of the M1 and M4 deposits in accordance with the NCIP and SCGIP.
2024-INT 00016 Published On: 09/13/2024
Question: For FERC-jurisdictional IRs to the RSC, is the site control acreage requirement based on MWac or MWdc?
Answer: “Site Control Guidance – Eff 10.26.2023.pdf” is a site control acreage guidance document posted on the DEP and DEC OASIS sites, the values are based on MWAC.
2024-INT 00015 Published On: 09/11/2024
Question: Are PSSE standard library (generic) models and PSSE User-Defined models required as part of the RSC interconnection application submission (NC/SC State Interconnection) for the Controlled PPA track? Where can I find the PSSE modeling guidelines?
Answer: PSSE models are required. If the PSSE models are not included with the initial Interconnection Request submission, the interconnection study team will request them during the Customer Engagement Window as this information is required for the Resource Solicitation Cluster study performed by Transmission Planning. Sections 7h and 8h of the Inverter Based Resource Data Request form located on the OASIS site (Duke_Energy_Inverter_Based_Resource_Data_Request_Form_(DEC,DEF,DEP).pdf (oati.com)) provides guidance for inverter and reactive power PSSE modeling.
2024-INT 00014 Published On: 09/10/2024
Question: Could you please clarify and reference the section in the RFP documents where it says when are the i) Interconnection Request RSC study deposit, and ii) RSC “M1” Security; released or refunded?
Answer: In Appendix O Section I “e. Each Interconnection Request will require an RSC study deposit as established in Attachment K 4.1.2 of the LGIP, NCIP 1.5.1.2, and SC GIP Appendix Duke CS 2.1.” This deposit is made at the time of the application before September 30, 2024. M1 is an equivalent amount, and that payment is due in January 2025 for projects invited to Step 2 of the RFP. See RFP Document at Section X.J. Any refunds will be processed in accordance with Sections 6.3.3 of the NCIP and SCGIP, and Section 16.4 of Attachment K to the LGIP. The security payment will be refunded once all accounts are settled.
2024-INT 00013 Published On: 09/10/2024
Question: For a UOT track submission, should we anticipate the M4 Milestone payment to be included into our overall purchase price amount or will the M4 payment be allocated in the Interconnection Cost Reimbursement Payment?
Answer: Please refer to the guidance provided in 2024-GEN 00011 and guidance provided in the RFP Document and stakeholder sessions regarding payments and fees associated with the 2024 RFP. All UOT proposals will also be responsible for completing the interconnection study process, including all study deposits (such as M4) and executing and maintaining an Interconnection Agreement, including any additional securities that may be required under such Interconnection Agreement, until the Interconnection Agreement is assigned to DEC/DEP at closing of the definitive agreement. So yes, the bidder will be responsible for making the M4 payment. Bidders have been instructed that their bid pricing is inclusive of any interconnection study deposits, i.e. the Asset Purchase Agreement or Build Transfer Agreement purchase price.
2024-INT 00012 Published On: 09/09/2024
Question: Wanting to follow up and clarify the response to FAQ 2024-INT 00011: Will the RSC only accept state-jurisdictional requests?
Answer: The Resource Solicitation Cluster (RSC) is limited to projects participating in the 2024 RFP; both FERC jurisdictional and State jurisdictional projects may participate in the RFP and therefore submit Interconnection Requests into the RSC. For projects looking to be a Qualifying Facility (QF) and sell all of their output to Duke Energy sized 80MW looking to bid PPA Track, a State jurisdictional Interconnection Request application for NC or SC shall be completed for purposes of participating in the 2024 RFP. For projects greater than 80MW looking to bid into the Utility Ownership Track (UOT), a FERC jurisdictional Interconnection Request application shall be completed for purposes of participating in the 2024 RFP. The response to FAQ 2024-INT 00011 is clarifying that FERC jurisdictional projects not participating in the 2024 RFP shall submit Interconnection Request applications during the next DISIS window, and not into the RSC.
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.