FERC Proposes To Reform Generator Interconnection Procedures

June 20, 2022

by Paul Ciampoli
APPA News Director
June 20, 2022

The Federal Energy Regulatory Commission (FERC) on June 16 issued a Notice of Proposed Rulemaking (NOPR) to reform its generator interconnection procedures and pro forma interconnection agreements to address interconnection queue backlogs.

Although the proposals in the NOPR are not directly applicable to public power transmission owners, public power utilities in regional transmission organization (RTO)/independent system operator (ISO) regions may be subject to the proposed requirements under RTO/ISO tariffs or other governing agreements. 

Also, as FERC specifically states in the NOPR, transmission providers that are not utilities subject to FERC’s general transmission jurisdiction (such as public power utilities) would be required to adopt the requirements of the NOPR as a condition of maintaining the status of any safe harbor tariff or otherwise satisfying the reciprocity requirements of FERC Order No. 888. 

FERC noted that at the end of 2021, there were more than 1,400 gigawatts of generation and storage waiting in interconnection queues throughout the country. This is more than triple the total volume just five years ago (Docket No. RM22-14-000).

“Projects now face an average timeline of more than three years to get connected to the grid. As the resource mix rapidly changes, the Commission’s policies must keep pace,” it said in a news release.

The proposed rule includes several key areas of reforms.

First, it would Implement a first-ready, first-served cluster study process: Under the proposed first-ready, first-served cluster study process, transmission providers would conduct larger interconnection studies encompassing numerous proposed generating facilities, rather than separate studies for each individual generating facility.

FERC said this approach would increase the efficiency of the interconnection process and help minimize delays. To ensure that ready projects can proceed through the queue in a timely manner, transmission providers also would impose additional financial commitments and readiness requirements on interconnection customers.

The NOPR also aims to improve interconnection queue processing speed.

The NOPR proposes to impose firm deadlines and establish penalties if transmission providers fail to complete interconnection studies on time, except in instances where force majeure is applicable.

Additionally, the NOPR proposes a more detailed affected systems study process, including a specific modeling standard and pro forma affected system agreements. The NOPR also proposes reforms to administratively simplify the process of studying interconnection requests that are all related to the same state-authorized or mandated resource solicitation.

The NOPR also incorporates technological advancements into the interconnection process. It proposes to require transmission providers to allow more than one resource to co-locate on a shared site behind a single point of interconnection and share a single interconnection request. This would create a minimum standard that would remove barriers for co-located resources by creating a more efficient standardized procedure for these types of configurations.

The NOPR also proposes to allow interconnection customers to add a generating facility to an existing interconnection request under certain circumstances without automatically losing their position in the queue. In addition, the NOPR proposes to require transmission providers to consider alternative transmission solutions if requested by the interconnection customer.  

It also calls for updating modeling and performance requirements for system reliability.

Specifically, the NOPR proposes certain modeling and performance requirements for non-synchronous generating facilities to address the unique characteristics of the changing resource mix. For example, to ensure that non-synchronous resources are better able to support reliability, the NOPR proposes to require them to continue providing power and voltage support during grid disturbances.

Comments on the NOPR are due 100 days after publication of the NOPR in the Federal Register. Reply comments are due 130 days after publication in the Federal Register.