(Inter)Connecting the dots of stakeholder responses to FERC Interconnection NOPR
Initial comments offer broad support for first-ready, first-served cluster study process.
Written by: Erin Smith, Principal Analyst
Publish Date: October 25, 2022
Estimated Reading Time: 20 minutes
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During the week ending on October 14, 2022, stakeholders filed initial comments in FERC Docket RM22-14 regarding FERC’s Notice of Proposed Rulemaking (NOPR) entitled “Improvements to Generator Interconnection Procedures and Agreements,” summarized in NE Flash 22-25. In a press release, FERC noted that at the end of 2021, there were over 1,400 GW of generation and storage waiting in interconnection queues across the country, which is more than triple the volume five years ago. FERC found that transmission providers regularly fail to meet interconnection study deadlines and that this contributes to the delays and backlogs in the interconnection queue. In the NOPR, FERC proposed to:
- Implement a first-ready, first-served cluster study process;
- Increase the speed of interconnection queue processing; and
- Incorporate technological advances into the interconnection process for large generating facilities.
Most of FERC’s proposed reforms would revise the Large Generator Interconnection Procedures (LGIP) and Large Generator Interconnection Agreement (LGIA), but some would apply to the Small Generator Interconnection Procedures (SGIP) and Small Generator Interconnection Agreement (SGIA). We summarized comments for the below stakeholders, selected to represent a range of perspectives with material relevance to renewable energy markets in the Northeast.
- New England States Committee on Electricity (NESCOE)
- NY State Agencies (New York Public Service Commission (NY PSC) and NYSERDA)
- New York State Department of State, Utility Intervention Unit (NY UIU)
- New Jersey Board of Public Utilities (NJ BPU)
- The State Agencies (including the Attorneys General of Connecticut, Delaware, District of Columbia (DC), Maryland, Massachusetts, and Rhode Island; the Connecticut Department of Energy and Environmental Protection, Connecticut Office of Consumer Counsel, Delaware Division of the Public Advocate, DC Office of the People’s Counsel, Maryland Office of People’s Counsel, and the Pennsylvania Office of Consumer Advocate)
- U.S. Department of Energy (US DOE)
- American Clean Power Association (ACPA) and RENEW Northeast (RENEW)
- American Public Power Association (APPA)
- Edison Electric Institute (EEI)
- Electric Power Supply Association (EPSA)
- Public Interest Organizations (including the Sustainable FERC Project, Sierra Club, National Resources Defense Council, Earthjustice, Acadia Center, Environmental Defense Fund, National Audubon Society, Southern Environmental Law Center, and Southface).
- Solar Energy Industries Association (SEIA)
- New York Transmission Owners (NYTO) (including Central Hudson Gas & Electric, Consolidated Edison Company of New York, Niagara Mohawk Power Corporation d/b/a National Grid, New York Power Authority (NYPA), New York State Electric & Gas (NYSEG), Orange and Rockland Utilities, Long Island Power Authority (LIPA), and Rochester Gas & Electric).
- PJM Transmission Owners (PJMTO)
Below, we unpack the key themes highlighted in comments from the above Northeast stakeholders.
Regional Differences and Flexibility
ISO-NE, NYISO, NEPOOL, NYUIU, the NY State Agencies, and EEI supported FERC’s proposed transition to a first-ready, first-served interconnection process (in practice, this means that projects would be processed as a function of their readiness to come online, rather than on a first-come, first-served basis in which projects are processed in the order that they enter the interconnection queue). However, the stakeholders urged FERC to recognize regional differences and allow flexibility in compliance rather than impose a uniform or prescriptive compliance requirement. The NYUIU expressed that while it supports the objectives of the NOPR, it is concerned that FERC’s proposed reforms may unintentionally bring higher costs to ratepayers. NYUIU stated that while speed and efficiency are important to the interconnection process, these goals shouldn’t create barriers to the completion of societally beneficial projects. NYUIU noted that NYISO has implemented or is considering process modifications that appear to mitigate several issues that FERC’s proposed reforms seek to address, and that FERC’s reforms seek to address some challenges that are not present within NYISO. The State Agencies stressed that FERC’s central duty in any final rule is to ensure that consumers aren’t charged excessive costs.
LBNL Study on Interconnection Costs in MISO
The U.S. DOE highlighted a recent study (discussed in NE Flash 22-41) by the Lawrence Berkeley National Lab (LBNL) that analyzed interconnection costs in the Midcontinent Independent System Operator (MISO) footprint with data and analysis relevant to FERC’s proposed rule.
Public Interconnection Information
FERC proposed to require that transmission providers publish an interactive visual representation of estimated capacity available at each bus in the transmission provider’s footprint, and to update this information within 30 days of a cluster study. This visual would show the estimated impact of the addition of a proposed generating facility on a transmission provider’s transmission system.
ISO-NE and NYISO claimed that such information would be of limited use, arguing that there is no way to have a visual representation that anticipates all the concerns in a cluster study. ISO-NE expressed that if FERC decides to include an information access requirement in the final rule, that it allow such information to be qualitative. NYUIU expressed concern about the cost to market participants if transmission providers are required to provide such a visual. EEI argued that FERC should implement parameters that balance the potential benefits to prospective customers with the challenges of ensuring that such tools are up-to-date. NYTOs argued that rather than uniformly mandating adoption of virtual tool requirements, FERC should allow regions flexibility to formulate pre-application processes that would be helpful to interconnection customers.
APPA, ACPA, RENEW, SEIA, and the Public Interest Organizations supported this proposal. SEIA asserted that requiring transmission providers to publish transmission capacity information wouldn’t impose a significant burden. APPA agreed, arguing that posting information and interactive capability as described in the NOPR could be feasibly implemented with available industry system simulation tools and without labor-intensive study obligations. SEIA and the Public Interest Organizations reasoned that understanding where constraints are and where network upgrades will likely be necessary helps interconnection customers (i.e., developers) make more efficient siting decisions and reduces the incentive to submit speculative interconnection requests. The Public Interest Organizations asserted that FERC should require transmission providers to provide hosting capacity information for substations near potential generation resource areas.
Optional Informational Interconnection Studies
FERC proposed to allow interconnection customers up to five informational interconnection studies at a time (to be completed in 45 days) to help them determine whether they want to enter the queue, with a deposit of $10,000 per request.
NYUIU, NYTOs, EEI, APPA, ACPA, RENEW, and SEIA argued that there should be no such requirement to offer optional information studies prior to a project filing an interconnection request. ISO-NE and NYISO claimed that while there are potential benefits, informational studies as described in the NOPR wouldn’t be able to reflect actual upgrades to be identified in a future cluster study. ISO-NE, NYTOs, and EEI further reasoned that 45 days would correspond to a very limited scope and insufficient time to develop cost estimates and to coordinate with affected systems. ISO-NE, NYUIU, NJBPU, APPA, and SEIA also stressed that this requirement would divert essential and limited resources away from full cluster studies. NYTOs argued that rather than uniformly mandating adoption of an informational interconnection study, FERC should allow regions flexibility to formulate pre-application processes that would be helpful to interconnection customers. ACPA and RENEW noted that providing better information prior to entering the queue has some value but must not distract from higher priority cluster studies.
The NY State Agencies and Public Interest Organizations expressed support of FERC’s proposal. The Public Interest Organizations argued that limiting how many studies one customer can request would perpetuate the status quo of limiting information that developers can gain.
First-Ready, First-Served Cluster Study Process
FERC proposed that all transmission providers be required to conduct a single cluster study and cluster re-study each year, and that interconnection requests must be submitted during an annual cluster request window. FERC also requested comment on whether it should require transmission providers to conduct cluster studies on subgroups of interconnection customers based on areas of geographic and electric relevance. FERC proposed the below timeframe for clustering activities.
- Cluster Request Window – 45 days
- Customer Engagement Window – 30 days
- Cluster Study – 150 days
- Cluster Re-Study – 150 days
- Facility Study – 90 to 180 days
ISO-NE, NYISO, NYUIU, NYTOs, NJBPU, EEI, EPSA, APPA, ACPA, RENEW, and the Public Interest Organizations expressed support for the use of a first-ready, first-served cluster study process, but argued that FERC should allow regional flexibility to determine clusters, cluster subgroups, and timelines. The Public Interest Organizations argued that a lack of information and queue processing inefficiency, rather than speculative interconnection requests, has played a larger role in interconnection queue backlogs. ACPA and RENEW expressed support for FERC’s proposal but argued that it could be further improved. NYUIU argued that the final rule shouldn’t specify a set of characteristics that define membership in a cluster. The NY State Agencies and ISO-NE also stressed that time for stakeholder engagement should be included in cluster study timelines, and ISO-NE argued for consideration of time to coordinate with Participating Transmission Owners (PTOs). ISO-NE argued that the timelines for the first three of FERC’s proposed clustering activities should be extended to ensure an efficient cluster study process, and proposed extending the first three windows to 60, 90, and 270 to 365 days, respectively. ACPA and RENEW, by contrast, stated that the 45-day cluster request window and 30-day customer engagement window that FERC proposed is appropriate. ISO-NE noted that it has already made enhancements to its interconnection process in recent years, including integration with the Forward Capacity Market (FCM), elective transmission upgrades (ETUs), and clustering. ISO-NE expressed that it would be preferable to preserve some of these enhancements as allowances for regional differences.
Allocation of Cluster Study Costs
FERC proposed to allocate 90% of the applicable cluster study costs to interconnection customers on a pro rata basis based on requested MWs in a cluster, and 10% to interconnection customers on a per capita basis based on the number of interconnection requests included in the cluster.
ISO-NE, NEPOOL, EPSA, SEIA, NJBPU, and the Public Interest Organizations support a proposal in which cluster study participants share the costs. SEIA recommended that cluster study costs should be allocated 50% pro rata based on MWs and 50% per capita based on number of interconnection requests in a cluster, rather than 90% and 10% as FERC proposed. NYISO and APPA argued that the final rule should provide transmission providers with flexibility to propose a methodology for allocating study costs in line with the design of the cluster study. ACPA and RENEW recommended that the shared cost of cluster studies be allocated at least in part based on the time and resources expended on a particular study. The Public Interest Organizations, however, argued that FERC’s proposed changes, alone, are insufficient to achieve just and reasonable rates. The Public Interest Organizations urged FERC to require transmission planners to use existing cost allocation methods for determining who stands to benefit from network upgrades, and then allocate the costs accordingly. NYTOs argued that its current study cost allocation methodology of using a per capita approach tied to actual costs is superior to the method proposed by FERC. NYTOs further argued that FERC’s proposed 90/10% split seems arbitrary.
Allocation of Network Upgrade Costs
In the NOPR, FERC proposed that later-in-time interconnection customers (i.e., interconnection customers that come online after a network upgrade is implemented and paid for) reimburse earlier-in-time interconnection customers for network upgrades that later-in-time customers use, on a pro rata basis. FERC reasoned that one or more developers can interconnect to the existing system with minimal expense, but that the next developer in the queue may find there is no more capacity at a given point of interconnection. That developer can thus be forced to finance expensive interconnection-related network upgrades. FERC elaborated that this approach places all the costs of needed upgrades on the developer whose project triggered the reliability need but that, once designed and built, new upgrades often have excess capacity that succeeding developers can access without additional costs, which FERC stated can be unjust and unreasonable.
The State Agencies and NYTOs expressed strong support for FERC’s proposal. NYISO, NYUIU, NYTOs, APPA, and EEI stated that FERC should permit regional flexibility regarding the cost allocation of network upgrades. EPSA expressed general support for the proposal, but cautioned that FERC did not provide enough detail and that it should provide an opportunity for comments prior to moving to a final rule once it has a more detailed proposal. ISO-NE and NESCOE indicated support for later-in-time interconnection customers to reimburse earlier interconnection customers for prior upgrades. NYTOs reasoned that NYISO’s Class Year study approach already satisfies the NOPR requirements and appropriately shares the cost of network upgrades between earlier and subsequent interconnection customers.
ACPA and RENEW argued that allocating network upgrade costs to future clusters won’t provide meaningful information at the time that initial projects are deciding whether to move forward. ACPA and RENEW recommended that if FERC moves forward with this proposal that it make any upgrade costs that might be transferred to future clusters as transparent as possible.
Increased Interconnection Study Deposits
FERC proposed increasing interconnection study deposits according to the below schedule.
- Facilities >20 MW and <80 MW: $35,000 + $1,000/MW
- Facilities >=80 MW and <200 MW: $150,000
- Facilities >=200 MW: $250,000
NYISO, NYTOs, APPA, SEIA, and EEI expressed support for these requirements, stating that they would result in fewer speculative interconnection projects. NEPOOL supported commercial readiness rules, but stressed that FERC should avoid being overly prescriptive of the specifics of how commercial readiness can be demonstrated. ACPA and RENEW noted that they don’t oppose the heightened deposit requirements so long as they are paired with predictability on interconnection study timing, as well as certainty for network upgrade costs. SEIA expressed support for the requirements, but argued that increased deposits should be paired with other reforms to ensure reliable information on transmission capacity. SEIA reasoned that without reliable information on where there are transmission constraints, developers will be unable to make efficient siting decisions and the incentive to submit multiple exploratory results will still exist.
Interconnection Study Site Control Requirements
FERC proposed to revise the LGIP to require an interconnection customer to demonstrate 100% site control at the time of the interconnection request.
EPSA, ACPA, RENEW, and the Public Interest Organizations stated that requiring 100% site control for generating facilities at the time of submitting an interconnection request is excessively stringent. Instead, ACPA and RENEW support an escalating schedule of site control through the interconnection process that would demonstrate progress and significant commitment without restrictive requirements. ACPA and RENEW recommended that FERC require 75% site control at the time of interconnection queue entry; 90% site control at the post-Cluster Study decision point; and 100% site control at the post-Facilities Study decision point, which is when interconnection customers must sign or file an LGIA. NYISO expressed that FERC should provide specific criteria to demonstrate 100% site control to facilitate implementation of the proposed rule. SEIA and NYTOs partially agreed, expressing support for more stringent site control requirements but stating that it isn’t always possible for serious projects customers to acquire 100% site control at the time of the interconnection request. SEIA recommended that FERC set a site control requirement of 75% for the generating site only at the time of interconnection to allow flexibility to adjust projects as necessary.
APPA, ACPA, RENEW, and SEIA supported submission of a deposit in lieu of site control requirements. ACPA and RENEW stressed that for projects located on public or federal lands or waters (such as offshore wind), additional flexibility is needed to recognize that these projects are uniquely situated with respect to the process of securing site control. NJBPU proposed revised site control requirements to accommodate offshore wind projects, but argued that offering an alternative deposit payment in lieu of demonstrating 100% site control is discriminatory towards specific resource types such as offshore wind. EEI, by contrast, cautioned that allowing interconnection customers to provide deposits in lieu of meeting certain milestones or readiness requirements can be used as a loophole for speculative projects to proceed. NYTOs, meanwhile, argued that alternative deposits must be sufficiently high to insure against speculative projects and proposed a deposit amount of $10,000 per MW, with a floor of $500,000 and a ceiling of $2 million.
Interconnection Study Commercial Readiness Framework
FERC proposed the below options for demonstrating commercial readiness (or, a deposit in lieu of the below).
- An executed term sheet related to a contract binding the sale of the generating facility’s energy or capacity, or ancillary services where the term of sale is over 5 years.
- Reasonable evidence that the project was selected in a resource plan or resource solicitation; or
- A provisional LGIA filed at FERC.
ACPA, RENEW SEIA, and the Public Interest Organizations argued that this requirement is flawed and should be withdrawn or substantially modified. SEIA argued that the options FERC proposed for projects to demonstrate commercial readiness to enter the interconnection queue set a near impossible standard for independent power producers to meet. The Public Interest Organizations also argued that incumbent utilities would have great difficulty meeting the NOPR’s proposed commercial readiness requirements. The Public Interest Organizations explained that utilities conducting RFPs for their resource plans often require an interconnection queue position as a precondition of bidding. ACPA and RENEW argued that this requirement, in practice, could limit the number of bidders for competitive procurements and result in higher costs for ratepayers. The Public Interest Organizations also stated that most power purchasers seek projects with advanced interconnection queue positions before signing a Power Purchase Agreement (PPA) or state procurement. The NY State Agencies agreed, stressing that such measures should be carefully balanced to ensure they aren’t overly burdensome to customers with legitimate projects that may be delayed for reasons out of their control. NESCOE, the NY State Agencies, and EPSA expressed general support of more commercial readiness requirements but expressed caution about unintended consequences, as the requirements appear to exclude non-contracted resources for which there may be other demonstrations that can reasonably substitute for an executed contract.
NYISO and NYTOs explained that they already use commercial readiness milestones in NYISO’s Class Year Study process and argued that FERC’s final rule should permit regions to make use of their existing commercial readiness frameworks. ISO-NE explained that its Tariff currently requires a valid interconnection request to participate in the FCM and noted that requiring proof that a customer has obtained a Capacity Supply Obligation (CSO) in the FCM as a means of demonstrating commercial readiness at the entry stage of the interconnection process would be problematic.
Interconnection Study Withdrawal Penalties
FERC proposed that interconnection customers who withdraw during the interconnection study process, or that don’t otherwise reach commercial operation, would be subject to withdrawal penalties.
NYTOs expressed support for withdrawal penalties. NYISO and ISO-NE asserted that FERC’s final rule should permit regions with existing withdrawal penalty requirements to retain such requirements, and to consider whether additional penalty requirements provide additional benefits. ISO-NE requested further guidance from FERC on how collected withdrawal penalties should be handled, including whether they should be credited to projects that remain in the queue or otherwise credited to load through existing Tariff mechanisms. EEI stressed that FERC should also institute a financial assurance requirement to reduce the likelihood that penalized entities are unable to pay. ACPA and RENEW recommended that FERC ensure that any penalties for queue withdrawal account for unanticipated cost increases. ACPA and RENEW also stressed that a withdrawal penalty equal to nine times the study cost for a project that withdraws after executing its LGIA is arbitrary and excessive. SEIA, by contrast, argued that excessive withdrawal penalties incent unviable projects to stay in the interconnection queue.
Elimination of the Reasonable Efforts Standard
To improve interconnection queue processing speed, FERC proposed to revise the pro form LGIP to eliminate the Reasonable Efforts Standard and to instead establish financial penalties when transmission providers fail to meet interconnection study deadlines, with a $500 per day penalty distributed to impacted interconnection customers.
The State Agencies, NYISO, and EEI argued that the final rule should not eliminate the Reasonable Efforts Standard and that instead require that FERC should encourage alternative ways to incentivize parties to coordinate to complete interconnection studies on time. The State Agencies argued that fining transmission providers does not address the root of interconnection study delays because they aren’t responsible for market forces causing an influx of new resources and they don’t have a role in developing emerging technologies.
ISO-NE, NYISO, NYUIU, NYTOs, the State Agencies, the NY State Agencies, APPA, and EEI reasoned that the addition of penalties would introduce potential for litigation or administrative processes, diverting resources from conducting studies with adverse consequences on ISO/RTOs, market participants, and ratepayers. NESCOE stressed that elimination of the Reasonable Efforts Standard should be implemented in a way that doesn’t penalize the transmission providers’ ratepayers. ISO-NE stated that elimination of the Reasonable Efforts Standard is only appropriate if strong commercial readiness requirements are put in place, transmission providers are afforded enough flexibility to establish reasonable study deadlines, and a FERC-driven administrative fact-finding process is established to apportion any penalties. NESCOE stated that a final rule should incentivize transmission providers to complete interconnection studies in a timely way but in a manner that also affords them sufficient flexibility to meet the needs of interconnection customers. ISO-NE also questioned how FERC plans to handle cases when the delay is not the fault of ISO-NE.
ACPA, RENEW, SEIA, the Public Interest Organizations, and NJBPU support FERC’s proposal to eliminate the Reasonable Efforts Standard, arguing that it has proven ineffective because there are currently no specific incentives for delivering on-time and accurate studies. ACPA and RENEW argued that FERC should adopt a balanced approach to ensure that transmission providers have appropriate incentives to provide on-time, high-quality studies. The Public Interest Organizations stated that they partially supported FERC’s proposal of a $500/day penalty, but proposed a few changes to FERC’s proposal. Namely, the Public Interest Organizations argued that the penalty amount should dictated by the scope and cost of the study, rather than be a set amount. The Public Interest Organizations also suggested that FERC require any transmission provider that reaches 100% of the financial penalty cap to keep paying the penalty, but have the money go to hiring a third-party consultant to provide modeling or other assistance to complete the delayed interconnection study.
Optional Resource Solicitation Study
FERC proposed to reform the LGIP to allow a resource planning entity (such as state procurements of renewable clean energy) to request an optional resource solicitation study.
ISO-NE, NYISO, NESCOE, ACPA, RENEW, NJBPU, and the Public Interest Organizations supported FERC’s proposal for an optional resource solicitation study, stressing that it should provide regions with flexibility for how the account for such solicitation processes within their interconnection procedures. NJBPU strongly supported this proposal, arguing that it would be a vital tool for New Jersey to achieve its offshore wind targets.
ACPA, RENEW, APPA and EPSA noted that they don’t object to this provision, but urged FERC to clarify how this mechanism would operate in conjunction with a first-ready, first-served framework. In the NOPR, interconnection requests that would be analyzed in the optional resource solicitation study would already need to hold a position in the interconnection queue. However, if these generation resources are competing in a resource solicitation in which they may not be selected, their interconnection requests could constitute the kind of speculative interconnection requests that FERC is trying to discourage. APPA questioned how such interconnection requests would qualify for inclusion in the interconnection queue in the first place under FERC’s proposed enhanced commercial readiness requirements. APPA requested that FERC clarify these issues.
SEIA strongly opposed allowing for optional resource solicitation studies, arguing they would provide opportunities to discriminate against independent power producers. SEIA argued that under FERC’s framework, a load serving entity (LSE) could request an optional resource solicitation study from the transmission provider and, as part of its request, the LSE would be responsible for identifying the valid interconnection requests. The LSE would then make integrated resource plan (IRP) decisions based on that study. SEIA reasoned that under this paradigm, LSEs would be incentivized to use the study to select generation owned by its associated generation subsidiaries, allowing those projects to meet the IRP demonstration of commercial readiness.
Shared Interconnection Requests for Co-Located Generation
FERC proposed to allow shared interconnection requests for co-located generation (including generation plus energy storage) sites behind one point of interconnection.
The State Agencies, NJBPU, APPA, ACPA, RENEW, SEIA, the Public Interest Organizations, and NYTO support this proposal, arguing that it will enable more efficient interconnection processes while providing greater visibility to transmission grid operators. NYISO and the NY State Agencies support this proposal and stated NYISO has already revised its LFIP and SGIP requirements to permit the use of co-located storage resources. NYTOs argued that FERC should provide regional flexibility to determine the types of co-located resources permitted in each ISO/RTO.
Generating Facility Additions to Interconnection Requests
FERC also proposed to allow interconnection customers to add a generating facility to an existing interconnection request without losing queue position if there isn’t a change to the requested interconnection service level.
NYISO and the NY State Agencies support this proposal, stating that New York’s Open Access Transmission Tariff (OATT) already allows for such modifications so long as the total requested ERIS and CRIS does not increase. APPA, SEIA, the Public Interest Organizations, and NJBPU also support this proposal, stressing that the addition of another facility would no longer be considered a material modification to the interconnection request, provided that the addition doesn’t have a material impact on the cost or timing of any interconnection request that is lower or equally queued.
ISO-NE argued that allowing addition of a generating facility to an existing interconnection request would potentially introduce major changes to study scope and upgrade results and would delay, rather than speed up, study times. ISO-NE argued that FERC should require that projects be fully conceived by the time a cluster study submittal window is closed, arguing that modifications could be proposed in a subsequent cluster study. NYTO expressed that certain changes in characteristics of the facility or of a resource should be deemed of significant magnitude to constitute a material modification.
Availability of Surplus Interconnection Service
FERC proposed to require that surplus interconnection service be available to interconnection customers after executing the LGIA rather than only after a generating facility enters commercial operation.
NYISO opposed this proposal because NYISO it does not provide for the utilization of surplus interconnection service, and explained that FERC has previously granted NYISO an independent entity variation from the surplus interconnection service requirement in its Order 845 proceeding. SEIA argued that allowing interconnection customers to use surplus interconnection process to add storage resources can provide significant benefits to the grid quickly and with a high degree of control and transparency.
Operating Assumptions for Interconnection Studies to Reflect Energy Storage
FERC proposed to require that transmission providers, at the interconnection customer’s request, use operating assumptions for interconnection studies that reflect the proposed operation of an electric storage resource or co-located resource containing an electric storage unit.
ISO-NE, NYISO, and NYTOs disagreed with the proposed requirements on operating assumptions in interconnection studies for electric storage resources, arguing that implementing the myriad of operating approaches isn’t expected to be implementable in system and market operations. NYISO argued that these requirements would add significant complexity and time required to complete interconnection studies. APPA agreed that incorporating such complexities could slow the pace of interconnection studies and argued that instead, FERC should give transmission providers the autonomy to decide whether additional transmission studies are needed even when the interconnection customer is suggesting operational assumptions. NYTOs argued that rather than mandating a standard, that FERC allow the transmission system planner and the transmission owners to collaborate on interconnection requests with an electric storage project to ensure it is reasonable and appropriate.
ACPA, RENEW, SEIA, and the Public Interest Organizations argued that enabling electric storage and hybrid storage and generation facilities to specify operating assumptions for interconnection studies would enable speedier interconnection processes and more efficient use of scarce transmission capacity. ACPA and RENEW elaborated that FERC should enable interconnection customers to request study criteria and assumptions to reflect the proposed operation of storage resources. ACPA and RENEW noted that electric storage resources are controllable with a level of precision and speed unparalleled by conventional generation resources, which they argued provides interconnection customers with new opportunities to accommodate transmission system reliability needs and make efficient use of scare transmission interconnection capacity. ACPA and RENEW further elaborated that the use of unrealistic study assumptions for electric storage in interconnection studies would result in rates, terms, and conditions that are unjust and unreasonable.
Incorporate Alternative Transmission Technologies into the Generator Interconnection Process
Alternative technologies such as advanced power flow control, transmission switching, dynamic line ratings, static synchronous compensators, and/or static volt-ampere reactive (VAR) compensators are important to consider. FERC proposed to revise the pro forma LGIP and SGIP to require transmission providers, upon request of the interconnection customer, to evaluate the requested alternative transmission solutions during the LGIP cluster study and the SGIP system impact study and facilities study within the generator interconnection process.
ISO-NE indicated that it supports incorporating alternative transmission technologies into the generator interconnection process where appropriate, but that inclusion must be balanced against the efficient completion of interconnection studies. NYISO also supported such consideration, but argued that it would be premature to require consideration of dynamic line ratings. NYTOs argued that alternative technologies should only be used in interconnection studies if they have been proven effective and appropriate in the planning context.
ACPA, RENEW, SEIA, and the Public Interest Organizations expressed support for evaluation of alternative transmission technologies. ACPA and RENEW argued that electric storage technology should be included as an alternative transmission technology so that it can be studied to potentially reduce or avoid the cost of conventional network upgrades associated with an interconnection request. EEI reasoned that while alternative technologies can provide benefits, their implementation should be evaluated by transmission providers in the context of system performance and not in a way that would prioritize interconnection customer preferences over those of the larger system and ratepayers. The Public Interest Organizations stressed that FERC shouldn’t limit the definition of alternative transmission technologies in its rulemaking.
Modeling and Performance Requirements for Non-Synchronous Generating Facilities
FERC preliminarily found that the pro forma LGIP and pro forma SGIP may be unduly discriminatory or preferential to the extent that they don’t require non-synchronous generating facilities (i.e., renewable energy projects such as solar and wind) to provide accurate and validated models to transmission providers during the generator interconnection process.
ISO-NE, NYTOs, EEI, and APPA indicated strong support for increased modeling and performance requirements for non-synchronous generating facilities. NYTOs argued that this would increase the accuracy of study results. EEI argued that the modeling requirements would improve transmission providers’ ability to identify appropriate interconnection facilities and network upgrades associated with interconnection requests for non-synchronous resources. ACPA and RENEW argued that FERC’s proposed requirements, with minor changes, can improve grid reliability while reducing unnecessary burdens on generators and transmission providers.
NYISO, by contrast, argued that FERC’s final rule should not include modeling and performance requirements for non-synchronous generating facilities, arguing that it would be inefficient and require NYISO to rebuild its study base case, as well as other software and resources. SEIA also opposed FERC’s proposal, arguing that the requirement is premature and would not result in useful modeling data for the transmission provider. SEIA argued that different models provide different uses and that no one model fits all situations, and that requiring interconnection customers to use generic rather than user-defined models could fail to identify the reliability impacts of a specific plant. SEIA requested that instead, FERC modify its requirement to require interconnection customers to provide all operating models within 1 year before the commercial operation date; to require transmission providers to make available to interconnection customers all necessary data to create the models; and to require transmission providers to provide clear modeling requirements and validation guidelines.
Reply comments are due November 14.