Articles + Publications June 27, 2022
FERC Interconnection NOPR Proposes Various Reforms
Executive Summary
On June 16, the Federal Energy Regulatory Commission (FERC or Commission) issued a Notice of Proposed Rulemaking (NOPR) focused on updating procedures for interconnecting large generating facilities (20MW and above) and small generating facilities (under 20MW). The NOPR proposes significant updates to FERC’s pro forma interconnection procedures, which were first established in the early 2000s. In the intervening years, however, the nation’s generation fleet has evolved, new technologies have emerged, and interconnection wait-times have steadily increased. The NOPR proposes various reforms to help address growing interconnection queue backlogs and process delays. Comments are due 100 days after the NOPR’s publication in the Federal Register. Reply comments are due 130 days after publication in the Federal Register.
Below is a summary of the primary reforms outlined in the NOPR, which fall into three broad categories: (1) implement a first-ready, first-served cluster study process; (2) increase the speed of interconnection queue processing; and (3) incorporate technological advancements into the interconnection process. FERC’s proposed reforms are discussed further in the full summary, linked below.
- Transitioning from a First-Come, First-Served Serial Process to a First-Ready, First-Served Cluster Study Process.
Proposed Compliance Procedures
FERC proposes to require that transmission providers submit compliance filings within 180 days of the effective date of a final order adopting the reforms. Transmission providers seeking deviations would be subject to the “independent entity” variation (for RTOs/ISO) and the “consistent with or superior to” standard for non-RTO/ISO transmission providers. For those transmission providers that have previously adopted reforms to their interconnection process, or certain such reforms where their respective tariff provisions would be modified by the final rule, “transmission providers must either comply with the final rule or demonstrate that these previously-approved variations continue to be consistent with or superior to the pro forma as modified by the final rule or continue to be permissible under the independent entity variation standard or regional reliability standard.
To read the full summary, please click here.
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