Staff Presentation - RM22-14

HEADLINES

Staff Presentation | NOPR on
Improvements to Generator
Interconnection Procedures and
Agreements
June 16, 2022

Docket No RM22-14-000

Item E-1 | News Release
Item E-1 is a draft Notice of Proposed Rulemaking [NOPR], to be issued pursuant to section
206 of the Federal Power Act, which proposes to reform the Commission’s standard generator
interconnection procedures and agreements.  The proposed reforms are intended to address
interconnection queue backlogs, improve certainty, and prevent undue discrimination for new
technologies to ensure that the pro forma generator interconnection procedures are just and
reasonable and not unduly discriminatory or preferential.
Today’s draft NOPR builds on Commission Order Nos. 2003 and 2006, in which the Commission
first required public utility transmission providers to adopt its standard procedures and
agreements for interconnecting large and small generating facilities, and Commission Order
No. 845, in which the Commission revised those procedures and agreements.  The electricity
sector has transformed significantly since the Commission established the pro forma
documents and has continued to change from the time Order No. 845 was issued.  The growth
of new resources seeking to interconnect to the transmission system coupled with the existing
serial first-come, first-served interconnection study process has created large interconnection
queue backlogs and uncertainty regarding the cost and timing of interconnecting to the
transmission system, potentially increasing costs for consumers.  Backlogs in the generator
interconnection queue, in turn, can create reliability issues as needed new generating facilities
are unable to reach commercial operation in an efficient and timely manner.  Accordingly, the
draft NOPR proposes reforms to revise the pro forma generator interconnection procedures
and agreements to increase the speed and efficiency of interconnection queue processing by,
among other things, requiring public utility transmission providers to adopt a first-ready, firstserved cluster study process.

The draft NOPR proposes to require public utility transmission providers to eliminate the serial
first-come, first-served study process currently required by the Commission’s existing standard
generator interconnection procedures and instead use a first-ready, first-served cluster study
process.  A first-ready, first-served cluster study process is a more efficient way of processing a
large interconnection queue because it allows transmission providers to study numerous
proposed generating facilities at the same time, rather than study each individual
interconnection customer’s request separately and serially.  Additionally, conducting a single
cluster study and cluster restudy each year can minimize delays that can arise from proposed
generating facility interdependencies and minimize the risk of cascading restudies when a
higher-queued interconnection customer withdraws.
As part of the proposed first-ready, first-served cluster study process, the draft NOPR proposes
more stringent financial commitments and readiness requirements for interconnection
customers to remain in the interconnection queue.  The draft NOPR preliminarily finds that
these proposed reforms will discourage speculative interconnection requests and allow
transmission providers to focus on processing interconnection requests that have a greater
chance of reaching commercial operation.  These proposed reforms pertain to study deposit
amounts, site control demonstration, required commercial readiness milestones, and
withdrawal penalties.  The draft NOPR also proposes a transition process whereby certain latestage customers will be allowed to proceed under the existing interconnection process.
The reforms proposed in this draft NOPR also endeavor to increase the speed of
interconnection queue processing by eliminating the “reasonable efforts” standard for
completing interconnection studies, implementing an affected systems study process, and
offering an optional resource solicitation study process.  First, the reforms proposed in this
draft NOPR would impose firm study deadlines on public utility transmission providers by
eliminating the reasonable efforts standard.  As proposed in the draft NOPR, those public
utility transmission providers who fail to meet their study deadlines would be subject to
penalties in certain instances.  Second, the draft NOPR proposes to require public utility
transmission providers to use a standardized and transparent affected systems study process. 
Finally, the draft NOPR also proposes to require public utility transmission providers to offer an
optional resource solicitation study process to allow a resource planning entity to obtain better
information about the interconnection costs of different combinations of projects that may be
selected in a state resource solicitation process or qualifying resource plan.
The draft NOPR also proposes reforms to incorporate technological advancements into the
interconnection process.  Specifically, the draft NOPR proposes to require public utility
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; to evaluate the
proposed addition of a generating facility to an interconnection request as long as the

interconnection customer does not request a change to the originally requested
interconnection service level; to allow interconnection customers to access the existing
surplus interconnection service process sooner once the original interconnection customer
has an executed interconnection agreement or requests the filing of an unexecuted one; to use
operating assumptions for interconnection studies that reflect the proposed operation of a
generating facility; and to evaluate alternative transmission solutions upon request of the
transmission customer.  The draft NOPR also proposes to require interconnection customers
requesting to interconnect a non-synchronous generating facility to include in the
interconnection request the models needed for accurate interconnection studies and to
require such generating facilities to ride-through abnormal frequency and voltage conditions
to address challenges associated with momentary cessation.
The draft NOPR seeks comment on the proposed reforms and encourages commenters to
identify enhancements that could further improve the generator interconnection process. 
Comments are due 100 days after publication in the Federal Register and reply comments are
due 130 days after publication in the Federal Register.
Thank you, this concludes our presentation.  We are happy to address any questions.
This page was last updated on June 16, 2022