Flummoxed by FERC Filings?
Stay out of policy purgatory with our in-depth status check on each ISO's recent compliance filings for Orders 2023 and 2023-A
We’ve said it before, and we’ll say it again: utility-scale interconnection is fraught with uncertainty. Whether you’re a transmission provider overwhelmed with a massive influx of applications or a project developer trying to navigate the interconnection black box, you’ve probably experienced more than your fair share of frustration.
And we can understand why. According to LBNL’s most recent version of “Queued Up,” ~12,000 projects, or 2.6 terawatts of renewable energy generation are idling in interconnection queues. While some ISOs have larger backlogs than others, the problem is nationwide, and we are only just starting to realize solutions.
Because the interconnection problem has far-reaching implications, the Federal Energy Regulatory Commission (FERC) jumpstarted the quest for solutions and issued Order Nos. 2023 and 2023-A. Together, these rulings are designed to reduce the backlogs and modernize the nation’s transmission system.
Officially known as “Improvements to Generator Interconnection Procedures and Agreements” these orders are certainly a step in the right direction. However, they also represent new and necessary challenges to transmission providers and project developers.
For instance, Orders 2023 and 2023-A require some transmission providers to completely overhaul existing interconnection processes, such as transitioning from serial requests to cluster studies. Though we expect this transition will accelerate study timelines, it will also introduce complexities that transmission providers must dedicate time and resources to fully understand.
Project developers are also affected by these policy changes. Depending on location, developers may find that rules have changed completely or that they’re stuck in “policy purgatory.” In some regions, queue windows are closed until further notice, and in others, “transition periods” have been implemented until the transmission provider is further along in compliance with Orders 2023 and 2023-A.
Returning to our sentiment at the beginning of this article, interconnection is already challenging enough. Considering that Order 1920 is also getting much attention, stakeholders need to stay updated on forthcoming changes from 2023.
In May 2024, each ISO submitted their compliance filings for FERC Orders 2023 and 2023-A. We’ve tried to simplify the process for you and have reviewed thousands of pages of compliance filings to develop a cheat sheet detailing how each ISO is executing requirements as outlined in the “Final Rule.”
As a refresher, the three main categories of reform in Order No. 2023 and 2023-A are:
Transitioning from a First-Come, First-Served Serial Process to a First-Ready, First-Served Cluster Study Process;
Facilitating Public Interconnection Information Access
Cluster Study Replaces Serial Study
Increased Financial Readiness and Site Control Requirements
Increasing the Speed of Interconnection Queue Processing;
Elimination of the Reasonable Efforts Standard
Affected Systems Standardization
Incorporating Technological Advancements in the Interconnection Process.
Co-location Flexibility
Incorporating Alternative Transmission Technologies
Modeling and Performance Requirements for Non-Synchronous Generating Facilities
We analyzed the recent compliance filings for SPP, MISO, PJM, ISO-NE, the NYISO, and the CAISO to develop the cheat sheet below, organized by the reform area subcategory. We did not include ERCOT, as it is not regulated by FERC.
Cells highlighted in “green” are reform areas the transmission provider accepts without question or is already compliant with. Cells highlighted in "blue” are areas for which the ISO is requesting an independent entity variation (IEV), and cells highlighted in “yellow” are areas the ISO is working on implementing.
We applaud the transmission providers that have commenced the transition and hope these rulings will meaningfully improve utility-scale interconnection in the United States. It is also worth noting that while this cheat sheet is a helpful tool for an overarching compliance perspective on FERC Orders 2023 and 2023-A, we highly recommend validating areas of interest in the linked filings found at the bottom of this article. Though lengthy, the filings do include more technical information that could be helpful in navigating the interconnection process successfully.
Please contact us if you have any questions or would like to learn more about our software automation solutions, Interconnect™ and SUGAR™, that help mitigate the interconnection backlog and complement FERC Orders 2023 and 2023-A.
Links to FERC Order 2023 compliance filings:
SPP:
MISO
PJM
ISO-NE
NYISO
CAISO