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6 Takeaways from FERC Order 2023 - FERC’s Latest Ruling on Interconnections

It's been a big week for the renewable industry and power systems engineers specifically. FERC's latest order, Order 2023 E-1 (Docket No. RM22-14-000) is broad and will fundamentally change the way we interconnect new resources on the grid. If implemented well, it can streamline the energy transition and improve reliability. If not, it could lead to more stagnation in the interconnection queues. Here are the top things to know, followed by a more detailed summary, and Telos’ experiences in these areas (attached).

Key Takeaways

  1. Developers will be expected to do more due diligence up-front - With increased penalties on withdrawing from the queue, developers will need to fully understand the markets and interconnection feasibility before applying for interconnection. Pre-feasibility studies are now critical.

  2. More standardization across the US – Many of the processes (sharing POIs, cluster studies, material modification studies, affected system studies) are already implemented at several ISOs. These best practices will become standard in all parts of the country, allowing ease of access into the queue.

  3. Alternative transmission technologies as a resource for cost and time savings in the cluster study process- The inclusion of alternative transmission technologies (GETs)-static synchronous compensators, static VAR compensators, advanced power flow control devices, transmission switching, synchronous condensers, voltage source converters, advanced conductors, and tower lifting- allows for the transmission provider to understand during the cluster study how alternatives to traditional network upgrades could benefit the cluster study through cost and time savings.

  4. RMS models, both generic and validated user defined, are required in the early stages of interconnection- Parity in RMS modeling requirements across the FERC regions will align the types of studies expected and will allow the interconnection studies to be performed with more rigor, ultimately preferring a model which looks more similar to the performance of the equipment to be installed, expressed through validation requirements (see attachment for definition of validated).

  5. EMT modeling efforts are at the discretion of each transmission operator- FERC requires the submission of validated user defined EMT models only if the transmission provider performs an EMT study as a part of the interconnection study process. This allows flexibility for the transmission provider to determine what makes sense in a given area.

  6. Order 2023 puts additional requirements on developers, transmission operators, equipment manufacturers, and consultants- Order 2023 is a step in the right direction to clear queue lines and help projects interconnect in an effective manner. Each of the components of Order 2023 will add to the workload of everyone involved: efforts to think strategically about entering the queue (developers); run the cluster studies and potentially rerun with GETs and/or project changes (transmission operators); and ensure the correct model type, that models run as expected, and that the equipment is in line with performance requirements (equipment manufacturers and consultants).

Telos has been involved in many of the areas impacted by FERC Order 2023 including:

  • Building project specific RMS user defined and generic models for developers to submit as a part of the interconnection study process

  • Building project specific EMT user defined models for developers to submit as a part of the interconnection study process

  • Working with various OEM models to understand the complexities and nuances of interconnection requirements with respect to modeling and performance

  • Testing models for ride-through requirement compliance, including PRC-024-3

  • Implementation and evaluating the impact of alternative transmission technologies

  • After completion of the interconnection process, helping developers ensure their RMS and EMT models match site performance through MOD-026 and MOD-027 testing

Reach out to learn more about how the new FERC Order 2023 might affect you and your ongoing wind, solar, and storage projects.


Summary of FERC Order 2023

FERC unanimously approved Item E-1 Order 2023 (Docket No. RM22-14-000) on July 28, 2023. The requirement for revision to pro forma Large Generator Interconnection Procedures (LGIP), pro forma Small Generator Interconnection Procedures (SGIP), pro forma Large Generator Interconnection Agreements (LGIA), and pro forma Small Generator Interconnection Agreements (SGIA) intends, as stated by FERC, to address interconnection queue backlogs, improve cost and timing uncertainty while additionally preventing undue discrimination for new technologies.

Since the pro forma was created 20 years ago, the technology requested for interconnection has evolved, as have the conditions encountered in various regions of the transmission system. FERC cites that at the end of 2022, more than 2,000 GW of generation and storage were waiting in the interconnection queues, further emphasizing the importance for reform and efficiency in connecting new projects. To put into perspective just how large this is, the total US utility-scale electricity-generation capacity was 1,160 GW, at the end of 2022.

The following details are taken directly from the FERC Order 2023. Following this breakdown will be more detail on Telos' experience and comments on many of these points included in the attachment.

FERC Order 2023 details the adopted reforms to the pro forma LGIP and pro forma LGIA including:

  1. Implementation of a first-ready, first-served cluster study process

    1. Transmission providers to publicly post available information pertaining to generator interconnection

    2. Transmission providers to use cluster studies as the interconnection study method

    3. Transmission providers to allocate cluster study costs on a pro rate and per capita basis

    4. Transmission providers to allocate network upgrade costs based on a proportional impact method

    5. Interconnection customers to pay study and commercial readiness deposits as part of the cluster study process

    6. Interconnection customers to demonstrate site control at the time of submission of interconnection request

    7. Transmission providers to impose withdrawal penalties on interconnection customers for withdrawing from the interconnection queue, with certain exceptions

  2. Increase the speed of interconnection queue processing

    1. Eliminates the reasonable efforts standard for conducting interconnection studies and imposes a financial penalty on transmission providers that fail to meet interconnection study deadlines

    2. Establishes an affected system study process and associated pro forma affected system agreements

  3. Incorporate technological advancements into the interconnection process

    1. Allow more than one generating facility to co-locate on a shared site behind a single point of interconnection (POI) while sharing the same interconnection request

    2. Evaluate proposed addition of a generating facility at the same POI prior to deeming such an addition a material modification if the addition does not change the originally requested interconnection service level

    3. Allow interconnection customers to access the surplus interconnection service process once the original interconnection customer has an executed LGIA or requests the filing of an unexecuted LGIA

    4. Use operating assumptions in interconnection studies that reflect the proposed charging behavior of an electric storage resource

    5. Evaluate the list of alternative transmission technologies enumerated in the final rule during the generator interconnection process

  4. Additional requirements for requests to interconnect a non-synchronous generating facility

    1. Provide the transmission provider with models needed for accurate interconnection studies

    2. Have the ability to maintain power production at pre-disturbance levels and provide dynamic reactive power to maintain system voltage during transmission system disturbances and within physical limits

    3. All newly interconnecting large generating facilities provide ride through capability consistent with standards and guidelines available in the balancing authority area

Order 2023 details the adopted reforms to the pro forma SGIP and pro forma SGIA including:

  1. Incorporation of alternative transmission technologies into the interconnection process

  2. Provide modeling and ride-through requirements for non-synchronous generating facilities

For further detail on Order 2023 with regard to inverter based resource modeling, evaluating alternative transmission technologies, ride-through requirements, Telos’ experiences, and our final thoughts- check out the blog attachment. Reach out to learn more about how the new FERC Order 2023 might affect you and your ongoing wind, solar, and storage projects.

Telos Energy FERC Order 2023 Blog Attachment
Download PDF • 114KB

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