[co-authors: Ben Duwve, Alex Spratley]
On September 10 and 11, 2024, FERC staff held a two-day workshop at its headquarters in Washington, DC on opportunities to further refine the generator interconnection queue process. Panelists and FERC staff discussed potential enhancements to transmission planning and processing interconnection requests over the course of six panels on discrete issues related to interconnection queue reform. Panelists included representatives from public utilities, independent power producers, transmission providers, RTOs/ISOs, research organizations, and technology firms. Key points from each panel are summarized below. On September 12, 2024, FERC issued a formal notice requesting written post-workshop comments, which are due October 15, 2024.
Chairman Willie Phillips provided opening remarks, noting the continued need to further reform the queue process following Order Nos. 1920, 1977, and 2023 to address emerging grid issues such as data center load growth, increased electrification, extreme weather, supply chain challenges, and resource retirements. The Chairman noted the unprecedented interest from the public in participating in the workshop.
Innovations Panel 1: Integrated Transmission Planning and Generator Interconnection
The panel discussed the potential efficiencies gained through closer integration of generator interconnection processes with transmission planning. Panelists indicated consensus on the following issues: (i) separation of transmission system network upgrades from interconnection facilities, (ii) adoption of proactive transmission system planning measures, (iii) adoption of effective cost allocation procedures and streamlining the interconnection and transmission planning processes, and (iv) conducting interregional assessments while implementing region-specific approaches. Panelists also debated the role of grid-enhancing technologies as well as proposals for independent transmission developers to expedite processes and avoid cost allocation disputes.
Innovations Panel 2: Exploring Different Approaches to Processing and Studying Generator Interconnection Requests
In the second Innovations session, panelists examined different approaches to processing and studying interconnection requests. In particular, panelists discussed the advantages and disadvantages of the “connect and manage” interconnection process used by ERCOT and how it could potentially be incorporated into FERC-jurisdictional markets and pro forma interconnection procedures and agreements. Although panelists agreed that the “connect and manage” model can get generators interconnected quickly, many voiced concerns that such an approach would still lead to congestion and may not address overarching resource adequacy concerns. Panelists also explored various other approaches that could build on the approaches recently adopted in Order No. 2023 to help process interconnection requests more efficiently.
Innovations Panel 3: Prioritizing Certain Generator Interconnection Requests
In the third Innovations session, panelists explored various methods for prioritizing interconnection requests to enhance queue efficiency and ensure just and reasonable rates. Many panelists emphasized the importance of prioritizing certain interconnection requests at the front-end and discussed several criteria and processes to indicate project readiness, such as competitive resource solicitation, alignment with resource adequacy goals, the ability to replace retiring infrastructure, and the use of parallel queues for ready projects. Panelists stressed that these criteria and processes must be non-discriminatory while ensuring the interconnection queue progresses efficiently.
Efficiencies Panel 1: Further Efficiencies in the Generator Interconnection Process
Commissioner Mark Christie provided opening remarks to begin the second day, noting the need to focus on prioritizing interconnecting generation that can be built quickly and efficiently. He also stated that there is an urgent need to address reliability and that Order No. 888 should be amended to permit state regulators to designate resources that should be prioritized within their jurisdiction.
In this session, the panel focused on efficiencies in the early stages of the interconnection process, particularly concerning data transparency before an application is submitted. Panelists discussed strategies such as proactive communication and sharing of study methodologies for eliminating upfront uncertainties amongst early stages of project development. Panelists also weighed prioritization and fast-track procedures with other avenues for increasing interconnection efficiency, such as increasing automation in the prioritization process, modifying project criteria, or improving usage of grid technologies.
Efficiencies Panel 2: Automation and Advanced Computing Technologies
In the second Efficiencies panel, the discussion explored potential areas for automation of the interconnection queue process. Panelists noted that automation has been applied to several steps in the interconnection process already, including site optimization for generating facilities and helping to process study backlogs; but most panelists emphasized the potential for further automation through software. Panelists emphasized that the type of large language Artificial Intelligence (“AI”) models that consumers are familiar with are not suitable for streamlining the queue. Rather, they explained that because of AI’s superior pattern recognition abilities, it can be best deployed to verify large datasets such as those used for upfront parameter verification of interconnection applications or instability models. Panelists warned, however, that while further automation may help streamline certain steps in the interconnection process, sound engineering judgment will still be required to ensure quality data inputs and outputs.
Efficiencies Panel 3: Post-Generator Interconnection Agreement Construction Phase
In the third Efficiencies session, the panel focused on inefficiencies in the ending stages of the interconnection process—namely, the construction process. Panelists discussed cost drivers after a generator interconnection agreement is signed and existing strategies, especially within RTOs/ISOs and certain utilities, to optimize interconnection. For example, CAISO has created Transmission Development Forums which, on a semi-annual basis, provide transmission owners an avenue to provide project updates and receive questions regarding their project’s development. Panelists also emphasized the need for proactive communication to identify and optimize around construction risks.
A webcast of the workshop, designated Docket No. AD24-9, as well as links to the comments and presentations, are available here. The formal notice requesting post-workshop comments is available here.
