On July 15, 2021, the Federal Energy Regulatory Commission (“FERC” or “Commission”) unanimously issued a wide-ranging advanced notice of proposed rulemaking (“ANOPR”), raising numerous proposals to consider revamping how regional transmission planning and generation interconnection are accomplished. If the proposals lead to a formal notice of proposed rulemaking, it will lead to a fundamental restructuring of the way in which transmission is planned and the cost that generation incurs to connect new generation to the transmission grid.
Chairman Glick and Commissioner Clements spoke to their concerns with the current regional transmission planning process in a concurrence to the issuance of the ANOPR:
"This Commission cannot sit idly by. . . . [W]e are concerned that existing regional transmission planning processes may be siloed, fragmented, and not sufficiently forward-looking, such that transmission facilities are being developed through a piecemeal approach that is unlikely to produce the type of transmission solutions that could more efficiently and cost-effectively meet the needs of the changing resource mix [the nation is facing]. Regional transmission planning processes generally do little to proactively plan for the resource mix of the future . . . . We are also concerned that current regional transmission planning processes are not sufficiently integrated with the generator interconnection processes, and are overwhelmingly focused on relatively near-term transmission needs, and that attempting to meet the needs of the changing resource mix through such a short-term lens will lead to inefficient transmission investments."
Regarding generation interconnection, the full slate of Commissioners stated:
"We believe it may be time to reexamine the rationale behind the Commission’s pricing policy established for interconnection-related network upgrades and to consider reforms to generator interconnection processes that would make such processes more efficient, less costly, and ensure that generation projects that are more “ready” than others are not unduly delayed in the queue."
The ANOPR questions all the historical and current bases on which transmission is planned and proposed generation connects to the grid.
Some of the Transmission Planning Issues for which FERC seeks comment include:
Some of the Generation Interconnection Issues for which FERC seeks comment include:
FERC discussed many proposals for how these transmission planning, generation interconnection and cost allocation reforms might be accomplished. FERC also asks for alternate means for it to consider.The implications of the ANOPR are massive. FERC is stepping up and asking the tough questions that may result in a long-needed revamp of transmission and generation interconnection planning and cost responsibility processes. Initial comments will be due in late October/early November. This is a unique, once-in-a-generation (no pun intended!) opportunity. We highly encourage all generators and investors to review the ANOPR and contact us with questions or if you would like to submit comments.
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