FERC Proposes Reforms to Benefit Interconnection of Renewable Resources, Including Solar

By Natara Feller, Esq. and Benjamin Falber

The Federal Energy Regulatory Commission (“FERC”) is proposing four reforms to better facilitate connection of small renewable generation facilities – particularly solar facilities - to the power grid.  On January 17, FERC issued a Notice of Proposed Rule Making (“NOPR”)  on interconnections for facilities of 20 megawatts or less.  This is excellent news for local, small scale solar and wind generation.

The proposed modifications to FERC’s small generator interconnection procedures are intended to reduce the time and cost to process interconnection requests, particularly those of solar generators.  The 4 proposed reforms: 

1. Help applicants better evaluate their interconnection options: Small facilities may request a report from transmission providers on system conditions at a point of interconnection before submitting a formal interconnection request.  For a fee of $300, a transmission provider would be required to make available, within 10 days, information on the capacity, existing generation, voltage, circuit distance, and other technical elements.  

2. Increase the threshold for the Fast Track Process from 2 MW to 5 MW facilities: The Fast Track Process has applicants go through a technical screening that detects safety or reliability issues. The Fast Track Process is an alternative to the Study Process, which is more costly and involves a scoping meeting, a feasibility study, a system impact study, and a facilities study.

3. Offer interconnection options, even if there are safety or reliability issues: the Transmission provider would be required to offer to:

• Make changes to the transmission system at the customer’s expense, or

• Hold a supplemental review at the customer’s expense,  or

• Evaluate the interconnection under the Study Process.

4. Provide small renewable generators an opportunity to be heard: Under the proposed changes, small renewable generation facilities will be given the opportunity to review and provide written comments on transmission upgrades before final plans are made in order to ensure that all interests are heard.

Notably, in addition to the generation capacity limit, eligibility for Fast Track review is based on sufficient line voltage at interconnection and a limit on circuit distance from interconnection to substation.   If the project fails any of the Fast Track screens, but the Transmission Provider nonetheless finds that there no safety or reliability issues, the Transmission Provider will provide a Small Generator Interconnection Agreement (SGIA). 

According to Commissioner Norris, state and local policies, including renewable portfolio standards, have significantly increased the growth of solar, and other types of renewable energy sources.  The proposed reforms are both necessary and responsive to the significant increase in small renewable resources as well as to the interconnection of renewable distributed energy. 

Opportunity to Submit Comments and Technical Workshop 

Comments on the NOPR are due June 3, 2013.  FERC also announced that it will hold a workshop before the end of the comment period to discuss the technical aspects of the NOPR.  Cleantech Law Partners is in the process of building a coalition to submit comments in this proceeding.  If you are interested in joining, please contact Natara Feller, Director of CLP’s FERC Practice Group at nfeller@cleantechlawpartners.com