On October 25, the Department of Energy issued a Request for Information (“RFI”) on its draft Transmission System Interconnection Roadmap (“Roadmap”), issued the same day. The draft Roadmap provides a series of recommendations intended to improve the transmission system interconnection process to facilitate the reliable, rapid, and equitable deployment of clean energy resources. Though some of the Roadmap’s recommendations align or overlap with recent FERC Order No. 2023, the Roadmap is intended to go beyond near-term process improvements and encourage industry-wide, long-term modifications to how the country approaches transmission-level interconnection. While most transmission reform efforts to date have focused on transmission providers and their processes, the Roadmap is unique in that it provides recommended action items for a wider group of interconnection stakeholders, including customers, state agencies, federal regulators, advocacy groups, consultants, and the research community. Responses to the RFI are due November 22, 2023 at 5 PM.
The Roadmap identifies four overarching goals – (i) increase data access and transparency; (ii) improve interconnection process and timing; (iii) promote economic efficiency; and (iv) maintain a reliable grid. To achieve these goals, the Roadmap offers a series of proposed near-, medium-, and short-term solutions, a handful of which are explored below.
With respect to data access and transparency, the Roadmap recommends greater and standardized visibility into existing projects in interconnection queues to allow market participants to make more educated development decisions. The Roadmap suggests that FERC’s basic interconnection data requirements do not go far enough, and that this lack of transparency is contributing to the high number of speculative interconnection requests and queue backlogs. Moves to publicize certain interconnection data, particularly interconnection costs, will likely receive a lukewarm reception from developers participating in competitive solicitations. The Roadmap also suggests greater transparency and useability for interconnection models, including identifying ways to make them more accessible to stakeholders operating with fewer resources, such as open source models.
To improve interconnection processes and timing, the Roadmap makes several recommendations that overlap with Order No. 2023, including promoting interconnection study timelines and enforcement of penalties, as well as more stringent commercial readiness requirements and financial commitments to participate in the interconnection queues. Other recommendations relate to staffing, including hiring temporary staff and outsourcing to more quickly eliminate mounting queue backlogs. Notably, the Roadmap floats the long-term possibility of transitioning to market-based queue rationing instead of open access. This would represent a paradigm shift in the interconnection process and likely require significant changes to wholesale markets and the industry, broadly. It also raises questions of fairness and equity as large developers (with large balance sheets) will be better positioned to participate in this model than other developers.
With respect to economic efficiency, the Roadmap suggests that a more proactive approach to identifying and allocating costs of transmission investments can reduce the frequency and magnitude of the costs. The Roadmap also recommends leveraging federal financial support through the tools under the Bipartisan Infrastructure Law’s Transmission Facilitation Program and the Inflation Reduction Act’s Transmission Facility Financing Loan Program. As a long-term option, the Roadmap recommends what it refers to as “delinking the interconnection process and network upgrade investments.” According to the Roadmap, removing network upgrade costs from the interconnection process could provide greater interconnection cost certainty upfront, resulting in a reduced number of speculative interconnection requests and subsequent delays – another paradigm shift.
Finally, on the reliability front, the Roadmap makes a series of recommendations to improve interconnection modeling and tools to help prevent large disturbance events. These include adopting interconnection requirements for inverter-based resources (an issue FERC released on order on last week), and identifying the need for new standards to reflect emerging technologies.
The RFI consists of eight questions seeking feedback on the Roadmap, including whether the Roadmap addresses the most urgent interconnection needs, barriers to executing the solutions in the Roadmap, and whether commenters believe the Roadmap introduces “sufficient out-of-the-box ideas” that can “inspire fundamental changes” to the interconnection processes. The RFI also requests feedback on whether the Roadmap sufficiently addresses diversity, equity, and inclusion issues in the interconnection process.
