FERC Reforms Small Generator Interconnection Procedures and Agreement to Facilitate Interconnection of Small Solar Generation and Energy Storage Projects

On November 22, 2013, the Federal Energy Regulatory Commission (FERC) issued a Final Rule (Order No. 792) promulgating reforms to its pro forma Small Generator Interconnection Procedures (SGIP) and pro forma Small Generator Interconnection Agreement (SGIA), which set forth terms and conditions for interconnection service for generators and other resources not larger than 20 MW, to make more efficient and less costly the Small Generating Facility interconnection process while continuing to ensure safety and transmission system reliability.  The reforms largely track the changes addressed in FERC’s Notice of Proposed Rulemaking issued in January 2013, as summarized in a prior post, with various adjustments to reflect suggestions and concerns raised in the rulemaking proceeding, and likely will further facilitate the growing market penetration of small generation and energy storage resources.  Renewable energy industry groups applauded the Final Rule for its potential to expedite and reduce the cost of interconnecting new solar-powered generating facilities.

Among other things, FERC in the Final Rule:

  • Provided Interconnection Customers with the option to request from the relevant Transmission Provider, for a default fee of $300, a pre-application report regarding system conditions at a possible Point of Interconnection, which the Transmission Provider must use “reasonable efforts” to provide within twenty days;
  • Revised the 2 MW threshold for participation in the SGIP’s Fast Track Process, consideration under which will now be based on individual system and generator characteristics up to a limit of 5 MW for inverter-based generators (FERC preserved the 2 MW Fast Track Process threshold for synchronous and induction generators due to technical differences between these generators and inverter-based generators);
  • Revised provisions related to the customer options meeting and supplemental review following a failure of the Fast Track Process screens so that the supplemental review is performed at the discretion of the Interconnection Customer, at its expense, based on actual costs, and includes a minimum load screen, voltage and power quality screen, and safety and reliability screen to determine if a Small Generating Facility may be interconnected safely and reliably;
  • Revised the pro forma SGIP Facilities Study Agreement to enable the Interconnection Customer to provide written comments on the upgrades required for the interconnection in the facilities study;
  • Clarified the definition of “Small Generating Facility” in the SGIP and SGIA to expressly include energy storage devices; and
  • Revised provisions related to measuring the capacity of generating facilities, including storage devices, to determine if a resource is a Small Generating Facility and whether it is eligible for the Fast Track Process.

Order No. 792 will become effective sixty days after publication in the Federal Register and requires each public utility Transmission Provider to submit a compliance filing within six months of the effective date to revise its SGIP and SGIA or other document(s) subject to FERC jurisdiction as necessary to demonstrate compliance with the reforms.