FERC Proposes Reforms to Facilitate Small Generator Interconnections

by Orrick, Herrington & Sutcliffe LLP
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On January 17, 2013, the Federal Energy Regulatory Commission (FERC) issued a notice of proposed rulemaking (NOPR) proposing reforms to the pro forma Small Generator Interconnection Procedures (SGIP) and the Small Generator Interconnection Agreement (SGIA).  Originally adopted in FERC’s Order No. 2006, the pro forma SGIP and SGIA govern the interconnection of small generating facilities – those with a capacity of 20 MW or smaller.  In the NOPR, FERC explains that market changes since the issuance of Order No. 2006, including the growth of small generator interconnection requests and the growth in solar photovoltaic installations, driven in part by state renewable energy goals and policies, necessitate a reevaluation of the SGIP and SGIA.  FERC states that it expects the proposed reforms to reduce the time and costs related to the interconnection of small generating facilities, while maintaining the reliability of the grid.

The NOPR proposes four principal reforms to the pro forma SGIP: 

  • providing interconnection customers with the option of requesting from the Transmission Provider a pre-application report providing existing information about system conditions at a possible Point of Interconnection;
  • increasing the generation capacity threshold for “Fast Track” interconnections from 2 MW to 5 MW, based on individual system and resource characteristics;
  • revising SGIP provisions related to the customer options meeting and the supplemental review following failure of the Fast Track screens that identify reliability or safety issues;
  • revising the pro forma SGIP Facilities Study Agreement by giving interconnection customers an opportunity to provide written comments on the upgrades that are necessary for the interconnection.

The NOPR also proposes clarifying revisions to the pro forma SGIP and SGIA.  FERC proposes to revise section 1.1.1 of the pro forma SGIP to require small generating facilities requesting Network Resource Interconnection Service to do so under the pro forma Large Generator Interconnection Procedures and execute a Large Generator Interconnection Agreement.  In addition, FERC proposes to modify section 1.5.4 of the pro forma SGIA to require interconnection customers to design, install, maintain and operate their small generator facilities in accordance with the latest frequency response reliability standards established by the North American Electric Reliability Corporation.

Comments on the proposed reforms are due June 3, 2013.  FERC will convene a workshop during the comment period to discuss the technical aspects of the proposals set forth in the NOPR.

If you have any questions regarding this matter, please contact:

Adam Wenner
Partner
awenner@orrick.com
202.339.8515

Cory Lankford
Managing Associate
clankford@orrick.com
202.339.8620

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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