On February 21, 2019, the Federal Energy Regulatory Commission (FERC) issued Order No. 845-A in response to motions for rehearing of Order No. 845, which set forth reforms to the generator interconnection process. In Order 845-A, FERC continues to remove barriers for integrating storage on the electric grid. FERC implemented these reforms to the interconnection process to provide storage customers with better information and more options for obtaining interconnection service so that there would be fewer interconnection requests that do not reach commercial operation.

FERC implemented ten reforms to ensure certainty for interconnection customers, promote more informed interconnection decisions, and enhance the interconnection process. Below is an outline of FERC’s specific reforms in each of those categories:

1. Ensure Certainty for Interconnection Customers

• Removes limits to using stand-alone upgrades on non-affected systems
• Requires transmission providers to establish interconnection dispute resolution procedures

2. Promote Informed Interconnection Decisions

• Requires transmission providers to devise and publish a method for determining contingent facilities
• Mandates that transmission providers list the specific study processes and assumptions for forming the network models used for interconnection studies
• Revises the definition of “Generating Facility” to explicitly include electric storage resources
• Establishes reporting requirements for aggregate interconnection study performance

3. Enhance the Interconnection Process

• Allows an interconnection customer to request a level of interconnection service that is lower than its generating facility capacity
• Requires transmission providers to allow for provisional interconnection agreements for limited operation of a generation facility prior to completion of the full interconnection process
• Mandates that transmission providers create processes for interconnection customers to use surplus interconnection service (that can be accommodated without necessitating the construction of new network upgrades) at existing points of interconnection
• Allows transmission providers to assess, and if necessary, study an interconnection customer’s technology changes without affecting the interconnection customer’s queued position

The regulations are effective 75 days after the date that the Order is published in the Federal Register. However, each public utility transmission provider must submit, by May 22, 2019, a single compliance filing that revises its LGIP and LGIA.