• FERC Proposes Reforms to Small Generator Interconnections
  • January 31, 2013
  • Law Firm: Troutman Sanders LLP - Atlanta Office
  • On January 17, 2013, FERC issued a Notice of Proposed Rulemaking (“NOPR”) that would revise the pro forma Small Generator Interconnection Procedures (“SGIP”) and Small Generator Interconnection Agreement (“SGIA”). The proposed revisions aim to reduce the time and cost of interconnection requests from small generators, promote more efficient interconnection, and eliminate barriers for the development of renewable energy. FERC also added in the NOPR that the proposed revisions help address various market changes, including “the growth of small generator interconnection requests and the growth in solar photovoltaic (PV) installations, driven in part by state renewable energy goals and policies.”

    In addition to some general clarifications to the existing pro forma SGIP and SGIA, the NOPR contains four proposed revisions:

    1. Allow interconnection customers the option to request a pre-application report, which would be provided by the transmission provider within 10 days and populated with existing information regarding the point of interconnection. (The customer would be required to pay a $300 fee for a pre-application report.)
    2. Increase the threshold for participation in the “Fast Track Process” - which is one of three alternative procedures for evaluating an interconnection request - from 2 MW to 5 MW. Eligibility should be based on an individual system’s characteristics such as: interconnection voltage level, circuit distance of the interconnection from the substation, and resource capacity.
    3. Revise the customer options meeting and the supplemental review for interconnection customers that fail the Fast Track screening process, and the 15 Percent Screen in particular. These proposed changes state that (a) a transmission provider will provide the interconnection customer an SGIA within five business days of the customer options meeting if the interconnection customer agrees to pay for the minor modifications proposed by the transmission provider, and (b) the interconnection customer can choose whether a supplemental review (which will consist of three additional screens), at a cost of $2,500, is performed or not.
    4. Revise the SGIP Facilities Study Agreement to allow interconnection customers the opportunity to submit comments on upgrades necessary for interconnection, while recognizing that the ultimate decision will be left to the transmission provider to decide whether those upgrades will be performed.

    FERC noted in the NOPR that it envisions that public utility transmission providers will see a significant penetration of distributed resources and more small generator interconnection requests as a result of the proposed changes. FERC also announced that it will hold a workshop before the end of the comment period to discuss the technical aspects of the NOPR. Comments will be due 120 days after publication in the Federal Register. Assuming the NOPR is published in the Federal Register within the next two weeks, public comments will likely be due towards the end of May.