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FERC Revises Interconnection Rules for Small Generators

By Bud Earley on December 10, 2013
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FERC recently revised its rules for interconnecting small generation facilities (no more than 20 MW) to the grid.  Among other things, the new rules provide increased flexibility in qualifying for a “fast track” interconnection process, especially for solar and energy storage resources.

Under FERC’s small generator interconnection procedures, a generator makes an interconnection request and the transmission provider then evaluates whether the generator can be interconnected to the grid safely and reliably.  One procedure for evaluating an interconnection request is the Study Process, which normally requires three studies to identify adverse system impacts and any system modifications required to accommodate the interconnection.  There is also a Fast Track procedure available to facilities no larger than 2 MW that employs technical screens to quickly identify any safety or reliability issues associated with a proposed interconnection.  If the screens are passed, the interconnection moves forward without further study.

FERC found that, due to the increasing number of small generator interconnection requests driven by state renewable portfolio standards and growth in solar PV installations, reforms were needed to avoid inefficient interconnection queue backlogs and facilities undergoing the more costly Study Process when they could be interconnected under the Fast Track Process safely and reliably.

The most significant reform FERC adopted was to revise the Fast Track eligibility threshold for  inverter-based machines.  An inverter is a device that converts the direct current (DC) output of a DC generator to alternating voltage (AC) so that it can be interconnected with the AC electric system. The output of a solar panel is DC.  With the new rules, under certain conditions (generator capacity and interconnection voltage and location) inverter-based facilities up to 5 MW will be eligible for the Fast Track process.  That’s more than double the existing 2 MW threshold, which remains for other machines.  Accordingly, this change should allow more solar facilities to use the Fast Track Process.  In fact, FERC’s rulemaking process for these reforms was started in response to a petition by the solar industry requesting significant improvements to federal interconnection rules for solar wholesale distributed generation.

Other reforms adopted by FERC include:

  • Energy storage devices are explicitly included in the definition of Small Generating Facility.
  • Interconnection customers may request from the transmission provider a pre-application report that provides readily available information about system conditions at any possible interconnection point.  These reports are expected to help a customer select the best site for its facility, reduce developer costs, and diminish the practice of multiple interconnection requests for a single project.
Photo of Bud Earley Bud Earley

Bud Earley, a non-lawyer senior advisor, provides analysis and advice on a wide range of federal and state energy regulatory issues, including transaction and rate issues, regional transmission organization (RTO) tariffs and rules, interconnection, retail choice and demand response for electricity customers…

Bud Earley, a non-lawyer senior advisor, provides analysis and advice on a wide range of federal and state energy regulatory issues, including transaction and rate issues, regional transmission organization (RTO) tariffs and rules, interconnection, retail choice and demand response for electricity customers, a natural gas pipelines and hydroelectric facility licenses, and LNG export authorizations.

Working with Covington teams, Mr. Earley has provided expert advice and analysis to investment firms, utilities, independent power producers, project developers, customers, marketers and U.S. and international energy companies,

Prior to joining Covington, Mr. Earley served for over 30 years in various staff positions at the Federal Energy Regulatory Commission (FERC). While at the FERC, Mr. Earley was instrumental in developing and applying policies regarding the transition of the electric utility industry to competition, including policies regarding independent power producers, transmission access, standard generator interconnection procedures, organized electricity markets, mergers and market-based rates.

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  • Posted in:
    Energy and Utilities
  • Organization:
    Covington & Burling LLP

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