The Federal Energy Regulatory Commission (FERC) clarified its position on Order 845 on February 21. “Order No. 845 adopted ten reforms to improve certainty for interconnection customers, promote more informed interconnection decisions, and enhance the interconnection process.”

FERC received 12 requests for a rehearing or clarification on Order 845. “The draft order grants in part and denies in part the requests for rehearing and clarification.” While most of the reforms in 845 will remain unchanged, FERC granted the rehearing for some of the reforms. The rehearing was granted to clarify “two aspects of the reform to remove a limitation on the interconnection customer’s option to build.”

The Order requires “transmission providers [to] explain why they do not consider a specific network upgrade to be a standalone network upgrade, and second, allows transmission providers to recover option to build oversight costs.” It also clarifies two different parts of the “option to build reform by finding, first, that the Order No. 845 option to build provisions apply to all public utility transmission providers, including those that reimburse interconnection customers for network upgrades, and second, that the option to build does not apply to stand alone network upgrades on affected systems.”

The rehearing also covered reforms to “create a surplus interconnection service process,” explaining that FERC has no intentions to “limit the ability of RTOs and ISOs to argue that an independent entity variation is appropriate.”

There were clarifications regarding the “study model and assumption transparency.” It found that:

• “Transmission providers may use the Commission’s critical energy/electric infrastructure information regulations as a model for evaluating entities that request network model information and assumptions.”
• “The phrase ‘current system conditions’ does not require transmission providers to maintain network models that reflect current real-time operating conditions of the transmission provider’s system but should reflect the system conditions currently used in interconnection studies.”

They also clarified the reforms to “institute interconnection study deadline reporting requirements.” Another clarification was on “the date for measuring study performance metrics and clarifies that the reporting requirements do not require transmission providers to post 2017 interconnection study metrics. Instead, the first required report will be for the first quarter of 2020.”

As for the reforms on “requesting interconnection service below generating facility capacity,” a partial rehearing was granted “to find that an interconnection customer may propose control technologies at any time at which it is permitted to request interconnection service below generating facility capacity.”

They also addressed “the reform that allows interconnection customers to request interconnection service below generating facility capacity,” clarifying that transmission providers “must provide a detailed explanation if it determines additional studies at the full generating facility capacity are necessary when the interconnection customer has requested service below full generating facility capacity.”

The draft order denied other requests for rehearings or clarification.

The draft order will go into effect 75 days after it is published in the Federal Register. Public utility transmission providers have to “submit a single compliance filing, within 90 days of the issuance of this order, to comply with Order No. 845 and this draft order on rehearing and clarification.”

• FERC