NextEra said FERC must address participant funding, which forces interconnecting generators to pay for all or most network upgrades, to provide near-term relief by implementing a nationwide reimbursement policy for generators that cover grid upgrades.
Additionally, NextEra said planning regions should be required to use a biannually updated, 20-year planning horizon to better prepare for changes to the generation resource mix and support transmission needs. Transmission providers, the company said, should be required to identify renewable energy zones where the development of generation capacity is likely.
"The issues raised in the ANOPR are critically important to the future of our country’s electric power system, and to the health of our planet," NextEra wrote in its comments to FERC. "The Commission has chosen to tackle them not a moment too soon."
Ørsted, a global leader in onshore and offshore wind development, also requested reform to participant funding for grid upgrades and more proactive transmission planning from RTO/ISOs, as well as a dedicated planning process for offshore wind generation. The Biden administration has set a goal of deploying 30 GW of offshore wind energy generating capacity by 2030.
"In addition to the amount of [offshore wind] generation that is anticipated by 2040, the location of this generation is also well understood,"Ørsted said in its comment to FERC. "Because most of the RTO/ISO transmission planning processes rely solely on interconnection requests and ten-year load forecasts, transmission planning fails to anticipate the size and scale of future OSW development. This results in inaccurate plans and transmission infrastructure investments that are insufficient to meet the needs of known future offshore wind generation."
Shell, likewise, urged FERC not to ignore offshore wind generation in its transmission and interconnection planning.
"Based on the scope and nature of the questions posed in the ANOPR, it appears that the Commission potentially was more focused on onshore transmission… The Commission must encourage more efficient intra-regional and inter-regional planning, incentive transmission buildout, mitigate “first-mover” risk, and provide incentives to utilities and RTOs/ISOs to properly staff and manage transmission-related processes."
Bp, with its growing global portfolio of solar and wind projects, said transmission infrastructure improvements, and extended planning horizons, are crucial to the company's goal of reaching net-zero carbon emissions by 2050 or sooner.
"While the exact location of all future generation may not be known, it is feasible to estimate future locations based on new, known generation with utility or other offtake contracts, additional generators with signed generator interconnection agreements, and data and information from the existing interconnection queues," bp wrote. "This information can serve to inform scenario modeling of the future energy generation mix and assess transmission needs over longer time horizons."
EDF Renewables, a leading developer of solar, wind, hydrogen, and energy storage in the U.S., suggested FERC approach reforms with targeted, instead of sweeping, policy changes.
"While in theory sweeping reform such as consolidating transmission planning and cost allocation with generator interconnection processes could result in greater long-term efficiency, getting there will invariably involve more process, multiple rounds of compliance filings, regulatory uncertainty, and delay in implementation than an approach that is more incremental in nature," EDF Renewables said in its comments. "A decade after its issuance, Order No. 1000 itself illustrates the difficulty in reforming transmission policy. A more targeted approach may achieve most of the benefit of a more comprehensive approach but be easier and faster to implement, especially if it is based on best practices that have emerged in different RTOs and results in greater consistency across RTOs. As a practical matter, EDFR would respectfully suggest that the Commission not let the perfect be the enemy of the good as it considers which policies to finalize in this rulemaking."