In the recently announced ANOPR on transmission planning, cost allocation, and generator interconnection reform process, FERC is seeking comments on whether it should require transmission providers to consider grid enhancing technologies in generator interconnection studies to interconnect renewable projects. FERC is also seeking comments from transmission providers who have already implemented and have experience with these technologies.
FERC is looking for comments on transmission planning, cost allocation, and generator interconnection processes since this could be one of the most important transmission planning orders from FERC since Order 2003. Renewable developers should note the focus of this FERC on speeding up renewable project interconnections because most regional grid operators have solar projects in the queue.
As a presenter at the recent PJM interconnection policy workshop put it, FERC Chair Glick and Commissioner Clements indicated their specific concerns with the current state of affairs in generator interconnections and transmission planning. Both FERC Commissioners are concerned that transmission planning is not integrated with generator interconnection planning, and planning focuses on meeting near-term needs.
Without stating it specifically, FERC with this ANOPR has laid out the problem of lack of transmission build-out to interconnect renewable projects. Even if Commissioner Danly dissents in the final order issuance, FERC Commissioners would have a majority vote.
Based on the NOPR on transmission line ratings, we know what the responses to FERC ANOPR on GETs topic would be
FERC issued a Notice of Proposed Rulemaking (NOPR) on “Managing Transmission Line Ratings” on November 19, 2020. FERC gave all interested parties 60 days to respond. Key stakeholder comments filed in that NOPR proceeding include,
1. Previous FERC Chairman Norman Bay wrote in EDF Renewables comments that transmission congestion could limit a RE project output, and hence EDF supports transparent transmission line ratings.
2. When new generator interconnection projects are delayed by more than a year, American Clean Power Association (ACP, previously American Wind Energy Association AWEA) and SEIA support implementing DLRs.
3. Clean Energy Parties (NRDC and others), ACP and SEIA, and the WATT Coalition support an option for interconnection customers to fund a DLR study if the TO does not study DLR as an alternative for network upgrades.
4. MISO Independent Market Monitor (IMM) also supports DLRs.
FERC defined Dynamic Line Ratings DLR as: “a transmission line rating that: (1) applies to a period of not greater than one hour; (2) reflects up-to-date forecasts of inputs such as (but not limited to) ambient air temperature, wind, solar irradiance intensity, transmission line tension, or transmission line sag; and (3) is calculated at least each hour, if not more frequently.”
The real issue is the Transmission Owner (TO) incentives, and the solution lies with FERC
In the FERC NOPR on transmission line ratings, in which FERC has not issued an order, three PJM TOs (AEP, Dominion, and Exelon) do not want FERC to mandate DLRs. MISO TOs in a joint filing and PJM say the same thing.
If FERC mandates DLRs, PJM TOs want PJM to have the flexibility to implement DLRs, and that PJM should consult their TOs.
In the ANOPR, FERC is also seeking comments on the TO incentives question in sections such as, Identifying Geographic Zones That Have Potential for High Amounts of Renewable Resource Development to Meet Increased Demand, Incentivizing Regional Transmission Facilities, Participant Funding and Eliminate Participant Funding for Interconnection-Related Network Upgrades. Hence FERC is looking to incentivize TOs to adopt GETs as alternatives to network upgrades.
FERC could adopt a criterion to implement DLRs
In their comments to FERC on transmission line rating NOPR, ACP and SEIA propose a criterion for implementing DLRs based on the following conditions:
• “Congestion costs have surpassed $1 Million per year;
• New generation interconnection has been delayed by more than one year due to factors that include transmission line capacity, or
• The generation has been curtailed by more than 20 percent on average for one year due to factors that include thermal constraints on line capacity.”
This criterion can be helpful for renewable developers to support in their comments to FERC on the ANOPR because it directly answers the question FERC is asking “whether FERC should require transmission providers to consider grid enhancing technologies in generator interconnection studies to interconnect renewable projects?”. The answer is yes. FERC should require DLRs under the above-stated conditions.
Once published in the federal register, transmission providers have 75 days to respond. Reply comments are due 105 days after the federal register publication date. Assuming August 2 as the publication date in the federal register, all interested parties can reply by October 15. Stakeholders can reply to other’s comments by November 15.
FERC may collect stakeholder comments via technical conferences held in different parts of the country. It is equally likely that FERC would issue a NOPR and then a final FERC Order. Meanwhile, RE developers should look at network upgrade costs from RTO generator interconnection studies and explore the possibility of GETs like solutions.