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Notice2024-18648

Innovations and Efficiencies in Generator Interconnection; Second Supplemental Notice of Staff-Led Workshop

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August 20, 2024

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Energy DepartmentFederal Energy Regulatory Commission

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<title>Federal Register, Volume 89 Issue 161 (Tuesday, August 20, 2024)</title>
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[Federal Register Volume 89, Number 161 (Tuesday, August 20, 2024)]
[Notices]
[Pages 67437-67440]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-18648]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. AD24-9-000]

Innovations and Efficiencies in Generator Interconnection; Second
Supplemental Notice of Staff-Led Workshop

As first announced in the Notice of Staff-Led Workshop issued in
this proceeding on May 13, 2024, as supplemented on June 27, 2024,
pursuant to 18 CFR 2.1(a), the Federal Energy Regulatory Commission
(Commission) will convene a staff-led workshop in the above-referenced
proceeding at Commission headquarters, 888 First Street NE, Washington,
DC 20426 on Tuesday, September 10, 2024 and Wednesday, September 11,
2024 from approximately 9:00 a.m. to 5:00 p.m. Eastern time. The
conference will be webcast.
Attached to this Second Supplemental Notice is an agenda for the
workshop, which includes a final workshop program and expected
speakers. The Commissioners may attend and participate in the workshop.
Panelists are asked to submit advance materials to provide written
answers to the questions presented for their respective panel and any
further information (e.g., summary statements, reports, whitepapers,
studies, or testimonies) that panelists believe should be included in
the record of this proceeding. Panelists should file all advance
materials in the AD24-9-000 docket by August 26, 2024.
Discussions at the workshop will not address compliance with
Commission Order No. 2023 \1\ or any pending Order No. 2023 compliance
filings. While the intent of the workshop is not to focus on any
specific matters before the Commission, in the event that panelist
materials or discussions focus on topics at issue in proceedings
currently pending before the Commission, a further notice will be
issued to identify those proceedings.
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\1\ Improvements to Generator Interconnection Procs. &
Agreements, Order No. 2023, 184 FERC ] 61,054, order on reh'g, 185
FERC ] 61,063 (2023), order on reh'g, Order No. 2023-A, 186 FERC ]
61,199 (2024).
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An additional supplemental notice will be issued following the
workshop with the opportunity for interested parties to submit post-
workshop comments.
The workshop will be open to the public to attend virtually or in
person and there is no fee for attendance. Information will also be
posted on the Calendar of Events on the Commission's website,\2\ prior
to the event. Attendees are requested to register through the
Commission's website on or before August 26, 2024. Registration will
help ensure that Commission staff can provide sufficient physical and
virtual facilities and to communicate with attendees in the case of
unanticipated emergencies or other changes to the conference schedule
or location. Access to the conference (virtual or in-person) may not be
available to those who do not register by August 26.
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\2\ <a href="https://www.ferc.gov/news-events/events/innovations-and-efficiencies-generator-interconnection-workshop-docket-no-ad24-9">https://www.ferc.gov/news-events/events/innovations-and-efficiencies-generator-interconnection-workshop-docket-no-ad24-9</a>.
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The workshop will be transcribed, and transcripts will be available
for a fee from Ace Reporting (202-347-3700). A link to the webcast of
this event and its recording will be available in the Commission
Calendar of Events at <a href="http://www.ferc.gov">www.ferc.gov</a>. The Commission provides technical
support for the free webcasts. Please call 202-502-8680 or email
<a href="/cdn-cgi/l/email-protection#6a091f191e05070f182a0c0f1809440d051c">[email&#160;protected]</a> if you have any questions.
Commission conferences are accessible under section 508 of the
Rehabilitation Act of 1973. For accessibility accommodations please
send an email to <a href="/cdn-cgi/l/email-protection#462725252335352f242f2a2f323f062023342568212930">[email&#160;protected]</a> or call toll free (866) 208-
3372 (voice) or (202) 502-8659 (TTY), or send a fax to (202) 208-2106
with the required accommodations.
For further information about this workshop, please contact:

Sarah McKinley (Logistical Information), Office of External Affairs,
202-502-8368, <a href="/cdn-cgi/l/email-protection#2e7d4f5c4f4600634d654740424b576e484b5c4d00494158">[email&#160;protected]</a>
Michael G. Henry (Technical Information), Office of Energy Policy and
Innovation, 202-502-8583, <a href="/cdn-cgi/l/email-protection#400d29232821252c6e08252e323900262532236e272f36">[email&#160;protected]</a>
Lewis Taylor (Legal Information), Office of General Counsel, 202-502-
8624, <a href="/cdn-cgi/l/email-protection#155970627c663b41746c797a6755737067763b727a63">[email&#160;protected]</a>.

Dated: August 14, 2024.
Debbie-Anne A. Reese,
Acting Secretary.

Staff-Led Workshop on Innovations and Efficiencies in Generator
Interconnection

Docket No. AD24-9-000

September 10 and 11, 2024

September 10 Agenda: Innovations

9:00 a.m.-9:15 a.m.: Welcome and Opening Remarks
9:15 a.m.-11:45 a.m.: Innovations Panel 1: Integrated Transmission
Planning and Generator Interconnection

This panel will discuss the extent to which transmission planning
and generator interconnection processes may be further integrated
beyond the reforms adopted in Order No. 1920.\3\ This panel will
explore ideas to more efficiently and proactively plan for and
interconnect new generation with increased cost certainty.
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\3\ Building for the Future Through Electric Regional
Transmission Planning and Cost Allocation, Order No. 1920, 187 FERC
] 61,068 (2024).
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Questions

1. Can efficiencies be gained through closer integration of
generator interconnection processes with transmission planning
processes? If so, how? What considerations need to be taken into
account? What are the advantages/disadvantages, including impacts on
consumers, to closer integration of these processes?
2. How might transmission providers more proactively, rather than
reactively, identify zones where new transmission capacity could most
efficiently accommodate proposed generating facilities?
3. What mechanisms may be appropriate for transmission providers to
use to determine the cost responsibility for such proactively planned
network upgrades? Is it appropriate for any such costs to be allocated
to load and if so, why? If it is appropriate, how should such costs be
allocated between load and interconnection customers both: (a) in
regions that use participant funding, i.e., where interconnection
customers are directly assigned network upgrade costs and (b) in
regions that do not use participant funding, i.e., where load is
assigned network upgrade costs? What are the advantages/disadvantages,

[[Page 67438]]

including impacts on consumers, of varying approaches to cost
responsibility?
4. Where the costs exceed estimates for such proactively planned
network upgrades, what are some approaches transmission providers could
use to address concerns regarding ensuring adequate funding? For any
given approaches proposed to ensure adequate funding, would these
mechanisms increase or decrease the time and/or costs required to
interconnect new resources, and how would this impact interconnection
customers?

Panelists

<bullet> Beth Garza--Senior Fellow, R Street Institute
<bullet> Arash Ghodsian--Vice President, Transmission & Policy,
Invenergy
<bullet> John Michael Haggerty--Principal, The Brattle Group
<bullet> Natasha Henderson--Senior Director of Grid Asset Utilization,
Southwest Power Pool
<bullet> Aubrey Johnson--Vice President of System Planning,
Midcontinent Independent System Operator, Inc.
<bullet> David Mindham--Director of Regulatory and Market Affairs, EDP
Renewables North America
<bullet> Zach Smith--Senior Vice President, System Resource Planning,
New York Independent System Operator

11:45 p.m.-12:45 p.m.: Lunch
12:45 p.m.-2:30 p.m.: Innovations Panel 2: Exploring Different
Approaches to Processing and Studying Generator Interconnection
Requests

This panel will focus on the viability and utility of different
approaches to organizing, processing, and studying generator
interconnection requests. Examples include a ``connect and manage''
process where interconnection requests for Energy Resource
Interconnection Service (ERIS) may be interconnected more quickly and
at lower cost than interconnection requests for Network Resource
Interconnection Service (NRIS), the use of competitive mechanisms (such
as an auction process) to allocate scarce capacity or to resolve
competition for the same point of interconnection, as well as other
potential approaches.

Questions

1. Please discuss the advantages and disadvantages of making ERIS,
which requires the proposed generating facility to mitigate overloads
through network upgrades to allow the generating facility to operate at
full output (albeit without the deliverability analysis that NRIS
entails), more like the approach used in the region managed by the
Electricity Reliability Council of Texas (ERCOT), sometimes referred to
as a ``connect and manage'' approach, which curtails the generating
facility in the study model when needed to minimize network upgrades at
the cost of risking real-time curtailments and subsequently identifies
necessary network upgrades through the transmission planning process.
2. How could elements of the ERCOT ``connect and manage'' approach
be incorporated into the current structure of Commission-jurisdictional
markets and pro forma generator interconnection procedures and
agreements?
a. Could customers interconnecting under this type of approach
eventually increase their deliverability or reduce curtailments, such
as by later converting to NRIS? How would this conversion be
accomplished?
b. In the context of RTO/ISO markets, how would an RTO/ISO account
for resources' differing levels of interconnection service (e.g.,
``connect and manage'' versus NRIS or its equivalent) and any
associated capacity rights when dispatching resources pursuant to
security-constrained economic dispatch?
3. What other approaches could build on the pro forma generator
interconnection procedures and agreements adopted in Order No. 2023 to
more efficiently organize interconnection queues and process
interconnection requests?
a. Should transmission providers proactively identify zones where
there is currently available transmission capacity or new transmission
capacity due to planned transmission facilities and provide information
on these zones to interconnection customers? If so, how should
transmission providers identify these zones and how should they
communicate that information to interconnection customers?
b. If transmission providers identify zones, as described in (a)
above, should auctions be used to assign queue positions or allocate
excess transmission capacity in those zones? What other approaches
could be considered?
c. How could such procedures ensure that generator interconnection
service is consistent with open access principles and is provided in a
manner that is not unduly discriminatory or preferential?

Panelists

<bullet> Liz Delaney--Vice President of Utility-Scale Policy and
Business Development, New Leaf Energy, Inc.
<bullet> Jennifer Galaway--Senior Manager of Regional Transmission
Development & Interconnection Services, Portland General Electric
<bullet> Dr. Warren Lasher--President, Lasher Energy Consulting LLC
<bullet> Tyler H. Norris--James B. Duke Fellow & Ph.D. Student, Duke
University
<bullet> Matt Picardi--Vice President of Regulatory Affairs, Shell
Energy North America
<bullet> Aaron Vander Vorst--Head of Growth Strategy and Transmission,
Enel North America
<bullet> Andy Witmeier--Director of Resource Utilization, Midcontinent
Independent System Operator, Inc.

2:30 p.m.-2:45 p.m.: Break
2:45 p.m.-4:30 p.m.: Innovations Panel 3: Prioritizing Certain
Generator Interconnection Requests

This panel will examine whether certain proposed generator
interconnection requests may be prioritized in the interconnection
queue without undue discrimination, building on the use of first-ready,
first-served cluster window deadlines and readiness milestones as
adopted by Order No. 2023.

Questions

1. Are there any viable, not unduly discriminatory methods for
further prioritization of interconnection requests to increase queue
efficiency and ensure just and reasonable rates?
2. Would prioritization of interconnection requests selected in
open competitive resource solicitations over other interconnection
requests that are not similarly selected add efficiency to the
generator interconnection process? How would this type of
prioritization affect the alignment of transmission planning, resource
solicitation, and generator interconnection processes? Under such a
prioritization, must an open competitive solicitation process meet
certain requirements to avoid infringing on the Commission's open
access transmission requirements?
3. Should interconnection requests for new generating facilities
submitted to replace existing generating facilities at existing points
of interconnection (replacement generation) have priority in the
transmission provider's processing of its interconnection queue over
the interconnection of new generating facilities at new points of
interconnection? If so, are there conditions that should be required
for such prioritization of replacement generation, for example, a
finding by the transmission provider that the replacement generation
allows for a faster or lower-cost interconnection as compared to the
interconnection of new generating facilities at new points of
interconnection?

[[Page 67439]]

4. Should interconnection requests from proposed new generating
facilities that meet certain resource adequacy or reliability needs
have priority over other interconnection requests for new generating
facilities?

Panelists

<bullet> Eric Blank--Chairman, Colorado Public Utilities Commission
<bullet> Joshua Burkholder--Managing Director of Integrated Resource
Planning, American Electric Power Company, Inc.
<bullet> Jason Burwen--Vice President of Policy and Strategy, GridStor
<bullet> Mike Calviou--Senior Vice President of US Policy & Regulation,
National Grid
<bullet> Adrien Ford--Wholesale Market Development Director,
Constellation Energy Generation, LLC
<bullet> Danielle Osborn Mills--Principal of Infrastructure Policy
Development, California ISO

4:30 p.m.-4:45 p.m.: Closing Remarks

September 11 Agenda

9:00 a.m.-9:15 a.m.: Welcome and Opening Remarks
9:15 a.m.-11:45 a.m.: Efficiencies Panel 1: Further Efficiencies in the
Generator Interconnection Process

This panel will evaluate the potential for increased efficiency
throughout the generator interconnection process as revised in the
Commission's Order No. 2023 \4\ (excluding topics covered in
Efficiencies Panels 2 and 3), such as providing additional pre-
application data to interconnection customers to allow for more
efficient decision-making or establishing fast-track processes for
interconnection requests at points of interconnection with fewer
transmission system constraints.
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\4\ Improvements to Generator Interconnection Procs. &
Agreements, Order No. 2023, 184 FERC ] 61,054, order on reh'g, 185
FERC ] 61,063 (2023), order on reh'g, Order No. 2023-A, 186 FERC ]
61,199 (2024).
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Questions

1. What specific types of additional pre-application data provided
to interconnection customers would facilitate greater efficiencies in
the application phase and the rest of the generator interconnection
process?
a. How would these types of data be helpful to interconnection
customers?
b. Are there inefficiencies or complications associated with
providing these types of additional pre-application data?
2. Regarding potential fast-track processes:
a. Of the existing fast-track processes, such as California ISO's
independent study process, which work well? What about them could be
improved or emulated to achieve greater efficiencies?
b. For interconnection requests that have little or minimal impact
on existing transmission capacity, should there be a fast-track process
or other prioritization method?
3. What types of remedial or mitigation mechanisms could address
instances where inadvertent oversights or technical difficulties result
in milestone failures, and interconnection customers do not learn of
these issues in time to file a waiver request? In such instances, where
good faith and a significant consequence to not meeting the particular
milestone are also present, how may transmission providers modify their
tariffs to reach a balanced resolution that enhances the stability of
the interconnection process while also ensuring that only viable
generating facilities remain in the queue?
4. What other opportunities exist to increase the efficiency of the
existing generator interconnection procedures and agreements?

Panelists

<bullet> Chris Barker--Managing Director, Transmission & Grid
Integration, Clearway Energy Group
<bullet> Donnie Bielak--Director, Interconnection Planning, PJM
Interconnection, LLC
<bullet> Jonathan E. Canis--General Counsel, Oceti Sakowin Power
Authority
<bullet> Brian Fitzsimons--CEO, GridUnity, Inc.
<bullet> Caitlin Marquis--Managing Director, Advanced Energy United
<bullet> Joe Rand--Energy Policy Researcher, Lawrence Berkeley National
Laboratory
<bullet> Martin Wyspianski--Vice President of Electric Engineering,
Electric Asset Management, Pacific Gas and Electric Company

11:45 p.m.-1:00 p.m.: Lunch
12:45 p.m.-2:30 p.m.: Efficiencies Panel 2: Automation and Advanced
Computing Technologies

This panel will assess opportunities for greater efficiency in the
processing and study of interconnection requests by automating
different steps in the process and using advanced computing
technologies, such as artificial intelligence, to shorten the timeline
from interconnection request to generator interconnection agreement.\5\
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\5\ Artificial intelligence (AI) is a broad term for a spectrum
of tools ranging from simple data validation to more sophisticated
machine learning and statistical modeling, to advanced deep learning
and generative AI.
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Questions

1. Please describe the different steps in the generator
interconnection process that may be automated and your experience
automating these steps, including data entry, base case model building,
running power flow studies, and identifying solutions. How can
automation reduce errors, improve study repeatability and transparency,
or address workforce needs?
2. Are you using AI tools in your generator interconnection
processes? Are these AI tools part of or separate from your work on
automation? What have been the advantages and disadvantages of adopting
these AI tools? Looking across the electric power industry, how common
is the use of AI tools?
3. Looking across the electric power industry, how common is
automation in the different steps of the generator interconnection
process (e.g., model building) today? What do you think are the main
challenges to broader adoption of automation? Do the Commission's
existing regulatory frameworks and/or utility processes present any
impediments in these areas? If so, what are the impediments? What role
can the Commission play in supporting the adoption of automation in the
generator interconnection process? What reforms, if any, would you
recommend that the Commission consider pursuing to facilitate greater
automation in the processing and study of interconnection requests?
4. Recognizing that a lack of standardized data inputs and outputs
can create challenges, how can automation reduce variability between
studies done by a given transmission provider or reduce variability of
studies between transmission providers?
5. In developing the base case model, what role can automation play
to address rapidly changing load forecasts or to improve the
coordination of generator interconnection and transmission planning?

Panelists

<bullet> David Bromberg--Co-Founder and CEO, Pearl Street Technologies
<bullet> Cody Doll--Sr. Manager of Transmission Business Management, at
NextEra Energy Resources
<bullet> Andrew Martin--Co-Founder and Transmission Lead, Nira Energy
<bullet> Anton Ptak--Director of Transmission and Interconnection, EDF
Renewables
<bullet> Jennifer Swierczek--Manager Generator Interconnection,
Southwest Power Pool

2:30 p.m.-2:45 p.m.: Break

[[Page 67440]]

2:45 p.m.-4:30 p.m.: Efficiencies Panel 3: Post-Generator
Interconnection Agreement Construction Phase

This panel will focus on the time period after execution of a
generator interconnection agreement (GIA), or its filing unexecuted,
through the commercial operation date (COD). Topics include
opportunities for greater efficiency, transparency, and accountability
in cost and time estimates for interconnection facilities and network
upgrades, as well as identifying other problems that contribute to
delays, such as supply chain issues, which may benefit from organized
cooperation among stakeholders.

Questions

1. What are the primary cost and timing concerns arising during the
period between execution, or unexecuted filing, of a GIA and the COD?
To the extent that cost increases and delays for interconnection
facilities and network upgrades are becoming more frequent, what are
the primary drivers of those issues?
2. Are there productive ways to increase transparency around
construction plans and progress of interconnection facilities and
network upgrades, such as CAISO's quarterly forum to track the status
of network upgrades, SPP's quarterly transmission project tracking
report, or California's newly instated metrics for tracking
distribution-level interconnection timeframes? What construction
metrics for interconnection facilities and network upgrades would be
most informative? How much documentation is reasonable and not unduly
burdensome?
3. Are there new approaches to sourcing equipment for
interconnection facilities and network upgrades that could be more
efficient? What safeguards would need to be in place for engineering,
procurement, and construction work for such facilities to begin
earlier? Is there a way to pool equipment purchasing or risk? Are there
efficiencies that may be achieved by standardizing engineering,
procurement, or construction of interconnection facilities and network
upgrades? Would pooling procurement of equipment provide manufacturers
with the certainty needed to increase their manufacturing capacity
thereby reducing lead times?
4. Are there efficiencies that may be gained by enhancing internal
transmission owner or RTO/ISO procedure, increasing staffing, or by
opening up interconnection facility studies and/or interconnection
facility construction work to contractors? How can the interconnection
study process be better aligned with interconnection customer-initiated
processes, such as permitting for the generating facility and generator
equipment procurement?

Panelists

<bullet> Lionel Chailleux--Senior VP, Market Development North America,
Hitachi Energy.
<bullet> Matthew Crosby--Senior Director, Grid Integration, Cypress
Creek Renewables
<bullet> Neil Millar--Vice President of Infrastructure and Operations
Planning Organization, California ISO
<bullet> Jing Shi--Managing Director of Renewable Integration, Duke
Energy
<bullet> Carrie Zalewski--Vice President of Transmission and
Electricity Markets, American Clean Power Association

4:30 p.m.-4:45 p.m.: Closing Remarks

[FR Doc. 2024-18648 Filed 8-19-24; 8:45 am]
BILLING CODE 6717-01-P

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