FERC Filings
FERC RTO NOPR COMMENTS
RTOs Should Facilitate Interconnection Of New Generation To The Grid
An Additional Function
In addition to the seven functions identified in the NOPR, there is one additional function that should be added to the Commission's list. An important function for an RTO, important enough to warrant consideration as an eighth requirement, is facilitating interconnections for new generators. While this is referenced in the context of Function 7, planning and expansion, streamlined interconnection processes are of sufficient importance to be addressed separately. EPSA's comment on this issue follows:
RTOs Should Facilitate Interconnection Of New Generation To The Grid
An important function for RTOs is to offer "streamlined" consideration of generators' new or enhanced interconnection requests. Competitive generation, in the form of new or expanded merchant facilities, provides important benefits to the developing competitive electricity markets. New and expanded projects inject competition into pricing for power, promote diversity in products and services offered to the market, and mitigate the vertical market power of incumbent utilities. In addition, new generation can add market liquidity. To do so, however, generators must be able to reach the greatest number of possible markets (sinks), and marketers need to be able to reach the most number of generators (sources). Fair, workable and well-established interconnection rules and procedures are critical to the success of merchant construction. This is an extremely important and timely issue, as over 100,000 megawatts of merchant capacity has now been announced.
Specifically, when developers of new generation plan to interconnect with the transmission grid, a knowledgeable, neutral, unaffiliated body is needed to oversee the system impact and other studies and to set appropriate security and other requirements and to provide confidence that the process is fair. A mandatory interconnection policy, definitive timelines for actions, confidentiality guidelines, and standardized interconnection agreements will facilitate fair and timely action by RTOs in evaluating new interconnection requests.
RTOs can play this important role in facilitating the interconnection of new generation, which goes beyond the RTOs role in planning for existing uses of the transmission system. RTOs should be required to develop clearly articulated and timely procedures for new generation interconnections. RTOs should also be clearly established as the "lead agency" for new interconnections. While existing transmission owners may have a limited role in performing certain studies, generation developers cannot be "whipsawed" between the RTO and transmission providers, each waiting for the other to take certain actions or complete certain studies.