On April 21, 2022, the Federal Energy Regulatory Commission (“FERC” or the issued a Notice of Proposed Rulemaking introducing proposals to reform the pro forma Open Access Transmission Tariff and the pro forma Large Generator Interconnection Agreement (“LGIA”) to update the Commission’s existing regional transmission planning and cost allocation requirements (the “Transmission Planning NOPR”). On June 16, 2022, the Commission also issued a Notice of Proposed Rulemaking presenting potential reforms to the pro forma LGIA and associated Procedures as well as to the pro forma Small Generator Interconnection Agreement and associated Procedures (together, the “Interconnection Agreements and Procedures”) to address the needs presented by the transforming grid and evolving resource mix (the “Interconnection NOPR”).
NERC CEO Endorsement
NERC Chief Executive Officer and President, James Robb, in his testimony before the U.S. Senate Committee on Energy and Natural Resources, stated that it “is imperative to understand and plan for the different operating characteristics of variable, inverter-based resources.
This includes time to study, plan for, and develop effective solutions to the challenges.” The Commission’s Transmission Planning NOPR recognizes that existing regional transmission planning requirements do not result in sufficiently long-term assessments of transmission needs.
The ERO Enterprise supports the Commission’s exploration of more sophisticated and better coordinated transmission planning. Transmission will be the key to support the resource transformation enabling delivery of energy from areas that have surplus energy to areas that are deficient. The frequency of such occurrences are increasing as extreme weather conditions resulting from climate change impact the fuel sources for variable energy resources. Regional transmission planning can ensure that sufficient amounts of transmission capacity will be needed to address these more frequent extreme weather conditions.
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