Brett A. Snyder and Lamiya N. Rahman ●
On October 25, 2023, the Department of Energy (“DOE”) released a draft roadmap addressing challenges to the interconnection of clean energy projects to the transmission grid. The roadmap, developed by the Interconnection Innovation e-Xchange (“i2X”),[1] identifies short-term (1–2 year), medium-term (2–5 year), and long-term (5+ year) solutions aimed at addressing barriers to connecting solar, wind, and battery projects to the grid and maintaining grid reliability.[2]
As the roadmap notes, interconnection requests have dramatically increased in the past decade, with 2,500 to 3,000 new requests a year, reflecting 400 to 600 GW/year of proposed capacity.[3] At the same time, constraints on transmission capacity and issues in the interconnection process have caused large backlogs, delays, and interconnection costs, resulting in a “more difficult and costly energy transition for ratepayers, utilities, and their regulators.”[4]
DOE has also issued a request for information (“RFI”) to seek feedback from interconnection stakeholders regarding the draft roadmap. Responses to the RFI are due on November 22, 2023.
The draft roadmap proposes interconnection improvements in four categories:
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- Increasing Data Access and Transparency. The draft roadmap proposes short-term and medium-term solutions that call on the Federal Energy Regulatory Commission (“FERC”), the Energy Information Administration (“EIA”), transmission providers, and interconnection customers, among others, to improve the scope, accessibility, and quality of data regarding projects already in the queue, interconnection study models and assumptions, and management and analysis of interconnection data.
- Improving Interconnection Process and Timing. The draft roadmap identifies various solutions to improve and expedite the interconnection process.
- Queue Management: The draft roadmap recommends, among other things, more stringent requirements for interconnection customers (g., stricter commercial readiness requirements, financial commitments, and withdrawal penalties); enforcement of interconnection study timelines and penalties for transmission providers completing studies; greater automation in the interconnection process; one-off interventions for mitigating backlogs; fast-track processes; and market-based approaches to rationing interconnection access.
- Affected System Studies: The draft roadmap proposes increased voluntary collaboration on affected system studies (e., studies that evaluate impacts on neighboring electricity systems); using an energy-only modeling standard; and evaluating interregional transmission solutions through joint transmission planning.
- Workforce Requirements: To address the growing need for employees in the interconnection process, the draft roadmap suggests quantifying increasing workforce requirements, upskilling the existing workforce, and considering improvements to compensation and benefits, among other workforce recommendations.
- Promoting Economic Efficiency. The roadmap also emphasizes improved cost allocation and transmission planning to ensure that new transmission facilities and upgrades are built and paid for in the most economically efficient manner.
- Cost Allocation: To improve allocative efficiency, the roadmap recommends evaluating options (including federal, state, and participant-funded options) for identifying and allocating proactive transmission investment costs; ensuring generators can interconnect without paying for congestion-related upgrades under energy-only interconnection service; and assessing options to delink the interconnection process and network upgrade investments to ensure greater upfront interconnection cost certainty.
- Coordinating Interconnection and Transmission Planning: The draft roadmap recommends that interconnection and long-term transmission planning be more closely aligned to ensure that facilities that would have been more efficiently incorporated in transmission plans are not implemented and paid for instead within the interconnection process. In this regard, the roadmap suggests greater data input, assumptions, and timing alignment between the interconnection and transmission planning processes. The draft roadmap also recommends that equity-related goals be included in transmission planning to address potential impacts on environmental justice communities.
- Interconnection Studies: The roadmap suggests developing new best-practice study methods to respond to changes in the generation mix and load; considering effective mitigation options that should be evaluated during interconnection studies, including alternative transmission technologies and control options for inverter-based resources (“IBRs”); and evaluating options to allow interconnection customers to self-fund and prepare their own interconnection studies.
- Maintaining Grid Reliability. Understanding and addressing how IBRs interact with the transmission grid is critical to ensuring grid reliability as more wind, solar, and battery projects connect to the grid. As the draft roadmap points out, IBR disconnection issues have been increasingly prevalent in recent years but have not been adequately identified in the interconnection study process. The draft roadmap identifies various suggestions to maintain and enhance grid reliability.
- Interconnection Models and Tools: The draft roadmap makes various suggestions to enhance modeling of IBRs during the interconnection process, including submission of validated electromagnetic transient (“EMT”) models for all IBRs and developing screening criteria to determine when EMT studies are needed in a region; developing rules for dynamic model quality testing and validation; and developing study process flow that better aligns with generation project development timelines.
- Interconnection Standards: The draft roadmap includes recommendations on implementing interconnection standards relating to IBR generator capabilities and expected performance. These include implementing harmonized and comprehensive interconnection requirements for IBRs; implementing plant conformity assessments as part of interconnection procedures; evaluating the need for new interconnection requirements to address expected performance from emerging technologies; assessing cybersecurity concerns in the interconnection process; and evaluating the relationship between the interconnection process and system reliability.
- Increasing Data Access and Transparency. The draft roadmap proposes short-term and medium-term solutions that call on the Federal Energy Regulatory Commission (“FERC”), the Energy Information Administration (“EIA”), transmission providers, and interconnection customers, among others, to improve the scope, accessibility, and quality of data regarding projects already in the queue, interconnection study models and assumptions, and management and analysis of interconnection data.
The draft roadmap also establishes five performance targets to measure progress in interconnection reforms:
| Target | Target Value | Recent Value[5] |
| Average time from interconnection request to interconnection agreement for completed projects | <18 months | 33 months (2022) |
| Three-year average completion rate (by capacity) | >30% | <15% (2016)[6] |
| Average interconnection costs for completed projects | Under Stakeholder Development | $87/kW (2020–2021) |
| Standard deviation of interconnection costs for all projects | <$150/kW | $ 551/kW (2020–2021) |
| Number of annual North American Electric Reliability Corporation (“NERC”) disturbance events for new IBRs attributed to inaccurate IBR modeling | 0 | 4 (2022) |
According to DOE, the draft roadmap proposes solutions that both build on and go beyond the interconnection reforms recently adopted by the FERC in Order No. 2023. In Order No. 2023, FERC adopted a final rule designed to streamline the process by which generation resources can connect to the interstate transmission grid, with compliance required for most transmission providers by April 2024. Among other things, Order No. 2023 revises the large generator interconnection procedures by:
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- Replacing the current first-come, first-served process with a first-ready, first-served interconnection cluster study process and increasing customer readiness and financial requirements;
- Increasing the speed of interconnection queue processing by, among other things, imposing strict study deadlines and penalties on transmission providers; and
- Incorporating technological advancements into the interconnection process.
In addition to the interconnection reforms in Order No. 2023, FERC has adopted or proposed various reforms to transmission planning, cost allocation, and grid reliability, including among other things:
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- A Notice of Proposed Rulemaking (“NOPR”) to implement longer-term approaches to regional transmission planning and cost allocation for transmission projects (Docket No. RM21-17)
- An NOPR to amend FERC’s existing regulations relating to its backstop permitting authority for siting certain interstate electric transmission facilities (Docket No. RM22-7)
- A recent Final Rule directing NERC to establish new or modified Reliability Standards to address reliability issues relating to IBRs (Order No. 901)
- A Final Rule directing NERC to establish standards regarding transmission planning for extreme weather events (Order No. 896)
- A Final Rule modifying the pro forma Open Access Transmission Tariff and FERC’s regulations to improve the accuracy and transparency of transmission line ratings (Order No. 881)
[1] Launched in 2022, i2X is a program led by DOE’s Solar Energy Technologies Office (“SETO”) and Wind Energy Technologies Office (“WETO”), in collaboration with several national laboratories and industry stakeholders. Through i2X, DOE undertakes stakeholder engagement, data collection and analysis, strategic roadmap development, and technical assistance with the goal of enabling “simpler, faster, and fairer interconnection of clean energy resources all while enhancing the reliability, resiliency, and security of our electric grid.” See energy.gov/eere/i2x/interconnection-innovation-e-xchange.
[2] U.S. Department of Energy, Transforming Interconnection: Paving the way to reliably achieve an energy transition on the U.S. transmission system by 2035 (Oct. 25, 2023), available at energy.gov/sites/default/files/2023-10/Draft%20i2X%20Transmission%20Roadmap.pdf.
[3] Id. at 1.
[4] Id.
[5] The draft roadmap also identifies the historical best values. See pp. 5-6.
[6] The draft roadmap notes that “Projects remain active in the queue for many years, so the recent value is pulled from a time period where little active projects remain. Values from more recent years are well below 5 percent given that they encompass projects that are still actively working through the interconnection queues.” See p. 5, n.9.