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On January 17, 2013, the Federal Energy Regulatory Commission
(FERC) issued a notice of proposed rulemaking (NOPR) proposing reforms to
the pro forma Small Generator
Interconnection Procedures (SGIP) and the Small Generator Interconnection
Agreement (SGIA). Originally adopted in FERC’s Order No. 2006, the pro forma SGIP and SGIA govern the
interconnection of small generating facilities – those with a capacity of
20 MW or smaller. In the NOPR, FERC explains that market changes
since the issuance of Order No. 2006, including the growth of small
generator interconnection requests and the growth in solar photovoltaic
installations, driven in part by state renewable energy goals and policies,
necessitate a reevaluation of the SGIP and SGIA. FERC states that it
expects the proposed reforms to reduce the time and costs related to the
interconnection of small generating facilities, while maintaining the
reliability of the grid.
The NOPR proposes four principal reforms to the pro forma SGIP:
- providing
interconnection customers with the option of requesting from the
Transmission Provider a pre-application report providing existing
information about system conditions at a possible Point of
Interconnection;
- increasing
the generation capacity threshold for “Fast Track” interconnections
from 2 MW to 5 MW, based on individual system and resource
characteristics;
- revising
SGIP provisions related to the customer options meeting and the
supplemental review following failure of the Fast Track screens that
identify reliability or safety issues;
- revising
the pro
forma SGIP Facilities Study Agreement by giving
interconnection customers an opportunity to provide written comments
on the upgrades that are necessary for the interconnection.
The NOPR also proposes clarifying revisions to the pro forma SGIP and SGIA. FERC
proposes to revise section 1.1.1 of the pro
forma SGIP to require small generating facilities requesting
Network Resource Interconnection Service to do so under the pro forma Large Generator
Interconnection Procedures and execute a Large Generator Interconnection
Agreement. In addition, FERC proposes to modify section 1.5.4 of the pro forma SGIA to require
interconnection customers to design, install, maintain and operate their
small generator facilities in accordance with the latest frequency response
reliability standards established by the North American Electric
Reliability Corporation.
Comments on the proposed reforms are due June 3, 2013.
FERC will convene a workshop during the comment period to discuss the
technical aspects of the proposals set forth in the NOPR.
If you have any questions regarding this matter, please contact:
Adam Wenner
Partner
awenner@orrick.com
202.339.8515
Cory Lankford
Managing Associate
clankford@orrick.com
202.339.8620
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