and the resource owner/operator recognizes that it must abide by
dispatch orders and bear the consequences of any limitations on its
operation that result in penalties.\2751\
---------------------------------------------------------------------------

    \2748\ Clean Energy Alliance Initial Comments at 14-15; NARUC
Initial Comments at 37; PacifiCorp Initial Comments at 41; Pattern
Energy Initial Comments at 12; Pine Gate Initial Comments at 51;
SEIA Initial Comments at 40; Union of Concerned Scientists Reply
Comments at 10-11.
    \2749\ NESCOE Reply Comments at 18 (citing NARUC Initial
Comments at 36-37).
    \2750\ Union of Concerned Scientists Reply Comments at 10-11.
    \2751\ AEP Initial Comments at 46-47.
---------------------------------------------------------------------------

(b) Comments in Opposition
    1461. Some commenters argue that the proposed reform is overly
burdensome on transmission providers and could add time and complexity
to the interconnection process.\2752\ For example, NYISO opposes the
proposed reform, arguing that it would not streamline the
interconnection study process and instead would add significantly more
complexity to the process and increase the time required to complete
studies.\2753\
---------------------------------------------------------------------------

    \2752\ Avangrid Initial Comments at 35; Enel Initial Comments at
74; ISO-NE Initial Comments at 40; NYISO Initial Comments at 51;
PacifiCorp Initial Comments at 41-42; PJM Initial Comments at 67;
Southern Initial Comments at 33.
    \2753\ NYISO Initial Comments at 51.
---------------------------------------------------------------------------

    1462. Some commenters oppose the proposed reform due to reliability
concerns.\2754\ PJM argues that the proposal would be extremely
difficult to police and enforce and would not guarantee that units will
operate within their studied parameters, putting PJM at operational
risk.\2755\ Southern opposes the proposed reform, stating that
transmission providers are ultimately responsible for planning for the
safety and reliable operation of their transmission systems, which
includes standard assumptions for interconnection studies.\2756\
Southern contends that it may be viable to provide an information-only
scenario using the assumptions provided by the interconnection
customer, but it would not be just and reasonable to allow
interconnection customers to dictate the study assumptions for their
electric storage, hybrid, or co-located resources. NYISO asserts that
its interconnection studies are designed to capture extreme system
scenarios to best maintain the reliability of the system and to be
prepared for rare extreme conditions and without such planning, the
interconnection studies could fail to identify essential non-local
network upgrades.\2757\ SDG&E argues that the reform may introduce
undue risk into the interconnection study process and could lead to the
transmission system being operated in an unstudied/unplanned
state.\2758\
---------------------------------------------------------------------------

    \2754\ Id. at 67; SDG&E Initial Comments at 8; Southern Initial
Comments at 33.
    \2755\ PJM Initial Comments at 67.
    \2756\ Southern Initial Comments at 33.
    \2757\ NYISO Initial Comments at 51.
    \2758\ SDG&E Initial Comments at 7.
---------------------------------------------------------------------------

    1463. However, several commenters disagree that the proposed reform
will introduce undue risk into the interconnection study process and
real-time operations.\2759\ CESA asserts that many transmission
providers continue to use historical planning standards that do not
consider the capability of advanced firmware and software controls to
dispatch resources in accordance with operating assumptions that can
provide much needed additional capacity to the transmission system,
which may result in continued delays and inefficiencies in the
interconnection process.\2760\
---------------------------------------------------------------------------

    \2759\ AEE Initial Comments at 41-42; CESA Reply Comments at 10
(citing SDG&E Initial Comments at 7); Clean Energy Associations
Initial Comments at 58; R Street Initial Comments at 16.
    \2760\ CESA Reply Comments at 10.
---------------------------------------------------------------------------

    1464. NARUC suggests that, in RTO/ISO regions, independent market
monitors may be well-positioned to track deviations from proposed
operational limits in real-time operations.\2761\ For non-RTO/ISO
regions, NARUC contends that it may be appropriate for an independent
transmission monitor or NERC regional reliability entity to serve in
such a role.
---------------------------------------------------------------------------

    \2761\ NARUC Initial Comments at 38.
---------------------------------------------------------------------------

(c) Comments on Specific Proposal
    1465. Some commenters support the flexibility that the proposed
reform provides on the basis that it would allow for better use of the
transmission system or help facilitate the interconnection process
while still allowing for adequate controls.\2762\ NRECA cautions,
however, that such flexibility should not come at the expense of the
NOPR's overall goal of reducing speculative interconnection requests,
withdrawals, and restudies.\2763\ APS also believes that operating
assumptions used in interconnection studies should be limited to
factors that can be automatically controlled by the interconnection
customer; otherwise, system issues may occur when interconnection
facilities are operating outside of the assumptions used in the
studies.\2764\ Although AEP generally supports the proposed reform
because interconnection studies should be as accurate as possible, AEP
notes that using operating assumptions provided by the interconnection
customer may complicate studies and thus realistic study time frames
must be adopted.\2765\
---------------------------------------------------------------------------

    \2762\ APS Initial Comments at 22; Cypress Creek Initial
Comments at 9; NRECA Initial Comments at 10, 44; rPlus Initial
Comments at 6.
    \2763\ NRECA Initial Comments at 44.
    \2764\ APS Initial Comments at 22.
    \2765\ AEP Initial Comments at 45.
---------------------------------------------------------------------------

    1466. Many commenters support the proposal to allow transmission
providers to require the use of controls to ensure compliance with
planned operation.\2766\ Clean Energy Associations argue that electric
storage resources are controllable with a level of precision and speed
unparalleled by conventional generating facilities, which provides
transmission owners and providers and interconnection customers with
new opportunities to accommodate transmission system reliability needs
and efficiently use scarce transmission interconnection capacity.\2767\
Clean Energy Associations assert that the proposed reform would
acknowledge the fact that electric storage resources are highly
controllable through hardware and software controls.\2768\ SEIA asserts
that power control systems, which electronically limit or control
steady state currents to a programmable limit, can ensure that electric
storage resources follow operating assumptions, and that their use is
growing.\2769\
---------------------------------------------------------------------------

    \2766\ AEE Initial Comments at 41-42; APS Initial Comments at
22; Bonneville Initial Comments at 23; Clean Energy Associations
Initial Comments at 52-58; ELCON Initial Comments at 10; Eversource
Initial Comments at 36; NARUC Initial Comments at 38; PPL Initial
Comments at 23; Public Interest Organizations Initial Comments at
49-50; SEIA Initial Comments at 40.
    \2767\ Clean Energy Associations Initial Comments at 52.
    \2768\ Clean Energy Associations Reply Comments at 10.
    \2769\ SEIA Reply Comments at 26-27 (citing IREC Initial
Comments, app. A at 43-48, 56, 159).
---------------------------------------------------------------------------

    1467. Idaho Power states that it currently has a generator control
and monitoring technology that can be leveraged for monitoring and
controlling electric storage charging.\2770\ However, Idaho Power
asserts that it will need to implement a control scheme for operators
to view and control interconnection facilities in order to
intermittently interrupt discharge and charging due to system
conditions and related outages, which would likely require upfront and
ongoing costs for both Idaho Power and interconnection customers. Idaho
Power requests that the Commission consider including additional
language to ensure that the

transmission provider can disconnect, or take other action, including
seeking damages, in the event that the charging electric storage
resource does not follow its schedule.
---------------------------------------------------------------------------

    \2770\ Idaho Power Initial Comments at 15-16.
---------------------------------------------------------------------------

    1468. Eversource states that it is essential for system operators
and transmission planners to have sufficient visibility and controls in
place to ensure that the transmission system is not placed in unstudied
and potentially insecure N-1 contingency states.\2771\ Eversource
suggests that this issue, as well as other issues of grid dispatch,
should be the subject of its own proceeding. Alternatively, Eversource
requests that the Commission require that interconnection customers
with proposed operational study assumptions have technological controls
in place that automatically limit the electric storage facility's
operation to the proposed operational parameters. Eversource further
requests that the Commission reflect these requirements in the body of
the pro forma LGIA, and not only the appendices.
---------------------------------------------------------------------------

    \2771\ Eversource Initial Comments at 35-36.
---------------------------------------------------------------------------

    1469. NARUC and Public Interest Organizations support the proposed
requirement to consider resources to be in breach of their LGIA if they
fail to operate as intended.\2772\ NARUC asserts that such a
consequence, in combination with technology and software that can limit
the operations of an electric storage resource, should sufficiently
mitigate behavior that deviates from planned.\2773\ Public Interest
Organizations contend that installing control technologies would allow
the transmission provider and interconnection customer to engage in an
interactive dialogue to develop a set of operating assumptions that
both satisfy the interconnection customer's operational desires and
align with ``good utility practice.'' \2774\
---------------------------------------------------------------------------

    \2772\ NARUC Initial Comments at 37; Public Interest
Organizations Initial Comments at 48-50.
    \2773\ NARUC Initial Comments at 37-38.
    \2774\ Public Interest Organizations Initial Comments at 48.
---------------------------------------------------------------------------

    1470. rPlus generally supports the proposal but argues that the
proposed termination requirements for the interconnection customer
should the operational characteristics not be met are too stringent and
restrictive.\2775\ rPlus agrees that it is important to memorialize the
studied operational assumptions in the interconnection agreement but
asserts that it would benefit from the inclusion of additional language
should deviation from the originally defined operational assumptions be
beneficial.
---------------------------------------------------------------------------

    \2775\ rPlus Initial Comments at 6.
---------------------------------------------------------------------------

    Therefore, rPlus suggests that the Commission remove any explicit
or implied requirement for electric storage resources not to charge
during peak load periods and add language to retain the possibility of
altering the operational characteristics when these changes would
benefit the reliable and efficient operation of the transmission system
or benefit ratepayers.
    1471. Invenergy supports the proposed reform to accommodate study
assumptions that more reasonably approximate anticipated actual
operations, but opposes requiring the studied operating conditions to
be memorialized in the interconnection agreement.\2776\ Invenergy
states that, if there are concerns that an unexpected event may require
a facility to occasionally operate outside those conditions, those
concerns should be addressed through the regional transmission planning
process, rather than forcing interconnection customers to fund upgrades
that are rarely if ever needed.\2777\
---------------------------------------------------------------------------

    \2776\ Invenergy Initial Comments at 59-61.
    \2777\ Id. at 61-62.
---------------------------------------------------------------------------

    1472. Several commenters suggest modifications to the proposal to
better achieve the Commission's goal. For example, Pine Gate suggests
that the Commission require transmission providers to use a uniform set
of minimum interconnection study requirements (e.g., by eliminating the
use of extreme contingency scenarios and overly conservative
operational characteristics and strategies) to facilitate effective,
efficient interconnection queue processing, which is an essential
prerequisite of consumer protection.\2778\ With respect to the
provision of ancillary services, Pine Gate requests that the
interconnection customer not be required to definitively indicate the
specific ancillary services that it would or would not provide in the
initial interconnection request because it is not possible for the
interconnection customer to know with certainty which ancillary
services it may be eligible to provide when it is ultimately placed in
service.\2779\ For this reason, Pine Gate requests that the Commission
require the interconnection customer to list in the original
interconnection request only whether it intends to provide ancillary
services generally.\2780\
---------------------------------------------------------------------------

    \2778\ Pine Gate Initial Comments at 55.
    \2779\ Id. at 52.
    \2780\ Id. at 53.
---------------------------------------------------------------------------

    1473. Union of Concerned Scientists urges the Commission to direct
in the final rule that technical capabilities offered by an
interconnection customer be appropriately recognized and used in the
modeling of transmission impacts and their mitigation, including the
ability to respond to contingencies and provide dynamic real or
reactive power, which if omitted could lead to millions of dollars of
costs to customers to provide such capability by other means.\2781\
---------------------------------------------------------------------------

    \2781\ Union of Concerned Scientists Reply Comments at 13-14.
---------------------------------------------------------------------------

    1474. Interwest supports allowing interconnection customers to
request that transmission providers apply certain study assumptions to
better approximate realistic operations and requiring transmission
providers to apply congestion management practices to unusual events,
developed through regional transmission planning processes, rather than
building in assumptions assuming worst-case operations scenarios.\2782\
---------------------------------------------------------------------------

    \2782\ Interwest Reply Comments at 15.
---------------------------------------------------------------------------

    1475. Public Interest Organizations recommend that, if a
transmission provider finds an interconnection customer's proposed
operating assumptions to be in conflict with ``good utility practice,''
the transmission provider should be required to provide the
interconnection customer with a clear explanation of why the submitted
operating assumptions are insufficient or inappropriate, and allow the
interconnection customer to revise and resubmit the proposed operating
assumptions as necessary, within a reasonable time period.\2783\
---------------------------------------------------------------------------

    \2783\ Public Interest Organizations Initial Comments at 47-48,
49.
---------------------------------------------------------------------------

    1476. Clean Energy Associations urge the Commission to define study
parameters such as ``peak load'' and ``net peak load.'' \2784\ Clean
Energy Associations request that the Commission define ``net peak
load'' as the period during which transmission providers must not study
a facility as withdrawing energy. Clean Energy Associations note that
in regions with high solar penetration, the net peak load hour diverges
from the peak load hour and migrates to later in the day and, under
these conditions, low prices during the peak load hour may create
incentives for storage to charge, whereas prices would be high during
the net peak load hour creating incentives to discharge. Therefore,
Clean Energy Associations contend that using the net peak load as the
period of study will ensure that studies continue to accurately reflect
expected economic price response of storage as system conditions
evolve.
---------------------------------------------------------------------------

    \2784\ Clean Energy Associations Initial Comments at 53-54.

---------------------------------------------------------------------------

    1477. NextEra and Clean Energy Associations urge the Commission to
require transmission providers to use additional study assumptions
beyond just whether electric storage and co-located resources
(including hybrid resources) should charge during peak load periods.
Both NextEra and Clean Energy Associations argue that transmission
providers should not study electric storage resources as injecting
energy during low load and shoulder periods because that does not
reasonably reflect the rational economic behavior and typical
operations of such resources.\2785\
---------------------------------------------------------------------------

    \2785\ NextEra Initial Comments at 37; Clean Energy Associations
Initial Comments at 53.
---------------------------------------------------------------------------

    1478. In contrast, MISO argues against requiring additional study
assumptions for electric storage resources.\2786\ MISO notes that there
may be times in the future when renewable resources are constrained or
unavailable due to the lack of fuel (e.g., no wind or sun) such that
the MISO transmission system will need to call upon electric storage
resources for injection: but, if these resources are not permitted to
discharge due to their operational assumptions, then the transmission
system's reliance on those resources could lead to reliability risks.
---------------------------------------------------------------------------

    \2786\ MISO Initial Comments at 116.
---------------------------------------------------------------------------

    1479. Several other commenters urge the Commission not to define
study parameters, such as ``peak load'' or ``net peak load,'' and
instead allow for regional flexibility.\2787\ For example, rather than
define peak load, Microgrid Resources states that the Commission should
require individual evaluation of the expected operating assumptions for
the resource(s) being studied.\2788\ Enel asserts that it does not
believe clear and transparent criteria regarding the peak load period
could be developed such that the limitations on a generating facility
could appropriately be modeled with only a few power flow model
``snapshots in time'' serving as the basis for the restriction.\2789\
---------------------------------------------------------------------------

    \2787\ Ameren Initial Comments at 29; Enel Initial Comments at
74; Idaho Power Initial Comments at 16; Microgrid Resources Initial
Comments at 8; Shell Initial Comments, app. A at iii.
    \2788\ Microgrid Resources Initial Comments at 8.
    \2789\ Enel Initial Comments at 74.
---------------------------------------------------------------------------

    1480. Several commenters support eliminating unrealistic
interconnection study assumptions for resource types other than
electric storage resources, such as assuming that a solar facility will
operate a night, or that a wind resource will produce maximum output
during low-wind seasons.\2790\ Ameren, Cypress Creek, Microgrid
Resources, NARUC, Pine Gate, and rPlus all request that the Commission
extend this reform to allow any resource type, not just electric
storage or co-located resources, to request that interconnection
studies be based on their particular operating assumptions and
characteristics.\2791\ NARUC further asserts that it is reasonable to
allow interconnection customers to request that transmission providers
not study interconnecting generating facilities in ways that are not
physically possible, subject to the same proposed requirement that the
generating facility be equipped with sufficient control technologies
and penalties for deviations.\2792\ Microgrid Resources urges the
Commission to define microgrid in the tariff, noting particularly the
inclusion of load, and to make clear that interconnection studies must
be based on operating assumptions for the microgrid as a whole.\2793\
---------------------------------------------------------------------------

    \2790\ Id.; AES Clean Energy Initial Comments at 24-25; Ameren
Initial Comments at 29; CREA and NewSun Initial Comments at 92;
Cypress Creek Initial Comments at 9-10; Invenergy Initial Comments
at 59-61; Microgrid Resources Initial Comments at 7-8; Pine Gate
Initial Comments at 54; Public Interest Organizations Initial
Comments at 48-49; R Street Initial Comments at 16; rPlus Initial
Comments at 6.
    \2791\ Ameren Initial Comments at 29; Cypress Creek Initial
Comments at 9-10; Microgrid Resources Initial Comments at 7; NARUC
Initial Comments at 38; Pine Gate Initial Comments at 54; rPlus
Initial Comments at 6.
    \2792\ NARUC Initial Comments at 38.
    \2793\ Microgrid Resources Initial Comments at 7.
---------------------------------------------------------------------------

    1481. Pattern Energy asserts that transmission providers should be
required to update their operating assumptions annually, after
stakeholder input.\2794\ Pattern Energy asserts that some transmission
providers require light-load reliability analysis for wind resources
but not for natural gas plants, which is unduly discriminatory.\2795\
---------------------------------------------------------------------------

    \2794\ Pattern Energy Initial Comments at 13.
    \2795\ Id. (referencing PJM Manual 14B at 47, section <IP_ADDRESS>).
---------------------------------------------------------------------------

    1482. Some commenters support expanding the proposed reforms to the
entire facility of hybrid or co-located resources. For instance, ENGIE
recommends that interconnection customers submitting hybrid or co-
located resources should be able to specify operating parameters across
the entire generating facility, including variable energy resources,
within their interconnection request to allow interconnection customers
to reflect parameters such as solar-based charging of the electric
storage resource more accurately.\2796\ Pine Gate states that co-
located resources are typically studied independently, which requires
studying the combined maximum injection of the two generating
facilities that are co-located, despite the fact that studying in this
manner overestimates the impact on the transmission system and could
trigger unnecessary network upgrades.\2797\ Pine Gate asserts that,
consistent with the NOPR's proposals regarding operating assumptions
for electric storage resources and co-located resources, the Commission
should permit an interconnection customer to specify the proposed
operation of all components of a co-located resource in its
interconnection request.
---------------------------------------------------------------------------

    \2796\ ENGIE Initial Comments at 11.
    \2797\ Pine Gate Initial Comments at 45.
---------------------------------------------------------------------------

    SEIA contends that studying two, co-located resources as a single
resource would be more accurate, as this would reflect the actual
electrical impact to the transmission system.\2798\
---------------------------------------------------------------------------

    \2798\ SEIA Initial Comments at 38.
---------------------------------------------------------------------------

    1483. Although not entirely opposed to the proposed reform,
PacifiCorp asserts that this proposed reform should not be extended to
co-located and hybrid resources because monitoring and enforcing
operational limitations could be complex, and incorporating operational
limitations could complicate the cluster study process.\2799\
Nevertheless, PacifiCorp encourages the Commission to permit
transmission providers to opt-in to extending this type of reform to
hybrid resources if appropriate for their systems.
---------------------------------------------------------------------------

    \2799\ PacifiCorp Initial Comments at 41-42.
---------------------------------------------------------------------------

    1484. Several other commenters urge the Commission to go further
and require transmission providers to use more realistic operating
assumptions without requiring the interconnection customer to request
that transmission provider do so.\2800\ Public Interest Organizations
argue that extending the reforms to all generation technologies would
help prevent unduly discriminatory treatment.\2801\ Therefore, Public
Interest Organizations recommend that the Commission require
transmission providers to work with interconnection customers to ensure
operating assumptions reflect physical, operational, and market
realities, ``good utility practice,'' and applicable reliability
standards. AES Clean Energy argues that the Commission should require
transmission providers to establish a process to revisit and update
operating assumptions of different resource types in consultation with
stakeholders to ensure that these operating assumptions are realistic
and approximately reflect

the expected actual operation of these resources.\2802\
---------------------------------------------------------------------------

    \2800\ AES Clean Energy Initial Comments at 24-25; CREA and
NewSun Initial Comments at 92; R Street Initial Comments at 16.
    \2801\ Public Interest Organizations Initial Comments at 49.
    \2802\ AES Clean Energy Initial Comments at 24-25.
---------------------------------------------------------------------------

    1485. Shell supports the use of accurate modeling assumptions,
including for variable energy resources, but argues that electric
storage and renewable resources should not be treated in the same way
because electric storage is dispatchable and renewable resources
generally are not dispatchable.\2803\ Further, Shell asserts that the
Commission should not assume all wind and solar resources are the same
(and not dispatchable).
---------------------------------------------------------------------------

    \2803\ Shell Initial Comments, app. A at iii.
---------------------------------------------------------------------------

    1486. AECI and NextEra oppose extending the proposed reform to
other resources types.\2804\ NextEra opposes extending customized
operating assumptions to wind and solar energy resources because doing
so could unduly complicate subsequent operational decisions for the
system operator and possibly restrict the system operator's ability to
call on resources when needed.\2805\ AECI proposes to continue studying
wind and solar resources as NRIS facilities that are dispatched at 100%
to avoid potential reliability issues at the worst times.\2806\ MISO
explains that it currently requires interconnection customers to be
responsible for limiting and controlling their own dispatch in some
conditions, but that it has no ability to monitor in real time if an
interconnection customer violates its operating limits.\2807\ MISO
states that it is unaware of any plant side control device or
operational tool that MISO could use to prevent a generating facility's
injection to enforce an electric storage resource's operating
assumptions regarding discharging. Idaho Power states that it is
unclear how a cluster study with multiple interconnection requests
could be performed when accounting for numerous and potentially
conflicting study parameters, such as ``low wind season'' for one
interconnection customer but not for another.\2808\ Idaho Power seeks
clarification of the definition of study parameters such as ``low wind
season.''
---------------------------------------------------------------------------

    \2804\ AECI Initial Comments at 8; NextEra Initial Comments at
37.
    \2805\ NextEra Initial Comments at 37.
    \2806\ AECI Initial Comments at 8.
    \2807\ MISO Initial Comments at 116.
    \2808\ Idaho Power Initial Comments at 16.
---------------------------------------------------------------------------

    1487. Some commenters support the Commission defining the terms
firm and non-firm charging service for electric storage resources and
requiring transmission providers to define study criteria to
interconnect related to both firm and non-firm charging.\2809\ For
example, Clean Energy Associations support enabling interconnection
customers with electric storage resources and hybrid resources to
request non-firm transmission service for their charging energy,
provided that transmission providers update study criteria and
interconnection processes for such service accordingly and provide
definitions of firm and non-firm charging service for electric storage
resources.\2810\ CESA argues that electric storage resources should not
be forced to use one type of charging service over another since some
resources may find it sufficient to take advantage of charging capacity
as it is available whereas others may want or need greater assurances
of charging capacity and are willing to pay for the requisite network
upgrades.\2811\ CESA urges the Commission to set requirements as to how
partial or full firm charging services should be offered on a flexible,
as-requested basis, such that an interconnection customer can seek firm
charging service for specific time windows or for a portion of the
electric storage resource's nameplate or interconnection capacity. CESA
asserts that, as discussed in the NOPR, accommodating firm and as-
available charging service options should reflect the operating
capabilities of the storage resource (i.e., price responsive,
dispatchable), achieve efficient market outcomes, and avoid expensive
and unnecessary upgrades.\2812\
---------------------------------------------------------------------------

    \2809\ CESA Initial Comments at 12-13; Clean Energy Associations
Initial Comments at 54-56; ENGIE Initial Comments at 12.
    \2810\ Clean Energy Associations Initial Comments at 54.
    \2811\ CESA Initial Comments at 12-13.
    \2812\ Id. at 12.
---------------------------------------------------------------------------

    1488. Clean Energy Associations assert that the Commission should
direct transmission providers to use the following criteria for
studying interconnection requests that opt for non-firm charging
service: (1) the electric storage resource should have the option to
receive electric energy using the existing firm or non-firm capacity of
the transmission system on an ``as available'' basis; (2) any study of
an electric storage resource charging should allow the interconnection
customer to elect to use a lower charging level or a control technology
to mitigate any identified constraints in lieu of being assigned
network upgrades to address such constraints; and (3) the electric
storage resource should receive information relative to any network
upgrades, charging restrictions, or control requirements in advance of
signing an interconnection agreement.\2813\ Clean Energy Associations
urge the Commission to direct transmission owners to indicate
conditions under which charging energy could be curtailed in
interconnection agreements that include non-firm service for charging
energy. Clean Energy Associations also caution that the Commission
should avoid recategorizing charging energy of electric storage
resources as a wholesale load, which would be contrary to the
Commission's findings in Order No. 841.
---------------------------------------------------------------------------

    \2813\ Clean Energy Associations Initial Comments at 55-56.
---------------------------------------------------------------------------

    1489. AEP suggests that clarifications would be needed for the
proposed definitions of firm and non-firm charging to be effective. For
example, AEP asserts that the proposed definitions for firm and non-
firm charging service conflate different products and services required
to charge an electric storage resource.\2814\ AEP argues that charging
service is not a form of interconnection service, nor is
interconnection service referred to in the industry as firm or non-
firm. According to AEP, it is the delivery service (i.e., transmission
and wholesale distribution service) that can be firm or non-firm and
therefore the relevant question is whether, in the interconnection
process, an electric storage resource can or needs to request to be
studied as a ``firm'' or ``non-firm'' load for delivery purposes. AEP
asserts that the Commission should recognize that, for electric storage
resources, the interconnection cluster study process should include an
analysis of transmission service. AEP notes that the Commission has
permitted the California utilities to study the need for wholesale
distribution upgrades required for charging on a firm basis as part of
the interconnection study process. AEP argues that, if it is
technically possible to distinguish loads, a load that affects human
safety, health, and welfare directly should have priority over the
charging of an electric storage resource, unless for example, if the
electric storage resource will be used for blackstart after an outage,
adding that the final rule does not need to interfere with emergency
load shedding protocols.
---------------------------------------------------------------------------

    \2814\ AEP Initial Comments at 48-50.
---------------------------------------------------------------------------

    1490. Shell asserts that the need for firm or non-firm transmission
service will vary by generating facility, as well as by the usage
pattern of the electric storage resource (e.g., whether the electric
storage resource is standalone or part of a hybrid resource that is AC-
coupled, DC-coupled, or DC-tight-

coupled).\2815\ Shell states that, if an electric storage resource is
charging from the transmission system as non-firm load, and the
resource owner is required to comply with the transmission provider's
real-time dispatch orders to cease charging from the transmission
system due to reliability concerns, then there is no need for long-term
firm transmission service reservations to serve the electric storage
resource. Shell contends that non-firm electric storage load should not
be required to acquire transmission service prior to charging from the
transmission system, as such charging will be captured by the revenue
meter and can be billed at the transmission provider's non-firm point-
to-point transmission rate at the end of the billing period.
---------------------------------------------------------------------------

    \2815\ Shell Initial Comments, app. A at iii.
---------------------------------------------------------------------------

    1491. Xcel suggests that the evaluation of non-firm charging must
assume a price and then the electric storage resource should be bound
to that price.\2816\ Xcel contends that, if an electric storage
resource is studied as non-firm load but ends up offering to buy energy
in the market above average market prices, the study will not represent
the resulting dispatch. Therefore, Xcel recommends that electric
storage resources and other non-firm load should be required to have a
maximum bid price that is included in Attachment C of the pro forma
LGIA.
---------------------------------------------------------------------------

    \2816\ Xcel Initial Comments at 46.
---------------------------------------------------------------------------

    1492. Some commenters oppose the Commission defining firm and non-
firm charging or requiring transmission providers to define study
criteria as part of this rulemaking.\2817\ For example, PPL asserts
that the Commission should leave defining such study parameters to the
transmission providers.\2818\
---------------------------------------------------------------------------

    \2817\ Ameren Initial Comments at 29; Idaho Power Initial
Comments at 16; PPL Initial Comments at 23.
    \2818\ PPL Initial Comments at 23.
---------------------------------------------------------------------------

    1493. Several commenters suggest clarifications to the proposed
reform regarding the timing of submitting operating assumptions.\2819\
Clean Energy Associations and ENGIE recommend that the Commission
define a clear decision point in the interconnection study process
before which interconnection customers may adjust operating assumptions
and after which inputs remain constant.\2820\ APS suggests that the
Commission modify the proposal to specify that any changes to the
operating assumptions initially provided by the interconnection
customer would be considered a material modification.\2821\
---------------------------------------------------------------------------

    \2819\ AES Clean Energy Initial Comments at 24; APS Initial
Comments at 22; Clean Energy Associations Initial Comments at 56-57;
ENGIE Initial Comments at 11.
    \2820\ Clean Energy Associations Initial Comments at 56-57;
ENGIE Initial Comments at 11.
    \2821\ APS Initial Comments at 22.
---------------------------------------------------------------------------

(d) Alternative Proposals and Requests for Further Process
    1494. Enel argues that using power flow studies and assuming
extreme transmission system conditions matches the concept of a firmer
product well (e.g., for NRIS or transmission service studies), but
applied to ERIS studies it implies that an ERIS resource cannot or will
not curtail, absorb congestion costs, or be redispatched to mitigate
transmission system disturbances, which goes beyond ``as available''
service and does not allow for lower-cost mitigation options.\2822\ For
these reasons, Enel recommends that the Commission direct transmission
providers to replace power flow studies with Security Constrained
Economic Dispatch analysis for ERIS service studies instead of the
Commission's proposed reform,\2823\ or in the alternative, require
appropriately supported fuel-based dispatch assumptions in ERIS and,
where appropriate, NRIS study models.\2824\
---------------------------------------------------------------------------

    \2822\ Enel Initial Comments at 75.
    \2823\ Id. at 73, 75.
    \2824\ Id. at 77-78.
---------------------------------------------------------------------------

    1495. Several other commenters support requiring transmission
providers to apply realistic fuel-based dispatch assumptions to all
resource types.\2825\ Additionally, Invenergy notes that both MISO and
SPP already use realistic fuel-based dispatch assumptions in their
interconnection study processes.\2826\ Although MISO believes that a
fuel-based dispatch methodology would address the concerns stated in
the NOPR about unrealistic operating assumptions, MISO also believes
that study methods should be flexible to the unique needs of a region's
stakeholders and that the Commission should allow flexibility regarding
how a transmission provider conducts its studies.\2827\ MISO asserts
that fuel-based dispatch enables more efficient generator
interconnection because it recognizes that not all generating
facilities will be dispatched up to their requested interconnection
service at all times of the year and that some fuels will not be
dispatched when other fuels are being dispatched.\2828\ MISO explains
that its current fuel dispatch method also addresses withdrawal for
electric storage resources and was informed by operational data.\2829\
---------------------------------------------------------------------------

    \2825\ Enel Initial Comments at 77-78; Interwest Reply Comment
at 15; Invenergy Initial Comments at 60-61.
    \2826\ Invenergy Initial Comments at 60-61.
    \2827\ MISO Initial Comments at 119.
    \2828\ Id. at 117, 119.
    \2829\ Id. at 117-118 (citing MISO, Business Practice Manual-15,
tbl. 6-1).
---------------------------------------------------------------------------

    1496. Public Interest Organizations encourage the Commission to
consider a requirement that would ensure operational and market
realities are appropriately reflected in operating assumptions for the
purposes of interconnection studies.\2830\ Public Interest
Organizations state that this could include both operational practices
and procedures as well as market-based price signals for curtailment
and congestion management. Furthermore, Public Interest Organizations
contend that fossil generating facilities should not be expected to
generate at or near peak output during times when market prices are
depressed, such as during periods of high renewable generation.\2831\
---------------------------------------------------------------------------

    \2830\ Public Interest Organizations Initial Comments at 48.
    \2831\ Id. at 48-49 (citing Joe Daniel & Sam Gomberg, Union of
Concerned Scientists, Why Does Wind Energy Get Wasted? (Nov. 16,
2021), https://www.ucsusa.org/resources/wind-oversupply-myths).
---------------------------------------------------------------------------

    1497. IREC asserts that interconnection application forms for small
generating facilities should be updated to include information about
electric storage resources and, where export controls are used, the
type of export control and the equipment type and settings that will be
used.\2832\ IREC asserts that, in order for the interconnection process
to fully recognize the ways electric storage resources can be designed
and controlled to avoid transmission system constraints, utilities
should consider operating profiles (which can include operating
schedules) in their feasibility studies and system impact
studies.\2833\
---------------------------------------------------------------------------

    \2832\ IREC Initial Comments at 15, attach. A.
    \2833\ Id. at 16, attach. A.
---------------------------------------------------------------------------

    1498. Several commenters urge the Commission to hold a technical
conference and/or open a new proceeding to sort out the complex details
of this proposed reform.\2834\ For example, Clean Energy Associations
note that the Commission could build a further evidentiary record
regarding parameters for evaluating electric storage and other
resources via a technical conference, with the aim of developing
reasonable and consistent assumptions across regions.\2835\ SEIA urges
the Commission to convene a technical conference in this proceeding

to increase transmission provider certainty and confidence in the
capabilities and testing of power control systems.\2836\ ISO-NE
suggests that its concerns with the proposed reform may be better
addressed through the establishment of a new category of
interconnection service for the charging mode of electric storage
devices as part of a separate proceeding.\2837\
---------------------------------------------------------------------------

    \2834\ Clean Energy Associations Initial Comments at 53;
Eversource Initial Comments at 35; ISO-NE Initial Comments at 40;
Puget Sound Initial Comments at 13.
    \2835\ Clean Energy Associations Initial Comments at 53.
    \2836\ SEIA Initial Comments at 27.
    \2837\ ISO-NE Initial Comments at 40.
---------------------------------------------------------------------------

(e) Comments Regarding Transmission Service Request Studies
    1499. Clean Energy Associations note that some RTOs/ISOs determine
the network upgrades needed to accommodate the charging of electric
storage resources as part of the interconnection process, whereas other
transmission providers do so in the transmission service request
process.\2838\ Similarly, Xcel states that charging from the
transmission system can be evaluated and approved through the
designation of a new delivery point as part of a transmission service
request.\2839\ Xcel further notes that it is unaware of a transmission
service study process defined in the pro forma tariff that specifically
evaluates non-firm load. Puget Sound states that it currently studies
charging outside of the interconnection process and recognizes that
charging could be considered a retail or a transmission product once
the load piece is interconnected.\2840\ However, Puget Sound asserts
that charging should be studied in the interconnection process, and the
transmission provider should be granted more time to study this
additional element. Puget Sound seeks clarity as to whether the
proposed reform means that charging should now be considered part of
the interconnection process, or if it can be part of the process should
the transmission provider wish to include it. Further, Puget Sound
argues that the Commission should standardize the pro forma LGIA to
include specific operating assumptions to avoid interconnection request
delays due to needing to file a non-conforming LGIA with the Commission
and/or interconnection customer hesitancy.
---------------------------------------------------------------------------

    \2838\ Clean Energy Associations Initial Comments at 54-55
(referencing, e.g., ISO-NE Planning Procedure No. 5-6, at 18 (2022);
MISO, Business Practice Manual 15-r24, at 53.
    \2839\ Xcel Initial Comments at 46-47.
    \2840\ Puget Sound Initial Comments at 11-12.
---------------------------------------------------------------------------

    1500. In contrast, Tri-State argues that it is inappropriate to
study charging of electric storage resources within a generator
interconnection study, and instead asserts that this type of analysis
is best performed as a part of a transmission service study, which
covers delivery of energy to load or charging of an electric storage
resource.\2841\ Similarly, SPP argues that evaluating the impact of an
electric storage resource's charging on the transmission system is
better suited to other existing processes designed to assess load
impact, such as the long-term transmission service study process, the
short-term transmission service evaluation process, or market
processes.\2842\
---------------------------------------------------------------------------

    \2841\ Tri-State Initial Comments at 22.
    \2842\ SPP Initial Comments at 25.
---------------------------------------------------------------------------

(f) Requests for Clarification and Flexibility
    1501. Pine Gate requests that the Commission provide additional
guidance regarding how transmission owners should perform studies and
what network upgrade costs will be allocated to interconnection
customers as a result.\2843\ Pine Gate states that transmission
providers may need to study electric storage or co-located resources
based on worst-case operating assumptions to understand the potential
impact these resources would have on the transmission system absent
operating restrictions being implemented. However, Pine Gate requests
that the Commission clarify that network upgrade costs will not be
assigned to the interconnection customer based on the unrealistic
worst-case scenarios where there is agreement to implement operating
restrictions.
---------------------------------------------------------------------------

    \2843\ Pine Gate Initial Comments at 52.
---------------------------------------------------------------------------

    1502. Elevate requests that the Commission clarify that the
proposed reform applies to all study processes related to the
interconnection of electric storage resources, including generator
replacement, surplus interconnection, and requests to modify an
existing generation resource, arguing that there is no reason for the
Commission to require that transmission providers use realistic study
parameters only in the context of requests for new interconnection
service while allowing unrealistic study assumptions in other study
processes.\2844\
---------------------------------------------------------------------------

    \2844\ Elevate Initial Comments at 13-14.
---------------------------------------------------------------------------

    1503. CAISO is concerned that, if not modified, the proposed reform
would require transmission providers to provide firm charging options,
whereas CAISO asserts that it does not currently provide firm charging
service and stakeholders have never requested such service.\2845\ CAISO
argues that requiring firm charging service would have a profound
impact on organized electricity markets and asserts that if the
Commission proposes to allow electric storage resources to bypass
economic dispatch and charge whenever they desire--even during stressed
peak conditions--it should do so expressly and not in the context of a
rulemaking addressing interconnection. CAISO asserts that the
Commission should consider a simple clarification and avoid requiring
transmission providers to offer firm charging, but instead require
transmission providers that offer firm charging to allow
interconnection customers to request it at the outset of their
interconnection request.
---------------------------------------------------------------------------

    \2845\ CAISO Initial Comments at 34-35.
---------------------------------------------------------------------------

    1504. Environmental Defense Fund urges the Commission to clarify
that an apparent failure to operate in accordance with agreed-upon
conditions should be treated as a normal alleged default or breach as
governed by article 17 of the pro forma LGIA, which would not result in
immediate termination.\2846\ Environmental Defense Fund asserts that
the requirements of article 17.1 of the pro forma LGIA state that a
breaching party be given an opportunity to cure the breach and that
termination is only available if the breaching party fails to cure or
the breach is not capable of being cured. Similarly, Hydropower
Commenters generally support the proposal, but believe that the
proposed requirement that if an interconnection customer fails to
operate its electric storage resource in accordance with the operating
assumptions memorialized in the interconnection agreement, the
interconnection customer may be considered in breach and the
transmission provider may pursue termination of the interconnection
agreement, is overly restrictive, will discourage the development of
pumped storage projects, and should be modified.\2847\ Instead,
Hydropower Commenters urge the Commission to provide for a standard
cure period to address deviations, and penalties in the event of
failure to cure.
---------------------------------------------------------------------------

    \2846\ Environmental Defense Fund Initial Comments at 6-7.
    \2847\ Hydropower Commenters Initial Comments at 23-24.
---------------------------------------------------------------------------

    1505. MISO states that the proposed reform is unclear because the
text of the NOPR states that the Commission intends operating
instructions to only apply to an electric storage resource's ability to
describe how it will withdraw energy from the transmission system
(i.e., charge a battery), whereas the proposed pro forma LGIP revisions
state that the operating assumptions can also apply to the manner the
interconnection request states that the electric storage

resource will discharge.\2848\ MISO asks that the Commission clarify
that the text of the NOPR is correct, and that the Commission did not
intend to propose to allow electric storage resources to define the
operating assumptions for how they will inject into the transmission
system because, according to MISO, allowing interconnection requests to
define operating assumptions regarding discharge would result in
operational problems and would be discriminatory to other generating
facilities.
---------------------------------------------------------------------------

    \2848\ MISO Initial Comments at 115.
---------------------------------------------------------------------------

    1506. Hydropower Commenters suggest that the proposed reform be
modified to include a simplified procedure for amending an
interconnection customer's interconnection agreement to optimize the
operating parameters of a pumped storage plant to the extent the
transmission system is available.\2849\
---------------------------------------------------------------------------

    \2849\ Hydropower Commenters Initial Comments at 24.
---------------------------------------------------------------------------

    1507. Some commenters note that several transmission providers
already study electric storage resources using more realistic operating
assumptions and assert that transmission providers should have the
flexibility to determine the assumptions used when studying generating
facilities interconnecting to the transmission system, including
operating assumptions for electric storage resources, while also
factoring in input from the interconnection customer.\2850\ NESCOE
argues that the final rule should require transmission providers to
work with the relevant states, transmission owners, electric storage
resource interconnection customers, and stakeholders in their region to
develop modeling assumptions for electric storage resources that are
reasonable, realistic, and ensure the ability to interconnect is
offered on a non-discriminatory basis.\2851\
---------------------------------------------------------------------------

    \2850\ APPA-LPPC Initial Comments at 29-30; Bonneville Initial
Comments at 23; MISO Initial Comments at 117; National Grid Initial
Comments at 41; NESCOE Reply Comments at 19.
    \2851\ NESCOE Reply Comments at 18.
---------------------------------------------------------------------------

    1508. National Grid recommends that the Commission provide regional
flexibility to adopt or decline this proposed reform after transmission
providers receive input from their stakeholders to determine if ad hoc
proposed operating assumptions for interconnection requests are
reasonable and appropriate or if certain pre-determined acceptable
ranges of assumptions are consistent with reliability.\2852\ APPA-LPPC
argues that the proposal could entail creating entirely new models for
off-peak scenarios, not just running sensitivity analyses from an
existing model, and therefore urges the Commission to give transmission
providers the autonomy to determine whether additional transmission
studies are needed.\2853\
---------------------------------------------------------------------------

    \2852\ National Grid Initial Comments at 41.
    \2853\ APPA-LPPC Initial Comments at 29-30.
---------------------------------------------------------------------------

iii. Commission Determination
    1509. We adopt the NOPR proposal, subject to modification, to
revise sections 3.1.2, <IP_ADDRESS>, <IP_ADDRESS>, 3.3.1, 3.4.2, 4.4.3, 7.3, 8.2,
and Appendix 1 of the pro forma LGIP and article 17.2 and Appendix H of
the pro forma LGIA to require transmission providers, at the request of
the interconnection customer, to use operating assumptions in
interconnection studies that reflect the proposed charging behavior of
electric storage resources \2854\ (whether standalone, co-located
generating facilities,\2855\ or part of a hybrid generating facility
\2856\)--i.e., whether the interconnecting generating facility will or
will not charge during peak load conditions--unless good utility
practice, including applicable reliability standards,\2857\ otherwise
requires the use of different operating assumptions.\2858\ We clarify
that studying electric storage resources, at the request of the
interconnection customer, according to their planned operating
assumptions means only the operating assumptions for withdrawals of
energy (e.g., the charging of an electric storage resource) in
interconnection studies.
---------------------------------------------------------------------------

    \2854\ An electric storage resource is a generating facility
capable of receiving electric energy from the grid and storing it
for later injection of electricity.
    \2855\ As noted above, co-located generating facilities are more
than one generating facility that are located on the same site and
that are connected at the same point of interconnection that are
operated and dispatched as separate generating facilities. See supra
section III.C.1.a.iii.
    \2856\ As noted above, a hybrid generating facility is a
generating facility composed of more than one device of different
technology types for the production and/or storage for later
injection of electricity that are located on the same site and are
operated and dispatched as a single integrated generating facility.
See supra section III.A.6.b.iii.
    \2857\ Applicable reliability standards means ``the requirements
and guidelines of the Electric Reliability Organization and the
Balancing Authority Area of the Transmission System to which the
Generating Facility is directly interconnected.'' See pro forma LGIP
section 1 (Definitions).
    \2858\ For clarity, we note that the reforms described in this
determination section and the related sections of the pro forma LGIP
apply to all interconnecting electric storage resources, whether
they are standalone, co-located generating facilities, or part of a
hybrid generating facility.
---------------------------------------------------------------------------

    1510. We find that by more accurately reflecting the technical
capabilities of electric storage resources in interconnection studies
through the use of appropriate operating assumptions, this reform
ensures the reliable interconnection of new electric storage resources
without overestimating their impact on the transmission system, thereby
ensuring just and reasonable rates by avoiding excessive and
unnecessary network upgrades that may hinder the timely development of
new generating facilities that stifles competition in the wholesale
market. We also find that reflecting the technical capabilities of
electric storage resources through the use of appropriate operating
assumptions in interconnection studies reduces unduly discriminatory or
preferential barriers to the interconnection of electric storage
resources.
    1511. We adopt the proposed revisions, subject to modification, to
section 3.1.2 of the pro forma LGIP to require transmission providers,
at the request of the interconnection customer, to use operating
assumptions that reflect the proposed charging behavior of an electric
storage resource, allow interconnection customers to resubmit their
operating assumptions if the transmission provider finds the originally
proposed operating assumptions are in conflict with good utility
practice, and allow the transmission provider to require the
interconnection customer to install additional control technologies. We
agree with Public Interest Organizations that transparency is necessary
when a transmission provider finds that an interconnection customer's
operating assumptions conflict with good utility practice.\2859\
Therefore, we modify the proposed revisions to section 3.1.2 of the pro
forma LGIP to require that, if a transmission provider finds an
interconnection customer's proposed operating assumptions to be in
conflict with good utility practice, the transmission provider must
provide the interconnection customer with a clear explanation in
writing of why the submitted operating assumptions are insufficient or
inappropriate by no later than 30 calendar days before the end of the
customer engagement window and allow the interconnection customer to
revise and resubmit the proposed operating assumptions one time at
least 10 calendar days before the end of the customer engagement
window.
---------------------------------------------------------------------------

    \2859\ Public Interest Organizations Initial Comments at 47-49.
---------------------------------------------------------------------------

    1512. We adopt the proposed revisions to section <IP_ADDRESS> of the pro
forma LGIP to require transmission providers to study electric storage
resources that request ERIS service according to the interconnection
customer's proposed operating

assumptions. We adopt the proposed revisions to section <IP_ADDRESS> of the
pro forma LGIP to require transmission providers to study electric
storage resources that request NRIS service according to the
interconnection customer's proposed operating assumptions.
    1513. We agree with Elevate and clarify that the reform to use
operating assumptions in interconnection studies, at the request of the
interconnection customer, that reflect the proposed charging behavior
of an electric storage resource applies to the operating assumptions
used in all study processes related to the interconnection of electric
storage resources. Accordingly, we modify the NOPR proposal to require
transmission providers, at the request of the interconnection customer,
to use operating assumptions that reflect the proposed charging
behavior of an electric storage resource in additional study processes,
as described below.
    1514. With respect to surplus interconnection service, we modify
the NOPR proposal to revise section 3.3.1 of the pro forma LGIP to
require transmission providers, at the request of the interconnection
customer, to use operating assumptions that reflect the proposed
charging behavior of an electric storage resource in the surplus
interconnection service process.
    1515. We adopt the proposed revisions to section 3.4.2 of the pro
forma LGIP to require interconnection customers to include in their
interconnection request the proposed operating assumptions that reflect
the proposed charging behavior of the electric storage resource and a
description of any control technologies that will limit the operation
of the electric storage resource to its intended operation.
    1516. To the extent an interconnection customer requests to modify
a generating facility already in the interconnection queue by adding an
electric storage resource to the interconnection request, the
transmission provider shall study such a modification in accordance
with section 4.4.3 of the pro forma LGIP using operating assumptions
that reflect the proposed charging behavior of an electric storage
resource, at the request of the interconnection customer. Accordingly,
we modify the NOPR proposal to revise section 4.4.3 of the pro forma
LGIP to require transmission providers, at the request of the
interconnection customer, to use operating assumptions that reflect the
proposed charging behavior of an electric storage resource in the
material modification process.
    1517. We adopt the proposed revisions to section 7.3 of the pro
forma LGIP to require transmission providers, at the request of the
interconnection customer, to use operating assumptions that reflect the
proposed charging behavior of an electric storage resource in the
cluster study process and to allow, but not require, transmission
providers to: (1) memorialize the generating facility's operating
assumptions in Appendix H of the interconnection customer's LGIA; and/
or (2) require control technologies (software and/or hardware) for an
electric storage resource that wishes to limit its operations during
peak load conditions, with such protection devices included in Appendix
C of the interconnection customer's LGIA.
    1518. We adopt the proposed revisions to section 8.2 of the pro
forma LGIP to require transmission providers, at the request of the
interconnection customer, to use operating assumptions that reflect the
proposed charging behavior of an electric storage resource in the
interconnection facilities study process.
    1519. We adopt the NOPR proposal to revise Appendix 1 of the pro
forma LGIP to require interconnection customers to provide to the
transmission provider as part of the initial interconnection request:
(1) the requested operating assumptions for the interconnecting
electric storage resource; and (2) a description of any applicable
control technologies. However, we agree with MISO and Pine Gate that it
is not necessary, and may not be possible, to specify the specific
ancillary services that an electric storage resource will provide
before entering the interconnection queue, particularly because the
market rules addressing the provision of ancillary services from
electric storage resources, whether they are standalone, part of co-
located generating facilities, or part of a hybrid generating facility,
are still being developed in multiple markets and such rules will
likely change over the coming years.\2860\ Therefore, we decline to
adopt the proposed revision to require interconnection customers to
list the specific ancillary services they intend to provide as part of
the initial interconnection request.\2861\ In addition, we agree with
MISO and CAISO that control technologies frequently evolve, and
interconnection customers that choose to specify operating assumptions
should be responsible for including appropriate control technologies
with their requests to use such operating assumptions. Therefore, we
also decline to adopt the proposed revision to require transmission
providers to publicly post a list of acceptable control technologies.
---------------------------------------------------------------------------

    \2860\ MISO Initial Comments at 118; Pine Gate Initial Comments
at 52.
    \2861\ NOPR, 179 FERC ] 61,194 at P 281.
---------------------------------------------------------------------------

    1520. We adopt the NOPR proposal to revise Appendix 1 of the pro
forma LGIP to require interconnection customers to provide to the
transmission provider any proposed operating assumptions for the
interconnecting electric storage resource as part of the initial
interconnection request. This timing ensures that the flexibility
provided by this reform does not delay the cluster study process by
ensuring the transmission provider has all necessary information at the
time interconnection studies commence. In response to commenters that
request that the Commission define a clear decision point after which
changes to operating assumptions may be considered a material
modification,\2862\ we reiterate that the operating assumptions must be
submitted as part of the initial interconnection request. Further, we
clarify that such operating assumptions only pertain to the proposed
charging behavior of an electric storage resource, i.e., whether the
interconnecting resource will or will not charge during peak load
conditions.
---------------------------------------------------------------------------

    \2862\ AES Clean Energy Initial Comments at 24; APS Initial
Comments at 22; Clean Energy Associations Initial Comments at 56-57;
ENGIE Initial Comments at 11.
---------------------------------------------------------------------------

    1521. We modify the NOPR proposal to add article 17.2 to the pro
forma LGIA to describe a violation of operating assumptions for
generating facilities, including for an electric storage resource. We
also add Appendix H to the pro forma LGIA as the location for the
interconnection customer to memorialize its operating assumptions. If
the owner of the generating facility fails to operate the generating
facility in accordance with its operating assumptions, as memorialized
in Appendix H of the pro forma LGIA, the transmission provider may
pursue termination of the LGIA through the breach and cure provisions
found in article 17 of the pro forma LGIA. As already provided for in
article 17 of the pro forma LGIA, we agree with Environmental Defense
Fund that interconnection customers should be given the opportunity to
cure a breach of the LGIA if possible.\2863\ We clarify that, if an
interconnection customer fails to operate its electric storage resource
in accordance with the operating assumptions memorialized in the
interconnection customer's LGIA, the

procedure for termination pursuant to articles 17.1.1 and 17.1.2 of the
pro forma LGIA is appropriate. We believe that repeat violations of the
operating assumptions memorialized in the LGIA are likely not
consistent with good utility practice.\2864\ Additionally, we agree
with rPlus and Idaho Power that there may be unique instances in real-
time operations during which a transmission provider would want an
electric storage resource to charge during peak load conditions (e.g.,
because the electric storage resource is located in a generation
pocket). Therefore, we clarify that, if done so at the direction of the
transmission provider to maintain the reliable and efficient operation
of the transmission system, an electric storage resource that operates
contrary to the operating assumptions specified in its LGIA in this
instance must not be considered in breach of its LGIA by the
transmission provider.
---------------------------------------------------------------------------

    \2863\ Environmental Defense Fund Initial Comments at 6-7.
    \2864\ The pro forma LGIA states that ``Each Party shall perform
all of its obligations under this LGIA in accordance with Applicable
Laws and Regulations, Applicable Reliability Standards, and Good
Utility Practice, and to the extent a Party is required or prevented
or limited in taking any action by such regulations and standards,
such Party shall not be deemed to be in Breach of this LGIA for its
compliance therewith.'' Pro forma LGIA art. 4.3 (Performance
Standards).
---------------------------------------------------------------------------

    1522. We believe that, taken together, the revisions to the pro
forma LGIP and pro forma LGIA will ensure that interconnection
customers adhere to the operating assumptions used to study their
electric storage resource and ameliorate concerns about possible
reliability problems expressed by commenters. We agree with commenters
that: (1) control devices can prevent electric storage resources from
charging during peak load conditions; (2) modern electric storage
resources can respond to signals from the transmission provider within
seconds; (3) electric storage resources generally do not have an
economic incentive to charge during peak load conditions; and (4) the
consequence of being considered in breach of the LGIA provides an
additional incentive for electric storage resources to follow the
agreed-upon operating assumptions memorialized in their LGIA. Further,
we note that some transmission providers already assume in their
interconnection studies that electric storage resources will not charge
during peak load conditions.\2865\ We emphasize that, irrespective of
these changes to operating assumptions, all electric storage resources
must continue to meet all requirements in the pro forma LGIP and pro
forma LGIA, as well as all applicable reliability standards.
---------------------------------------------------------------------------

    \2865\ Bonneville Initial Comments at 23; MISO Comments at 117;
see also PacifiCorp, 182 FERC ] 61,131 (2023) (accepting, subject to
condition, revisions to PacifiCorp's LGIP and LGIA to allow
PacifiCorp to study electric storage resources in its
interconnection study process using operating assumptions that more
accurately reflect their expected operation).
---------------------------------------------------------------------------

    1523. We agree with commenters that the speed and control with
which electric storage resources can respond to signals from
transmission providers sufficiently distinguishes the charging behavior
of electric storage resources from that of firm customer end-use load.
Therefore, for purposes of determining any network upgrades necessary
to accommodate the reliable interconnection of electric storage
resources, we find that the charging of electric storage resources
should not be modeled equivalently to firm customer end-use load in
interconnection studies if the interconnection customer memorializes
its operating assumptions in the LGIA and installs control
technologies, if required, to limit its operations as specified.
    1524. For clarity and in response to MISO's concern about
conflicting descriptions of the reform in the NOPR preamble and the
proposed revisions to the pro forma LGIP, we modify the proposed
revisions to the pro forma LGIP to clarify that these requirements
apply only to the operating assumptions for withdrawals of energy
(e.g., proposed charging behavior of electric storage resources,
whether standalone, co-located generating facilities, or part of a
hybrid generating facility), not to discharging.
    1525. In response to Pine Gate's request for clarification about
what network upgrade costs will be allocated to interconnection
customers as a result of the adoption of the revisions related to
operating assumptions, we clarify that the transmission provider must
not assign network upgrade costs to the interconnection customer based
on those worst-case operating assumptions (e.g., charging at maximum
capacity during peak load conditions) where there is agreement from the
interconnection customer to, if required, implement operating
restrictions including installing or demonstrating that the generating
facility already has control technologies (software and/or hardware) to
limit its operations during peak load conditions. As addressed above,
we believe that these conditions sufficiently address any reliability
concerns associated with the unexpected operation of an electric
storage resource and thus believe it is appropriate for the
transmission provider to only assign costs for network upgrades based
on the proposed charging behavior of the electric storage
resource.\2866\
---------------------------------------------------------------------------

    \2866\ See, e.g., AEE Initial Comments at 41-42; AEP Initial
Comments at 46-47; CESA Reply Comments at 10; Clean Energy
Associations Initial Comments at 52, 56-58; NARUC Initial Comments
at 37; NESCOE Reply Comments at 18; Public Interest Organizations
Initial Comments at 48-50; R Street Initial Comments at 16; SEIA
Reply Comments at 26-27.
---------------------------------------------------------------------------

    1526. Several commenters point out that not all transmission
providers use the same process to study the charging of electric
storage resources. Some transmission providers determine the network
upgrades needed to accommodate the charging of an electric storage
resource in the interconnection process, whereas other transmission
providers do so exclusively as part of a transmission service
request.\2867\ In response to these commenters, we clarify that the
requirement for transmission providers to use operating assumptions, at
the request of the interconnection customer, in interconnection studies
that reflect the proposed charging behavior of an electric storage
resource applies only to the operating assumptions that transmission
providers use in the interconnection process. This requirement does not
apply to transmission service requests and this final rule does not
propose to modify the process for requesting transmission service. In
response to Puget Sound,\2868\ we further clarify that this reform does
not require transmission providers to study charging as part of the
interconnection process if they do not already do so. If a transmission
provider does not determine the network upgrades needed to accommodate
the charging of an electric storage resource through the
interconnection process, then on compliance the transmission provider
must demonstrate why this reform does not apply to that particular
transmission provider.
---------------------------------------------------------------------------

    \2867\ See, e.g., Clean Energy Associations Initial Comments at
55; Puget Sound Initial Comments at 11-12; SPP Initial Comments at
25; Tri-State Initial Comments at 22; Xcel Initial Comments at 46-
47.
    \2868\ Puget Sound Initial Comments at 11-12.
---------------------------------------------------------------------------

    1527. In the NOPR, the Commission sought comment on whether to
define ``peak load period'' and/or ``net peak load'' period.\2869\
Given the variation in the scenarios that transmission providers study
in the interconnection process (e.g., summer peak load, winter peak
load, shoulder peak load, light load conditions, etc.), we agree with
commenters that regional flexibility is warranted.\2870\ Therefore, we
decline to adopt standardized definitions of ``peak

load period'' and/or ``net peak load'' period.
---------------------------------------------------------------------------

    \2869\ NOPR, 179 FERC ] 61,194 at P 287.
    \2870\ See, e.g., Ameren Initial Comments at 29; Microgrid
Resources Initial Comments at 8.
---------------------------------------------------------------------------

    1528. In the NOPR, the Commission also sought comment on whether to
define firm and non-firm charging for electric storage resources and
require transmission providers to define study criteria and possible
ways to interconnect related to both firm and non-firm charging.\2871\
Further, the Commission sought comment on proposed definitions of firm
and non-firm charging service. Several commenters express concerns
about defining firm and non-firm charging service, including whether
the proposed definitions conflate interconnection and transmission
service. We believe that, given the other reforms adopted herein
regarding operating assumptions, the proposed definitions of firm and
non-firm charging service are not necessary to ensure that transmission
providers, at the request of the interconnection customer, use more
realistic operating assumptions to study electric storage resources in
the interconnection process and to avoid excessive and unnecessary
network upgrades that may otherwise hinder the timely development of
new electric storage resources. Therefore, we decline to adopt any
definitions of firm and non-firm charging service. As a result, we also
clarify that this final rule does not require transmission providers to
define conditions under which electric storage resources will be
curtailed. In response to CAISO's concern that a proposed definition of
firm charging service would require transmission providers that do not
currently provide firm charging service to do so, we clarify that this
final rule does not require transmission providers to provide firm
charging service.
---------------------------------------------------------------------------

    \2871\ NOPR, 179 FERC ] 61,194 at P 288.
---------------------------------------------------------------------------

    1529. In the NOPR, the Commission sought comment on whether to
expand this reform to address operating assumptions for additional
generating facility technologies that may currently be inaccurately
modeled, such as variable energy resources.\2872\ The Commission also
sought comment on whether other operating assumptions, in addition to
the assumption that electric storage resources withdraw energy during
peak load periods, should be addressed as part of this proposed reform.
In response to several commenters' concerns about potential reliability
impacts and the administrative burden of extending the NOPR proposal to
also address injections of power from electric storage resources or
other resource types, we decline in this final rule to extend the
reform to apply to additional generating facility technologies or to
other operating assumptions. We clarify that this reform does not apply
to the operating assumptions used to study the injection of power from
electric storage resources or the injection of power from other
resource types (e.g., natural gas, solar, wind, etc.). We encourage
transmission providers to examine on an individual basis what operating
assumptions used to study the injection of power may be appropriate to
render the study process more accurate. Similarly, we decline to
require transmission providers to use fuel-based dispatch assumptions
to study the injection of power from all resource types in
interconnection studies at this time, as suggested by some commenters.
We acknowledge that fuel-based dispatch assumptions may be able to
address some of the identified challenges associated with inaccurate
modeling assumptions for all resource types and encourage transmission
providers to evaluate the merits of adopting it, but we do not believe
that adopting such a requirement on a generic basis is supported by the
record.
---------------------------------------------------------------------------

    \2872\ Id. P 286.
---------------------------------------------------------------------------

    1530. We decline to address the potential implications of this
reform for transmission providers with Commission-approved
interconnection processes that vary from the pro forma requirements
adopted in Order Nos. 2003 and 845. As explained in the section IV of
this final rule, transmission providers with such variations from the
pro forma LGIP and pro forma LGIA may seek approval as part of the
compliance process to maintain those variations, which the Commission
will consider on a case-by-case basis. What we adopt in this final rule
are requirements that are part of the pro forma LGIP and pro forma
LGIA, and we therefore only address the interaction of the requirements
adopted herein with existing requirements that are part of the pro
forma process and not variations thereto.
    1531. We also decline to require transmission providers to use
standardized operating assumptions, as some commenters suggest.\2873\
In the NOPR, the Commission did not propose to require transmission
providers to use standardized operating assumptions, and we decline to
do so here.
---------------------------------------------------------------------------

    \2873\ Puget Sound Initial Comments at 12; Pine Gate Initial
Comments at 54.
---------------------------------------------------------------------------

    1532. In response to comments from Hydropower Commenters'
suggestion that the final rule include a simplified procedure for
amending an executed interconnection agreement to optimize the
operating parameters of a pumped storage plant already in
operation,\2874\ we find that such a request is outside the scope of
this proceeding. In the NOPR, the Commission did not propose a new
study process for resources already in operation to amend operating
assumptions memorialized in their interconnection agreements.
---------------------------------------------------------------------------

    \2874\ Hydropower Commenters Initial Comments at 24.
---------------------------------------------------------------------------

    1533. In response to Microgrid Resources' request that the
Commission explicitly include microgrids in the provisions of this
rulemaking applied to hybrid resources,\2875\ we find such a request to
be outside the scope of this proceeding. The Commission did not propose
to define microgrids or apply specific reforms to microgrids in the
NOPR, and we decline to do so now. Further, in response to Microgrid
Resources' and IREC's requests that the Commission extend the proposed
reforms for hybrid resources to the pro forma SGIP,\2876\ we note that
the NOPR did not propose to revise the pro forma SGIP to require
transmission providers to use operating assumptions in interconnection
studies that reflect the proposed charging behavior of an electric
storage resource, and we decline to do so here.
---------------------------------------------------------------------------

    \2875\ Microgrid Resources Initial Comments at 7.
    \2876\ Id.; IREC Initial Comments at 15, attach. A.
---------------------------------------------------------------------------

2. Incorporating the Enumerated Alternative Transmission Technologies
Into the Generator Interconnection Process
a. Consideration of the Enumerated Alternative Transmission
Technologies in Interconnection Studies Upon Request of the
Interconnection Customer
i. Need for Reform and NOPR Proposal
    1534. In the NOPR, the Commission stated that alternative
transmission technologies can provide substantial benefits to optimize
the transmission system in specific scenarios because they often can be
deployed both more quickly and at lower costs than other network
upgrades.\2877\ The Commission stated that, despite these potential
benefits, alternative transmission technologies often do not receive
the same consideration during generator interconnection processes as
other network upgrades.\2878\ The Commission preliminarily found that
failing to consider alternative transmission technologies that can be
deployed both more quickly and at lower costs than network upgrades may
render

Commission-jurisdictional rates unjust and unreasonable.
---------------------------------------------------------------------------

    \2877\ NOPR, 179 FERC ] 61,194 at P 294.
    \2878\ Id. P 296.
---------------------------------------------------------------------------

    1535. The Commission proposed to revise the pro forma LGIP and pro
forma SGIP to require transmission providers, upon request of the
interconnection customer, to evaluate the requested alternative
transmission solution(s) during the pro forma LGIP cluster study and
the pro forma SGIP system impact study and facilities study within the
generator interconnection process.\2879\
---------------------------------------------------------------------------

    \2879\ Id. P 297.
---------------------------------------------------------------------------

    1536. To provide more certainty for evaluation purposes, and focus
on technologies that serve a transmission function and thus are subject
to Commission jurisdiction, the Commission proposed to specify the
technologies that the interconnection customer may request to be
evaluated.\2880\ Specifically, the Commission proposed revisions to the
pro forma LGIP and pro forma SGIP to require transmission providers to
consider the following technologies within the cluster study of the pro
forma LGIP and within the system impact study and facilities study of
the pro forma SGIP upon request of the interconnection customer:
advanced power flow control, transmission switching, dynamic line
ratings, static synchronous compensators, and static VAR compensators.
The Commission stated that it believes that the deployment of these
transmission technologies may reduce interconnection costs by providing
lower cost network upgrades to interconnect new generating
facilities.\2881\
---------------------------------------------------------------------------

    \2880\ Id. P 298.
    \2881\ Id.; see also id. PP 294-95, 298.
---------------------------------------------------------------------------

    1537. The Commission explained that, under this proposal, the
interconnection customer may request, at the relevant scoping meeting,
that the transmission provider consider a single, multiple, or all
technologies on this list.\2882\ The Commission proposed that the
transmission provider would be required to evaluate the transmission
technologies identified above for feasibility, cost, and time savings
within the cluster study for the pro forma LGIP and the system impact
study and facilities study for the pro forma SGIP, upon request of the
interconnection customer. The Commission explained that the
transmission provider, upon this request, must evaluate the identified
transmission technology and, if feasible, determine whether it should
be used, consistent with good utility practice and other applicable
regulatory standards. Transmission providers would continue to retain
discretion regarding whether to use the transmission technology.
---------------------------------------------------------------------------

    \2882\ Id. P 299.
---------------------------------------------------------------------------

    1538. The Commission sought comment on whether the list of
alternative transmission technologies is sufficient.\2883\ In
particular, the Commission sought comment on whether storage that
performs a transmission function, synchronous condensers, and voltage
source converters should be included in the list of alternative
transmission technologies. The Commission also sought comment on: (1)
whether there are software, operational, or other barriers to the use
of these transmission technologies as proposed; (2) whether the use of
alternative transmission technologies as supplements for, or in the
place of, traditional network upgrades is sufficient to guarantee a
level of service to accommodate an interconnection customer seeking
NRIS, or whether such a network upgrade can only be used if the
interconnection customer requested ERIS; (3) whether the existing study
processes and models in the generator interconnection process remain
suitable for considering alternative transmission technologies, whether
additional processes or models are needed, and if so, which entity
should be responsible for developing them; (4) how costs incurred for
evaluating alternative transmission technology study requests would be
allocated among interconnection customers in the cluster; (5) what
reasonable number of transmission technology study requests from each
interconnection customer would be workable, the burden (in terms of
both time and resources) on transmission providers required to evaluate
such requests, and whether interconnection study deadlines may need to
be extended to account for time needed to evaluate the alternative
transmission technology study requests; and (6) whether provisional
interconnection service consideration for transmission technologies
should be mandatory.\2884\
---------------------------------------------------------------------------

    \2883\ Id. P 300.
    \2884\ Id. P 301.
---------------------------------------------------------------------------

ii. Comments
(a) Comments in Support
    1539. Numerous commenters support the Commission's proposal because
they believe that it could reduce interconnection costs, increase
flexibility, increase the speed of interconnections, and improve
reliability.\2885\ Commenters assert that the proposed alternative
transmission technologies in the NOPR can reduce costs.\2886\ With
respect to reducing interconnection costs, SEIA contends that, by
decreasing the costs of network upgrades, the proposal will reduce the
number of withdrawals from the interconnection queue, creating a more
stable and efficient interconnection process.\2887\ SEIA also claims
that decreasing these costs will reduce the interconnection costs for
interconnection customers, who may then reflect those savings in power
purchase agreements or integrated resource plan submissions.\2888\
Commenters contend that, if the Commission were to not adopt this
proposal, the failure to lower interconnection costs by evaluating
alternative transmission technologies would impose unjust and
unreasonable costs on interconnection customers.\2889\
---------------------------------------------------------------------------

    \2885\ ACORE Reply Comments at 3-4; AEE Initial Comments at 42;
AEE Reply Comments at 41; AES Initial Comments at 25; Amazon Initial
Comments at 5-6; Clean Energy Associations Initial Comments at 61-
62; Clean Energy Associations Reply Comments at 9; Clean Energy
Buyers Initial Comments at 5; Consumer Protection Coalition Reply
Comments at 2; CREA and NewSun Initial Comments at 92; EDF
Renewables Initial Comments at 14; ENGIE Initial Comments at 12;
EPRI Initial Comments at 20-21; Fervo Energy Reply Comments at 8-9;
Illinois Commission Initial Comments at 14; Invenergy Initial
Comments at 52; NARUC Initial Comments at 38-39; OSPA Reply Comments
at 14; Ohio Commission Consumer Advocate Initial Comments at 15; OMS
Initial Comments at 19; [Oslash]rsted Initial Comments at 3;
[Oslash]rsted Reply Comments at 8; R Street Initial Comments at 9;
SEIA Initial Comments at 41; Tesla Initial Comments at 8; WATT
Coalition Initial Comments at 2; WATT Coalition Reply Comments at 1;
Joint Fed.-State Task Force on Elec. Transmission, Technical
Conference, Docket No. AD21-15-000, recording at 1:16:18-1:24:02
(approx.) (Commissioner Darcie Houck) (July 16, 2023).
    \2886\ Cyprus Creek Initial Comments at 26; SEIA Initial
Comments at 40; Shell Initial Comments, app. A at v-vi.
    \2887\ SEIA Initial Comments at 40; see also AEE Initial
Comments at 42; EDF Renewables Initial Comments at 14; ENGIE Initial
Comments at 12; [Oslash]rsted Initial Comments at 37; OMS Initial
Comments at 19.
    \2888\ SEIA Initial Comments at 40-41.
    \2889\ Clean Energy Associations Reply Comments at 9-10;
Environmental Defense Fund Initial Comments at 7; Fervo Energy Reply
Comments at 9; NARUC Initial Comments at 38.
---------------------------------------------------------------------------

    1540. With respect to reducing interconnection delays, Illinois
Commission asserts, for example, that alternative transmission
technologies allow resources to come online more quickly and allow for
better use of the existing transmission system, requiring fewer
transmission buildouts.\2890\ OMS contends that failing to consider
alternative transmission technologies risks requiring longer lead-time
network upgrades.\2891\ WATT Coalition argues that use of the
appropriate technologies will result in fewer withdrawals from

the interconnection queue and a reduction in restudies and
delays.\2892\ WATT Coalition points out that, when interconnection
customers withdraw, grid enhancing technologies offer additional value
because they are scalable and modular to address evolving needs and can
be redeployed as those needs continue to change.\2893\
---------------------------------------------------------------------------

    \2890\ Illinois Commission Initial Comments at 14.
    \2891\ OMS Initial Comments at 19.
    \2892\ WATT Coalition Initial Comments at 2.
    \2893\ Id. at 2-3; WATT Coalition Reply Comments at 5-6.
---------------------------------------------------------------------------

    1541. With respect to reliability, Ohio Commission Consumer
Advocate contends that some alternative transmission technologies could
provide substantial benefits by resolving thermal overloads and
avoiding voltage collapse.\2894\
---------------------------------------------------------------------------

    \2894\ Ohio Commission Consumer Advocate Initial Comments at 15.
---------------------------------------------------------------------------

    1542. Some commenters argue that a requirement to study alternative
transmission technologies would not slow down interconnection studies
overall.\2895\ For example, AEE states that, if a technology is not
proven or commercially viable, it will be quickly ruled out of further
evaluation under prevailing study approaches.\2896\ ACORE claims that
an evaluation of alternative transmission technologies would not be a
burden but rather an integral part of interconnection studies because
such an evaluation will likely reduce the number of withdrawals and
restudies.\2897\ WATT Coalition argues that, because transmission
providers currently use an iterative process when conducting
interconnection studies, adding the proposed list of alternative
transmission technologies to an iterative solution set should not
significantly change the time frame or complexity of studies.\2898\
---------------------------------------------------------------------------

    \2895\ ACORE Reply Comments at 3-4; AEE Initial Comments at 44;
ENGIE Initial Comments at 13; Fervo Energy Initial Comments at 7.
    \2896\ AEE Initial Comments at 44.
    \2897\ ACORE Reply Comments at 3-4.
    \2898\ WATT Coalition Reply Comments at 2.
---------------------------------------------------------------------------

(b) Comments in Opposition
    1543. Some commenters argue that the proposal is unnecessary
because transmission providers already consider alternative
transmission technologies in interconnection studies.\2899\ For
example, Southern states that transmission providers already include
the assessment of alternative transmission technologies such as static
VAR compensators as needed in interconnection studies.\2900\ AEE
responds that, if alternative transmission technologies are already
being evaluated, then the proposal will not place an additional burden
on interconnection queues.\2901\
---------------------------------------------------------------------------

    \2899\ Bonneville Initial Comments at 23-24; MISO Initial
Comments at 120; MISO Reply Comments at 12; Southern Initial
Comments at 29.
    \2900\ Southern Initial Comments at 29.
    \2901\ AEE Reply Comments at 42-43.
---------------------------------------------------------------------------

    1544. Several commenters oppose the proposal because they believe
it conflates the use of alternative transmission technologies in
operations with their use in planning.\2902\ For instance, MISO argues
that alternative transmission technologies are not necessarily the
solution needed for any particular interconnection because these are
often operational solutions that are inappropriate for wide-scale
deployment in a planning process, which reviews an entire cycle of
proposed interconnections and identifies solutions to support those
interconnections for the expected lifetime of their
interconnection.\2903\ MISO claims that using alternative transmission
technologies in planning for interconnection rather than in operations
may be inconsistent with ``good utility practice'' and ``applicable
regulatory standards'', and MISO expresses concerns about the impact or
effectiveness of using alternative transmission technologies in place
of network upgrades.\2904\ NYTOs assert that alternative transmission
technologies should generally not be used in interconnection studies
unless they are effective in the planning context.\2905\ PJM argues
that alternative transmission technologies should not be incorporated
into the generator interconnection process because they do not
represent long-term solutions that can serve as blanket substitutes for
the need for transmission expansion.\2906\ In response, AEE and WATT
Coalition argue that the primary purpose of alternative transmission
technologies is to serve as a complementary bridge technology while
more robust transmission is built.\2907\
---------------------------------------------------------------------------

    \2902\ MISO Initial Comments at 120; NRECA Initial Comments at
45-46; NYTOs Initial Comments at 32: PJM Initial Comments at 68.
    \2903\ MISO Initial Comments at 120; see also NRECA Initial
Comments at 45-46.
    \2904\ MISO Initial Comments at 122-123.
    \2905\ NYTOs Initial Comments at 32; see also Puget Sound
Initial Comments at 13-14.
    \2906\ PJM Initial Comments at 68.
    \2907\ AEE Reply Comments at 43-44; WATT Coalition Reply
Comments at 3-4.
---------------------------------------------------------------------------

    1545. Some commenters express concern that alternative transmission
technologies are not always appropriate for addressing long-term,
interconnection-related reliability issues.\2908\ Southern adds that,
because transmission providers already consider these technologies and
are subject to mandatory reliability standards, interconnection
customers should not be able to request certain reliability fixes
because their overall focus may be to minimize cost instead of
maximizing reliability.\2909\ EEI asserts that building firm
transmission capacity or replacing or upgrading limiting equipment
provides a more reliable long-term solution than the use of alternative
transmission technologies because they are not dependable for reducing
congestion or providing more capacity in the long-term or during
extreme system conditions.\2910\
---------------------------------------------------------------------------

    \2908\ AECI Initial Comments at 9; AEP Initial Comments at 51;
Avangrid Initial Comments at 36; Southern Initial Comments at 29;
U.S. Chamber of Commerce Initial Comments at 12.
    \2909\ Southern Initial Comments at 29.
    \2910\ EEI Initial Comments at 20.
---------------------------------------------------------------------------

    1546. Ameren and EEI oppose the proposal because they assert it
overlaps with pending proposals in other proceedings.\2911\ EEI argues
the Commission should not promulgate requirements related to
alternative transmission technologies in this proceeding while other
Commission proceedings meant to address the use of these same
technologies are pending.\2912\ ACORE responds that, given the benefits
of incorporating alternative transmission technologies in
interconnection studies, there is no justification for delaying this
requirement pending action in the other Commission proceedings.\2913\
---------------------------------------------------------------------------

    \2911\ Ameren Initial Comments at 30; EEI Initial Comments at
20.
    \2912\ EEI Initial Comments at 21 (citing Electric Transmission
Incentives Policy Under Section 219 of the Federal Power Act, Notice
of Proposed Rulemaking, Docket No. RM20-10-000; Grid-Enhancing
Technologies, Notice of Workshop, Docket No. AD19-19-000;
Implementation of Dynamic Line Ratings, Notice of Inquiry, Docket
No. AD22-5-000; Building for the Future Through Electric Regional
Transmission Planning and Cost Allocation and Generator
Interconnection, Notice of Proposed Rulemaking, Docket No. RM21-17-
000).
    \2913\ ACORE Reply Comments at 4.
---------------------------------------------------------------------------

    1547. Other commenters argue that requiring interconnection studies
to consider alternative transmission technologies will increase
interconnection study timelines and therefore slow interconnection
request processing speeds, contrary to the NOPR's objective.\2914\
Puget Sound asserts that ``the time is not ripe'' to enforce new
standards concerning alternative transmission technologies, given the
sweeping changes proposed in the NOPR, adding that advanced
transmission technologies requirements

may not be possible in the short term and could negate the Commission's
goals to streamline the interconnection process.\2915\
---------------------------------------------------------------------------

    \2914\ AECI Initial Comments at 9; AEP Initial Comments at 53;
Avangrid Initial Comments at 35; Dominion Initial Comments at 41;
EEI Initial Comments at 21; Eversource Initial Comments at 36-37;
Indicated PJM TOs Initial Comments at 55; Indicated PJM TOs Reply
Comments at 18; ISO-NE Initial Comments at 41; MISO Initial Comments
at 11, 123; National Grid Initial Comments at 42-43; Puget Sound
Initial Comments at 13.
    \2915\ Puget Sound Initial Comments at 13.
---------------------------------------------------------------------------

    1548. MISO contends that some alternative transmission
technologies, e.g., technologies that can control line impedances, may
shift the burden of system impacts to other parties by causing
additional new constraints.\2916\ Indicated PJM TOs are concerned that,
if one interconnection customer request changes power flows, such as
through the use of phase angle regulators, it will impact other
interconnection customers and effectively require a whole additional
set of studies for large areas of the transmission system.\2917\ AECI
argues that the appropriate balance of the burden to justify the use of
a particular technology should rest with the interconnection customer
so that ``capricious study requests'' are avoided.\2918\
---------------------------------------------------------------------------

    \2916\ MISO Initial Comments at 122, 124.
    \2917\ Indicated PJM TOs Initial Comments at 55.
    \2918\ AECI Initial Comments at 9.
---------------------------------------------------------------------------

    1549. Several commenters argue that the NOPR proposal is overly
burdensome for transmission providers.\2919\ For instance, MISO TOs
note the competing interests (i.e., accelerating the interconnection
process and layering numerous additional requirements and significantly
increasing the number of studies an RTO/ISO and its transmission owners
must perform).\2920\ MISO argues that the Commission's proposal would
require MISO to conduct 4,780 evaluations in the first phase of its
interconnection study process.\2921\ MISO contends that, when
evaluating how these technologies can be incorporated, the effects on
the rest of the interconnection queue and system can generate debate
that could slow down the interconnection process. Similarly, National
Grid claims that new alternative transmission technologies can present
modeling uncertainties (e.g., operating parameters and cost
uncertainties) and potential software limitations that transmission
owners would need an unforeseeable amount of time to evaluate and could
lead to possible penalties if study deadlines are not met.\2922\
---------------------------------------------------------------------------

    \2919\ Dominion Initial Comments at 41; EEI Initial Comments at
21; Eversource Initial Comments at 36-37; MISO TOs Initial Comments
at 30; NextEra Initial Comments at 6.
    \2920\ MISO TOs Initial Comments at 30.
    \2921\ MISO Initial Comments at 11.
    \2922\ National Grid Initial Comments at 42-43.
---------------------------------------------------------------------------

(c) Comments on Specific Proposal
(1) List of Alternative Transmission Technologies
    1550. Some commenters broadly support the list of proposed
alternative transmission technologies,\2923\ with others supporting
particular technologies (e.g., dynamic line ratings \2924\ and advanced
power flow control \2925\).
---------------------------------------------------------------------------

    \2923\ NARUC Initial Comments at 39; OMS Initial Comments at 19;
[Oslash]rsted Initial Comments at 16; WATT Coalition Initial
Comments at 3; Xcel Initial Comments at 47.
    \2924\ Illinois Commission Initial Comments at 14; OMS Initial
Comments at 19; WATT Coalition Initial Comments at 2; Joint Fed.-
State Task Force on Elec. Transmission, Technical Conference, Docket
No. AD21-15-000, recording at 1:16:18-1:24:02 (approx.)
(Commissioner Darcie Houck) (July 16, 2023).
    \2925\ WATT Coalition Initial Comments at 2; Joint Fed.-State
Task Force on Elec. Transmission, Technical Conference, Docket No.
AD21-15-000, recording at 1:16:18-1:24:02 (approx.) (Commissioner
Darcie Houck) (July 16, 2023).
---------------------------------------------------------------------------

    1551. MISO and SoCal Edison oppose the proposed list of
technologies because they contend that it includes technologies that
are not appropriate for interconnection.\2926\ MISO asserts that,
although the deployment of devices such as static series synchronous
compensators could solve some problems, they could create other issues
(e.g., a change to the impedance of any one transmission facility could
cause problems or impact operations elsewhere), requiring the holistic
management of their operation and deployment.\2927\ SoCal Edison claims
that certain technologies that the interconnection customer may request
to be evaluated, such as dynamic line ratings, have not been fully
tested by certain RTOs/ISOs and thus should be excluded from the
permissible list of options requested by an interconnection
customer.\2928\
---------------------------------------------------------------------------

    \2926\ MISO Initial Comments at 122; SoCal Edison Initial
Comments at 20.
    \2927\ MISO Initial Comments at 122.
    \2928\ SoCal Edison Initial Comments at 20.
---------------------------------------------------------------------------

    1552. Some commenters assert that, although dynamic line ratings
may be beneficial during operations, they may not be appropriate for
interconnection or transmission planning.\2929\ Others note several
operational challenges of using dynamic line ratings in
interconnection, such as: (1) there is currently no Commission or NERC
guidance on how to use dynamic line ratings absent thorough data on
wind conditions, temperature, and other future system conditions;
\2930\ and (2) interconnection study software is not capable of
incorporating dynamic line ratings, and it is not clear what
assumptions should be used on affected systems.\2931\ ISO-NE argues
that the Commission should continue to consider the use and
implementation of this technology in Docket No. AD22-5, rather than
here.\2932\ In response, WATT Coalition argues that there is
significant value in considering dynamic line ratings in planning,
adding that dynamic line ratings and other grid enhancing technologies
are not more difficult to study than legacy devices and traditional
solutions.\2933\
---------------------------------------------------------------------------

    \2929\ Indicated PJM TOs Initial Comments at 56; ISO-NE Initial
Comments at 41; NYTOs Initial Comments at 32-33; PacifiCorp Initial
Comments at 44; Tri-State Initial Comments at 23; U.S. Chamber of
Commerce Initial Comments at 12-13.
    \2930\ PacifiCorp Initial Comments at 44.
    \2931\ Tri-State Initial Comments at 23.
    \2932\ ISO-NE Initial Comments at 41.
    \2933\ WATT Coalition Reply Comments at 4-6.
---------------------------------------------------------------------------

    1553. While acknowledging the benefits that advanced power flow
control devices provide for real-time operations, Indicated PJM TOs
contend that they are inappropriate in the context of implementing
solutions to facilitate interconnection.\2934\ Tri-State claims that
advanced power flow control devices may push power onto other affected
systems, which is a more significant challenge in non-RTO/ISO
scenarios.\2935\ MISO asserts that the widespread use of advanced flow
control devices can have widespread impacts due to sizeable adjustments
to line impedances and that using these devices could result in a
cascade of issues across the system, pushing the problem and the costs
of remedying it to other customers.\2936\ WATT Coalition asserts that
automatic power factor controllers are just as effective at mitigating
overloads as reconductoring but that automatic power factor controllers
are the only flexible AC transmission system devices that suffer from
the ``perverse incentive'' identified by stakeholders because
installation costs are much lower than the upgrades they compete
with.\2937\ PacifiCorp states that in the course of the interconnection
study process it often considers the use of advanced power flow control
devices as potential alternatives to standard system
infrastructure.\2938\
---------------------------------------------------------------------------

    \2934\ Indicated PJM TOs Initial Comments at 56.
    \2935\ Tri-State Initial Comments at 23.
    \2936\ MISO Initial Comments at 122.
    \2937\ WATT Coalition Initial Comments at 3.
    \2938\ PacifiCorp Initial Comments at 43.
---------------------------------------------------------------------------

    1554. Some commenters raise concerns about using transmission
switching for interconnection. For instance, Tri-State questions
whether transmission switching is meant to be a remedial action scheme
or to create permanent open points on the system, which it argues may
be problematic in non-RTOs/ISOs and may result in

reduced reliability on the transmission system.\2939\ MISO argues that
applying automatic topology changes would be remedial action schemes,
noting that MISO and its transmission owners have attempted to reduce
the number of remedial action schemes employed on the system as a
matter of good utility practice.\2940\ PacifiCorp contends that
transmission switching is a complex process that can be implemented
only under particular factual scenarios and system conditions, adding
that it is unlikely that system congestion could be reliably reduced by
requiring the analysis of transmission switching in the study
process.\2941\
---------------------------------------------------------------------------

    \2939\ Tri-State Initial Comments at 23.
    \2940\ MISO Initial Comments at 122.
    \2941\ PacifiCorp Initial Comments at 44.
---------------------------------------------------------------------------

    1555. Other commenters argue that the Commission should not limit
the alternative transmission technologies to a pre-approved list.\2942\
Some commenters contend that the Commission's proposal could limit
future grid enhancing technologies that might be the best solution
because the list includes only five technologies and would not require
transmission providers to consider new grid enhancing technologies
until the list is expanded.\2943\ AEE and ENGIE ask the Commission to
provide a non-exhaustive list of alternative transmission technologies
and allow any alternative transmission technologies or grid enhancing
technologies that are proven and commercially viable to qualify for
evaluation, consistent with the Commission's statutory obligation to
``encourage, as appropriate, the deployment of advanced transmission
technologies'' and the list of alternative transmission technologies
included in that statute.\2944\
---------------------------------------------------------------------------

    \2942\ Amazon Initial Comments at 6-7; CTC Global Initial
Comments at 17; ENGIE Initial Comments at 13; Environmental Defense
Fund Initial Comments at 7; Invenergy Initial Comments at 52;
Microgrid Resources Initial Comments at 8; NRECA Initial Comments at
46; Public Interest Organizations Initial Comments at 53-55; Xcel
Initial Comments at 47.
    \2943\ Ameren Initial Comments at 31-32; MISO Reply Comments at
13-14; Shell Initial Comments, app. A at v.
    \2944\ AEE Initial Comments at 44-45 (citing 42 U.S.C. 16422);
ENGIE Initial Comments at 13.
---------------------------------------------------------------------------

    1556. Commenters suggest adding the following technologies to the
list: (1) synchronous condensers and voltage source converters; \2945\
(2) IBR technology solutions for advanced control capabilities and
control parameter tuning; \2946\ (3) microgrid control technologies;
\2947\ and (4) remedial action schemes, which they contend are an
effective and inexpensive way to mitigate local transmission
constraints the use of which is not allowed in many transmission
providers' policies.\2948\
---------------------------------------------------------------------------

    \2945\ NARUC Initial Comments at 39; Xcel Initial Comments at
47.
    \2946\ EPRI Initial Comments at 21.
    \2947\ Microgrid Resources Initial Comments at 8.
    \2948\ Enel Initial Comments at 80.
---------------------------------------------------------------------------

    1557. Several commenters also suggest adding advanced conductors to
the required list of alternative transmission technologies.\2949\ VEIR
and ACORE argue that advanced conductors may be a beneficial
alternative to network upgrades because: (1) advanced conductors meet
the same criteria of quick deployment and low cost and have advantages
over other network upgrades, especially the elimination of additional
siting and permitting requirements; \2950\ and (2) a recent Grid
Strategies LLC report finds ``short lead time to reconductor existing
lines can help manage risk and uncertainties and significantly increase
system capacity to mitigate overloads identified in interconnection
studies.'' \2951\ NARUC asks the Commission to consider requiring an
evaluation of the accuracy of transmission line ratings on surrounding
or impacted transmission facilities if requested by an interconnection
customer.\2952\ Additionally, Ampjack proposes tower lifting to
increase transmission line ratings due to the time savings, lack of
outages, and use of existing structures.\2953\
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    \2949\ ACORE Initial Comments at 6-7; CTC Global Initial
Comments at 6-9; VEIR Initial Comments at 5-7.
    \2950\ VEIR Initial Comments at 5-7.
    \2951\ ACORE Initial Comments at 7 (citing Jay Caspary and Jesse
Schneider, Grid Strategies, LLC, Opportunities to Use Advanced
Conductors to Accelerate Grid Decarbonization, at 9 (Feb. 2022),
https://acore.org/wp-content/uploads/2022/03/Advanced_Conductors_to_Accelerate_Grid_Decarbonization.pdf).
    \2952\ NARUC Initial Comments at 39-40.
    \2953\ Ampjack Initial Comments at 1-4.
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    1558. Many commenters recommend that the Commission add storage
that performs a transmission function to the list.\2954\ Illinois
Commission contends that storage that performs a transmission function
can relieve congestion, maintain reliability, and be placed on the
transmission system more quickly and cheaply than building new
transmission lines.\2955\ Tesla suggests expanding the list to include
batteries as virtual transmission, arguing that it provides several
benefits (e.g., providing emergency capacity for congested transmission
lines and surplus generation and surplus load capacity to allow
operation of transmission lines closer to thermal capacity without risk
of outage and averting the need for load shed by providing grid
stability service).\2956\ Clean Energy Associations note that the
Commission has approved tariffs for storage that performs a
transmission function. Clean Energy Associations assert that it would
be inconsistent to prohibit an interconnection customer from adding
electric storage to an interconnection request specifically to address
transmission reliability impacts in lieu of conventional upgrades,
while at the same time allowing an interconnection customer to add such
storage to an interconnection request for purposes unrelated to
transmission reliability or allowing an interconnection customer to
limit electric storage operations as a means to avoid network
upgrades.\2957\
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    \2954\ AES Initial Comments at 25; Clean Energy Associations
Initial Comments at 62; Clean Energy Associations Reply Comments at
9; ENGIE Initial Comments at 13; Illinois Commission Initial
Comments at 14-15; Illinois CUB Reply Comments at 1; NARUC Initial
Comments at 39; NESCOE Reply Comments at 19; NY Commission and
NYSERDA Initial Comments at 10; Ohio Commission Consumer Advocate
Initial Comments at 17; OMS Initial Comments at 19; [Oslash]rsted
Initial Comments at 16; Tesla Initial Comments at 8-9; Union of
Concerned Scientists Reply Comments at 14-15; Xcel Initial Comments
at 47; Joint Fed.-State Task Force on Elec. Transmission, Technical
Conference, Docket No. AD21-15-000, recording at 1:16:18-1:24:02
(approx.) (Commissioner Darcie Houck) (July 16, 2023).
    \2955\ Illinois Commission Initial Comments at 14-15.
    \2956\ Tesla Initial Comments at 8-9.
    \2957\ Clean Energy Associations Initial Comments at 62-63.
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    1559. Other commenters do not agree with adding storage that
performs a transmission function to the list.\2958\ MISO notes that,
although it already evaluates storage that performs a transmission
function in its generator interconnection process, it was a subject of
considerable debate.\2959\ Shell states that, while storage that
performs a transmission function may provide system benefits, it has
concerns regarding the ability of storage that performs a transmission
function to ``queue jump'' interconnection customers, thus putting
those customers at a competitive disadvantage.\2960\
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    \2958\ Ameren Initial Comments at 31; MISO Initial Comments at
121; Shell Initial Comments, app. A at v.
    \2959\ MISO Initial Comments at 121.
    \2960\ Shell Initial Comments, app. A at v.
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(2) Whether To Mandate the Consideration of Alternative Transmission
Technologies
    1560. Several commenters argue that these technologies should be
studied by default, rather than at the request of the interconnection
customer, with some suggesting an ``opt-out'' that the

interconnection customer could elect.\2961\ Fervo Energy argues that
mandating the consideration of grid enhancing technologies could be
more efficient and facilitate more and faster interconnection, although
there may be delays initially as transmission providers adjust.\2962\
Clean Energy Associations ask that transmission providers automatically
evaluate grid enhancing technologies, unless all interconnection
customers in a cluster opt out.\2963\ [Oslash]rsted recommends that the
Commission consider requiring that advanced transmission technologies
be studied and implemented when network upgrades are needed but cannot
be completed within three years of being identified.\2964\
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    \2961\ ACORE Initial Comments at 6; AEE Initial Comments at 42,
44; AEE Reply Comments at 41-42; Amazon Initial Comments at 6; Clean
Energy Associations Initial Comments at 63-64; Environmental Defense
Fund Initial Comments at 7; ELCON Initial Comments at 11; ENGIE
Initial Comments at 13; Fervo Energy Reply Comments at 9; Hannon
Armstrong Initial Comments at 2; Invenergy Initial Comments at 52-
53; R Street Initial Comments at 16; WATT Coalition Initial Comments
at 2; WATT Coalition Reply Comments at 1; Joint Fed.-State Task
Force on Elec. Transmission, Technical Conference, Docket No. AD21-
15-000, recording at 1:16:18-1:24:02 (approx.) (Commissioner Darcie
Houck) (July 16, 2023).
    \2962\ Fervo Energy Reply Comments at 9.
    \2963\ Clean Energy Associations Initial Comments at 63.
    \2964\ [Oslash]rsted Reply Comments at 8.
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    1561. CAISO contends that the Commission should simply require
transmission providers to include a statement in their tariffs that
they will consider alternative transmission technologies for every
interconnection and incorporate them when they are the cost-effective
solution.\2965\ CAISO states that this would allow the interconnection
customer to request an unexecuted interconnection agreement and to
raise with the Commission any transmission provider refusal to consider
a technology.\2966\ Ohio Commission Consumer Advocate suggests that
transmission providers and interconnection customers mutually determine
an appropriate number of evaluations for grid enhancing
technologies.\2967\
---------------------------------------------------------------------------

    \2965\ CAISO Initial Comments at 38.
    \2966\ Id.; see also MISO Reply Comments at 13.
    \2967\ Ohio Commission Consumer Advocate Initial Comments at 16.
---------------------------------------------------------------------------

(3) Alternative Transmission Technologies in Provisional
Interconnection Service
    1562. Some commenters argue that alternative transmission
technologies could assist with provisional interconnection service. For
instance, R Street and Hannon Armstrong assert that these technologies
can be used as a temporary measure until other network upgrades are
completed, thus reducing the cost and delays of generator
interconnection, even if they only serve as a bridge to a permanent
solution set, such as cluster network upgrades.\2968\ NextEra contends
that, when an alternative transmission technology may serve as a
temporary solution, the transmission provider should reasonably
cooperate with requests from an interconnection customer willing to
fund installation of that technology as an interim solution.\2969\
Fervo Energy asks the Commission to require transmission providers to
consider alternative transmission technologies when responding to a
provisional interconnection request if these technologies allow for
earlier in-service dates.\2970\
---------------------------------------------------------------------------

    \2968\ R Street Initial Comments at 16; Hannon Armstrong Initial
Comments at 2.
    \2969\ NextEra Initial Comments at 38-39.
    \2970\ Fervo Energy Reply Comments at 10.
---------------------------------------------------------------------------

    1563. Others oppose requiring evaluation of alternative
transmission technologies for provisional interconnection
service.\2971\ For instance, MISO argues that the consideration of
advanced transmission technologies for provisional interconnection
service should not be mandatory because it may result in delays that
are contrary to the goals of this proceeding.\2972\