interconnection customer's expense, and each study would require a
$10,000 deposit, subject to a true-up based on actual study costs.
---------------------------------------------------------------------------

    \179\ Id. P 43.
---------------------------------------------------------------------------

    70. The Commission proposed that, within seven business days of the
receipt of a prospective interconnection customer's request for an
informational interconnection study, the transmission provider would
have to provide the prospective interconnection customer with an
informational interconnection study agreement.\180\ The Commission
explained that the informational interconnection study agreement would
specify the technical data that the prospective interconnection
customer must provide and an estimate of the expected costs of the
study, including, to the extent known by the transmission provider, an
estimate of the study costs expected to be incurred by any relevant
affected systems. Under the proposal, the prospective interconnection
customer would have 10 business days to execute the agreement and
deliver it to the transmission provider, along with the relevant
technical data and study deposit, after which the transmission provider
would have 45 calendar days to complete the study.
---------------------------------------------------------------------------

    \180\ Id. P 44.
---------------------------------------------------------------------------

    71. The Commission proposed that the informational interconnection
study would consist of a sensitivity analysis based on the assumptions
specified in the informational interconnection study agreement.\181\
Under the proposal, the informational interconnection study would
identify potential interconnection facilities and network upgrades that
may be required to interconnect the prospective interconnection
customer's proposed generating facility, including an approximation of
the costs of such interconnection facilities and network upgrades. The
Commission noted that the transmission provider would also coordinate
with affected systems that may be impacted by the prospective
interconnection customer's request to provide information on affected
systems-related issues.
---------------------------------------------------------------------------

    \181\ Id. P 45.
---------------------------------------------------------------------------

    72. The Commission proposed an informational interconnection study
agreement form, which explains that the informational interconnection
study is performed solely for informational purposes and is not binding
on either party.\182\ The proposed agreement also requires the study
report to provide specific information, including, at a minimum: (1)
preliminary identification of any circuit breaker short circuit
capability limits exceeded; (2) preliminary identification of any
thermal overload or voltage limit violations; and (3) estimated network
upgrade costs related to the identified overloads and violations.
---------------------------------------------------------------------------

    \182\ Id. P 46.
---------------------------------------------------------------------------

    73. The Commission sought comment on: (1) whether the informational
interconnection study, as proposed, would provide prospective
interconnection customers with sufficient and timely information to
inform decision-making prior to submitting an interconnection request;
(2) whether transmission providers should be required to establish a
request window of a limited number of days each year in which potential
interconnection customers can request an optional informational
interconnection study; and (3) the burdens on transmission providers of
conducting informational studies and whether other options, such as the
proposal discussed below for public interconnection information, might
strike a better balance of providing interconnection customers with
useful information while making efficient use of transmission provider
resources.\183\
---------------------------------------------------------------------------

    \183\ Id. PP 47-48.
---------------------------------------------------------------------------

    74. Additionally, the Commission proposed to add new section 3.1.2
to the pro forma LGIP, which provides that interconnection customers
evaluating different options (such as different sizes, sites, or
voltages) are encouraged but not required to use the new informational
interconnection study proposed in the NOPR before entering the cluster
study.\184\
---------------------------------------------------------------------------

    \184\ Id. P 66.
---------------------------------------------------------------------------

ii. Comments
(a) Comments in Support
    75. Several commenters support the NOPR proposal to require
transmission providers to offer an informational interconnection study
to prospective interconnection customers.\185\ Several commenters agree
that the informational interconnection study proposal could reduce the
number of speculative or other interconnection requests \186\ and
improve the efficiency of siting decisions.\187\ Some commenters expect
that these changes will have other benefits for the interconnection
process, including cost savings from fewer and more viable
interconnection requests,\188\ a reduced need for project withdrawals
and queue restudies,\189\ and reduced burden on transmission providers,
which will result in fewer interconnection study delays.\190\
---------------------------------------------------------------------------

    \185\ Affected Interconnection Customers Initial Comments at 30;
Clean Energy States Initial Comments at 4; Consumers Energy Initial
Comments at 3; Duke Southeast Utilities Initial Comments at 6;
Evergreen Action Initial Comments at 3; Fervo Energy Initial
Comments at 2; Illinois Commission Initial Comments at 6; Interwest
Initial Comments at 4, 7; NESCOE Reply Comments at 2; Public
Interest Organizations Initial Comments at 18; Southern Initial
Comments at 28; Tesla Initial Comments at 4; Tri-State Initial
Comments at 5.
    \186\ Fervo Energy Initial Comments at 2-3; Google Initial
Comments at 4; NRECA Initial Comments at 13; NY Commission and
NYSERDA Initial Comments at 6-8.
    \187\ Duke Southeast Utilities Initial Comments at 6-7; ISO-NE
Initial Comments at 18; NARUC Initial Comments at 5; NRECA Initial
Comments at 13; Pine Gate Initial Comments at 13-14; Tesla Initial
Comments at 4.
    \188\ Evergreen Action Initial Comments at 3; NARUC Initial
Comments at 5.
    \189\ Evergreen Action Initial Comments at 3; NRECA Initial
Comments at 13.
    \190\ Google Initial Comments at 4.
---------------------------------------------------------------------------

    76. MISO and Fervo Energy state that it is helpful for a
prospective interconnection customer to compare how various MW sizes,
points of interconnection, or other scenarios could affect costs,
especially for prospective interconnection customers that cannot
perform such analysis in house, and that the NOPR's

informational interconnection study proposal would assist in these
goals.\191\ Pacific Northwest Organizations argue that, without upfront
interconnection cost information, independent power producers may be
discouraged from entering the interconnection queue if they are
subjected to higher withdrawal fees, which may result in preventing
them from being considered in request for proposals (RFPs) in the
Pacific Northwest.\192\
---------------------------------------------------------------------------

    \191\ Fervo Energy Initial Comments at 2; MISO Initial Comments
at 22.
    \192\ Pacific Northwest Organizations Initial Comments at 3-4.
---------------------------------------------------------------------------

    77. Some commenters stress the importance of the informational
interconnection study in light of the other reforms proposed in the
NOPR. For instance, Northwest and Intermountain aver that the
informational study will be the primary resource for interconnection
customers to demonstrate the feasibility and cost effectiveness of
their interconnection plan and will serve as the foundation for
subsequent negotiations for the documents that will establish
commercial readiness of their project for the cluster study
process.\193\ Pacific Northwest Organizations assert that the NOPR's
proposed commercial readiness framework would be problematic in the
region without something like the informational interconnection study
to discover costs before entering the queue.\194\
---------------------------------------------------------------------------

    \193\ Northwest and Intermountain Initial Comments at 6-7.
    \194\ Pacific Northwest Organizations Initial Comments at 3.
---------------------------------------------------------------------------

    78. Several commenters are generally supportive of the NOPR
proposal but either (1) offer qualifications to that support \195\ or
(2) request specific changes to the proposal.\196\
---------------------------------------------------------------------------

    \195\ Idaho Power Initial Comments at 3 (stating that it only
supports the proposal if the informational interconnection study
requirements are less prescriptive and allow for more flexibility);
NRECA Initial Comments at 8 (stating that it does not oppose the
proposal as long as the final rule includes a larger package of
reforms to reduce speculative interconnection requests and speed up
interconnection queues as well as affords reasonable flexibility on
compliance); Ohio Commission Consumer Advocate Initial Comments at 6
(stating that informational studies should not interfere with other
interconnection studies).
    \196\ ACE-NY Initial Comments at 10; Avangrid Initial Comments
at 21; Clean Energy Buyers Initial Comments at 7; ELCON Initial
Comments at 4-5; NY Commission and NYSERDA Initial Comments at 6-7;
Pattern Energy Initial Comments at 20; Pine Gate Initial Comments at
11-13; Southern Initial Comments at 28.
---------------------------------------------------------------------------

(b) Comments in Opposition
    79. Many commenters oppose the NOPR proposal to require
transmission providers to offer an informational interconnection study
to prospective interconnection customers.\197\ Many commenters argue
that the informational interconnection study proposal could be a burden
or divert resources,\198\ which they contend would increase delays for
the interconnection queue and other studies.\199\ Dominion insists that
the decision as to whether to offer informational interconnection
studies should be the transmission provider's and must have
limits.\200\ Longroad Energy states that transmission-interconnected
generating facilities are typically complex facilities with unique
operating characteristics which would be poorly approximated in
simplified studies.\201\ Environmental Defense Fund states that, while
it supported the informational interconnection studies proposal in its
initial comments, after review of the other comments submitted, it
recommends that the Commission reconsider the proposal and ensure that
any informational interconnection study reform not delay other
interconnection processes.\202\
---------------------------------------------------------------------------

    \197\ AECI Initial Comments at 3; AEP Initial Comments at 7; AEP
Reply Comments at 2; APPA-LPPC Initial Comments at 3; Avangrid
Initial Comments at 21; Bonneville Initial Comments at 3; CAISO
Initial Comments at 5; Clean Energy Associations Initial Comments at
13; Dominion Reply Comments at 5; EEI Initial Comments at 11; EEI
Reply Comments at 7-8; Enel Initial Comments at 9; ENGIE Initial
Comments at 2; Eversource Initial Comments at 5; Indicated PJM TOs
Initial Comments at 12; Indicated PJM TOs Reply Comments at 14;
Longroad Energy Reply Comments at 3; NextEra Initial Comments at 5;
NextEra Reply Comments at 8; North Dakota Commission Initial
Comments at 3-4; NV Energy Initial Comments at 14; OMS Initial
Comments at 5; [Oslash]rstead Initial Comments at 7; PG&E Initial
Comments at 9; PJM Initial Comments at 45; PPL Initial Comments at
4; SEIA Initial Comments at 3; SPP Initial Comments at 2, 3-4;
Vermont Electric and Vermont Transco Initial Comments at 3; WIRES
Initial Comments at 8.
    \198\ AECI Initial Comments at 3; AEE Reply Comments at 5-6; AEP
Initial Comments at 7-8; AEP Reply Comments at 2; AES Initial
Comments at 4; Alliant Energy Initial Comments at 4; APPA-LPPC
Initial Comments at 9; APS Initial Comments at 5; Bonneville Initial
Comments at 3; CAISO Initial Comments at 6; Clean Energy Buyers
Initial Comments at 6; Clean Energy States Initial Comments at 4;
Dominion Reply Comments at 5-6; Environmental Defense Fund Reply
Comments at 5; EEI Initial Comments at 11-12; EEI Reply Comments at
8-9; ELCON Initial Comments at 4-5; Enel Initial Comments at 9;
ENGIE Initial Comments at 2; Eversource Initial Comments at 5;
Google Initial Comments at 5; Idaho Power Initial Comments at 3;
Indicated PJM TOs Initial Comments at 12; Indicated PJM TOs Reply
Comments at 14; Longroad Energy Reply Comments at 4-5; MISO Reply
Comments at 17; National Grid Initial Comments at 9; NESCOE Reply
Comments at 2; NextEra Reply Comments at 8-9, 11-12; New Jersey
Commission Initial Comments at 21; North Dakota Commission Initial
Comments at 3-4; NRECA Initial Comments at 14; NV Energy Initial
Comments at 14; NYISO Initial Comments at 16; OMS Initial Comments
at 5; Pine Gate Initial Comments at 12; PPL Initial Comments at 4-6;
SDG&E Initial Comments at 3-4; SEIA Initial Comments at 3; SEIA
Reply Comments at 4; SoCal Edison Initial Comments at 12; Tesla
Initial Comments at 4; Vermont Electric and Vermont Transco Initial
Comments at 3; WIRES Initial Comments at 8.
    \199\ AECI Initial Comments at 3; AEP Initial Comments at 7-8;
AEP Reply Comments at 2-3; AES Initial Comments at 4; Alliant Energy
Initial Comments at 4; APS Initial Comments at 4; Bonneville Initial
Comments at 3; CAISO Initial Comments at 6; Dominion Initial
Comments at 9; Duke Southeast Utilities Initial Comments at 7-8;
Environmental Defense Fund Reply Comments at 5; EEI Initial Comments
at 11; ELCON Initial Comments at 4-5; Eversource Initial Comments at
5-6; Google Initial Comments at 5; Idaho Power Initial Comments at
3; Indicated PJM TOs Initial Comments at 13; MISO Reply Comments at
17; National Grid Initial Comments at 7, 10-11; NESCOE Reply
Comments at 2; NextEra Reply Comments at 8; New Jersey Commission
Initial Comments at 21; North Dakota Commission Initial Comments at
3-4; NRECA Initial Comments at 14; NYISO Initial Comments at 16-19;
OMS Initial Comments at 5; Pennsylvania Commission Initial Comments
at 11; PG&E Initial Comments at 9; PG&E Reply Comments at 5; Pine
Gate Initial Comments at 12; PJM Initial Comments at 45; PPL Initial
Comments at 4; SEIA Initial Comments at 4; SoCal Edison Initial
Comments at 12; Tesla Initial Comments at 4.
    \200\ Dominion Reply Comments at 5.
    \201\ Longroad Energy Reply Comments at 7.
    \202\ Environmental Defense Fund Reply Comments at 5.
---------------------------------------------------------------------------

    80. Several commenters contend that the informational
interconnection study proposal would not likely be valuable.\203\ Clean
Energy Associations assert that the proposed informational
interconnection study would provide no information related to
stability-driven network upgrades, rendering it near-useless in areas
where stability limits are most typically the driver of network
upgrades.\204\ APPA-LPPC warn that informational interconnection
studies could engender controversy because prospective interconnection
customers would, notwithstanding the informational nature of the
studies, likely rely upon the study results in

making investment decisions, even though the informational study
results would inevitably diverge from the actual interconnection study
results.\205\
---------------------------------------------------------------------------

    \203\ AEE Initial Comments at 9-10; AEE Reply Comments at 5-6;
AEP Initial Comments at 7; AEP Reply Comments at 2; Alliant Energy
Initial Comments at 4; CAISO Initial Comments at 5-6; Clean Energy
Associations Initial Comments at 14; CREA and NewSun Initial
Comments at 42; Dominion Reply Comments at 5; EEI Initial Comments
at 12; EEI Reply Comments at 8; Enel Initial Comments at 9; ENGIE
Initial Comments at 2; Eversource Initial Comments at 5-6; Indicated
PJM TOs Initial Comments at 12; Indicated PJM TOs Reply Comments at
14; ISO-NE Initial Comments at 19; Longroad Energy Reply Comments at
3; MISO Initial Comments at 20-21; MISO Reply Comments at 17-18;
NextEra Initial Comments at 5, 10-11; NextEra Reply Comments at 9;
North Dakota Commission Initial Comments at 4; NRECA Initial
Comments at 14; NV Energy Initial Comments at 14; NYISO Initial
Comments at 17; OMS Initial Comments at 5; Pacific Northwest
Utilities Initial Comments at 8 n.13; PG&E Initial Comments at 9;
PG&E Reply Comments at 4; PJM Initial Comments at 45; SDG&E Initial
Comments at 3-4; SEIA Initial Comments at 3; SEIA Reply Comments at
3; SoCal Edison Initial Comments at 11-12; WIRES Initial Comments at
8.
    \204\ Clean Energy Associations Initial Comments at 14.
    \205\ APPA-LPPC Initial Comments at 12.
---------------------------------------------------------------------------

    81. Several commenters argue that the proposal is not an
improvement over the status quo.\206\ National Grid and NextEra assert
that it is unclear how the proposal would save any time compared to the
status quo, and that the best way for an interconnection customer to
obtain the necessary information is by entering and proceeding through
the interconnection queue with transmission providers focusing on
actual studies.\207\ NextEra adds that the proposed informational
interconnection study is only informative in extreme cases, such as
very limited capacity available on a transmission line, which the
interconnection customer should be able to identify themselves.\208\
---------------------------------------------------------------------------

    \206\ National Grid Initial Comments at 9; New Jersey Commission
Initial Comments at 21; Vermont Electric and Vermont Transco Initial
Comments at 3.
    \207\ National Grid Initial Comments at 9; NextEra Initial
Comments at 12.
    \208\ NextEra Initial Comments at 12.
---------------------------------------------------------------------------

    82. CREA and NewSun express concern that the NOPR proposal places
too much reliance on the usefulness of the informational
interconnection study in order to justify the financial readiness and
commitment NOPR proposals.\209\ They assert that the informational
interconnection study is not a useful replacement for the feasibility
study, which takes into account the impact of other interconnection
customers in the interconnection queue cluster. Therefore, CREA and
NewSun ask the Commission to instead retain the feasibility study as
part of the cluster study process to allow interconnection customers to
obtain cluster-level information on likely costs and network upgrades
before proceeding further with major deposits and irretrievable
commitments.
---------------------------------------------------------------------------

    \209\ CREA and NewSun Initial Comments at 46-47.
---------------------------------------------------------------------------

    83. Several commenters point to the experience with similar studies
in SPP and MISO as evidence that the optional informational
interconnection study proposal will be little-used in practice.\210\
SPP reports that its interconnection customers explained that their
time could be more effectively spent working on the more definitive
system impact studies, that the feasibility and preliminary impact
studies did not provide results that could be relied on in making
business decisions, and that this same outcome would be true of the
proposed informational interconnection study.\211\
---------------------------------------------------------------------------

    \210\ AEE Initial Comments at 10; AEP Initial Comments at 8,12;
Clean Energy Associations Initial Comments at 14; Enel Initial
Comments at 9-10; Longroad Energy Reply Comments at 3-4; MISO
Initial Comments at 21; NextEra Reply Comments at 8; Omaha Public
Power Initial Comments at 3; SEIA Reply Comments at 3; SPP Initial
Comments at 3. NextEra argues that transmission providers with large
numbers of interconnection requests have tried optional
interconnection studies and have not found them to be useful.
NextEra Reply Comments at 10.
    \211\ SPP Initial Comments at 3.
---------------------------------------------------------------------------

    84. Several commenters point to the inability of the informational
interconnection studies to provide reliable cost estimates \212\ and
believe that the information provided in these studies will be quickly
outdated.\213\ The New Jersey Commission is concerned that this
approach may not materially reduce the uncertainty interconnection
customers currently face.\214\ In particular, many commenters contend
that the informational interconnection study is not meaningful in the
context of a cluster interconnection
---------------------------------------------------------------------------

    \212\ AEP Initial Comments at 8; Ameren Initial Comments at 5;
CAISO Initial Comments at 5; Clean Energy Associations Initial
Comments at 14; CREA and NewSun Initial Comments at 43; Cyprus Creek
Initial Comments at 13; Enel Initial Comments at 9; Interwest
Initial Comments at 7-8; NextEra Initial Comments at 5; NRECA
Initial Comments at 14; PJM Initial Comments at 45; SoCal Edison
Initial Comments at 11-12.
    \213\ AEP Initial Comments at 8; Alliant Energy Initial Comments
at 4; Dominion Initial Comments at 10; Enel Initial Comments at 9;
Eversource Initial Comments at 9; Interwest Initial Comments at 7-8;
PJM Initial Comments at 45; PJM TOs Initial Comments at 13; SEIA
Reply Comments at 4.
    \214\ New Jersey Commission Initial Comments at 21.
---------------------------------------------------------------------------

    process.\215\ Commenters argue that, because the informational
interconnection study does not provide information on other
interconnection customers that would enter the interconnection queue at
the same time, there is no guarantee that the study results will even
approximate the actual network upgrade costs determined by the cluster
results.\216\
---------------------------------------------------------------------------

    \215\ Id.; AEE Initial Comments at 9-10; Avangrid Initial
Comments at 23-24; Clean Energy Associations Initial Comments at 14;
CREA and NewSun Initial Comments at 43; Dominion Reply Comments at
6; EEI Initial Comments at 12; EEI Reply Comments at 8; Enel Initial
Comments at 9; Eversource Initial Comments at 9-10; ISO-NE Initial
Comments at 18-19; MISO Initial Comments at 21; NRECA Initial
Comments at 14; NV Energy Initial Comments at 14; PJM Initial
Comments at 45; PPL Initial Comments at 5; SEIA Initial Comments at
4-5; SEIA Reply Comments at 3-4; SoCal Edison Initial Comments at
12; SPP Initial Comments at 2-3.
    \216\ AEE Initial Comments at 9-10; CAISO Initial Comments at 5-
6; CREA and NewSun Initial Comments at 44; Dominion Initial Comments
at 10; Duke Southeast Utilities Initial Comments at 7; EEI Reply
Comments at 8; Indicated PJM TOs Initial Comments at 13; ISO-NE
Initial Comments at 18-19; MISO Initial Comments at 22; NextEra
Initial Comments at 11-12; New Jersey Commission Initial Comments at
21; PG&E Reply Comments at 5; PPL Initial Comments at 5; SEIA Reply
Comments at 3-4; SoCal Edison Initial Comments at 12.
---------------------------------------------------------------------------

    85. Some commenters expect the proposal will work against the
Commission's goal of faster interconnection queue processing.\217\ Some
commenters state that any reduction in speculative interconnection
requests will be offset by an increase in speculative informational
interconnection requests, which would require transmission providers to
shift their focus from the actual interconnection queue to this more
burdensome informational interconnection process, which is outside of
their interconnection study process.\218\ NRECA states that, if the
proposal is included in the final rule, the Commission should ensure
that it is limited and is not expanded into an elaborate serial study
process prior to the cluster study process.\219\ Avangrid notes that
some transmission providers have recently eliminated interconnection
studies to reduce interconnection queue processing time.\220\
Pennsylvania Commission asserts that the Commission should assess the
results of the NOPR's proposed reforms before requiring any new study
processes that may further slow the interconnection queue process.\221\
---------------------------------------------------------------------------

    \217\ AEE Reply Comments at 6; AEP Initial Comments at 11;
Avangrid Initial Comments at 22-23; CAISO Initial Comments at 6;
Dominion Reply Comments at 6-7; National Grid Initial Comments at 7;
NESCOE Reply Comments at 2; NV Energy Initial Comments at 14;
Pennsylvania Commission Initial Comments at 11-12.
    \218\ AECI Initial Comments at 4; AEP Initial Comments at 11;
APPA-LPPC Initial Comments at 11-12; Bonneville Initial Comments at
3 (citing NOPR, 179 FERC ] 61,194 at PP 20, 22, 166); Clean Energy
Buyers Initial Comments at 6; Dominion Reply Comments at 6; NextEra
Initial Comments at 12; NYISO Initial Comments at 17; Pennsylvania
Commission Initial Comments at 11 (explaining that because the
informational study is not binding on any party, the study does not
move projects through the interconnection queue).
    \219\ NRECA Initial Comments at 14.
    \220\ Avangrid Initial Comments at 23 (citing NOPR, 179 FERC ]
61,194 at P 56 n.111).
    \221\ Pennsylvania Commission Initial Comments at 11-12.
---------------------------------------------------------------------------

    86. Several commenters note the challenge of staffing to fulfill
the informational interconnection study requirements given the limited
number of qualified planners and engineers.\222\
---------------------------------------------------------------------------

    \222\ Id. at 11; AEP Initial Comments at 10-11; APPA-LPPC
Initial Comments at 12; Avangrid Initial Comments at 22-23;
Bonneville Initial Comments at 5; Eversource Initial Comments at 5-
6; Indicated PJM TOs Initial Comments at 12; Indicated PJM TOs Reply
Comments at 14; LADWP Initial Comments at 2; OMS Initial Comments at
5.
---------------------------------------------------------------------------

    87. Several commenters urge the Commission to weigh the benefits
against the burdens to determine whether to adopt the informational
interconnection study proposal.\223\

WAPA states that, while it agrees that it is important to provide
prospective interconnection customers with additional information, it
has concerns about the proposed timelines and penalties, the potential
amount of informational interconnection study requests it could
receive, and its ability to process up to five simultaneous
informational interconnection study requests per interconnection
customer.\224\ According to Vermont Electric and Vermont Transco, even
if the informational interconnection studies envisioned by the NOPR
provide interconnection customer benefits, the burdens of providing
informational interconnection studies with cost estimates under the
NOPR's short proposed time frames and low deposit amounts would be
considerable especially for smaller companies such as Vermont Electric
and Vermont Transco.\225\ Other commenters contend that the
informational interconnection study proposal has insufficient
benefits.\226\
---------------------------------------------------------------------------

    \223\ Ameren Initial Comments at 5; R Street Initial Comments at
9; Xcel Initial Comments at 20.
    \224\ WAPA Initial Comments at 4-5.
    \225\ Vermont Electric and Vermont Transco Initial Comments at
3.
    \226\ Id.; AEP Initial Comments at 7; AES Initial Comments at 4;
EEI Initial Comments at 11; ENGIE Initial Comments at 2; NextEra
Initial Comments at 10-11; [Oslash]rstead Initial Comments at 7; PJM
Initial Comments at 45; SEIA Initial Comments at 3.
---------------------------------------------------------------------------

    88. Given PJM's opposition to the informational interconnect study,
it recommends modifying the proposed new section 3.1.2 to the pro forma
LGIP to encourage, but not require, interconnection customers
evaluating different project characteristics to use a prescreening
tool, such as the queue scope tool PJM is developing, prior to
submitting an interconnection request.\227\
---------------------------------------------------------------------------

    \227\ PJM Initial Comments at 19 (explaining that the queue
scope is an interactive prescreening tool that will allow
interconnection customers to screen potential points of
interconnection and assess grid capacity (head room) based on a
given amount of MW injection or withdrawal at a given point of
interconnection and that the tool will be available at no charge).
PJM's proposed section 3.1.2 of the pro forma LGIP would read:
``Interconnection Customers evaluating different options . . . to
use the prescreening tool (Section 6.1 of this LGIP) before entering
the Cluster Study.''
---------------------------------------------------------------------------

iii. Commission Determination
    89. We decline to adopt the NOPR proposal to modify the pro forma
LGIP to require transmission providers to offer an informational
interconnection study for prospective interconnection customers. We are
persuaded by commenters' concerns that requiring an informational
interconnection study could divert the transmission provider's
resources away from the cluster studies we require in this final rule
and undermine the benefits of those reforms that seek to reduce
interconnection study delays, costs, and burden on constrained
engineering labor. Moreover, we agree with commenters that highlight
the various limitations of an informational interconnection study.
Notably, an informational interconnection study, as proposed in the
NOPR, would have provided a serial, snapshot-in-time analysis on the
impact of a single interconnection request, but, in the context of the
subsequent cluster study, the actual impact of an interconnection
request within a larger cluster would reflect different assumptions and
differ from the informational interconnection study, providing minimal
or no value to interconnection customers. The cost estimates that
result from such an informational interconnection study would bear
little correspondence to costs determined during a cluster study
process and thus provide minimal value to interconnection customers.
    90. We also find persuasive comments that the informational
interconnection study requirement proposed in the NOPR is not the most
effective way to provide interconnection customers with the needed pre-
interconnection queue information. At the same time, we continue to
believe that there is a lack of information available to prospective
interconnection customers prior to entering the interconnection queue,
especially given other interconnection customer-related reforms adopted
in this final rule.\228\ Therefore, as discussed below, we adopt the
NOPR proposal to set minimum requirements for transmission providers to
publicly post available information pertaining to generator
interconnection.\229\ We find that the posting of this information
provides a better balance between the benefits of additional
information for prospective interconnection customers and the burdens
on transmission providers.
---------------------------------------------------------------------------

    \228\ See Northwest and Intermountain Initial Comments at 6-7.
    \229\ See infra section III.A.1.c.iii.
---------------------------------------------------------------------------

    91. In response to commenters that support the informational
interconnection study NOPR proposal, below we explain how several of
the NOPR proposals that we adopt in this final rule address their
specific concerns. To address commenters' concerns with the number of
speculative interconnection requests,\230\ we adopt more stringent site
control requirements and increased commercial readiness deposit
requirements,\231\ which we believe will better address these concerns
than the informational interconnection study proposal. Additionally, we
find that the minimum requirements for transmission providers to
publicly post available information pertaining to generator
interconnection \232\ and the existing requirements in section 2.3 of
the pro forma LGIP for transmission providers to post up-to-date base
case study models on their Open Access Same-time Information System
(OASIS) or other password-protected websites will improve the
efficiency of siting decisions \233\ and will provide interconnection
customers with information about the feasibility of their
interconnection plans.\234\
---------------------------------------------------------------------------

    \230\ Fervo Energy Initial Comments at 2-3; Google Initial
Comments at 4; NRECA Initial Comments at 13; NY Commission and
NYSERDA Initial Comments at 6-8.
    \231\ See infra sections III.A.6.b.iii, III.A.6.c.iii.
    \232\ See infra section III.A.1.c.iii.
    \233\ Duke Southeast Utilities Initial Comments at 6-7; ISO-NE
Initial Comments at 18; NARUC Initial Comments at 5; NRECA Initial
Comments at 13; Pine Gate Initial Comments at 13-14; Tesla Initial
Comments at 4.
    \234\ Northwest and Intermountain Initial Comments at 6-7;
Pacific Northwest Organizations Initial Comments at 3.
---------------------------------------------------------------------------

    92. We are not persuaded that the informational interconnection
study proposal would benefit the interconnection process through: (1)
cost savings from fewer, more feasible interconnection requests; \235\
(2) a reduced need for interconnection request withdrawals and
restudies; \236\ and (3) accurate upfront interconnection cost
information.\237\ On the contrary, the Commission's adoption of the
cluster study reforms in this final rule \238\ means that the serial
nature of the informational interconnection study would fail to reflect
the outcome of the cluster study, and thus would provide minimal, if
any, benefits to interconnection customers.\239\ We also no longer
believe that adopting the informational interconnection study

proposal would reduce burdens on transmission providers.\240\ This is
because the record overwhelmingly demonstrates that the proposal would
result in additional burdens on transmission providers and would likely
cause transmission providers to divert resources from their cluster
study process to conduct informational interconnection studies,\241\
thus increasing study delays and costs. Similarly, we decline CREA and
NewSun's request that the Commission retain the feasibility study
instead of the informational interconnection study. As we discuss
below, the feasibility study was required for the serial study process
but is no longer relevant for the cluster study process.\242\ We
believe that our requirement for transmission providers to publicly
post certain interconnection information will provide interconnection
customers with the information they need prior to entering the
interconnection queue, and therefore decline to adopt CREA and NewSun's
request to maintain the feasibility study.
---------------------------------------------------------------------------

    \235\ Evergreen Action Initial Comments at 3; NARUC Initial
Comments at 5.
    \236\ Evergreen Action Initial Comments at 3; NRECA Initial
Comments at 13.
    \237\ Fervo Energy Initial Comments at 2; MISO Initial Comments
at 22; Pacific Northwest Organizations Initial Comments at 3-4.
    \238\ See infra section III.A.2.
    \239\ See AEE Initial Comments at 9-10; Avangrid Initial
Comments at 23-24; Clean Energy Associations Initial Comments at 14;
CREA and NewSun Initial Comments at 43; Dominion Reply Comments at
6; EEI Initial Comments at 12; EEI Reply Comments at 8; Enel Initial
Comments at 9; Eversource Initial Comments at 9-10; ISO-NE Initial
Comments at 18-19; MISO Initial Comments at 21; New Jersey
Commission Initial Comments at 21; NRECA Initial Comments at 14; NV
Energy Initial Comments at 14; PJM Initial Comments at 45; PPL
Initial Comments at 5; SEIA Initial Comments at 4-5; SEIA Reply
Comments at 3-4; SoCal Edison Initial Comments at 12; SPP Initial
Comments at 2-3.
    \240\ See Google Initial Comments at 5 (arguing that the
informational interconnection study requirement alone would likely
increase the burden on transmission providers in a way that would
lengthen delays).
    \241\ Id.; AECI Initial Comments at 3; AEE Reply Comments at 5-
6; AEP Initial Comments at 7-8; AEP Reply Comments at 2; AES Initial
Comments at 4; Alliant Energy Initial Comments at 4; APPA-LPPC
Initial Comments at 9; APS Initial Comments at 5; Bonneville Initial
Comments at 3; CAISO Initial Comments at 6; Clean Energy Buyers
Initial Comments at 6; Clean Energy States Initial Comments at 4;
Dominion Reply Comments at 5-6; Environmental Defense Fund Reply
Comments at 5; EEI Initial Comments at 11-12; EEI Reply Comments at
8-9; ELCON Initial Comments at 4-5; Enel Initial Comments at 9;
ENGIE Initial Comments at 2; Eversource Initial Comments at 5; Idaho
Power Initial Comments at 3; Indicated PJM TOs Initial Comments at
12; Indicated PJM TOs Reply Comments at 14; Longroad Energy Reply
Comments at 4-5; MISO Reply Comments at 17; National Grid Initial
Comments at 9; NESCOE Reply Comments at 2; New Jersey Commission
Initial Comments at 21; NextEra Reply Comments at 8-9, 11-12; North
Dakota Commission Initial Comments at 3-4; NRECA Initial Comments at
14; NV Energy Initial Comments at 14; NYISO Initial Comments at 16;
OMS Initial Comments at 5; Pine Gate Initial Comments at 12; PPL
Initial Comments at 4-6; SDG&E Initial Comments at 3-4; SEIA Initial
Comments at 3; SEIA Reply Comments at 4; SoCal Edison Initial
Comments at 12; Tesla Initial Comments at 4; Vermont Electric and
Vermont Transco Initial Comments at 3; WIRES Initial Comments at 8.
    \242\ See infra section III.A.2.f.iii.
---------------------------------------------------------------------------

    93. Because we do not adopt the NOPR proposal to require
transmission providers to offer an informational interconnection study,
we decline to adopt the proposal to add new section 3.1.2 to the pro
forma LGIP to encourage interconnection customers to use the
informational interconnection study.
c. Public Interconnection Information
i. NOPR Proposal
    94. In the NOPR, the Commission proposed to require transmission
providers to maintain and make publicly available an interactive visual
representation of available interconnection capacity (commonly known as
a ``heatmap'') as well as a table of relevant interconnection metrics
that allow prospective interconnection customers to see certain
estimates of a potential generating facility's effect on the
transmission provider's transmission system.\243\ Specifically, the
Commission proposed to revise section 6.4 of the pro forma LGIP to
require transmission providers to post on their public website a
heatmap of estimated incremental injection capacity (in MW) available
at each bus in the transmission provider's footprint under N-1
conditions, as well as provide a table of results showing the estimated
impact of the addition of a proposed project (based on the user-
specified MW amount, voltage level, and point of interconnection) for
each monitored facility impacted by the proposed project on: (1) the
distribution factor; (2) the MW impact (based on the proposed project
size and the distribution factor); (3) the percentage impact on the
monitored facility (based on the MW values of the proposed project and
the monitored facility rating); (4) the percentage of power flow on the
monitored facility before the proposed project; and (5) the percentage
power flow on the monitored facility after the injection of the
proposed project. The Commission explained that these metrics would be
calculated based on the power flow model of the cluster study or
restudy with the transfer simulated from each bus to the whole
transmission provider's footprint (to approximate Network Resource
Interconnection Service (NRIS)), and with the incremental capacity at
each bus decremented by the existing and queued generation in the
cluster (based on the existing or requested interconnection service
limit of the generation). The Commission proposed to require
transmission providers to update this information within 30 days after
the completion of each cluster study and restudy.
---------------------------------------------------------------------------

    \243\ NOPR, 179 FERC ] 61,194 at P 51.
---------------------------------------------------------------------------

    95. The Commission sought comment on whether: (1) there are any
security concerns with this proposed requirement; and (2) the
assumptions specified for the analysis are the right set of
assumptions.\244\
---------------------------------------------------------------------------

    \244\ Id. P 52.
---------------------------------------------------------------------------

ii. Comments
(a) Comments in Support
    96. Many commenters express support for the NOPR's proposal to
require transmission providers to provide public interconnection
information.\245\ Several commenters agree that the NOPR proposal will
provide valuable information to interconnection customers before they
enter the interconnection queue.\246\ Several commenters aver that the
proposal could reduce the number of interconnection requests withdrawn
\247\ and therefore could reduce costs for all parties.\248\ Alliant
Energy and Clean Energy Associations also see value in the standardized
format of the proposed

public interconnection information.\249\ R Street states that a
properly done visual representation of interconnection capacity can be
a ``powerful decentralized self-screening tool.'' \250\ R Street states
that better information and simpler deliverability requirements shift
congestion performance risk to generating facilities while reducing
barriers to entry.\251\ The Ohio Commission Consumer Advocate states
that the visual map of available interconnection capacity would be
useful both to transmission providers and interconnection customers and
would encourage information sharing on transmission system congestion
during the interconnection process.\252\ Google argues that making
these data publicly available to consumers would allow buyers to make
informed choices regarding power procurement.\253\ Additionally, Google
asserts that there needs to be a standard of reasonable care applied to
ensure that the publicly available information is reasonably current
and useful to avoid exploratory interconnection requests.\254\ SEIA
argues that greater transparency will increase competition between
merchant and utility developed generating facilities, benefiting
consumers.\255\ Illinois Commission contends that, if properly
implemented, the NOPR proposal will increase the pace at which new
generating facilities can connect to the transmission system,
furthering state policy objectives.\256\
---------------------------------------------------------------------------

    \245\ ACE-NY Initial Comments at 11; AES Initial Comments at 3;
Affected Interconnection Customers Initial Comments at 30; APPA-LPPC
Initial Comments at 13; CAISO Initial Comments at 7; CESA Initial
Comments at 7; Clean Energy Associations Initial Comments at 12;
Clean Energy Buyers Initial Comments at 6-7; Colorado Commission
Initial Comments at 8; Consumers Energy Initial Comments at 3; CREA
and NewSun Initial Comments at 44-45; Duke Southeast Utilities
Initial Comments at 6; Environmental Defense Fund Initial Comments
at 3; Environmental Defense Fund Reply Comments at 2-3; ELCON
Initial Comments at 4; ENGIE Initial Comments at 2; Evergreen Action
Initial Comments at 3; Fervo Energy Initial Comments at 2; Google
Initial Comments at 14; Google Reply Comments at 6; Illinois
Commission Initial Comments at 6; Interwest Initial Comments at 7;
New Jersey Commission Initial Comments at 11-12; Northwest and
Intermountain Initial Comments at 9-10; NY Commission and NYSERDA
Initial Comments at 8; [Oslash]rsted Initial Comments at 7; Pattern
Energy Initial Comments at 23; Pine Gate Initial Comments at 13;
Public Interest Organizations Initial Comments at 18-19; R Street
Initial Comments at 8, 10; Southern Initial Comments at 28; Tesla
Initial Comments at 6-7; Vistra Initial Comments at 1, 4.
    \246\ Alliant Energy Initial Comments at 5; Clean Energy
Associations Initial Comments at 12; CREA and NewSun Initial
Comments at 44-45; Duke Southeast Utilities Initial Comments at 6;
EEI Initial Comments at 12-13; ELCON Initial Comments at 6; ENGIE
Initial Comments at 2; Evergreen Action Initial Comments at 3; Fervo
Energy Initial Comments at 2-3; Illinois Commission Initial Comments
at 6; Indicated PJM TOs Initial Comments at 14; Indicated PJM TOs
Reply Comments 6; ISO-NE Initial Comments at 26-27; New Jersey
Commission Initial Comments at 12; NY Commission and NYSERDA Initial
Comments at 8; Ohio Commission Consumer Advocate Initial Comments at
7; Pacific Northwest Utilities Initial Comments at 13; SEIA Initial
Comments at 5.
    \247\ CESA Initial Comments at 9; CESA Reply Comments at 3;
Consumers Energy Initial Comments at 3; CREA and NewSun Initial
Comments at 44-45; Duke Southeast Utilities Initial Comments at 6;
Environmental Defense Fund Initial Comments at 3; EEI Initial
Comments at 12-13; ELCON Initial Comments at 6; Evergreen Action
Initial Comments at 3; Google Initial Comments at 14; Illinois
Commission Initial Comments at 6-7; New Jersey Commission Initial
Comments at 12; NY Commission and NYSERDA Initial Comments at 8;
Pacific Northwest Utilities Initial Comments at 13; SEIA Initial
Comments at 5.
    \248\ Evergreen Action Initial Comments at 3; New Jersey
Commission Initial Comments at 12.
    \249\ Alliant Energy Initial Comments at 5; Clean Energy
Associations Initial Comments at 12.
    \250\ R Street Initial Comments at 10.
    \251\ R Street Reply Comments at 2.
    \252\ Ohio Commission Consumer Advocate Initial Comments at 7.
    \253\ Google Initial Comments at 4.
    \254\ Google Reply Comments at 7.
    \255\ SEIA Reply Comments at 5.
    \256\ Illinois Commission Initial Comments at 6.
---------------------------------------------------------------------------

    97. Some commenters contend that the proposal to provide public
interconnection information is not overly burdensome.\257\ APPA-LPPC
members report that the information posting and interactive capability
described in the NOPR could be feasibly implemented with available
industry system simulation tools.\258\ Clean Energy Associations state
that heatmaps should be as automated as possible, without significant
commitments of staff or resources.\259\
---------------------------------------------------------------------------

    \257\ APPA-LPPC Initial Comments at 16; Clean Energy
Associations Initial Comments at 12-13; Google Initial Comments at
14; New York State Department Initial Comments at 8; Pennsylvania
Commission Initial Comments at 13; SEIA Initial Comments at 6.
    \258\ APPA-LPPC Initial Comments at 16.
    \259\ Clean Energy Associations Initial Comments at 13.
---------------------------------------------------------------------------

    98. Several commenters point to the fact that some transmission
providers are already developing such tools as evidence that these
tools are unlikely to cause further delays to stressed interconnection
queues or additional burden on transmission providers.\260\ For
instance, some commenters note that MISO already offers a heatmap that
represents geographically advantageous siting locations.\261\ Several
commenters also note that PJM is developing such a tool.\262\ PJM
states that in 2023 its queue scope tool will provide a congestion map
with colors or symbols indicating the worst flowgate loading at each
point of interconnection.\263\ SPP states that it is also developing a
tool to be implemented by 2025 that would provide much of the
functionality described in the Commission's public information proposal
to new interconnections.\264\
---------------------------------------------------------------------------

    \260\ Id. at 12; Environmental Defense Fund Reply Comments at 3;
ENGIE Initial Comments at 2-3; Pennsylvania Commission Initial
Comments at 13.
    \261\ CESA Reply Comments at 5; Fervo Energy Reply Comments at
3; OMS Initial Comments at 3, 6; R Street Initial Comments at 10;
SEIA Initial Comments at 6.
    \262\ CESA Reply Comments at 4; Fervo Energy Reply Comments at
3; Indicated PJM TOs Initial Comments at 14; Ohio Commission
Consumer Advocate Initial Comments at 7; Pennsylvania Commission
Initial Comments at 13; PJM Initial Comments at 48; PPL Initial
Comments at 9; R Street Initial Comments at 10; SEIA Initial
Comments at 6.
    \263\ PJM Initial Comments at 46-47.
    \264\ SPP Initial Comments at 4.
---------------------------------------------------------------------------

    99. Several commenters contend that the public information proposal
is a more reasonable balance of costs and benefits relative to the
informational interconnection study proposal.\265\ Pennsylvania
Commission states that, once a public information tool is established,
it may require fewer ongoing resources, continuing to inform
interconnection customers while freeing those resources for additional
interconnection studies as compared to the proposed informational
interconnection study.\266\
---------------------------------------------------------------------------

    \265\ Ameren Initial Comments at 5; APPA-LPPC Initial Comments
at 16; APS Initial Comments at 5; Bonneville Initial Comments at 5;
Pennsylvania Commission Initial Comments at 13; PJM Initial Comments
at 45-48; R Street Initial Comments at 10.
    \266\ Pennsylvania Commission Initial Comments at 13.
---------------------------------------------------------------------------

(b) Comments in Opposition
    100. A few commenters oppose the NOPR proposal to require
transmission providers to provide public interconnection
information.\267\ A larger number of commenters express reservations
about the proposal,\268\ in particular regarding its usefulness \269\
or the burden it creates.\270\ Other commenters request that the
Commission make public interconnection information posting
optional.\271\
---------------------------------------------------------------------------

    \267\ Avangrid Reply Comments at 4; El Paso Electric Initial
Comments at 8; PG&E Initial Comments at 9.
    \268\ AEP Initial Comments at 13; Idaho Power Initial Comments
at 3; NextEra Initial Comments at 12-13; Omaha Public Power Initial
Comments at 4; PacifiCorp Initial Comments at 13-14; SPP Initial
Comments at 4; Tri-State Initial Comments at 4; WAPA Initial
Comments at 7-8.
    \269\ AEP Initial Comments at 13; Idaho Power Initial Comments
at 3; ISO-NE Initial Comments at 17; Longroad Energy Reply Comments
at 7; Omaha Public Power Initial Comments at 4; PacifiCorp Initial
Comments at 13-14; SPP Initial Comments at 4; WAPA Initial Comments
at 7-8.
    \270\ AECI Initial Comments at 5; Dominion Initial Comments at
12; National Grid Initial Comments at 7; NextEra Initial Comments at
12-13; Omaha Public Power Initial Comments at 4; PacifiCorp Initial
Comments at 13-14; SPP Initial Comments at 4.
    \271\ AEP Initial Comments at 13; Avangrid Initial Comments at
21-22; SPP Initial Comments at 4.
---------------------------------------------------------------------------

    101. Several commenters argue that the proposal to require
transmission providers to provide public interconnection information is
not useful,\272\ particularly because it might not provide sufficient
detail \273\ or commercially actionable information for interconnection
customers.\274\ Commenters explain that heatmaps are specific to a
moment in time and thus not representative of actual available
injection across the transmission system, which is ever-changing.\275\
NextEra observes that heatmaps do not contain actionable information
for interconnection and instead focus on energy prices and
congestion.\276\ ISO-NE, MISO, and Omaha Public Power note that a
visual representation of interconnection capacity cannot account for
all of the conditions identified in a system impact study, including
different system stresses, operability issues (e.g., N-1-1), stability
and voltage issues, and weak transmission system issues.\277\

Longroad Energy asserts that generator interconnection heatmaps or
hosting capacity maps can be of some use for interconnections to the
distribution system but are unlikely to be beneficial for projects
interconnecting at transmission voltages.\278\
---------------------------------------------------------------------------

    \272\ Dominion Initial Comments at 13; Idaho Power Initial
Comments at 3; ISO-NE Initial Comments at 17; NextEra Initial
Comments at 12; New York State Department Initial Comments at 8;
NYISO Initial Comments at 17; Omaha Public Power Initial Comments at
4; PacifiCorp Initial Comments at 14.
    \273\ AECI Initial Comments at 5; Dominion Initial Comments at
13; Longroad Energy Reply Comments at 7; National Grid Initial
Comments at 8; New York State Department Initial Comments at 8;
Omaha Public Power Initial Comments at 4.
    \274\ AEE Initial Comments at 9; Cypress Creek Initial Comments
at 13; NextEra Initial Comments at 12.
    \275\ AECI Initial Comments at 5; AEP Initial Comments at 13;
New York State Department Initial Comments at 8; NYISO Initial
Comments at 17.
    \276\ NextEra Initial Comments at 12.
    \277\ ISO-NE Initial Comments at 17; MISO Initial Comments at 26
(citing NOPR, 179 FERC ] 61,194 at P 50 & n.105); Omaha Public Power
Initial Comments at 4.
    \278\ Longroad Energy Reply Comments at 7.
---------------------------------------------------------------------------

    102. Some commenters do not believe that the heatmap proposal will
appreciably reduce speculative interconnection requests.\279\ MISO
explains that, in its experience, few interconnection customers use its
interconnection heatmap tool and instead tend to use their own
tools.\280\ Puget Sound states that, even with a heatmap, if an
interconnection customer has a request that would require energy
transfer across balancing authorities, it would have to submit an
interconnection request to get information on the scope of necessary
network upgrades.\281\ NV Energy asserts that a heatmap of its
transmission system would be of little value, appearing as though there
is no available transfer capacity, because the generation in its
interconnection queue is more than five times the level of NV Energy
load.\282\ Meanwhile, Puget Sound states that a heatmap of its
territory would only account for generation and interconnection
capacity in its balancing authority footprint even though its
transmission goes beyond this footprint.\283\
---------------------------------------------------------------------------

    \279\ Idaho Power Initial Comments at 3; PPL Initial Comments at
9.
    \280\ MISO Initial Comments at 25-26.
    \281\ Puget Sound Initial Comments at 6.
    \282\ NV Energy Initial Comments at 10.
    \283\ Puget Sound Initial Comments at 6.
---------------------------------------------------------------------------

    103. Several commenters contend that a heatmap tool as proposed
would be less useful in a cluster study than it is in a serial process
because it cannot include similarly queued generation.\284\ Ohio
Commission Consumer Advocate questions whether it will capture the
``dynamic elements'' of cluster studies and restudies.\285\ PacifiCorp
and AEP state that the mere fact that an area is not shown as congested
on a heatmap does not mean that it will be a suitable interconnection
location, particularly if multiple interconnection customers seek to
interconnect there.\286\
---------------------------------------------------------------------------

    \284\ CAISO Initial Comments at 8; CREA and NewSun Initial
Comments at 48; Duke Southeast Utilities Initial Comments at 6-7;
MISO Initial Comments at 26; Ohio Commission Consumer Advocate
Initial Comments at 7; PacifiCorp Initial Comments at 15.
    \285\ Ohio Commission Consumer Advocate Initial Comments at 7.
    \286\ AEP Initial Comments at 13; PacifiCorp Initial Comments at
15.
---------------------------------------------------------------------------

    104. Longroad Energy and PacifiCorp express concern that the
heatmap tools would not be restricted to prospective interconnection
customers and could instead be used by third-party consultants for
their own business interests; for instance, real estate speculators
could use the information to secure exclusive site control for
locations that show significant generator interconnection
capacity.\287\ According to Longroad Energy, such risk is particularly
harmful to wind and solar generation interconnection customers' needs
for large tracts of land to accommodate their generation
equipment.\288\
---------------------------------------------------------------------------

    \287\ Longroad Energy Reply Comments at 7; PacifiCorp Initial
Comments at 15.
    \288\ Longroad Energy Reply Comments at 7.
---------------------------------------------------------------------------

    105. Some commenters assert that maintaining the heatmap and
posting required information on available interconnection capacity
would be burdensome for transmission providers, especially in non-RTO/
ISO regions.\289\ Similarly, NV Energy states that it participates in
the CAISO energy imbalance market and its energy management system does
not currently have the technical functionality to build an interactive
map that shows information like the available interconnection
capacity.\290\ Some commenters argue that the heatmaps may provide
insufficient benefit to justify cost, resources, and time it would take
to produce them.\291\ Omaha Public Power further asserts that
interconnection customers will likely find it more valuable for a
transmission provider invest in more reliable and consequential
studies.\292\ Pacific Northwest Utilities assert that the Commission
should present additional data regarding the benefits of requiring a
heatmap before mandating their use.\293\ Clean Energy Associations
recommend that the Commission consider other means of increasing
information to prospective interconnection customers, such as public
scoping meetings prior to the prospective interconnection customers
entering the interconnection queue.\294\
---------------------------------------------------------------------------

    \289\ National Grid Initial Comments at 7-8; PacifiCorp Initial
Comments at 13; Tri-State Initial Comments at 7.
    \290\ NV Energy Initial Comments at 10.
    \291\ Dominion Initial Comments at 13; National Grid Initial
Comments at 8; NextEra Initial Comments at 12; New York State
Department Initial Comments at 8; Omaha Public Power Initial
Comments at 4; Pacific Northwest Utilities Initial Comments at 14;
PPL Initial Comments at 9; Tri-State Initial Comments at 4; WAPA
Initial Comments at 7.
    \292\ Omaha Public Power Initial Comments at 4.
    \293\ Pacific Northwest Utilities Initial Comments at 14.
    \294\ Clean Energy Associations Initial Comments at 14.
---------------------------------------------------------------------------

    106. Some commenters express concern that the public information
proposal will impose new costs on ratepayers and market
participants.\295\ WAPA states that, given its defined appropriations
and budgets, it is difficult to create new programs, unlike for larger
investor-owned utilities or RTOs/ISOs.\296\ Dominion estimates that
implementation would require a large up-front financial commitment,
potentially for third-party software and personnel hours, and longer-
term financial commitment to maintain such a site.\297\ NV Energy
contends that creating such a heatmap showing interconnection
capabilities would require finding an eligible software, an ongoing
expense.\298\
---------------------------------------------------------------------------

    \295\ New York State Department Initial Comments at 8; SoCal
Edison Initial Comments at 13.
    \296\ WAPA Initial Comments at 7.
    \297\ Dominion Initial Comments at 12.
    \298\ NV Energy Initial Comments at 10.
---------------------------------------------------------------------------

    107. Several commenters speak to the burden of additional staffing
needs to provide public interconnection information. National Grid
states that the interactive visual representation tool, even if
contracted from a third party, would require significant time
commitments from numerous personnel with relevant and advanced
expertise in transmission and interconnection engineering.\299\ Tri-
State notes that the Commission has recognized the lack of available
engineers and that imposing a heatmap requirement would exacerbate the
problem.\300\ Dominion and Duke Southeast Utilities state that any
additional process would require additional financial and personnel
resources, and also burden the same personnel that are already engaged
in managing the interconnection queue.\301\ El Paso Electric argues
that transmission providers should not be required to allocate human
resources from interconnection studies to monthly transmission line
capacity estimates because the staff reallocation could cause
interconnection study backlogs.\302\ PacifiCorp states that this burden
will be particularly onerous to transmission providers outside RTO/ISO
regions, which have comparatively few transmission staff
available.\303\
---------------------------------------------------------------------------

    \299\ National Grid Initial Comments at 7-8.
    \300\ Tri-State Initial Comments at 8.
    \301\ Dominion Initial Comments at 13; Duke Southeast Utilities
Initial Comments at 7.
    \302\ El Paso Electric Initial Comments at 7.
    \303\ PacifiCorp Initial Comments at 13.
---------------------------------------------------------------------------

    108. Several commenters suggest that interconnection customers, on
their own or with consultants, can perform studies with the available
information that would provide estimates on available capacity similar
to that produced under

the NOPR proposal.\304\ PPL states that interconnection customers can
make their own such maps using transmission planning models the
Commission makes available following a Freedom of Information Act
request.\305\ APPA-LPPC argue that the Commission fails to establish
that the information already available to prospective interconnection
customers under the existing pro forma LGIP, along with the substantial
supplement implemented with Order No. 845, is inadequate.\306\ SoCal
Edison states that the information included in the NOPR proposal and
more is already available if interconnection customers request it from
the Commission for their own studies or use studies developed by
transmission providers.\307\ The Ohio Commission Consumer Advocate
states that the determination of a suitable site depends largely on the
location and geography of the resources, which is publicly available
from national labs and the U.S. Energy Information Administration.\308\
---------------------------------------------------------------------------

    \304\ Id. at 15; AEP Initial Comments at 8; APPA-LPPC Initial
Comments at 9; El Paso Electric Initial Comments at 7; PPL Initial
Comments at 9; SoCal Edison Initial Comments at 14.
    \305\ PPL Initial Comments at 9.
    \306\ APPA-LPPC Initial Comments at 9.
    \307\ SoCal Edison Initial Comments at 14.
    \308\ Ohio Commission Consumer Advocate Initial Comments at 6-7.
---------------------------------------------------------------------------

    109. Several commenters state that sufficient data are already
required to be posted on OASIS.\309\ According to Idaho Power, Order
No. 2003-A required interconnection study reports to be publicly
available and provide locational and cost information for previously
studied interconnections, but this has not reduced the amount of
interconnection requests at congested locations.\310\ SoCal Edison and
NYISO state that this information is already available in FERC Form
715, where it is protected with a non-disclosure agreement as critical
energy infrastructure information (CEII) and has the benefit of being
available in one centralized location.\311\ On the other hand, ACE-NY
disagrees with the assertion that FERC Form 715 provides sufficient
information for interconnection customers to do their own analysis,
asserting that the FERC Form 715 database base cases do not contain
sufficient data about the generation interconnection queue and study
assumptions and are therefore inadequate.\312\ Rather, ACE-NY argues
that more detailed base cases such as those currently being made
available by MISO and PJM, should be required.
---------------------------------------------------------------------------

    \309\ Duke Southeast Utilities Initial Comments at 6-7; Idaho
Power Initial Comments at 3; NV Energy Initial Comments at 10;
PacifiCorp Initial Comments at 14-15.
    \310\ Idaho Power Initial Comments at 3.
    \311\ NYISO Initial Comments at 17; SoCal Edison Initial
Comments at 14.
    \312\ ACE-NY Reply Comments at 3-4.
---------------------------------------------------------------------------

    110. Several commenters state that the usefulness of public
interconnection information proposal will depend on the implementation
details.\313\ For example, Illinois Commission and CESA recognize that
the accuracy of the heatmaps is an important part of how useful they
will be.\314\ Puget Sound states that it has considered creating such a
heatmap but has concerns about its effectiveness given implementation
challenges.\315\ SPP states that technology, information, and tools are
quickly evolving and that a standardization tool might be obsolete
before it is implemented.\316\ CESA explains that currently CAISO
provides static, snapshot-in-time transmission capability estimates
that are helpful but do not capture locational granularity or other
projects already in the interconnection queue, making it difficult to
make an informed project siting decision and at times requiring data
requests of CAISO.\317\ For this reason, CESA stresses that the
heatmaps and associated data must be made available in a user-friendly
format. CREA and NewSun argue that the Commission should be careful not
to overestimate the ability to forecast interconnection costs and
project viability that will ultimately result from a cluster
study.\318\ Several commenters stress that any potential increase in
transparency and interconnection process performance resulting from
this proposal must outweigh the additional burden imposed on
transmission providers.\319\
---------------------------------------------------------------------------

    \313\ CESA Initial Comments at 8-9; Illinois Commission Initial
Comments at 6; Puget Sound Initial Comments at 6; SPP Initial
Comments at 4.
    \314\ CESA Initial Comments at 9; Illinois Commission Initial
Comments at 6.
    \315\ Puget Sound Initial Comments at 6.
    \316\ SPP Initial Comments at 4.
    \317\ CESA Initial Comments at 8.
    \318\ CREA and NewSun Initial Comments at 48.
    \319\ Cypress Creek Initial Comments at 14; EEI Initial Comments
at 12-13; Eversource Initial Comments at 11; New Jersey Commission
Initial Comments at 22-23; New York State Department Initial
Comments at 8-9.
---------------------------------------------------------------------------

(c) Comments on Specific Proposal
(1) Metrics
    111. While some commenters agree with the Commission's proposed
table of metrics,\320\ multiple commenters suggest additional metrics
that should be posted.\321\ For instance, Public Interest Organizations
request information on the available interconnection capacity
(including, at a minimum, a snapshot of existing available
interconnection capacity and associated transmission during high load
conditions for each substation) including projects already in the
interconnection queue, and the capacity those projects are
requesting,\322\ as well as metrics on whether power flows from a point
of interconnection are likely to serve low income and people of color
communities (which would be consistent with Executive Order
13985).\323\ Other commenters suggest that the posted metrics should
also include: circuit strength and the harmonics of transmission system
elements; \324\ limiting elements at a substation or associated
transmission infrastructure; \325\ the level of congestion and resource
curtailment by location (historic, current, and/or expected); \326\
overload conditions; \327\ contingencies that drive the impacts to the
monitored facility; \328\ for a given transmission line, information on
the circuit (e.g., single or double), the conductor type, pole types,
the ratings of the equipment, and the age of the equipment; \329\
flowgate data, such as disconnect switches, breakers, transformers,
conductors, series reactors, and ground clearances of lines; \330\
change file models of network upgrades for deliverability in advance of
providing study results; \331\ base case models paired with
contingencies including local contingencies (below

200 kV); \332\ incremental injection capacity available at each bus in
the transmission provider's footprint under N-1 conditions with a five-
year outlook; \333\ the rating of the monitored facility; \334\
estimated costs of interconnection or transmission service, including
where interconnection is likely to be costly and not costly; \335\
proposed upgrades in the region that could affect interconnection
requests; \336\ lists of potential upgrades that would be needed to
export power to other regions or that would allow the transmission
provider to increase injection capacity at each substation; \337\ more
granular load growth data, defined by region, which could be combined
with existing and planned generation and congestion to view anticipated
system changes; \338\ and the share that all generating facilities
contribute to a network upgrade along with their share of allocated
costs.\339\ Tesla requests information that would particularly
developers of non-synchronous generating facilities to decide what
project controls might be best suited for a given point of
interconnection, including: the number of generating facilities and
power control devices (including series compensation systems, static
synchronous compensator devices and other power control devices) that
are two busses away from the given point of interconnection; the
circuit breaker short circuit ratings of the nearest substation; and
the maximum and minimum fault current in megavolt amperes (MVA) at the
given point of interconnection.\340\
---------------------------------------------------------------------------

    \320\ NOPR, 179 FERC ] 61,194 at P 51.
    \321\ Ameren Initial Comments at 5; Bonneville Initial Comments
at 7; Clean Energy Buyers Initial Comments at 7-8; MISO Initial
Comments at 25 (agreeing that the five data points are sufficient
but adding that, if the first is provided, then prospective
interconnection customers can calculate the other four).
    \322\ Public Interest Organizations Initial Comments at 19-20.
    \323\ Public Interest Organizations Reply Comments at 11-12
(citing 16 U.S.C. 824(a); Nat'l Ass'n for Advancement of Colored
People v. FPC, 425 U.S. 662, 669-670 (1976); Executive Order 13985,
``Executive Order on Advancing Racial Equity and Support for
Underserved Communities Through the Federal Government'' (Jan. 20,
2021)); see also Navajo Utility Initial Comments at 9.
    \324\ SEIA Initial Comments at 6.
    \325\ AES Initial Comments at 5-7; Hannon Armstrong Initial
Comments at 2; Pattern Energy Initial Comments at 23; Public
Interest Organizations Initial Comments at 19.
    \326\ AEP Initial Comments at 13; Clean Energy Associations
Initial Comments at 12; Pine Gate Initial Comments at 14.
    \327\ Ameren Initial Comments at 6; R Street Initial Comments at
10.
    \328\ Pattern Energy Initial Comments at 23.
    \329\ NextEra Initial Comments at 11.
    \330\ AES Initial Comments at 6; Pattern Energy Initial Comments
at 23; Pine Gate Initial Comments at 14; SEIA Reply Comments at 4.
    \331\ AES Initial Comments at 5; Pine Gate Initial Comments at
14; SEIA Reply Comments at 5.
    \332\ AES Initial Comments at 5; SEIA Reply Comments at 5.
    \333\ AES Initial Comments at 5; SEIA Reply Comments at 5.
    \334\ Pattern Energy Group Initial Comments at 23; SEIA Reply
Comments at 5.
    \335\ Bonneville Initial Comments at 5; Eversource Initial
Comments at 11.
    \336\ [Oslash]rsted Initial Comments at 7; Pattern Energy
Initial Comments at 23; Public Interest Organizations Initial
Comments at 19; SEIA Reply Comments at 5.
    \337\ Clean Energy Associations Initial Comments at 13; Public
Interest Organizations Initial Comments at 20-21.
    \338\ Google Initial Comments at 6, 14.
    \339\ AES Initial Comments at 5-7, 13-14.
    \340\ Tesla Initial Comments at 7.
---------------------------------------------------------------------------

    112. Several commenters highlight that additional information
regarding transmission system conditions, such as previous cluster
studies and models, posted in a secure way subject to CEII processes,
would allow interconnection customers to conduct their own initial
analyses of system conditions and desirable points of
interconnection.\341\ SoCal Edison states that, alternatively, the
transmission providers could identify areas where new generation is
desired, guided by state processes identifying the locations that can
accommodate additional generation currently or locations intended for
types of generation sought state policy.\342\
---------------------------------------------------------------------------

    \341\ ACE-NY Initial Comments at 11; AES Initial Comments at 5;
Clean Energy States Alliance Initial Comments at 4; CREA and NewSun
Initial Comments at 47; ENGIE Initial Comments at 3; NextEra Reply
Comments at 9; PJM Initial Comments at 7; PPL Initial Comments at 9;
SEIA Reply Comments at 4.
    \342\ SoCal Edison Initial Comments at 14-15.
---------------------------------------------------------------------------

    113. Some commenters oppose these requests for additional metrics.
Dominion notes that tracking and providing the information requested by
Public Interest Organizations, including documenting the study process,
providing enhanced interconnection queue tracking, and metrics on
constraints that cause bottlenecks, would be burdensome, taking
engineers' time, slowing down the cluster study process, and diverting
resources.\343\ EEI and WIRES contend that certain information on
transmission line design, such as circuit type, conductor type, and
pole type, would be overly burdensome and offer little benefit, adding
that this information could invite potential disputes or be used to
threaten to the reliability of the transmission system or for
commercial gain if the information is not subject to confidentiality
protections.\344\ EEI also asserts that any additional information
beyond that proposed in the NOPR would complicate the interconnection
process by adding another potential area of dispute and risks potential
``backseat driving'' by the interconnection customer, while the
transmission provider is responsible for performing and standing by its
study results.\345\
---------------------------------------------------------------------------

    \343\ Dominion Reply Comments at 8.
    \344\ EEI Reply Comments at 9-10; WIRES Reply Comments at 5-6.
    \345\ EEI Reply Comments at 9-10.
---------------------------------------------------------------------------

    114. Some commenters disagree as to the appropriate level of
granularity of the required metrics. SEIA and ENGIE support the NOPR
proposal to require transmission providers to post bus-level
interconnection capacity constraints.\346\ Dominion disagrees, arguing
that requiring capacity constraint information to be provided at the
bus-level is outside the scope of the NOPR and would not necessarily be
useful in a networked system where injection at one bus will affect the
capability at other buses and significant additional power flow
analysis would be required to determine these values at each bus.\347\
According to Dominion, information about bus-level interconnection
capacity constraints makes more sense where the system is radial in
nature and injection capability at one bus is not dependent on
contingencies or injections at another bus. Eversource adds that bus
level information will not provide significant benefits because it may
be too simplistic if it is not based on N-1 conditions or if it fails
to incorporate stability considerations.\348\ Public Interest
Organizations state that many utilities provide hosting capacity
information on their websites at the distribution level in heatmaps or
tables, in particular to help distributed solar interconnection
customers, and this information is required by states and updated
regularly.\349\ Public Interest Organizations ask the Commission to
require analogous hosting capacity information to be provided by
transmission providers for all potential generation locations with
exemptions for urban substations where there is limited potential for
generation development. PJM requests that, rather than requiring that
all buses be made available in a large RTO/ISO, a transmission provider
should be allowed to screen and only present the majority of the
feasible points of interconnection.\350\ As an alternative to providing
information at every bus, Tri-State states that a transmission provider
could post the most recent cluster study to provide information for the
buses that were studied as opposed to studying all buses on the system,
while also making clear that the heatmap does not reflect
interconnection requests in neighboring systems.\351\ Similarly,
Bonneville argues that cluster studies would not provide the
incremental injection capacity at each bus on the transmission
provider's system, which would warrant a separate study, and therefore,
transmission providers should be afforded flexibility to provide this
capacity information as it becomes available.\352\
---------------------------------------------------------------------------

    \346\ ENGIE Initial Comments at 2-3; SEIA Initial Comments at 5.
    \347\ Dominion Reply Comments at 8-9.
    \348\ Eversource Initial Comments at 11.
    \349\ Public Interest Organizations Initial Comments at 20
(citing National Renewable Energy Laboratory, Advanced Hosting
Capacity Analysis, https://www.nrel.gov/solar/market-research-analysis/advanced-hosting-capacity-analysis.html).
    \350\ PJM Initial Comments at 48-49.
    \351\ Tri-State Initial Comments at 8.
    \352\ Bonneville Initial Comments at 6-7.
---------------------------------------------------------------------------

    115. Some commenters argue that the proposed heatmap is not an
ideal way to present public interconnection information. For instance,
Illinois Commission states that it is not immediately evident what
information maps posted to an RTO/ISO website would reflect.\353\ For
example, Illinois Commission questions whether

congestion maps would reflect present congestion or congestion that
might arise after generating facilities interconnect. Fervo Energy
states that additional research might be needed to determine the most
useful informational suite.\354\ Clean Energy Associations proposes,
and SEIA supports, that two maps, one for Energy Resource
Interconnection Service (ERIS) and one for capacity or NRIS, should be
made available where appropriate, and notes that in ISO-NE overlapping
impact analysis is used to determine eligibility for capacity
NRIS.\355\ Finally, Clean Energy Associations and ISO-NE recommend that
the Commission consider allowing information to be qualitative, such
that, rather than a ``hosting map,'' transmission providers could post
a map and accompanying report regarding system conditions at various
points on the transmission system.\356\
---------------------------------------------------------------------------

    \353\ Illinois Commission Initial Comments at 6.
    \354\ Fervo Energy Reply Comments at 3.
    \355\ Clean Energy Associations Initial Comments at 12; SEIA
Reply Comments at 5.
    \356\ Clean Energy Associations Reply Comments at 3; ISO-NE
Initial Comments at 17.
---------------------------------------------------------------------------

(2) Security of Critical Information
    116. Several commenters express concern that the NOPR's proposed
heatmap and/or metrics may create a security risk \357\ by, among other
things, indicating areas where transmission is heavily loaded and more
vulnerable to interference.\358\ In particular, LADWP and Bonneville
express concerns over sharing distribution factor and MW impact, which
they believe could identify highly stressed transmission lines, as well
as concerns with identifying the line locations, which are not
currently provided publicly.\359\ LADWP further expresses concern with
CEII issues that may arise from publicly releasing a table of metrics
regarding the estimated impact of a potential generating facility.\360\
---------------------------------------------------------------------------

    \357\ EEI Reply Comments at 9-10; Indicated PJM TOs Initial
Comments at 15; LADWP Initial Comments at 3; NRECA Initial Comments
at 16-17; PacifiCorp Initial Comments at 16; PPL Initial Comments at
8; SoCal Edison Initial Comments at 13-14; WIRES Reply Comments at
5-6.
    \358\ LADWP Initial Comments at 3; PacifiCorp Initial Comments
at 16; PPL Initial Comments at 8.
    \359\ Bonneville Initial Comments at 6; LADWP Initial Comments
at 3.
    \360\ LADWP Initial Comments at 3.
---------------------------------------------------------------------------

    117. Other commenters counter that the security risks associated
with the NOPR proposal are reasonable or non-existent. For example,
Pacific Northwest Utilities and Puget Sound states that the purpose of
the heatmap is to provide an overview of interconnection capacity,
which is unlikely to implicate CEII, and thus the risk of unrestricted
critical infrastructure information should be low.\361\ Indicated PJM
TOs and PPL state that a visual map with limited information, excluding
reliability constraints or other particular information that could be
used to identify vulnerabilities, could be made public without security
concerns and highlight PJM as a good example of this.\362\ Xcel states
that it does not have security concerns about posting estimated
injection capacity but that some of the more detailed information
should be limited.\363\ MISO states that it is currently unaware of any
security concerns associated with the proposal.\364\
---------------------------------------------------------------------------

    \361\ Pacific Northwest Utilities Initial Comments at 15; Puget
Sound Initial Comments at 6-7.
    \362\ Indicated PJM TOs Initial Comments at 14-15; PPL Initial
Comments at 8-9.
    \363\ Xcel Initial Comments at 22.
    \364\ MISO Initial Comments at 27.
---------------------------------------------------------------------------

    118. While SoCal Edison and Southern assert that there should be no
requirement on transmission providers to make public or display any
CEII or confidential information,\365\ other commenters contend that
the CEII label should not be used to unreasonably impede
interconnection customers' access to interconnection information
necessary to understand the cost and other impacts of locating their
projects in different areas of the transmission system.\366\ Some
commenters recommend that the Commission require transmission providers
to make CEII data available only to interconnection customers who meet
restricted access requirements, such as through a secure portal or
subject to a confidentiality agreement.\367\ Pattern Energy asks that
this information be made available through a cost-free process that
takes no longer than two weeks,\368\ and Pine Gate adds that the
retrieval of this information should not require background checks, as
required by certain transmission providers.\369\ EEI suggests that
transmission providers should have the discretion to identify sensitive
information that should be withheld.\370\ Clean Energy States add that
the Commission may want to limit access to permitted users, controlling
the copying and dissemination of data, or take other security
measures.\371\
---------------------------------------------------------------------------

    \365\ SoCal Edison Initial Comments at 14; Southern Initial
Comments 28.
    \366\ CESA Reply Comments at 4; Google Reply Comments at 7;
Pattern Energy Initial Comments at 24.
    \367\ Google Reply Comments at 7; Indicated PJM TOs Initial
Comments at 15; ISO-NE Initial Comments at 17; NRECA Initial
Comments at 16; Pattern Energy Initial Comments at 24; SEIA Initial
Comments at 6; SEIA Reply Comments at 5.
    \368\ Pattern Energy Initial Comments at 24.
    \369\ Pine Gate Initial Comments at 14.
    \370\ EEI Initial Comments at 13.
    \371\ Clean Energy States Initial Comments at 5.
---------------------------------------------------------------------------

(3) Miscellaneous
    119. SEIA requests that the Commission require transmission
providers to use the most recent available study models as well as the
most recently completed system impact study in creating their data
results.\372\
---------------------------------------------------------------------------

    \372\ SEIA Initial Comments at 6.
---------------------------------------------------------------------------

    120. A few commenters express concern with the proposal to require
updated information 30 days after the completion of each cluster study
and restudy and instead request that the Commission allow for regional
flexibility on the timing of updates.\373\ MISO states that, as
written, the NOPR proposal would require it to update the tool
available to help interconnection customers pre-screen for potential
points of interconnection each time a regional system impact study is
issued, which would be numerous times during a calendar year due to the
configuration of MISO's transmission system.\374\ PJM states that it is
not feasible for an RTO/ISO as large as PJM to update an interactive
public interconnection information tool within 30 days after completing
a cluster restudy.\375\ PJM states that, once the tool includes light
load results, it will be uploading four to six datasets a year with
each dataset including millions of points of interconnection flowgate
records, which may eventually not be feasible to maintain from a
storage perspective. According to El Paso Electric, the interconnection
queue changes often as interconnection customers withdraw their
requests and therefore transmission providers should not be required to
update capacity line estimates monthly because the burden on staff
could increase interconnection study delays.\376\ Tri-State explains
that only a subset of buses and lines are studied in each cluster
study, so to require an estimate of the injection capacity at every bus
in each cluster study to be posted within 30 days would greatly
increase the scope and cost and would likely have a negative impact on
the time to complete the study and cause rates to increase.\377\
---------------------------------------------------------------------------

    \373\ Bonneville Initial Comments at 8; El Paso Electric Initial
Comments at 7; MISO Initial Comments at 26; Pacific Northwest
Utilities Initial Comments at 14; PJM Initial Comments at 49; Tri-
State Initial Comments at 7.
    \374\ MISO Initial Comments at 26-27.
    \375\ PJM Initial Comments at 49.
    \376\ El Paso Electric Initial Comments at 7.
    \377\ Tri-State Initial Comments at 7.
---------------------------------------------------------------------------

    121. On the other hand, [Oslash]rsted notes that any system
representation needs to

be frequently updated to be useful and avoid the risk of becoming out-
of-date,\378\ and Public Interest Organizations state that hosting
capacity data should be updated at least quarterly.\379\ Environmental
Defense Fund argues that the public interconnection information should
be updated immediately at the end of each cluster request window so
that interconnection customers using that information are informed of
generating facilities being studied that may impact transmission
capacity.\380\
---------------------------------------------------------------------------

    \378\ [Oslash]rsted Initial Comments at 6.
    \379\ Public Interest Organizations Initial Comments at 20.
    \380\ Environmental Defense Fund Initial Comments at 3.
---------------------------------------------------------------------------

(4) Requests for Flexibility
    122. Several commenters request flexibility from the Commission
with respect to the particular information included in a potential
heatmap.\381\ Dominion asserts that the proposal is overly prescriptive
and that the Commission should focus on the goal itself rather than
uniformity.\382\ Clean Energy Associations state that the heatmaps may
need to be tailored to the services offered by a particular
transmission provider, because their services are not uniform.\383\
Several commenters claim that flexibility will help ensure that the
information provided is useful and understandable, and will place a
reasonable level of burden on transmission providers.\384\ MISO states
that flexibility is reasonable given the burden on transmission
providers of maintaining a heatmap tool relative to the limited value
of frequent updates given that few interconnection customers use this
tool and its inability to include future queued projects that will be
relevant to the prospective interconnection customer.\385\ Bonneville
also argues that flexibility is needed to ensure consistency with
security requirements.\386\ On the other hand, Cypress Creek asserts
that, as a broad consideration, the particular types of information to
be made transparent that are valuable should be determined by the
Commission in consultation with market participants who are best
positioned to identify information relevant to financing and
constructing new projects.\387\
---------------------------------------------------------------------------

    \381\ Avangrid Initial Comments at 21-22; Bonneville Initial
Comments at 6-8; Dominion Initial Comments at 14; MISO Initial
Comments at 27; NY Commission and NYSERDA Initial Comments at 8;
NYTOs Initial Comments at 8; Pacific Northwest Utilities Initial
Comments at 14; PJM Initial Comments at 48; Puget Sound Initial
Comments at 6; SEIA Initial Comments at 6; Southern Initial Comments
at 28; SPP Initial Comments at 4; WAPA Initial Comments at 7-8.
    \382\ Dominion Initial Comments at 13.
    \383\ Clean Energy Associations Initial Comments at 12.
    \384\ Avangrid Initial Comments at 21-22; Bonneville Initial
Comments at 6-8; Cypress Creek Initial Comments at 14; MISO Initial
Comments at 27; NY Commission and NYSERDA Initial Comments at 7-8;
NYTOs Initial Comments at 8; Pacific Northwest Utilities Initial
Comments at 14; WAPA Initial Comments at 8.
    \385\ MISO Initial Comments at 26-27.
    \386\ Bonneville Initial Comments at 6.
    \387\ Cypress Creek Initial Comments at 14.
---------------------------------------------------------------------------

    123. Several commenters ask for flexibility in the way information
is shared. SEIA states that whether the data are in a map or other
format is not as important as the product itself.\388\ NYTOs expect
that flexibility would allow regions to adopt some form of the virtual
tool as long as it is clear that the information is illustrative, non-
binding, and subject to change.\389\ NRECA states that smaller
generation and transmission cooperatives may be able to just post a
table with bus names and injection capability and present the same
useful information in a more economical way.\390\ NV Energy states
that, if it were to post to its OASIS the CAISO locational marginal
price map with a link to CAISO's OASIS to provide a list of interchange
limits and interchange schedules, this would be just as valuable as a
map for its own transmission system.\391\
---------------------------------------------------------------------------

    \388\ SEIA Initial Comments at 6.
    \389\ NYTOs Initial Comments at 9.
    \390\ NRECA Initial Comments at 16.
    \391\ NV Energy Initial Comments at 10.
---------------------------------------------------------------------------

    124. Some commenters argue that transmission providers that already
provide public interconnection information should have flexibility to
use their existing systems to comply.\392\ However, Environmental
Defense Fund avers that this flexibility should not extend to
transmission providers who, prior to the NOPR, were without a
substantial public interconnection information system, because they
have no sunk costs related to public interconnection information
systems.\393\
---------------------------------------------------------------------------

    \392\ Environmental Defense Fund Reply Comments at 4; OMS
Initial Comments at 6.
    \393\ Environmental Defense Fund Reply Comments at 4.
---------------------------------------------------------------------------

    125. Several commenters express concern that heatmaps would be
technically difficult to implement outside of RTOs/ISOs and ask the
Commission to provide non-RTO/ISO regions with flexibility in how they
comply with the mapping tool.\394\ Tri-State states that, in non-RTO/
ISO regions, it is common for multiple transmission providers to use a
single substation, making injection capacity dependent on
interconnection requests in neighboring interconnection queues and
their associated study assumptions.\395\ Tri-State, therefore,
encourages the Commission to permit variations among heatmaps, adding
that entities in non-RTOs/ISOs should not be required to study every
bus.\396\
---------------------------------------------------------------------------

    \394\ Dominion Initial Comments at 12-14; NRECA Initial Comments
at 16; NV Energy Initial Comments at 10; PPL Initial Comments at 9;
Puget Sound Initial Comments at 5-6; Tri-State Initial Comments at
8.
    \395\ Tri-State Initial Comments at 8.
    \396\ Id.; see also Eversource Initial Comments at 11.
---------------------------------------------------------------------------

    126. Xcel recommends that the Commission consider applying the
requirement only in RTO/ISO regions or granting non-RTO/ISO
transmission providers sufficient time, such as two years, to
comply.\397\ WAPA asks the Commission to first require data
visualization by larger utilities, wait approximately 18 months after
implementation, and then measure the benefits of interactive tools
produced by larger utilities, giving stakeholders a chance to comment
before extending the heatmap requirement.\398\
---------------------------------------------------------------------------

    \397\ Xcel Initial Comments at 22.
    \398\ WAPA Initial Comments at 8.
---------------------------------------------------------------------------

    127. On the other hand, some commenters expressly argue that
uniformity should be required inside and outside of RTO/ISO
regions.\399\ Google states that such publicly available information
would begin to address the critical information advantage that
transmission owners have over independent power producers, particularly
in non-RTO/ISO regions.\400\ R Street notes that non-RTO/ISO regions
may have additional challenges in implementing such a tool but states
that this should not eliminate their requirement to do so and those
regions could be granted extra implementation time.\401\
---------------------------------------------------------------------------

    \399\ Environmental Defense Fund Reply Comments at 3; Fervo
Energy Reply Comments at 3; Google Initial Comments at 6; R Street
Initial Comments at 10.
    \400\ Google Reply Comments at 6.
    \401\ R Street Initial Comments at 10.
---------------------------------------------------------------------------

(d) Requests for Clarification or Technical Conference
    128. Several commenters seek clarification on the information
transmission providers are required to present in the heatmap, use of
that information, who has the responsibility of presenting the
information, timing of updating that information and recovery of costs
for providing this information. PJM asks that the Commission clarify
that an interactive visual congestion map could comply, instead of
requiring its specific form.\402\
---------------------------------------------------------------------------

    \402\ PJM Initial Comments at 48.
---------------------------------------------------------------------------

    129. APPA-LPPC ask the Commission to clarify that it is not
proposing that

transmission providers be required to conduct any individualized
analyses or take any action in response to particular prospective
interconnection customers' use of the interactive tools.\403\
---------------------------------------------------------------------------

    \403\ APPA-LPPC Initial Comments at 13-14.
---------------------------------------------------------------------------

    130. Some commenters request that the Commission make clear that
the public information is published only as a guide and not as a
binding or definitive statement of available interconnection capacity
or costs.\404\ Xcel asks the Commission to clarify that transmission
providers have no liability associated with the posting of public
information.\405\ EEI urges the Commission to make clear that
interconnection customers that rely exclusively on this information,
including these maps, do so at their own risk.\406\
---------------------------------------------------------------------------

    \404\ AECI Initial Comments at 5; AEE Initial Comments at 9; AEP
Initial Comments at 13; Ameren Initial Comment at 6; CAISO Initial
Comments at 8; Duke Southeast Utilities Initial Comments at 6-7; EEI
Initial Comments at 12-13; National Grid Initial Comments at 8-9;
New York State Department Initial Comments at 8; NYISO Initial
Comments at 17; NYTOs Initial Comments at 9.
    \405\ Xcel Initial Comments at 22.
    \406\ EEI Initial Comments at 13.
---------------------------------------------------------------------------

    131. Eversource asks that the Commission clarify that ``no
information would be required to be made available before the
conclusion of the first cluster study.'' \407\
---------------------------------------------------------------------------

    \407\ Eversource Initial Comments at 11.
---------------------------------------------------------------------------

    132. Dominion seeks clarification that, in an RTO/ISO context, the
proposed requirements to maintain a visual representation would apply
to the RTO/ISO, and not additionally to individual transmission
owners.\408\
---------------------------------------------------------------------------

    \408\ Dominion Initial Comments at 14.
---------------------------------------------------------------------------

    133. Several commenters request clarification on how the public
information proposal will be funded.\409\ Some commenters assert that a
user-pays model is the only appropriate funding mechanism because not
all interconnection customers will use the public information tools,
and the transmission provider or their customers should not be required
to pay for work that only benefits some.\410\ Tri-State asserts that it
might increase the $5,000 application fee to cover the significant
heatmap costs.\411\
---------------------------------------------------------------------------

    \409\ National Grid Initial Comments at 8; PacifiCorp Initial
Comments at 14; Tri-State Initial Comments at 7-8.
    \410\ National Grid Initial Comments at 8; PacifiCorp Initial
Comments at 14.
    \411\ Tri-State Initial Comments at 8.
---------------------------------------------------------------------------

    134. AEP, Tesla, and ACORE ask the Commission to initiate a
proceeding and hold a technical conference to, among other things,
identify useful information tools that could be feasibly developed,
establish uniform and transparent study assumptions, share best
practices, and help less sophisticated interconnection customers learn
to use available tools and information to lessen their own risk before
entering an interconnection queue.\412\
---------------------------------------------------------------------------

    \412\ ACORE Reply Comments at 3, AEP Initial Comments at 13, 15;
Tesla Initial Comments at 6.
---------------------------------------------------------------------------

iii. Commission Determination
    135. We adopt, without modification, the NOPR proposal to revise
pro forma LGIP section 6.4, now section 6.1, to require transmission
providers to publicly post available information pertaining to
generator interconnection (i.e., public interconnection information or
a heatmap). We require transmission providers to update the heatmap
within 30 calendar days after the completion of each cluster study and
cluster restudy. Such heatmaps must be calculated under N-1 conditions
and studied based on the power flow model of the transmission system
with the transfer simulated from each point of interconnection to the
whole transmission provider's footprint (to approximate NRIS), and with
the incremental capacity at each point of interconnection decremented
by the existing and queued generation at that location (based on the
existing or requested interconnection service limit of such
generation). We require transmission providers to provide the following
information as outputs at each point of interconnection: (1) the
distribution factor; (2) the MW impact (based on the proposed project
size and the distribution factor); (3) the percentage impact on each
impacted transmission facility (based on the MW values of the proposed
project and the facility rating); (4) the percentage of power flow on
each impacted transmission facility before the proposed project; and
(5) the percentage power flow on each impacted transmission facility
after the injection of the proposed project.
    136. We find that the benefit of providing further transparency to
interconnection customers about potential points of interconnection
outweighs the added administrative burden to transmission providers.
Commenters generally support supplementing the existing publicly
available interconnection information and note their broad support for
the NOPR proposal.\413\ Many commenters further assert that the heatmap
will provide valuable information to interconnection customers before
they enter the interconnection queue,\414\ and as SEIA explains,
interconnection customers currently lack substantial information prior
to entering the interconnection queue, which is valuable in determining
whether to proceed with a proposed generating facility.\415\ In
particular, the information that we require transmission providers to
provide to prospective interconnection customers will allow such
interconnection customers to learn about available interconnection
capacity as well as other metrics that reflect the impact of the
addition of a proposed generating facility to the transmission
provider's transmission system at a particular point of
interconnection. Such information may allow a prospective
interconnection customer to estimate expected congestion,\416\ and, in
turn, to assess likely network upgrades triggered by a proposed
generating facility or the possibility of curtailment of a proposed
generating facility.
---------------------------------------------------------------------------

    \413\ ACE-NY Initial Comments at 11; AES Initial Comments at 3;
Affected Interconnection Customers Initial Comments at 30; APPA-LPPC
Initial Comments at 13; CAISO Initial Comments at 7; CESA Initial
Comments at 7; Clean Energy Associations Initial Comments at 12;
Clean Energy Buyers Initial Comments at 6-7; Colorado Commission
Initial Comments at 8; Consumers Energy Initial Comments at 3; CREA
and NewSun Initial Comments at 44-45; Duke Southeast Utilities
Initial Comments at 6; Environmental Defense Fund Initial Comments
at 3; Environmental Defense Fund Reply Comments at 2-3; ELCON
Initial Comments at 4; ENGIE Initial Comments at 2; Evergreen Action
Initial Comments at 3; Fervo Energy Initial Comments at 2; Google
Initial Comments at 14; Google Reply Comments at 6; Illinois
Commission Initial Comments at 6; Interwest Initial Comments at 7;
New Jersey Commission Initial Comments at 11-12; Northwest and
Intermountain Initial Comments at 9-10; NY Commission and NYSERDA
Initial Comments at 8; [Oslash]rsted Initial Comments at 7; Pattern
Energy Initial Comments at 23; Pine Gate Initial Comments at 13;
Public Interest Organizations Initial Comments at 18-19; R Street
Initial Comments at 8, 10; R Street Reply Comments at 2; Southern
Initial Comments at 28; Tesla Initial Comments at 6-7; Vistra
Initial Comments at 1, 4.
    \414\ Alliant Energy Initial Comments at 5; Clean Energy
Associations Initial Comments at 12; CREA and NewSun Initial
Comments at 44-45; Duke Southeast Utilities Initial Comments at 6;
EEI Initial Comments at 12-13; ELCON Initial Comments at 6; ENGIE
Initial Comments at 2; Evergreen Action Initial Comments at 3; Fervo
Energy Initial Comments at 2-3; Google Initial Comments at 4;
Illinois Commission Initial Comments at 6; Indicated PJM TOs Initial
Comments at 14; Indicated PJM TOs Reply Comments 6; ISO-NE Initial
Comments at 26-27; New Jersey Commission Initial Comments at 12; NY
Commission and NYSERDA Initial Comments at 8; Ohio Commission
Consumer Advocate Initial Comments at 7; Pacific Northwest Utilities
Initial Comments at 13; SEIA Initial Comments at 5.
    \415\ SEIA Initial Comments at 6.
    \416\ Google Initial Comments at 14.
---------------------------------------------------------------------------

    137. With access to this type of information, a prospective
interconnection customer will be able to better assess the viability of
a proposed generating facility before it submits an interconnection
request and therefore may be able to submit fewer exploratory

and unviable interconnection requests. We believe that, by reducing the
number of speculative interconnection requests, this reform will reduce
the delays caused by restudies triggered by interconnection request
withdrawals and overcrowded interconnection queues.\417\ We believe
that this information is also beneficial in the cluster study context,
contrary to some commenters' concerns regarding the availability of
information about the composition of the cluster and the effect of the
other proposed generating facilities in the cluster. In fact,
interconnection customers will be able to evaluate the viability of
their proposed generating facility in the context of a cluster by using
the publicly posted information as a baseline and incorporating the
cluster information that transmission providers are required to post,
during the customer engagement window, per new pro forma LGIP section
3.4.5 (Customer Engagement Window). Further, the heatmap requirement
will standardize the information available to interconnection customers
across regions and such standardization will provide interconnection
customers with consistency as they assess the viability of proposed
generating facilities, including where to site them, across
regions.\418\ Despite MISO's assertion that interconnection customers
typically use their own tools to conduct analyses, as opposed to MISO's
heatmap, several commenters identify MISO's heatmap tool as an example
of a transmission provider posting generator interconnection
information that is useful for prospective interconnection
customers.\419\ Therefore, we continue to find that it is important to
make similar information available to prospective interconnection
customers across the country to ensure comparable access to information
and the above mentioned resultant benefits of such information for the
interconnection process.
---------------------------------------------------------------------------

    \417\ See CESA Initial Comments at 9; CESA Reply Comments at 3;
Consumers Energy Initial Comments at 3; CREA and NewSun Initial
Comments at 44-45; Duke Southeast Utilities Initial Comments at 6;
Environmental Defense Fund Initial Comments at 3; EEI Initial
Comments at 12-13; ELCON Initial Comments at 6; Evergreen Action
Initial Comments at 3; Google Initial Comments at 14; Illinois
Commission Initial Comments at 6-7; New Jersey Commission Initial
Comments at 12; NY Commission and NYSERDA Initial Comments at 8;
Pacific Northwest Utilities Initial Comments at 13; SEIA Initial
Comments at 5.
    \418\ See, e.g., Alliant Energy Initial Comments at 5; Clean
Energy Associations Initial Comments at 12.
    \419\ ACE-NY Initial Comments at 11; AES Initial Comments at 3;
Affected Interconnection Customers Initial Comments at 30; APPA-LPPC
Initial Comments at 13; CAISO Initial Comments at 7; CESA Initial
Comments at 7; Clean Energy Associations Initial Comments at 12;
Clean Energy Buyers Initial Comments at 6-7; Colorado Commission
Initial Comments at 8; Consumers Energy Initial Comments at 3; CREA
and NewSun Initial Comments at 44-45; Duke Southeast Utilities
Initial Comments at 6; Environmental Defense Fund Initial Comments
at 3; ELCON Initial Comments at 4; ENGIE Initial Comments at 2;
Evergreen Action Initial Comments at 3; Fervo Energy Initial
Comments at 2; Google Initial Comments at 14; Google Reply Comments
at 6; Illinois Commission Initial Comments at 6; Interwest Initial
Comments at 7; New Jersey Commission Initial Comments at 11-12;
Northwest and Intermountain Initial Comments at 9-10; NY Commission
and NYSERDA Initial Comments at 8; [Oslash]rsted Initial Comments at
7; Pattern Energy Initial Comments at 23; Pine Gate Initial Comments
at 13; Public Interest Organizations Initial Comments at 18-19; R
Street Initial Comments at 8, 10; Southern Initial Comments at 28;
Tesla Initial Comments at 6-7; Vistra Initial Comments at 1, 4.
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    138. Some commenters assert that the NOPR proposal is not useful
\420\ in part because it does not provide sufficient detail and may not
correspond with future study conditions,\421\ its usefulness depends on
its implementation,\422\ and it is unlikely to address cost uncertainty
challenges.\423\ In response to such objections, we find that the
public interconnection information requirements we adopt in this final
rule will provide further transparency of interconnection conditions,
but, as we have acknowledged above, will remain non-binding and
therefore cannot provide cost certainty. We recognize that this
requirement does not provide real-time transmission system information,
but we find that this information is valuable to prospective
interconnection customers before they enter the interconnection queue.
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    \420\ Dominion Initial Comments at 13; Idaho Power Initial
Comments at 3; ISO-NE Initial Comments at 17; NextEra Initial
Comments at 12; New York State Department Initial Comments at 8;
NYISO Initial Comments at 17; Omaha Public Power Initial Comments at
4; PacifiCorp Initial Comments at 14.
    \421\ Dominion Initial Comments at 13; New York State Department
Initial Comments at 8; Omaha Public Power Initial Comments at 4.
    \422\ Indicated PJM TOs Initial Comments at 14; New York State
Department Initial Comments at 8; NYTOs Initial Comments at 9; SPP
Initial Comments at 4.
    \423\ AEE Initial Comments at 9; Cypress Creek Initial Comments
at 13.
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    139. We disagree with commenters that assert that the NOPR proposal
is overly burdensome.\424\ By moving the pro forma LGIP from a serial
to a cluster study process, the reforms adopted in this final rule will
reduce the number of studies and restudies performed by transmission
providers, therefore reducing the burden on both transmission providers
and their staff. In addition, as commenters assert, and we agree, the
information posting and interactive capability we require in this final
rule could feasibly be implemented with available industry system
simulation tools.\425\ We also agree with Clean Energy Associations
that providing these data in a standardized format should be a
``relatively low-impact'' requirement for transmission providers.\426\
This appears to be consistent with comments from Dominion that suggests
that the majority of the burden associated with complying with this
reform will be through an up-front financial commitment in new
software, rather than ongoing costs.\427\ Having made such software
commitments, though, transmission providers should be able to automate
much of the heatmap development, without significant commitments of
staff or resources. In doing so, we expect the ongoing costs of
maintaining such a heatmap to be relatively low. Moreover, because
transmission providers must use the most recent cluster study or
cluster restudy to populate the heatmap, they will not face the burden
of individualized analyses, which addresses the concern raised by some
commenters.\428\
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    \424\ Dominion Initial Comments at 13; National Grid Initial
Comments at 8; New York State Department Initial Comments at 8;
NextEra Initial Comments at 12; Omaha Public Power Initial Comments
at 4; Pacific Northwest Utilities Initial Comments at 14; PPL
Initial Comments at 9; Tri-State Initial Comments at 4; WAPA Initial
Comments at 7.
    \425\ APPA-LPPC Initial Comments at 13; Pennsylvania Commission
Initial Comments at 13, which explains that transmission providers
are already implementing these tools further illustrates the point:
heatmaps will not likely cause further delay in already-stressed
queues.
    \426\ Clean Energy Associations Initial Comments at 23-13; see
also ACORE Reply Comments at 3 (stating that collaboration to
increase automation of interconnection studies is a best practice
that could be adopted elsewhere).
    \427\ Dominion Initial Comments at 12.
    \428\ See APPA-LPPC Initial Comments at 13-14.
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    140. We adopt the requirement for transmission providers to update
the heatmaps within 30 calendar days after the completion of each
cluster study and cluster restudy. We recognize the need to balance the
burden of a specific update frequency with the value of ensuring
uniform, up-to-date information that can inform prospective
interconnection customers evaluating whether to enter the next cluster.
While some commenters support the timeline proposed in the NOPR,\429\
others argue that it is overly burdensome or, given the division of
their footprint into regions that have different timelines, would
trigger frequent updates. We find that the requirements we adopt here

establish an appropriate period of time because, as discussed above,
once the necessary software is in place, updating the heatmap after the
completion of a study is expected to be largely automated without
significant commitments of staff or resources. As the record
demonstrates, such heatmaps can be implemented with available industry
system simulation tools \430\ and with a standardized format that
causes the burden to be a ``relatively low-impact'' requirement for
transmission providers,\431\ once transmission providers have invested
in new software.\432\
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    \429\ Environmental Defense Fund Initial Comments at 3;
[Oslash]rsted Initial Comments at 6; Public Interest Organizations
Initial Comments at 20.
    \430\ APPA-LPPC Initial Comments at 13-14; Pennsylvania
Commission Initial Comments at 13.
    \431\ Clean Energy Associations Initial Comments at 23-13; see
also ACORE Reply Comments at 3 (stating that collaboration to
increase automation of interconnection studies is a best practice
that could be adopted elsewhere).
    \432\ Dominion Initial Comments at 12.
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    141. In response to Eversource, which asks the Commission to
clarify that the heatmap would not be required to be made available
before the first cluster study concludes,\433\ we agree and further
clarify that the heatmap would not be required to be made available
until after the transition period. In response to El Paso Electric's
comments regarding the burden of a monthly update,\434\ we clarify that
the heatmaps must be updated within 30 calendar days after the
completion of each cluster study and cluster restudy, not on a cycle of
every 30 calendar days.
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    \433\ Eversource Initial Comments at 11.
    \434\ El Paso Electric Initial Comments at 7.
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    142. In response to comments from PJM, Bonneville, and Tri-State
requesting flexibility for the posting of information for points of
interconnection that have yet to be studied,\435\ we clarify that
transmission providers need to provide updates only for anything that
has changed in the most recent cluster study or restudy after the first
cluster study after the Commission-approved effective date of the
transmission provider's filing in compliance with this final rule.
Requiring transmission providers to study each potential point of
interconnection, rather than just those requested in each cluster,
would expand the scope of this requirement. In turn, requiring such
expanded studies would be inconsistent with ensuring that
interconnection customers are able to interconnect in a reliable,
efficient, transparent, and timely manner. In response to PJM, which
states that transmission providers should be allowed to use prescreened
datasets that capture a majority of the feasible points of
interconnection that remove existing generator buses on the low side of
the generator step-up unit, rather than using all buses to populate the
heatmap,\436\ we agree that the heatmap may not differ significantly
between the existing generating facility's point of interconnection on
the low voltage side of the generating facility's step-up unit and the
high voltage side of the step-up unit. If that is the case, this final
rule provides transmission providers with the flexibility to populate
the heatmap with only the high side of the step-up unit.
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    \435\ Bonneville Initial Comments at 6; PJM Initial Comments at
48-49; Tri-State Initial Comments at 8.
    \436\ PJM Initial Comments at 48-49.
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    143. In response to comments arguing that the Commission has failed
to demonstrate that information already made available is
inadequate,\437\ we disagree. The heatmap requirement is distinct from
information that transmission providers are already required to
provide. The existing pro forma LGIP requires transmission providers to
post the interconnection models and assumptions on OASIS or a password-
protected website. But the information that we require to be posted in
compliance with this final rule is the output of such models and
assumptions. We believe that publicly posting such resulting output is
necessary to aid prospective interconnection customers in their
decision-making prior to entering the interconnection queue. While
interconnection customers, on their own or through the hiring of
consultants, may be capable of performing studies with information
already published by transmission providers to arrive at information
similar to that required as part of this final rule, we believe that
making high-level information more easily accessible to all prospective
interconnection customers is needed to remedy unjust and unreasonable
Commission-jurisdictional rates. While Order No. 845 and FERC Form 715
do require certain, more detailed information to be filed with the
Commission and/or posted on OASIS or a password-protected website,\438\
access to this information has not addressed the problem of speculative
interconnection requests that we aim to remedy with several reforms
adopted in this final rule.
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    \437\ APPA-LPPC Initial Comments at 9; Duke Southeast Utilities
Initial Comments at 6-7; Idaho Power Initial Comments at 3; New York
State Department Initial Comments at 8; NV Energy Initial Comments
at 10; NYISO Initial Comments at 17; Ohio Commission Consumer
Advocate Initial Comments at 6-7; PacifiCorp Initial Comments at 14-
15; PG&E Initial Comments at 9-10; SoCal Edison Initial Comments at
14.
    \438\ Order No. 845, 163 FERC ] 61,043 at P 236.
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    144. We recognize the need to balance security concerns with the
benefits of additional transparency. While some commenters express
security-related concerns with the NOPR proposal,\439\ as discussed
below, we are not modifying the Commission's CEII procedures,\440\
which we believe are sufficient to address security concerns raised in
comments. Some commenters state that publicly posting information that
indicates areas of transmission congestion or constraints is a risk as
these areas are more vulnerable. We are not persuaded by these concerns
and note that location-specific congestion information is already
publicly available in RTO/ISO markets. Moreover, the Commission's
regulations already provide that, upon request, transmission providers
must make available all data used to calculate available transfer
capability, total transfer capability, capacity benefit margin, and
transmission reliability margin for any constrained posted paths
publicly available (including the limiting element(s) and the cause of
the limit (e.g., thermal, voltage, stability)).\441\ Additionally, we
find these concerns to be speculative, particularly in light of the
fact that MISO already provides similar information over a large area.
Rather, we agree with those commenters that do not believe that the
NOPR proposal introduces additional security concerns.\442\
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    \439\ Bonneville Initial Comments at 6; Indicated PJM TOs
Initial Comments at 15; LADWP Initial Comments at 3; NRECA Initial
Comments at 16-17; PacifiCorp Initial Comments at 16; PPL Initial
Comments at 8; SoCal Edison Initial Comments at 13-14.
    \440\ 18 CFR 388.113 (2022), which govern ``the procedures for
submitting, designating, handling, sharing, and disseminating [CEII]
submitted to or generated by the Commission'' (emphasis added).
    \441\ 18 CFR 37.6(b)(2) (2022).
    \442\ MISO Initial Comments at 27.
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    145. In response to concerns from PPL and LADWP regarding the
distribution factor analysis being made public,\443\ we are not
persuaded and find these concerns to be speculative as well. MISO has
long made distribution factors publicly available and states it is
currently unaware of any security concerns associated with the
proposal.\444\ As such, there is no evidence in the record to suggest
this posting has raised any concerns in the past. Moreover, we observe
that the distribution factor analyses informing the heatmaps are the
result of multi-year forward projections that inevitably

diverge from actual, real-time conditions, mitigating any potential
concerns with publicly posting this information.
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    \443\ LADWP Initial Comments at 3; PPL Initial Comments at 8-9.
    \444\ MISO Initial Comments at 27.
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    146. We are similarly unpersuaded by potential data confidentiality
concerns.\445\ As with distribution factors, we find such concerns to
be speculative and contrary to the experience of MISO, which, for the
last several years, has already provided this information
publicly,\446\ as well as contrary to the statements of commenters that
support the NOPR proposal and do not raise data confidentiality
concerns.\447\
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