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

    \2971\ Ameren Initial Comments at 32; MISO Initial Comments at
124.
    \2972\ MISO Initial Comments at 124.
---------------------------------------------------------------------------

(4) Alternative Transmission Technologies for NRIS or ERIS
    1564. Some commenters responded to whether the use of alternative
transmission technologies can support an interconnection customer's
request for NRIS, or whether the use of such technologies can only be
used if the interconnection customer requested ERIS. Hannon Armstrong
asserts that one or more of these alternative transmission technologies
may be able to delay or eliminate the needed network upgrades
identified in interconnection studies under both ERIS and NRIS.\2973\
MISO argues that technologies that merely curtail generation would not
be suitable for interconnection requests seeking NRIS as they could not
pass the deliverability test, while technologies that can control
transmission line impedances, such as phase shifters, are acceptable
for NRIS.\2974\ Invenergy contends that a given alternative
transmission technology may only facilitate ERIS service in certain
circumstances but that there is no reason to limit the scope of
alternative transmission technologies at the outset without having
performed any relevant analysis.\2975\ Clean Energy Associations ask
the Commission to require transmission providers to publicly post any
service differences (e.g., if use of a given technology would enable
ERIS but not necessarily NRIS).\2976\
---------------------------------------------------------------------------

    \2973\ Hannon Armstrong Initial Comments at 2.
    \2974\ MISO Initial Comments at 124.
    \2975\ Invenergy Initial Comments at 53.
    \2976\ Clean Energy Associations Initial Comments at 62.
---------------------------------------------------------------------------

(5) Study and Network Upgrade Cost Allocation for Alternative
Transmission Technologies
    1565. Commenters address the Commission's question about how costs
incurred for evaluating alternative transmission technology study
requests would be allocated among interconnection customers in the
cluster. WATT Coalition argues that any marginal increase of study
costs to accommodate the evaluation of grid enhancing technologies
should be allocated evenly across interconnection customer cluster
study participants.\2977\ However, NARUC and Indicated PJM TOs
disagree, asserting that additional costs incurred for evaluating
alternative transmission technologies should be allocated to the
requesting interconnection customer(s) to maintain cost certainty and
equity.\2978\ Fervo Energy proposes that, if the requested alternative
transmission technology would benefit more than one interconnection
customer in the cluster, a pro rata allocation of study cost among
those interconnection customers would be appropriate; however, if the
requested technology only serves one interconnection customer, Fervo
Energy argues that direct cost allocation for that study cost is
appropriate.\2979\ Fervo Energy adds that it would support pro rata
allocation of costs even if the Commission mandates consideration of
alternative transmission technologies.\2980\
---------------------------------------------------------------------------

    \2977\ WATT Coalition Initial Comments at 4.
    \2978\ NARUC Initial Comments at 40; Indicated PJM TOs Reply
Comments at 17-18.
    \2979\ Fervo Energy Initial Comments at 7.
    \2980\ Fervo Energy Reply Comments at 10.
---------------------------------------------------------------------------

    1566. NextEra argues that, under the ``but for'' principle of cost
allocation, the interconnection customer's cost responsibility should
be limited to the cost of the alternative transmission technology that
would have sufficed as a long-term solution for a given network
upgrade, especially when transmission providers choose instead to
construct more costly upgrades beyond what is

required for the interconnection customer's proposed generating
facility.\2981\ Tri-State instead argues that the Commission's proposal
does not consider the likely outcome of an interconnection request
advancing with a new technology, which will force the subsequent
interconnection customer to fund costly network upgrades when it would
be more equitable for the interconnection customers to share the cost
of a single network upgrade.\2982\
---------------------------------------------------------------------------

    \2981\ NextEra Initial Comments at 38.
    \2982\ Tri-State Initial Comments at 23.
---------------------------------------------------------------------------

(6) Timing of Alternative Transmission Technology Evaluation Requests
    1567. Some commenters discuss limiting the request to include
alternative transmission technologies to the initial stages of the
interconnection process. ISO-NE and NESCOE argue that any alternatives
that are proposed should be included in the initial interconnection
request with specific assumptions that can be studied.\2983\
---------------------------------------------------------------------------

    \2983\ ISO-NE Initial Comments at 41; NESCOE Reply Comments at
21.
---------------------------------------------------------------------------

    1568. Other commenters argue that interconnection customers should
be able to request the study of alternative transmission technologies
later in the interconnection process or when more information is
available.\2984\ Clean Energy Associations contend that transmission
providers should be required to post the costs of requested
technologies and give interconnection customers the flexibility to
adopt appropriate solutions, subject to system conditions and any
limitations in the area.\2985\ [Oslash]rsted suggests that once cluster
studies are done, and if the required upgrades are outside of the
cluster area, then alternate transmission technologies, with the
addition of energy storage, should be evaluated by the transmission
provider during its system impact study phase.\2986\
---------------------------------------------------------------------------

    \2984\ EDF Renewables Initial Comments at 14-15; Enel Initial
Comments at 79; Fervo Energy Reply Comments at 9; Invenergy Initial
Comments at 55; [Oslash]rsted Initial Comments at 9.
    \2985\ Clean Energy Associations Initial Comments at 62.
    \2986\ [Oslash]rsted Initial Comments at 9 (referencing
definition of ``alternative transmission technologies,'' NOPR, 179
FERC ] 61,194 at P 294 n.406).
---------------------------------------------------------------------------

    1569. NARUC asks the Commission to ensure that there is an
opportunity for information exchange between the transmission provider
and interconnection customer to design alternative transmission
technology solutions and supports implementation of a time frame to
facilitate that information exchange.\2987\ Ohio Commission Consumer
Advocate contends that some changes would be required to address unique
attributes of grid enhancing technologies that may be overlooked by
existing frameworks and that the cost and duration of modeling and
evaluations would be best addressed by transmission providers in
concert with interconnection customers.\2988\
---------------------------------------------------------------------------

    \2987\ NARUC Initial Comments at 40-41.
    \2988\ Ohio Commission Consumer Advocate Initial Comments at 16.
---------------------------------------------------------------------------

(d) Requests for Clarification and Flexibility
    1570. Ameren asks how software or operational barriers (such as
whether the MISO software can model the technology) will be
addressed.\2989\ Ameren asks for clarification as to who pays for the
software necessary to model the alternative transmission technology and
whether that gets assigned to the interconnection customer requesting
the use of the advanced transmission technology or to the cluster of
interconnection customers, some of which may prefer a different
solution that does not involve use of an advanced transmission
technology. Ameren claims that it is unclear what happens if
interconnection customers within the same cluster disagree about using
an alternative transmission technology in place of a network upgrade
and whether consensus is required.
---------------------------------------------------------------------------

    \2989\ Ameren Initial Comments at 32.
---------------------------------------------------------------------------

    1571. NARUC suggests that the Commission clarify that transmission
providers need not perform a separate study for each requested
alternative transmission technology.\2990\ NARUC also asks the
Commission to clarify that interconnection customers bear the burden of
designing the alternative transmission technology solutions, preparing
necessary technical data, and determining whether it is temporary or
permanent.
---------------------------------------------------------------------------

    \2990\ NARUC Initial Comments at 40.
---------------------------------------------------------------------------

    1572. NEPOOL urges the Commission to receive input from each RTO/
ISO to consider how much flexibility to provide with respect to the
list of alternative transmission technologies because they are the most
informed with respect to which alternative transmission technologies
are feasible.\2991\ Similarly, NYTOs ask the Commission to allow
regions to determine which alternative transmission technologies would
be appropriate and beneficial in performing interconnection studies
instead of mandating their use.\2992\
---------------------------------------------------------------------------

    \2991\ NEPOOL Initial Comments at 17.
    \2992\ NYTOs Initial Comments at 32-33.
---------------------------------------------------------------------------

    1573. Some commenters underscore the importance of transmission
providers retaining the discretion to decline to adopt an alternative
transmission technology in the place of a network upgrade.\2993\
National Grid argues that, to the extent an interconnection customer
requests evaluation of a new alternative transmission technology beyond
the list proposed in the NOPR and provides studies in support of its
proposed use, the transmission owner should be permitted to determine
whether the evaluation of such a new technology will be
beneficial.\2994\ Indicated PJM TOs request that, if the final rule
requires transmission providers to consider alternative transmission
technologies, the transmission provider and transmission owners have
the ability to reject the request without a study when they have
knowledge or experience that the request will not work.\2995\
---------------------------------------------------------------------------

    \2993\ Ameren Initial Comments at 31; APS Initial Comments at
23; Indicated PJM TOs Initial Comments at 57; National Grid Initial
Comments at 42; PacifiCorp Initial Comments at 43; Xcel Initial
Comments at 47.
    \2994\ National Grid Initial Comments at 42.
    \2995\ Indicated PJM TOs Reply Comments at 17.
---------------------------------------------------------------------------

(e) Miscellaneous
    1574. Invenergy argues that, if an alternative transmission
technology is not selected, the transmission providers should provide
detailed reports, including a cost-benefit analysis, behind the
decision and there should be a process to resolve disagreements over
the decision with the interconnection customer.\2996\ R Street requests
that the Commission require transmission providers to describe the
benefits, or lack thereof, of the set of technologies listed in the
NOPR.\2997\ WATT Coalition and California Public Utilities Commissioner
Darcie Houck request that transmission providers abide by strict
standards when studying grid enhancing technologies.\2998\
---------------------------------------------------------------------------

    \2996\ Invenergy Initial Comments at 54.
    \2997\ R Street Initial Comments at 16.
    \2998\ WATT Coalition Initial Comments at 3-4; Joint Fed.-State
Task Force on Elec. Transmission, Technical Conference, Docket No.
AD21-15-000, recording at 1:16:18-1:24:02 (approx.) (Commissioner
Darcie Houck) (July 16, 2023).
---------------------------------------------------------------------------

    1575. In addition to the study of alternative transmission
technologies that the Commission envisions, [Oslash]rsted recommends
requiring the deployment of these alternative transmission technologies
as a medium-term or long-term alternative to transmission build
out.\2999\
---------------------------------------------------------------------------

    \2999\ [Oslash]rsted Initial Comments at 16.
---------------------------------------------------------------------------

    1576. EDF Renewables suggests that the Commission require the
consideration of alternative transmission technologies not only in

interconnection and transmission planning but also in market operations
upon an interconnection customer's request.\3000\
---------------------------------------------------------------------------

    \3000\ EDF Renewables Initial Comments at 14-15.
---------------------------------------------------------------------------

    1577. Enel claims that interconnection customer interconnection
facilities are underutilized and could be networked into the
transmission system to mitigate transmission constraints and to
increase system reliability.\3001\ Enel suggests that the Commission
add language to the pro forma LGIA that allows interconnection
facilities to convert to distribution facilities or regional
transmission facilities.
---------------------------------------------------------------------------

    \3001\ Enel Initial Comments at 80-81.
---------------------------------------------------------------------------

iii. Commission Determination
    1578. We adopt, with modifications, the proposed revisions to
section 7.3 of the pro forma LGIP, and sections 3.3.6 and 3.4.10 of the
pro forma SGIP. We modify the NOPR proposal to require transmission
providers to evaluate the following enumerated list of alternative
transmission technologies: static synchronous compensators, static VAR
compensators, advanced power flow control devices, transmission
switching, synchronous condensers, voltage source converters, advanced
conductors, and tower lifting. We modify proposed pro forma LGIP
section 7.3 to require transmission providers to evaluate the list of
alternative transmission technologies enumerated in this final rule
during the cluster study, including any restudies, of the generator
interconnection process in all instances (i.e., for all interconnection
customers in a cluster), without the need for a request from an
interconnection customer. We require transmission providers to evaluate
each alternative transmission technology listed in pro forma LGIP
section 7.3 and to determine, in the transmission provider's sole
discretion, whether it should be used, consistent with good utility
practice, applicable reliability standards, and other applicable
regulatory requirements. Finally, we require transmission providers to
include, in the pro forma LGIP cluster study report, an explanation of
the results of the evaluation of the enumerated alternative
transmission technologies for feasibility, cost, and time savings as an
alternative to a traditional network upgrade.
    1579. We modify the enumerated list of alternative transmission
technologies from the NOPR proposal to: (1) retain synchronous, static
VAR compensators, advanced power flower control, and transmission
switching in the list; (2) add synchronous condensers, voltage source
converters, advanced conductors, and tower lifting to the list; and (3)
remove dynamic line ratings from the list. Generally, we find that
these enumerated alternative transmission technologies are those with
the most potential to be useful to reduce interconnection costs by
providing lower cost network upgrades to interconnect new generating
facilities and, thus, we require transmission providers to evaluate
these technologies in the interconnection process for their
feasibility, cost, and time savings potential.
    1580. We also adopt, with modifications, the proposed revisions to
sections 3.3.6 and 3.4.10 of the pro forma SGIP. Consistent with the
pro forma LGIP requirement, we require transmission providers to
evaluate the enumerated alternative transmission technologies in all
instances, without the need for a request from an interconnection
customer. We modify the proposal to require such evaluations to occur
during the pro forma SGIP feasibility study and system impact study of
the generator interconnection process, as opposed to in the pro forma
SGIP system impact study and facilities study. We find that it is
appropriate to modify the proposal so that these evaluations occur
during the relevant pro forma SGIP studies where network upgrades are
identified, consistent with the pro forma LGIP requirement. We require
transmission providers to evaluate each alternative transmission
technology listed in pro forma SGIP sections 3.3.6 and 3.4.10 and
determine, in the transmission provider's sole discretion, whether it
should be used, consistent with good utility practice, applicable
reliability standards, and other applicable regulatory requirements.
    1581. Finally, we require transmission providers to include, in the
feasibility study report and system impact study report, an explanation
of the results of the evaluation of the enumerated alternative
transmission technologies for feasibility, cost, and time savings as an
alternative to a traditional network upgrade. We note that this reform
is one of the few reforms in this final rule that applies to small
generating facilities, in addition to large generating facilities. As
described below, we find that the enumerated alternative transmission
technologies that we are requiring transmission providers to evaluate
in their interconnection studies are appropriate for evaluation in the
pro forma SGIP context because they are scalable, and we find that the
enumerated alternative transmission technologies have the potential to
provide similar benefits in the context of both small and large
generating facilities, including cost and time savings. As such, we
adopt, with modifications, the proposed revisions to require
transmission providers to evaluate the enumerated alternative
transmission technologies in all instances in both the pro forma LGIP
and pro forma SGIP.
    1582. This final rule does not create a presumption in favor of
substituting alternative transmission technologies for necessary
traditional network upgrades, either categorically or in specific
cases.\3002\ This final rule is agnostic as to whether, in a specific
case, an alternative transmission technology is an acceptable
alternative to a traditional network upgrade,\3003\ ``that would allow
the interconnection customer to flow the output of its generating
facility onto the transmission provider's transmission system in a safe
and reliable manner.'' \3004\ The determination in each specific case
whether to require a traditional network upgrade or an alternative
transmission

technology is to be made by the transmission provider, and the
determination should be consistent with good utility practice,
applicable reliability standards, and other applicable regulatory
requirements.\3005\ This rule mandates a process of evaluation of
alternatives to traditional network upgrades, not outcomes in specific
cases.
---------------------------------------------------------------------------

    \3002\ See PJM Initial Comments at 68 (``PJM therefore cautions
the Commission not to conflate the operational benefits of
alternative transmission technologies . . . with the need to address
significant capacity enhancement needs (short and long-term) or
long-range transmission needs under rapid growth or changing
resource mix scenarios.''); MISO Initial Comments at 120 (``However,
the Commission fails to recognize that these technologies may be
evaluated in the generator interconnection process already but may
nonetheless not be adopted as they are not the appropriate solution
to a Transmission Issue related to an interconnection.'').
    \3003\ See MISO Initial Comments at 121-22 (``Further, although
these technologies may be evaluated, the technologies identified by
the Commission still may not provide the appropriate solution from a
planning perspective.[ ] Many of the technologies identified are
appropriately considered as operational tools or short-term
solutions but are not necessarily appropriate for planning to
support a particular generator interconnection.'').
    \3004\ See Order No. 2003, 104 FERC ] 61,103 at P 767 (``Both
Energy Resource Interconnection Service and Network Resource
Interconnection Service provide for the construction of Network
Upgrades that would allow the Interconnection Customer to flow the
output of its Generating Facility onto the Transmission Provider's
Transmission System in a safe and reliable manner''); Order No.
2003-A, 106 FERC ] 61,220 at P 404; pro forma LGIA art. 9.3
(``Transmission Provider shall cause the Transmission System and the
Transmission Provider's Interconnection Facilities to be operated,
maintained and controlled in a safe and reliable manner and in
accordance with this LGIA''); Midwest Indep. Transmission Sys.
Operator, Inc., 138 FERC ] 61,233, at P 190 (2012), reh'g denied,
139 FERC ] 61,253 (2012), partial reh'g granted on other grounds,
150 FERC ] 61,035 (2015). See also pro forma LGIA art. 9.4
(``Interconnection Customer shall at its own expense operate,
maintain and control the Large Generating Facility and
Interconnection Customer's Interconnection Facilities in a safe and
reliable manner and in accordance with this LGIA'').
    \3005\ See MISO Initial Comments at 123 (``Additionally, as
noted by the Commission in the proposed reform, although alternative
transmission technologies may be useful tools for operations,
relying on these tools for planning for interconnection may not be
consistent with `good utility practice' and `applicable regulatory
standards.' '').
---------------------------------------------------------------------------

    1583. Based on the record, we affirm the Commission's preliminary
finding in the NOPR that alternative transmission technologies have the
potential to provide benefits to optimize the transmission system in
specific scenarios.\3006\ Specifically, a number of commenters argue
that selecting alternative transmission technologies as network
upgrades may reduce interconnection costs by providing lower cost
transmission solutions to interconnecting new generating facilities
\3007\ and may allow for a faster interconnection by providing
solutions that can be implemented more quickly.\3008\ Commenters also
point out that alternative transmission technologies allow for better
use of the existing transmission system,\3009\ can enhance
reliability,\3010\ and may reduce withdrawals, restudies, and overall
interconnection delays.\3011\ In addition, several commenters argue
that decreasing the costs of network upgrades will reduce the number of
withdrawals from interconnection queues, which will ultimately create a
more efficient interconnection process by reducing the number of
restudies triggered by withdrawals.\3012\ Furthermore, commenters argue
that alternative transmission technologies offer additional value
because they are scalable and modular to address evolving needs and can
be redeployed as those needs continue to change.\3013\ We find that
failing to evaluate the enumerated alternative transmission
technologies renders Commission-jurisdictional rates unjust and
unreasonable and fails to ensure that interconnection customers are
able to interconnect in a reliable, efficient, transparent, and timely
manner.\3014\
---------------------------------------------------------------------------

    \3006\ NOPR, 179 FERC ] 61,194 at PP 294-295.
    \3007\ AEE Initial Comments at 42; EDF Renewables Initial
Comments at 14; ENGIE Initial Comments at 12; OMS Initial Comments
at 19; [Oslash]rsted Initial Comments at 3; SEIA Initial Comments at
40.
    \3008\ AEE Initial Comments at 42; OMS Initial Comments at 19;
[Oslash]rsted Initial Comments at 3; SEIA Initial Comments at 40.
    \3009\ Illinois Commission Initial Comments at 14; Joint Fed.-
State Task Force on Elec. Transmission, Technical Conference, Docket
No. AD21-15-000, recording at 1:16:18-1:24:02 (approx.)
(Commissioner Darcie Houck) (July 16, 2023).
    \3010\ AEE Initial Comments at 42; Ohio Commission Consumer
Advocate Initial Comments at 15; Joint Fed.-State Task Force on
Elec. Transmission, Technical Conference, Docket No. AD21-15-000,
recording at 1:16:18-1:24:02 (approx.) (Commissioner Darcie Houck)
(July 16, 2023).
    \3011\ [Oslash]rsted Initial Comments at 3, 15-16; R Street
Initial Comments at 16; SEIA Initial Comments at 40; WATT Coalition
Initial Comments at 2.
    \3012\ SEIA Initial Comments at 41; WATT Coalition Initial
Comments at 2.
    \3013\ WATT Coalition Initial Comments at 2-3; WATT Coalition
Reply Comments at 5-6.
    \3014\ NOPR, 179 FERC ] 61,194 at P 296; see Clean Energy
Associations Reply Comments at 9-10; Environmental Defense Fund
Initial Comments at 7; Fervo Reply Comments at 9; NARUC Initial
Comments at 38.
---------------------------------------------------------------------------

    1584. However, as stated above,\3015\ this final rule mandates a
process of evaluation of alternative transmission technologies, not
outcomes in specific cases, and does not create a presumption in favor
of using an alternative transmission technology as a substitute for a
traditional network upgrade deemed necessary in a specific case.
Rather, under the approach adopted here, in all cases, the transmission
provider is required only to evaluate the use of alternative
transmission technologies as network upgrades consistent with good
utility practice, applicable reliability standards, and other
applicable regulatory requirements.\3016\ We recognize that, after the
transmission provider evaluates the enumerated alternative transmission
technologies, the transmission provider, in its sole discretion, may
still decide to remedy an identified reliability problem with a
traditional network upgrade.
---------------------------------------------------------------------------

    \3015\ See supra P 1582.
    \3016\ See MISO Initial Comments at 122-123.
---------------------------------------------------------------------------

    1585. We modify the proposed requirement that transmission
providers evaluate the enumerated alternative transmission technologies
only at the request of the interconnection customer. Instead, we
require transmission providers to evaluate the enumerated alternative
transmission technologies in all instances, without a request from an
interconnection customer. We find that this approach both ensures that
the enumerated alternative transmission technologies are considered in
the interconnection process and avoids introducing additional
procedural complexity to the interconnection process. This approach,
which was suggested by many commenters,\3017\ will provide the benefits
of an evaluation of the enumerated alternative transmission
technologies more broadly and consistently and in a more efficient
manner. We believe that modifying the proposal addresses concerns
raised by commenters about the NOPR proposal.\3018\ More specifically,
evaluating alternative transmission technologies only by request, as
proposed in the NOPR, would create an overly complicated and time-
consuming process under which transmission providers evaluate each
alternative transmission technology for each interconnection request
individually. Commenters also raise concerns about the impact on costs
and timing for the entire cluster if only a portion of the cluster
requests evaluation of alternative transmission technologies or if
interconnection customers within the same cluster disagree about using
an alternative transmission technology.\3019\ Given these concerns, and
the potential for benefits to be gained by the evaluation and use, at
the transmission provider's sole discretion, of the enumerated
alternative transmission technologies, we find that it would be overly
burdensome and complex to require transmission providers to track and
process interconnection customer-specific study requests and to resolve
conflicts between interconnection customers' different study requests,
at the expense of those benefits.
---------------------------------------------------------------------------

    \3017\ ACORE Initial Comments at 6; AEE Initial Comments at 42;
CAISO Initial Comments at 38; Amazon Initial Comments at 6; ELCON
Initial Comments at 11; Fervo Energy Reply Comments at 9; Hannon
Armstrong Initial Comments at 2; Invenergy Initial Comments at 52-
53; R Street Initial Comments at 16; Joint Fed.-State Task Force on
Elec. Transmission, Technical Conference, Docket No. AD21-15-000,
recording at 1:16:18-1:24:02 (approx.) (Commissioner Darcie Houck)
(July 16, 2023).
    \3018\ Indicated PJM TOs Initial Comments at 55; MISO Initial
Comments at 11, 121; MISO TOs Initial Comments at 30; National Grid
Initial Comments at 42-43.
    \3019\ CAISO Initial Comments at 38; Puget Sound Initial
Comments at 13; Ameren Initial Comments at 32.
---------------------------------------------------------------------------

    1586. The record before us demonstrates that the requirements we
adopt today will not overly burden transmission providers.\3020\ We
find that requiring transmission providers to evaluate the enumerated
alternative transmission technologies in each interconnection study
will not be a significant additional burden on interconnection queues
for those transmission providers that already consider alternative
transmission technologies in their interconnection process.
Furthermore, we find that the benefits of evaluating and implementing
the enumerated alternative transmission technologies outweigh the
potential

burden or the potential of increased study times. As recognized by
commenters and explained above, the evaluation and use, at the
transmission provider's sole discretion, of the enumerated alternative
transmission technologies could decrease network upgrade costs,
withdrawals, and restudies, thereby increasing the efficiency of the
interconnection process overall. For these reasons, we disagree with
commenters that argue that requiring transmission providers to evaluate
the enumerated alternative transmission technologies is contrary to the
NOPR's goal of increasing the speed of interconnection queue
processing.
---------------------------------------------------------------------------

    \3020\ AEE Initial Comments at 44; ENGIE Initial Comments at 13;
ACORE Reply Comments at 3-4.
---------------------------------------------------------------------------

    1587. We find that, in conducting an evaluation of the enumerated
alternative transmission technologies, it is appropriate for
transmission providers to continue to retain discretion regarding
whether to use each enumerated alternative transmission technology,
consistent with the NOPR.\3021\ The requirement is to evaluate the
enumerated alternative transmission technologies in the interconnection
process for feasibility, cost, and time savings and to determine
whether, in the transmission provider's sole discretion, an alternative
transmission technology should be used as a solution--consistent with
good utility practice, applicable reliability standards, and other
applicable regulatory requirements.\3022\ The transmission provider
must determine whether using any of the enumerated alternative
transmission technologies is an appropriate and reliable network
upgrade ``that would allow the interconnection customer to flow the
output of its generating facility onto the transmission provider's
transmission system in a safe and reliable manner.'' \3023\ The
requirement to make such a determination before allowing for the use of
the enumerated alternative transmission technologies addresses concerns
that their use may impinge on reliability, delay network upgrades
instead of reducing the need for them or obviating the need for them
altogether, or fail to address all transmission system issues that a
traditional network upgrade would address. We recognize the need to
avoid time-consuming delays and costly disputes or litigation over
interconnection costs that could arise as a result of this
reform.\3024\ Therefore, we find that, if a transmission provider
evaluates the enumerated alternative transmission technologies as
required herein and, in its sole discretion, determines not to use any
enumerated alternative transmission technologies as an alternative to a
traditional network upgrade, the transmission provider has complied
with this final rule, including tariffs filed pursuant to this final
rule.
---------------------------------------------------------------------------

    \3021\ NOPR, 179 FERC ] 61,194 at P 299.
    \3022\ See MISO Initial Comments at 122-123 (``Additionally, as
noted by the Commission in the proposed reform, although alternative
transmission technologies may be useful tools for operations,
relying on these tools for planning for interconnection may not be
consistent with `good utility practice' and `applicable regulatory
standards.' '').
    \3023\ See Order No. 2003, 104 FERC ] 61,103 at P 767 (``Both
Energy Resource Interconnection Service and Network Resource
Interconnection Service provide for the construction of Network
Upgrades that would allow the Interconnection Customer to flow the
output of its Generating Facility onto the Transmission Provider's
Transmission System in a safe and reliable manner''); Order No.
2003-A, 106 FERC ] 61,220 at P 404; pro forma LGIA art. 9.3
(``Transmission Provider shall cause the Transmission System and the
Transmission Provider's Interconnection Facilities to be operated,
maintained and controlled in a safe and reliable manner and in
accordance with this LGIA''); Midwest Indep. Transmission Sys.
Operator, Inc., 138 FERC ] 61,233, at P 190 (2012), reh'g denied,
139 FERC ] 61,253 (2012), partial reh'g granted on other grounds,
150 FERC ] 61,035 (2015). See also pro forma LGIA art. 9.4
(``Interconnection Customer shall at its own expense operate,
maintain and control the Large Generating Facility and
Interconnection Customer's Interconnection Facilities in a safe and
reliable manner and in accordance with this LGIA'').
    \3024\ See SPP Initial Comments at 26 (``Even though the
Commission has stated that transmission providers retain the
discretion regarding whether to use such technologies, the very fact
that the transmission provider is required to evaluate them will
lead to disputes if the transmission provider then exercises that
discretion.'').
---------------------------------------------------------------------------

    1588. Because we modify the NOPR proposal and require transmission
providers to evaluate the enumerated alternative transmission
technologies in all instances, we find that the final rule will not
``effectively require a whole additional set of studies for large areas
of the transmission system'' or exponentially increase the number of
studies needed to consider the various combinations, as Indicated PJM
TOs argue could occur under the NOPR proposal.\3025\ This is because
transmission providers will not be evaluating the enumerated
alternative transmission technologies for a subset of interconnection
customers within a cluster--but rather for the entire cluster.
---------------------------------------------------------------------------

    \3025\ Indicated PJM TOs Initial Comments at 55.
---------------------------------------------------------------------------

    1589. Regarding WATT Coalition and California Public Utility
Commissioner Darcie Houck's request that transmission providers abide
by strict standards when studying alternative transmission
technologies,\3026\ we decline to adopt any such standards in the pro
forma LGIP and pro forma SGIP governing the evaluation of alternative
transmission technologies. We find that it is appropriate to continue
to rely on transmission providers to use good utility practice,
applicable reliability standards, and other applicable regulatory
requirements, in their evaluations of alternative transmission
technologies, including the enumerated list, because the specific
evaluation may depend on the transmission provider's individual
transmission system, cluster makeup, and other factors. Similarly,
regarding National Grid's concern that studying every potential
alternative transmission technology for every interconnection request
could cause transmission providers to be penalized for not meeting
study deadlines,\3027\ the final rule does not require the study of all
technologies considered alternative transmission technologies but
rather the evaluation of the enumerated alternative transmission
technologies. Further, we find that the transmission provider--
consistent with good utility practice, applicable reliability
standards, and other applicable regulatory requirements--retains the
sole discretion to determine whether a particular technology in the
enumerated list of alternative transmission technologies is appropriate
and reliable as a network upgrade, or not, for a given cluster.
---------------------------------------------------------------------------

    \3026\ WATT Coalition Initial Comments at 3-4; Joint Fed.-State
Task Force on Elec. Transmission, Technical Conference, Docket No.
AD21-15-000, recording at 1:16:18-1:24:02 (approx.) (Commissioner
Darcie Houck) (July 16, 2023).
    \3027\ National Grid Initial Comments at 42-43.
---------------------------------------------------------------------------

    1590. We also believe that the requirement that transmission
providers evaluate the enumerated alternative transmission technologies
for an entire cluster--rather than on an individual interconnection
customer-request basis--and the modifications to the enumerated list of
alternative transmission technologies (as discussed below) will ease
the burden on transmission providers, thereby lessening the risk that
they are unable to complete studies by the required deadlines. We note
that we are not dictating how a transmission provider must evaluate
each enumerated alternative transmission technology on the list in each
instance; we recognize that in some cases transmission providers may be
able to rapidly determine if a certain enumerated alternative
transmission technology is inappropriate for further study. In response
to Invenergy's request that transmission providers should provide
detailed evaluation reports on why an alternative transmission
technology was not selected, transmission providers are required to
include an explanation of the results of the evaluation of the required
alternative transmission

technologies for feasibility, cost, and time savings as an alternative
to a traditional network upgrade in the applicable study report.
However, we do not direct any additional detailed requirements related
to this reporting requirement because we find they are not needed or
appropriate. We find the required explanation of the results of the
transmission provider's evaluation included in the applicable study
report provides sufficient transparency without placing a further
burden on transmission providers that would delay the processing of
interconnection requests.
    1591. Because we modify the NOPR proposal to require transmission
providers to evaluate all the enumerated alternative transmission
technologies in all instances, i.e., regardless of an interconnection
customer requesting such an evaluation, we decline to adopt commenters'
request to require transmission providers to evaluate the required
alternative transmission technologies by default with an ``opt-out''
option for interconnection customers. We are not persuaded that there
are benefits to including an ``opt-out'' option in the requirement, and
we find it would be overly burdensome and complex to require
transmission providers to track and process interconnection customers'
requests to ``opt-out'' of the evaluation of certain alternative
transmission technologies. Further, an ``opt-out'' would run contrary
to our goal to have transmission providers evaluate the enumerated
technologies in order to achieve beneficial outcomes like decreasing
network upgrade costs, withdrawals, and restudies, thereby increasing
the efficiency of the interconnection process overall.
    1592. As discussed above, the enumerated alternative transmission
technologies that transmission providers must evaluate in
interconnection studies are: static synchronous compensators, static
VAR compensators, synchronous condensers, advanced power flow control,
transmission switching, voltage source converters, advanced conductors,
and tower lifting. We discuss each technology in turn.
    1593. Regarding synchronous and static VAR compensators, we find
that, in providing reactive power to the transmission system, such
devices could reduce interconnection costs by providing the voltage
support where needed for the new generation facility being
interconnected to operate reliably, rather than building a traditional
network upgrade to resolve the voltage support issues. This potentially
results in lower cost network upgrades to interconnect new generating
facilities. ISO-NE states that it already evaluates static synchronous
compensators when evaluating interconnection requests.\3028\ Similarly,
as Indicated PJM TOs attest, PJM already considers static synchronous
compensators in its interconnection and transmission planning
processes.\3029\ Accordingly, we find that synchronous and static VAR
compensators are appropriately included in the list of alternative
transmission technologies enumerated in this final rule that
transmission providers must evaluate in the interconnection process.
---------------------------------------------------------------------------

    \3028\ ISO-NE Initial Comments at 41.
    \3029\ Indicated PJM TOs Initial Comments at 57.
---------------------------------------------------------------------------

    1594. Regarding advanced power flow controls, we find that these
devices allow power to be pushed and pulled to alternate lines with
spare capacity leading to maximum utilization of transmission capacity
and mitigation of overloads. Advanced power flow control devices can be
scaled back as needed, providing an advantage over new lines or
reconductors.\3030\ PacifiCorp attests that it often considers the use
of advanced power flow control devices as potential alternatives to
standard system infrastructure, and Indicated PJM TOs note that PJM and
PJM transmission owners already consider the appropriateness of power
flow control devices when conducting interconnection studies.\3031\ As
discussed above, our decision to modify the NOPR proposal and require
transmission providers to evaluate the enumerated alternative
transmission technologies in all instances addresses Indicated PJM TOs'
statement that evaluation of advanced power flow control devices in the
interconnection process would significantly increase the complexity of
interconnection studies and thus could cause delays in their
completion.\3032\ We acknowledge the possibility that use of advanced
power flow control devices can have impacts on line impedance which may
result in issues in other parts of the system, as suggested by MISO.
However, the requirement of this Final rule is merely that the
transmission provider evaluate each alternative transmission
technology, not that they deploy them in all circumstances. We
appreciate, and expect, that if a transmission provider's evaluation
demonstrates that deployment of advanced power flow control devices
would create issues on the transmission provider's system as described
by MISO, it will not select that advanced power flow control as the
network upgrade.\3033\
---------------------------------------------------------------------------

    \3030\ AEE Initial Comments at 42.
    \3031\ PacifiCorp Initial Comments at 43; Indicated PJM TOs at
57.
    \3032\ Supra P 1585.
    \3033\ See also infra P 1602.
---------------------------------------------------------------------------

    1595. We also retain transmission switching on the enumerated list
of alternative technologies in this final rule. Transmission switching
can be used to route energy around areas with high congestion and
improve the overall transfer capability of the system, potentially
resulting in lower network upgrade costs. In regard to PacifiCorp's
argument that transmission switching is a complex process that can be
implemented only under very particular factual scenarios and system
conditions, transmission providers are already required to evaluate the
impact of the proposed interconnection on the reliability of the
transmission system \3034\ and thus should understand whether the
factual scenarios and system conditions exist that would make a
transmission switching solution appropriate. In response to Tri-State's
question about whether transmission switching is meant to be a remedial
action scheme or to create permanent normally open points on the
system, this final rule does not prescribe how transmission providers
deploy any of the enumerated alternative transmission technologies on
their systems if they determine to use them. To Tri-State's concern
that transmission switching solutions may be ``problematic in highly
interconnected systems not operating in an RTO/ISO,'' we reiterate that
transmission providers retain the discretion to determine whether to
deploy any of the enumerated alternative transmission technologies,
including transmission switching solutions.
---------------------------------------------------------------------------

    \3034\ See pro forma LGIP section 7.3; pro forma SGIP sections
3.3.1, 3.4.1.
---------------------------------------------------------------------------

    1596. We find that the record supports including synchronous
condensers and voltage source converters to the list because these
technologies similarly may reduce interconnection costs in situations
where voltage support is a constraint and where a new or modified
transmission line with these technologies may provide a lower cost
network upgrade option to interconnect new generating facilities.
Specifically, ISO-NE states that it already evaluates synchronous
condensers when evaluating interconnection requests,\3035\ and NARUC
and Xcel urge the Commission to include evaluation of synchronous
condensers and voltage

source converters in the interconnection process.\3036\
---------------------------------------------------------------------------

    \3035\ ISO-NE Initial Comments at 41.
    \3036\ NARUC Initial Comments at 39; Xcel Initial Comments at
47.
---------------------------------------------------------------------------

    1597. We also add advanced conductors and tower lifting to the list
of alternative transmission technologies enumerated in this final rule.
We note the comments arguing that advanced conductors may be beneficial
as network upgrades.\3037\ ACORE explains that deploying advanced
conductors can significantly increase transmission capacity and allow
for the interconnection of new generating facilities without the
construction of new network upgrades.\3038\ Similarly, we find that
tower lifting has the potential to increase transmission line ratings
by providing additional clearance from the ground.\3039\ By increasing
transmission line ratings, there will be more ``headroom'' on the
system to address normal and contingency conditions identified in
interconnection studies, and likely a reduced need for network
upgrades.\3040\ Given these potential benefits to interconnection
customers, we require transmission providers to evaluate advanced
conductors and tower lifting in the interconnection process.
---------------------------------------------------------------------------

    \3037\ ACORE Initial Comments at 6-7; CTC Global Initial
Comments at 6-9; VEIR Initial Comments at 5-6.
    \3038\ ACORE Initial Comments at 7 (citing Jay Caspary and Jesse
Schneider, Grid Strategies, LLC, Opportunities to Use Advanced
Conductors to Accelerate Grid Decarbonization, at 2 (Feb. 2022),
https://acore.org/wp-content/uploads/2022/03/AdvancedConductorstoAccelerateGridDecarbonization.pdf).
    \3039\ See Ampjack Initial Comments at 4. As with other network
upgrades, we note that tower lifting may require a modification to a
certificate of public convenience and necessity (CPCN) or similar
permit issued by a state utility regulator, which may include tower
height limits or other physical restrictions. To the extent the
transmission provider considers potential delays or the possibility
of not receiving such a state CPCN modification when evaluating
potential network upgrades, it should include a similar
consideration in its evaluation of alternative transmission
technologies.
    \3040\ See id. at 1, 4.
---------------------------------------------------------------------------

    1598. We remove dynamic line ratings from the list of enumerated
alternative transmission technologies proposed in the NOPR. We agree
with commenters that the technology may be less beneficial in the
interconnection context than in the transmission operations and
planning context because, for example, dynamic line ratings' ability to
increase the available interconnection service depends on favorable
weather and congestion parameters.\3041\ That is, while dynamic line
ratings may relieve congestion to increase available interconnection
service temporarily or in the short-term, they may not be an adequate
substitute for building interconnection facilities and/or traditional
network upgrades identified through the interconnection study process
that are needed to reliably interconnect a generating facility to the
transmission system during all hours.
---------------------------------------------------------------------------

    \3041\ Indicated PJM TOs Initial Comments at 56; ISO-NE Initial
Comments at 41; NYTOs Initial Comments at 32-33; PacifiCorp Initial
Comments at 44; Tri-State Initial Comments at 23; U.S. Chamber of
Commerce Initial Comments at 12-13.
---------------------------------------------------------------------------

    1599. We decline to add storage that performs a transmission
function to the list of alternative transmission technologies
enumerated in this final rule. The Commission has determined that the
evaluation of whether a storage resource performs a transmission
function requires a case-by-case analysis of either how a particular
storage resource would be operated or the requirements set forth in a
tariff governing selection of such storage resources. For example, in
approving SPP's proposal to establish a framework under which an
electric storage resource may be considered a transmission asset
(thereby making the selected storage resources eligible for cost-based
rate recovery through transmission rates), the Commission identified
five considerations that, together, ensure that a selected storage
resource will serve a transmission function.\3042\
---------------------------------------------------------------------------

    \3042\ Sw. Power Pool, Inc., 183 FERC ] 61,153, at P 29 (2023).
---------------------------------------------------------------------------

    1600. We clarify that transmission providers are not precluded from
studying a technology that is not included in the enumerated list of
alternative transmission technologies. Under the modified requirement,
transmission providers must evaluate the enumerated alternative
transmission technologies in all instances, but we are not precluding a
transmission provider from studying or evaluating any other technology,
including those such as dynamic line ratings that we have determined
not to add to the list of technologies enumerated in this final rule.
We acknowledge that certain transmission providers already evaluate in
certain studies transmission technologies not included in the final
rule list.\3043\ In addition, we clarify that, with respect to this
final rule determination, transmission providers are not required to
propose and justify on compliance any technology it studies in the
interconnection process beyond those required in this final rule.
---------------------------------------------------------------------------

    \3043\ For example, PacifiCorp notes that it already considers
advanced power flow technologies as potential alternatives to
standard system infrastructure. PacifiCorp Initial Comments at 43.
---------------------------------------------------------------------------

    1601. In the NOPR, the Commission generally proposed a method to
allocate the costs of cluster studies and the costs of network upgrades
within a cluster through the interconnection study process.\3044\ With
respect to study costs, the Commission sought comment on how costs
incurred for evaluating alternative transmission technology study
requests would be allocated among interconnection customers in the
cluster under a NOPR proposal in which interconnection customers would
identify and request particular technologies to be studied.\3045\ Given
our modification to the NOPR proposal to require transmission providers
to evaluate the enumerated alternative transmission technologies in the
pro forma LGIP cluster study on behalf of the whole cluster, rather
than upon an individual customer's request, we find that it is not
necessary to consider alternative cost allocation methods for cluster
study costs and network upgrade costs associated with the enumerated
alternative transmission technologies. Specifically, we clarify that
the allocation of cluster study costs for, and substation and system
network upgrades associated with, the enumerated alternative
transmission technologies must be consistent with the allocation of
costs for cluster studies and associated substation and system network
upgrades for any other network upgrades because the enumerated
alternative transmission technologies located on the high-side of the
point of interconnection would fall within the definition of substation
and system network upgrades,\3046\ and they would be adopted only if
they resolve system reliability issues triggered by an interconnection
request. In other words, the enumerated alternative transmission
technologies must be included among the set of options transmission
providers consider when studying a cluster and any implemented
enumerated alternative transmission technologies must receive the same
cost treatment as any other option.
---------------------------------------------------------------------------

    \3044\ See NOPR, 179 FERC ] 61,194 at PP 82-83, 88-89.
    \3045\ Id. P 301.
    \3046\ Network Upgrades are ``the additions, modifications, and
upgrades to the Transmission Provider's Transmission System required
at or beyond the point at which the Interconnection Facilities
connect to the Transmission Provider's Transmission System to
accommodate the interconnection of the Large Generating Facility to
the Transmission Provider's Transmission System.'' Pro forma LGIP
section 1 (Definitions).
---------------------------------------------------------------------------

    1602. Accordingly, the cost allocation concerns raised by several
commenters in response to the NOPR proposal are now unfounded.\3047\
Regarding MISO's concern that some alternative transmission
technologies may shift the burden of system impacts to other

parties,\3048\ we find that the possibility of this burden shifting is
minimal because the revised pro forma LGIP, as adopted in this final
rule, requires transmission providers to evaluate the enumerated
alternative transmission technologies on a cluster-wide basis for
feasibility, cost, and time savings. We recognize that, after the
transmission provider evaluates the enumerated alternative transmission
technologies, the transmission provider, in its sole discretion, may
still decide to remedy an identified reliability problem with a
traditional network upgrade.
---------------------------------------------------------------------------

    \3047\ AEP Initial Comments at 52-53; Ameren Initial Comments at
32; NextEra Initial Comments at 38; and Tri-State Initial Comments
at 23.
    \3048\ MISO Initial Comments at 122.
---------------------------------------------------------------------------

    1603. Regarding cost treatment for the enumerated alternative
transmission technologies in the pro forma SGIP, the Commission did not
propose to require, and this final rule does not adopt, cluster studies
for small generator interconnection requests. Accordingly, the study
process for small generating facilities in the pro forma SGIP remains a
serial process and costs for evaluating the enumerated alternative
transmission technologies must be allocated to the small generator
interconnection request being studied. Likewise, the costs for any
implemented enumerated alternative transmission technologies must be
allocated to a small generator interconnection customer consistent with
the allocation of any other network upgrade costs in the small
generator interconnection process.
    1604. As explained in section III.A.3 of this final rule, we are
not requiring transmission providers to allocate study costs on a pro
rata basis, as Fervo Energy requests. Because this final rule does not
adopt the NOPR proposal for interconnection customers to request the
study of particular technologies, we need not address the arguments
raised by NARUC and Indicated PJM TOs related to the study costs
associated with that unadopted proposal.
    1605. The Commission sought comment on whether transmission
providers should be required to evaluate whether alternative
transmission technologies can be deployed on a temporary basis to
provide provisional interconnection service. We are not persuaded by
arguments in favor of such a requirement. While we acknowledge
commenters' arguments that alternative transmission technologies could
serve as a temporary solution to reduce the overall costs and delays of
generator interconnection, we agree with MISO that mandatory evaluation
of alternative transmission technologies for provisional
interconnection service could hinder ensuring that interconnection
customers are able to interconnect in a reliable, efficient,
transparent, and timely manner by adding burden and delay.\3049\
---------------------------------------------------------------------------

    \3049\ MISO Initial Comments at 124.
---------------------------------------------------------------------------

    1606. The Commission also sought comment on whether alternative
transmission technologies as supplements for, or in the place of,
traditional network upgrades was sufficient to guarantee a level of
service to accommodate an interconnection customer seeking NRIS, or
whether such a network upgrade could only relate to ERIS.\3050\ We
agree with commenters that the enumerated alternative transmission
technologies may enable NRIS, but such a determination will be
dependent on the analysis by the particular transmission provider and
the particular technology under evaluation. We decline to adopt Clean
Energy Association's proposal that transmission providers be required
to post additional information beyond the explanation of the results of
the evaluation of each alternative transmission technology. As
discussed above, transmission providers must include, in the applicable
study report, an explanation of the results of the evaluation of the
enumerated alternative transmission technologies for feasibility, cost,
and time savings.
---------------------------------------------------------------------------

    \3050\ NOPR, 179 FERC ] 61,194 at P 301.
---------------------------------------------------------------------------

    1607. We find that the following commenters' proposals are outside
the scope of this proceeding and, therefore, we do not address the
substance: (1) requiring transmission providers to consider alternative
transmission technologies in market operations at the request of the
interconnection customer; \3051\ (2) adding language to the pro forma
LGIA that would allow interconnection facilities to convert to
distribution or regional transmission facilities; \3052\ and (3)
requiring transmission providers to study and implement advanced
transmission technologies when network upgrades are needed but cannot
be completed within three years of being identified.\3053\
---------------------------------------------------------------------------

    \3051\ EDF Renewables Initial Comments at 14-15.
    \3052\ Enel Initial Comments at 80-81.
    \3053\ [Oslash]rsted Reply Comments at 8.
---------------------------------------------------------------------------

    1608. Because we adopt a requirement for transmission providers to
evaluate the enumerated alternative transmission technologies, rather
than at the request of the interconnection customer, we do not address
comments regarding the following issues, which become moot by this
modification to the NOPR proposal: the timing of submission of the
alternative transmission technology evaluation request; \3054\ the
burden of proof for a submission of an alternative transmission
technology evaluation request; \3055\ whether there should be a limit
on alternative transmission technology evaluation requests; \3056\
whether transmission providers and transmission owners should be able
to reject alternative transmission technology evaluation requests;
\3057\ whether an interconnection customer can request evaluation of an
alternative transmission technology not on the required list; \3058\
and whether transmission providers need to perform a separate study for
each requested alternative transmission technology.\3059\
---------------------------------------------------------------------------

    \3054\ Enel Initial Comments at 79; Invenergy Initial Comments
at 55; see also EDF Renewables Initial Comments at 14-15; Fervo
Energy Reply Comments at 9.
    \3055\ AECI Initial Comments at 9; NARUC Initial Comments at 40;
ISO-NE Initial Comments at 41; NESCOE Reply Comments at 21.
    \3056\ EEI Initial Comments at 21.
    \3057\ Indicated PJM TOs Reply Comments at 17.
    \3058\ National Grid Initial Comments at 42.
    \3059\ NARUC Initial Comments at 40.
---------------------------------------------------------------------------

    1609. We do not find compelling commenters' request that the
Commission not require the evaluation of alternative transmission
technologies while other proceedings concerning grid enhancing
technologies are pending.\3060\ The Commission proposed and received
extensive comment on evaluation of alternative transmission
technologies in the interconnection process. Based on the record, we
find that it is appropriate for the Commission to adopt a modified NOPR
proposal to require transmission providers to evaluate the required
list of enumerated alternative transmission technologies.
---------------------------------------------------------------------------

    \3060\ EEI Initial Comments at 20; see also Ameren Initial
Comments at 30.
---------------------------------------------------------------------------

b. Annual Informational Report
i. NOPR Proposal
    1610. In the NOPR, in order to add transparency to the evaluation
process and deployment of alternative transmission technologies in
generator interconnection processes, the Commission proposed to revise
the pro forma LGIP and pro forma SGIP to require transmission providers
to submit an annual informational report to the Commission that details
whether, and if so how, advanced power flow control, transmission
switching, dynamic line ratings, static synchronous compensators, and
static VAR compensators were considered in interconnection requests
over the last year.\3061\ The Commission proposed to create a new
docket to collect all annual informational report filings, and proposed
that any informational reports that transmission providers file at the
Commission would be for informational

purposes and would neither be formally noticed nor require additional
action by the Commission. The Commission sought comment on: (1) whether
to require transmission providers to explain why an alternative
transmission technology that was considered was not deployed; and (2)
the scope of the annual informational report, and whether additional
information should be included.
---------------------------------------------------------------------------

    \3061\ NOPR, 179 FERC ] 61,194 at P 302.
---------------------------------------------------------------------------

ii. Comments
(a) Comments in Support
    1611. A broad group of commenters support the NOPR proposal.\3062\
Many commenters agree that the reports would be beneficial to
interconnection customers because they would provide insight as to why
alternative transmission technologies were or were not deployed.\3063\
Some commenters contend that the annual informational report will allow
interconnection customers to better tailor their requests to consider
alternative transmission technologies, such that those requests are
most likely to be successful.\3064\ Similarly, commenters argue that
the annual informational reports would allow sharing of best practices
in the industry on the use of these technologies and their evaluation,
and would lessen concerns over the potential risks of new technologies
by socializing examples of their consideration and
implementation.\3065\ ELCON and Fervo Energy assert that the annual
informational reports will provide interconnection customers with
additional information to ascertain the feasibility of certain
configurations and interconnection points.\3066\
---------------------------------------------------------------------------

    \3062\ APPA-LPPC Initial Comments at 32; Clean Energy Buyers
Initial Comments at 5; ELCON Initial Comments at 8; Enel Initial
Comments at 81; Eversource Initial Comments at 37-38; CTC Global
Initial Comments at 13; NARUC Initial Comments at 41; Pine Gate
Initial Comments at 59; Public Interest Organizations Initial
Comments at 55; SEIA Initial Comments at 41; WATT Coalition Initial
Comments at 3.
    \3063\ NARUC Initial Comments at 41; Pine Gate Initial Comments
at 59.
    \3064\ Pine Gate Initial Comments at 59.
    \3065\ CTC Global Initial Comments at 13; Eversource Initial
Comments at 37-38.
    \3066\ ELCON Initial Comments at 8; Fervo Energy Reply Comments
at 9-10.
---------------------------------------------------------------------------

    1612. Additionally, Enel states that transmission providers can be
resistant to using advanced transmission technologies, and the annual
informational report will allow the Commission to evaluate whether a
transmission provider is artificially restricting the use of advanced
transmission technologies, similar to the study completion metrics
required by the Commission in Order No. 845.\3067\ Some commenters
argue that if the Commission observes that transmission providers are
routinely citing certain technical or other reasons for not deploying
certain technologies, the annual informational report will provide a
record from which it can initiate action in a separate proceeding to
remedy the issue.\3068\
---------------------------------------------------------------------------

    \3067\ Enel Initial Comments at 81.
    \3068\ CTC Global Initial Comments at 13; Pine Gate Initial
Comments at 59.
---------------------------------------------------------------------------

    1613. Several commenters argue in support of the annual
informational report to promote transparency between market
participants, interconnection customers, and regulators.\3069\ Lastly,
commenters argue that the additional work and obligation for the annual
informational report would be an effective use of limited resources to
benefit the efficiency, transparency, and modernization of the
interconnection process.\3070\
---------------------------------------------------------------------------

    \3069\ Eversource Initial Comments at 37-38; NARUC Initial
Comments at 41.
    \3070\ Enel Initial Comments at 81; Eversource Initial Comments
at 37-38.
---------------------------------------------------------------------------

(b) Comments in Opposition
    1614. Some commenters oppose the proposal on the basis that it
would be too burdensome.\3071\ Xcel Energy does not believe annual
informational reports are necessary and requests that any informational
reporting requirements be limited to decrease the burden on the
engineers that need to focus on performing the interconnection
studies.\3072\ PacifiCorp states that imposing an additional reporting
obligation on transmission providers would not only be duplicative, but
it would add to an already significant list of administrative tasks
that transmission providers must undertake to comply with existing, and
proposed, interconnection obligations, without clear benefit.\3073\
NYTOs believe that preparing and submitting an annual informational
report with detailed analysis of the consideration of alternative
transmission technologies would require dedicated resources on the part
of the transmission provider.\3074\ MISO asserts that the annual
informational report at this time may not be useful, especially in the
already transparent RTO/ISO context, and could divert scarce staff
resources from the work of moving forward in the study and agreements
process for implementing much-needed new generation.\3075\ Similarly,
Indicated PJM TOs state that PJM currently maintains a publicly
available website that details all the types of network upgrades
necessary to support interconnections, including the types of devices
identified here by the Commission.\3076\ CAISO also opposes the
proposal because CAISO believes that it is contrary to the goal of
reducing interconnection queue backlogs by adding more studies and
reporting requirements onto transmission provider staff.\3077\
---------------------------------------------------------------------------

    \3071\ Ameren Initial Comments at 33; CAISO Initial Comments at
39; MISO Initial Comments at 125; NYTOs Initial Comments at 33;
PacifiCorp Initial Comments at 44; Xcel Initial Comments at 48.
    \3072\ Xcel Initial Comments at 48.
    \3073\ PacifiCorp Initial Comments at 44.
    \3074\ NYTOs Initial Comments at 33.
    \3075\ MISO Initial Comments at 125; MISO Reply Comments at 18.
    \3076\ Indicated PJM TOs Initial Comments at 57-58.
    \3077\ CAISO Initial Comments at 38.
---------------------------------------------------------------------------

    1615. Idaho Power believes that the report may simply result in
more disputes over why one entity allows a particular technology, while
another one does not.\3078\
---------------------------------------------------------------------------

    \3078\ Idaho Power Initial Comments at 16.
---------------------------------------------------------------------------

    1616. CAISO and MISO also argue that there is limited value to
interconnection reports.\3079\ CAISO argues that in this NOPR, the
Commission recognizes that imposing reporting requirements in Order No.
845 failed to incentivize transmission providers to meet their study
obligations, and thus the Commission should not repeat that mistake
here by burdening transmission provider staff with yet another
reporting requirement.\3080\ Similarly, MISO points out that neither
the Commission nor any commenter used the interconnection queue reports
required by Order No. 845 to discuss the topic of study delays.\3081\
---------------------------------------------------------------------------

    \3079\ CAISO Initial Comments at 39; MISO Reply Comments at 18-
19.
    \3080\ CAISO Initial Comments at 39.
    \3081\ MISO Reply Comments at 18-19.
---------------------------------------------------------------------------

(c) Comments on Specific Proposal
    1617. Several commenters emphasize the importance of transparency
when an alternative transmission technology is not selected.\3082\
ENGIE asks the Commission to require transmission providers to provide
publicly available information addressing why or why not an alternative
transmission technology was adopted or rejected in a specific
case.\3083\ CTC Global believes that transmission providers should be
required to include explanations regarding the alternative transmission
technologies considered, deployed, or rejected in the annual
reports.\3084\ CTC

Global requests that the Commission also mandate reporting on the
energy efficiency of the components used in various network upgrades
and through the interconnection process.\3085\ Eversource suggests
that, in addition to the five technologies listed in the NOPR,
transmission providers be allowed to provide reporting on any other
grid enhancing technology or alternative transmission technology that
was considered during the prior year.\3086\
---------------------------------------------------------------------------

    \3082\ CTC Global Initial Comments at 14, 17-18; ENGIE Initial
Comments at 13; Eversource Initial Comments at 37-38; Fervo Energy
Initial Comments at 7.
    \3083\ ENGIE Initial Comments at 13.
    \3084\ CTC Global Initial Comments at 17-18.
    \3085\ Id. at 14.
    \3086\ Eversource Initial Comments at 37-38.
---------------------------------------------------------------------------

    1618. In contrast, Ameren argues that, if the Commission imposes
this reporting burden on transmission providers, it should not further
exacerbate the burden by requiring the transmission provider to also
report explanations of common obstacles to the use of these alternative
transmission technologies.\3087\ Instead, Ameren states that the
Commission should encourage interconnection customers and transmission
providers to share with Commission staff through a technical conference
or other forum the types of technologies being considered and whether
adopted. Ameren suggests that this type of information gathering should
be undertaken before the Commission imposes specific reforms or
reporting requirements.
---------------------------------------------------------------------------

    \3087\ Ameren Initial Comments at 33.
---------------------------------------------------------------------------

iii. Commission Determination
    1619. We decline to adopt the NOPR proposal to require transmission
providers to submit an annual informational report to the Commission
that details whether, and if so how, the list of alternative
transmission technologies were considered in interconnection studies
over the last year. We are persuaded by commenters' arguments that the
time and resources required to produce the annual informational report
may hinder the ability to increase the speed of interconnection queue
processing.\3088\ We find that these challenges outweigh the
incremental increased transparency to the evaluation process and
deployment of alternative transmission technologies in generator
interconnection processes, particularly in light of additional
reporting requirements in other parts of this final rule.
---------------------------------------------------------------------------

    \3088\ MISO Initial Comments at 125; MISO Reply Comments at 18;
NYTOs Initial Comments at 33; PacifiCorp Initial Comments at 44;
Xcel Initial Comments at 48.
---------------------------------------------------------------------------

    1620. Specifically, the annual informational report would be
duplicative of the requirement in section 7.3 of the pro forma LGIP and
sections 3.3.6 and 3.4.10 of the pro forma SGIP that we adopt in this
final rule. Under these provisions, transmission providers must explain
how the required alternative transmission technologies were evaluated
for feasibility, cost, and time savings in each pro forma LGIP cluster
study report or pro forma SGIP feasibility study and system impact
study reports. The description of the results of the evaluation
required in these reports should provide transparency into the
evaluation process and deployment of alternative transmission
technologies in generator interconnection processes. In response to
Enel's argument that an annual informational report will allow the
Commission to evaluate if a transmission provider is artificially
restricting the use of alternative transmission technologies, we find
that this concern is adequately addressed through the modified
requirement that transmission providers evaluate all required
alternative transmission technologies by default in all studies and
restudies.
3. Modeling and Ride-Through Requirements for Non-Synchronous
Generating Facilities
a. Modeling Requirements
i. Need for Reform and NOPR Proposal
    1621. In the NOPR, the Commission preliminarily found that the pro
forma LGIP and pro forma SGIP may be unduly discriminatory or
preferential to the extent that they do not require non-synchronous
generating facilities to provide accurate and validated models to
transmission providers during the generator interconnection
process.\3089\ Specifically, the Commission noted that, while
Attachment A to Appendix 1 of the pro forma LGIP and Attachment 2 of
the pro forma SGIP require all generating facilities to submit certain
types of information, the information required is only sufficient to
accurately model the behavior of synchronous generating facilities. The
Commission stated its concern that, without a reform to require
interconnection customers developing non-synchronous generating
facilities \3090\ to provide sufficiently accurate and validated
models, interconnection studies may not identify the appropriate
interconnection facilities and network upgrades, which could lead to
unjust and unreasonable rates for interconnection service.\3091\
---------------------------------------------------------------------------

    \3089\ NOPR, 179 FERC ] 61,194 at P 318.
    \3090\ Non-synchronous generating facilities are ``connected to
the bulk power system through power electronics, but do not produce
power at system frequency (60 Hz).'' They ``do not operate in the
same way as traditional generators and respond differently to
network disturbances.'' Reactive Power Requirements for Non-
Synchronous Generation, Order No. 827, 81 FR 40793 (June 23, 2016),
155 FERC ] 61,277, at P 10 n.24 (2016).
    \3091\ NOPR, 179 FERC ] 61,194 at P 319.
---------------------------------------------------------------------------

    1622. The Commission proposed to revise Attachment A to Appendix 1
of the pro forma LGIP and Attachment 2 of the pro forma SGIP to ensure
that all interconnection customers requesting to interconnect a non-
synchronous generating facility must provide the transmission provider
with the models needed for accurate interconnection studies.\3092\
Pursuant to this proposal, interconnection customers requesting to
interconnect a non-synchronous generating facility would be required to
provide models that contain the details necessary to accurately model
the performance of the generating facility in response to system
disturbances in accordance with the control system settings that would
be used by the interconnection customer during the commissioning and
operation of the generating facility.
---------------------------------------------------------------------------

    \3092\ Id. P 328.
---------------------------------------------------------------------------

    1623. Specifically, the Commission proposed to require each
interconnection customer requesting to interconnect a non-synchronous
generating facility to submit to the transmission provider: (1) a
validated, user-defined root mean square (RMS) positive sequence
dynamic model; (2) an appropriately parameterized, generic library RMS
positive sequence dynamic model, including a model block diagram of the
inverter control system and plant control system, that corresponds to a
model listed in a new table of acceptable models or a model otherwise
approved by WECC; and (3) a validated EMT model, if the transmission
provider performs an EMT study as part of the interconnection study
process.\3093\
---------------------------------------------------------------------------

    \3093\ Id. P 329.
---------------------------------------------------------------------------

    1624. With regard to the validated, user-defined RMS positive
sequence dynamic model, the Commission proposed to define a user-
defined model as any set of programming code created by equipment
manufacturers or developers that captures the latest features of
controllers that are mainly software-based and represents the entities'
control strategies but does not necessarily correspond to any
particular generic library model.\3094\ The Commission explained that
in order for this model to be ``validated,'' it must be confirmed that
the equipment behavior is consistent with the model behavior, and
described how the interconnection customer may make such confirmation.
---------------------------------------------------------------------------

    \3094\ Id. P 330.

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

    1625. With regard to the appropriately parameterized, generic
library RMS positive sequence dynamic model, the Commission proposed a
table of acceptable generic library models based on the current WECC
list of approved dynamic models for renewable energy generating
facilities.\3095\ The Commission noted that WECC's list of approved
dynamic models has also been integrated into NERC reliability
guidelines and that these models represent the current state of the art
with regard to dynamic modeling requirements for non-synchronous
generating facilities.
---------------------------------------------------------------------------

    \3095\ Id. P 331.
---------------------------------------------------------------------------

    1626. The Commission stated that it believed that these models
represent the full spectrum of modeling data that transmission
providers need to perform accurate interconnection studies for non-
synchronous generating facilities.\3096\ The Commission also recognized
that the modeling data proposed to be required from non-synchronous
generating facilities may be more voluminous than that required of
synchronous generating facilities; however, the Commission noted that
this data submission requirement is intended to result in a comparable
level of modeling accuracy among all generating facilities.
---------------------------------------------------------------------------

    \3096\ Id. P 332.
---------------------------------------------------------------------------

    1627. The Commission stated that an interconnection customer's
failure to provide the above information within the deadlines
established in the pro forma LGIP and pro forma SGIP would make the
interconnection request incomplete and would be considered invalid in
accordance with section 3.4.3 of the pro forma LGIP and section 1.3 of
the pro forma SGIP.\3097\ Pursuant to those provisions, if the
interconnection customer does not cure the deficiency within the 10-
business day cure period, the interconnection request will be
considered withdrawn pursuant to section 3.7 of the pro forma LGIP and
section 1.3 of the pro forma SGIP. The Commission also proposed to
require that any proposed modification of the interconnection request
be accompanied by updated models of the proposed generating
facility.\3098\
---------------------------------------------------------------------------

    \3097\ Id. P 333.
    \3098\ Id. P 334.
---------------------------------------------------------------------------

    1628. The Commission sought comment on: (1) whether the proposed
reforms are necessary and/or sufficient to ensure that interconnection
customers proposing non-synchronous generating facilities would submit
models during the generator interconnection process that accurately
reflect the behavior of their proposed generating facility; (2) whether
the inclusion of the table based on NERC guidelines that cite WECC-
approved models is appropriate; and (3) if not, how the Commission
could require interconnection customers to submit models that are
widely known in industry to be accurate without listing specific
models.\3099\
---------------------------------------------------------------------------

    \3099\ Id. P 335.
---------------------------------------------------------------------------

ii. Comments
(a) Comments in Support
    1629. Many commenters support the NOPR proposal.\3100\ SPP states
that it has the highest penetration of IBRs \3101\ of any RTO/ISO, so
it is particularly sensitive to potential harm that could occur if
those resources fail to perform as expected.\3102\ ISO-NE argues that
data issues are one of the largest causes of study delays in its
region, and requiring data accuracy will improve study processing time
and support first-ready, first-served reforms.\3103\ NERC contends that
the existing interconnection process does not provide sufficiently
accurate and validated models for IBRs.\3104\
---------------------------------------------------------------------------

    \3100\ AEP Initial Comments at 54; APPA-LPPC Initial Comments at
33; APS Initial Comments at 24; CAISO Initial Comments at 39; Clean
Energy Associations Initial Comments at 65; EEI Initial Comments at
23; NERC Initial Comments at 9-10; EPRI Initial Comments at 19;
Eversource Initial Comment at 38; ISO-NE Initial Comments at 42;
MISO Initial Comments at 125; MISO TOs Initial Comments at 33; NARUC
Initial Comments at 42; National Grid Initial Comments at 44; North
Carolina Commission and Staff Initial Comments at 27; NRECA Initial
Comments at 48; NYTOs Initial Comments at 33; Ohio Commission
Initial Comments at 17; OMS Initial Comments at 20; PacifiCorp
Initial Comments at 45; PPL Initial Comments at 25; R Street Initial
Comments at 17; SPP Initial Comments at 27; U.S. Chamber of Commerce
Initial Comments at 13.
    \3101\ ``Inverter-based resource'' (IBR) refers to a resource
that is asynchronously connected to the transmission system and is
either completely or partially interfaced with the bulk power system
through power electronics. See Reliability Guideline: BPS-Connected
Inverter-Based Resource Performance, at vii, https://www.nerc.com/comm/RSTC_Reliability_Guidelines/Inverter-Based_Resource_Performance_Guideline.pdf. The term ``non-synchronous
generating facilities'' refers to the same resources.
    \3102\ SPP Initial Comments at 27.
    \3103\ ISO-NE Initial Comments at 42.
    \3104\ NERC Initial Comments at 18.
---------------------------------------------------------------------------

(b) Comments in Opposition
    1630. Several commenters oppose the NOPR proposal in its
entirety,\3105\ while additional commenters express concerns about
specific aspects. Pine Gate asserts that the Commission should not
incorporate requirements into the pro forma LGIP and pro forma SGIP
that are already being addressed by NERC through the standards
development process.\3106\ Pine Gate states that the pro forma LGIA and
pro forma SGIA require interconnection customers to remain compliant
with the applicable reliability standards, and recommends that the
Commission address these modeling and performance reforms under the
generic statement regarding compliance with applicable NERC Reliability
Standards or by adding a similar statement in each applicable section
of article 9 in the pro forma LGIA.\3107\
---------------------------------------------------------------------------

    \3105\ ENGIE Initial Comment at 13-14; NYISO Initial Comments at
53-54; Pine Gate Initial Comments at 60-61; SEIA Initial Comments at
41.
    \3106\ Pine Gate Initial Comments at 60.
    \3107\ Id. at 60-61 (citing pro forma LGIA art. 9.1).
---------------------------------------------------------------------------

    1631. NYISO argues that the final rule should not include a
modeling requirement because it would be inefficient and necessitate a
rebuild of NYISO's study base case.\3108\ NYISO explains that, if the
NOPR proposal is adopted, its interconnection study analysis would take
much longer to ensure accurate results, significantly slowing the
interconnection process.
---------------------------------------------------------------------------

    \3108\ NYISO Initial Comments at 53-54.
---------------------------------------------------------------------------

    1632. ENGIE argues that the required models in the NOPR proposal
are very detailed, there are few consultants that perform this
modeling, and the value obtained is low because the study likely will
become outdated as project components are substituted for more advanced
technologies. ENGIE recommends requiring a power flow and dynamic
model, which it contends provides sufficient information on reliability
impacts.\3109\
---------------------------------------------------------------------------

    \3109\ ENGIE Initial Comments at 13-14.
---------------------------------------------------------------------------

(c) Comments on Specific Proposal
(1) Cure Period for Modeling Information
    1633. AES asserts that a 10-day cure period for interconnection
customers to correct or provide additional information on models for
non-synchronous generating facilities is not adequate and that no less
than a 20 business-day cure period is needed.\3110\
---------------------------------------------------------------------------

    \3110\ AES Initial Comments at 25-26.
---------------------------------------------------------------------------

(2) Transmission Provider Requirements
    1634. SEIA requests that the Commission modify the NOPR proposal to
require transmission providers to make available to interconnection
customers the necessary system data needed to create accurate models,
provide clear modeling requirements and validation guidelines and
procedures,\3111\ and engage stakeholders before making any modeling
changes.
---------------------------------------------------------------------------

    \3111\ SEIA Initial Comments at 42-43 (citing, e.g., CAISO,
Electromagnetic Transient Modeling Requirements (Apr. 14, 2021),
http://www.caiso.com/Documents/CaliforniaISOElectromagneticTransientModelingRequirements.pdf.).

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

(3) Models Not Available Early in Interconnection Study Process
    1635. Multiple commenters argue that accurate models for non-
synchronous generating facilities may not be available early in the
interconnection study process and may need to be updated during the
process.\3112\ Pine Gate and Public Interest Organizations assert that
the Commission should revise the NOPR proposal to allow for later
submission of such models to reduce the administrative burden on
transmission providers and interconnection customers.\3113\
---------------------------------------------------------------------------

    \3112\ Alliant Energy Initial Comments at 10-11; Clean Energy
Associations Initial Comments at 66; EPRI Initial Comments at 17-18;
NextEra Initial Comments at 40; [Oslash]rsted Initial Comments at
17; Pine Gate Initial Comments at 61; PPL Initial Comments at 25;
Public Interest Organizations Reply Comments at 13; SEIA Initial
Comments at 42.
    \3113\ Pine Gate Initial Comments at 61; Public Interest
Organizations Reply Comments at 13.
---------------------------------------------------------------------------

    1636. SEIA requests that the Commission modify the NOPR proposal to
require interconnection customers to provide all operating models
within one year before the commercial operation date of the generating
facility, so that the models reflect the most accurate operating
information.\3114\ Clean Energy Associations assert that models
requested very early in the interconnection study process, before
product feature details have been finalized, may need to be updated
prior to commercial operation, and argue that minor model changes
should not result in excessive triggering of material modification
rules.\3115\
---------------------------------------------------------------------------

    \3114\ SEIA Initial Comments at 42.
    \3115\ Clean Energy Associations Initial Comments at 66.
---------------------------------------------------------------------------

    1637. Alliant Energy and PPL state that technical information
provided at the time an interconnection request is submitted can become
outdated during the interconnection study process,\3116\ and Alliant
Energy asserts that the Commission should therefore provide for
flexibility as to when and how required information for modeling
requirements is provided.\3117\ [Oslash]rsted argues that offshore wind
interconnection customers may not be able to provide a validated model
at the time of the interconnection request due to long lead times in
generating facility development and equipment that is still being
developed.\3118\
---------------------------------------------------------------------------

    \3116\ Alliant Energy Initial Comments at 10-11; PPL Initial
Comments at 25.
    \3117\ Alliant Energy Initial Comments at 10-11.
    \3118\ [Oslash]rsted Initial Comments at 17.
---------------------------------------------------------------------------

    1638. EPRI suggests that an alternative approach to the NOPR
proposal is to require the use of models that generally conform to the
capability and performance standards Institute of Electrical and
Electronics Engineers (IEEE) Standard 2800-022 and IEEE Standard 1547-
2018 during the interconnection study process, and notes that such
studies are subject to further assessment once a detailed, site-
specific model is available.\3119\
---------------------------------------------------------------------------

    \3119\ EPRI Initial Comments at 18.
---------------------------------------------------------------------------

(4) RMS Models
    1639. Several commenters request modifications to the proposed
requirements for RMS models.\3120\ Tesla and SEIA argue that the
Commission should require transmission providers to accept user-defined
library RMS positive sequence dynamics models, as these models better
reflect the actual technology intended to be used by the resource,
results in a much greater degree of modeling accuracy, and can help
support greater penetration of renewable resources.\3121\ In addition,
Tesla suggests that the Commission seek informational submissions from
transmission providers regarding software tools and resources needed to
integrate more accurate user-defined RMS modeling. Clean Energy
Associations argue that the transmission provider should have
discretion to require a user-defined RMS model, a generic library RMS
model (with site-specific parameterization), or both, instead of always
being required to collect both.\3122\ MISO encourages the Commission to
require that the user-defined model be compatible with the transmission
provider's software.\3123\ Further, MISO requests that the Commission
confirm that the user-defined model meets the transmission provider's
MOD-032-1 requirements. Longroad Energy recommends that the Commission
require NERC to improve the degree to which power flow software vendors
allow accurate modeling of IBR technology before the Commission
establishes modeling standards that might stifle technological
improvements.\3124\
---------------------------------------------------------------------------

    \3120\ Clean Energy Associations Initial Comments at 65-66;
Eversource Initial Comments at 39; ISO-NE Initial Comments at 42-43;
MISO Initial Comments at 125; SEIA Initial Comments at 43; Tesla
Initial Comments at 11.
    \3121\ SEIA Initial Comments at 43; Tesla Initial Comments at
11.
    \3122\ Clean Energy Associations Initial Comments at 65-66.
    \3123\ MISO Initial Comments at 125.
    \3124\ Longroad Energy Reply Comments at 20.
---------------------------------------------------------------------------

    1640. Other commenters express concern with the difficulties of
user-defined models.\3125\ Eversource requests that the Commission
specify that all positive sequence models provided must be non-
proprietary and accessible to neighboring utilities, system operators,
and other entities that need to access them.\3126\ ISO-NE asserts that
it does not accept user-defined models under its interconnection study
procedures and requests that the final rule allow for a process where
accurate, working, non-proprietary models are provided and screened in
advance of the study process.\3127\
---------------------------------------------------------------------------

    \3125\ Eversource Initial Comments at 39; ISO-NE Initial
Comments at 42.
    \3126\ Eversource Initial Comments at 39.
    \3127\ ISO-NE Initial Comments at 43.
---------------------------------------------------------------------------

(5) Model Validation
    1641. Some commenters argue that the Commission should provide
further direction regarding model validation requirements for non-
synchronous generating facilities.\3128\ NERC and SDG&E argue that
reliability assessments indicate that model validation with actual
installed equipment and a ``true-up'' of generator interconnection
modeling would help ensure proper analysis and studies prior to
commissioning.\3129\ NERC recommends that the Commission enhance the
interconnection process by ensuring more rigorous plant commissioning,
with both the interconnection customer and the transmission provider
signing off on models used in studies as compared with actual installed
equipment.\3130\ In addition, NERC asks the Commission to require
transmission providers to conduct quality review of models before study
and require interconnection customers to satisfy quality review
milestones.\3131\
---------------------------------------------------------------------------

    \3128\ Clean Energy Associations Initial Comments at 66-67; NERC
Initial Comments at 18-20; EPRI Initial Comments at 14-15;
[Oslash]rsted Initial Comments at 16, 18; SDG&E Reply Comments at 3;
Tesla Initial Comments at 10.
    \3129\ NERC Initial Comments at 18; SDG&E Reply Comments at 3.
    \3130\ NERC Initial Comments at 18.
    \3131\ Id. at 20.
---------------------------------------------------------------------------

    1642. Tesla argues that, in lieu of multiple attestations or test
data, the Commission should develop an approach to validation that
requires interconnection customers to submit ``model-to-model'' and
``product-to-model'' benchmarking data for non-synchronous generating
facilities.\3132\
---------------------------------------------------------------------------

    \3132\ Tesla Initial Comments at 10.
---------------------------------------------------------------------------

    1643. Clean Energy Associations assert that the Commission should
add language that provides that the attestation required for model
validation be the best available by the original equipment manufacturer
at the time of model delivery.\3133\ In addition, Clean Energy
Associations and [Oslash]rsted argue that the Commission should define
the

phrase ``accurate and validated models.'' \3134\ Clean Energy
Associations explain that it is common practice to submit an
interconnection request with advanced, next-generation equipment that
the manufacturer may still be developing, in which case the product and
validated models may not be available at the time of the
interconnection request, and request that the Commission allow
transmission providers flexibility to accommodate such new equipment in
their interconnection studies.\3135\
---------------------------------------------------------------------------

    \3133\ Clean Energy Associations Initial Comments at 66.
    \3134\ Id.; [Oslash]rsted Initial Comments at 16, 18.
    \3135\ Clean Energy Associations Initial Comments at 67.
---------------------------------------------------------------------------

    1644. Clean Energy Associations and [Oslash]rsted assert that, if
accurate and validated models require a comparison with unit level
factory tests, then this may not be feasible for offshore wind farms,
especially if they are connecting with HVDC transmission
technology.\3136\ They explain that these types of configurations are
often project-specific and do not have a definition of a ``validated
model.'' [Oslash]rsted also requests that the Commission explain why a
``model block diagram of the inverter control system and plant control
system'' is necessary given the availability of WECC model block
diagrams in simulation tools.\3137\
---------------------------------------------------------------------------

    \3136\ Id. at 66-67; [Oslash]rsted Initial Comments at 16-17.
    \3137\ [Oslash]rsted Initial Comments at 18.
---------------------------------------------------------------------------

    1645. EPRI argues that the Commission should modify the language in
the pro forma LGIA and pro forma SGIA to ensure that all models are
validated and appropriately parameterized.\3138\ EPRI contends that the
NOPR proposal fails to provide adequate directions and requirements
with respect to model validation, testing, verification, and conformity
assessment, as required during various stages of the interconnection
process. EPRI asserts that a ``validated'' plant model would not be
available during the interconnection study stage because validation of
the plant model is not possible--within reasonable efforts--until after
the commissioning and commercial operation of the generating facility.
EPRI states that alternatives to this would be requiring generic models
that are appropriately parametrized and conform to IEEE Standard 2800-
2022 requirements.
---------------------------------------------------------------------------

    \3138\ EPRI Initial Comments at 14-15.
---------------------------------------------------------------------------

(6) Table of Acceptable RMS Models
    1646. Several commenters agree that a table of acceptable RMS
models based on NERC guidelines that cite WECC-approved models is
appropriate.\3139\ Ameren asserts that the Commission should provide a
table based on NERC guidelines that cite WECC-approved models as one
but not the only example.\3140\ Shell agrees that a table based on NERC
guidelines is appropriate as long as the functionality and proprietary
controls are adequately reflected (e.g., mimic the actual inverter
performance of manufacturers' models).\3141\ Shell explains that a
generic model may not be able to support the operational
characteristics of inverters. SPP states that, in its experience, some
manufacturers do not support WECC-approved generic dynamics models and
that having Commission support for more specific, detailed, and vetted
modeling information requirements will be helpful to improve data
quality and access.\3142\
---------------------------------------------------------------------------

    \3139\ Ameren Initial Comments at 34; Bonneville Initial
Comments at 24; Shell Initial Comments, app. A, at vi; Tri-State
Initial Comments at 24.
    \3140\ Ameren Initial Comments at 34.
    \3141\ Shell Initial Comments, app. A, at vi.
    \3142\ SPP Initial Comments at 28.
---------------------------------------------------------------------------

    1647. R Street and EPRI offer alternatives to a table based on NERC
guidelines that cite WECC-approved models.\3143\ R Street argues that
providing a list of models in the final rule is not prudent given the
dynamic nature of the table, and that the list should instead be posted
on relevant public industry websites, including those of NERC.\3144\
EPRI states that one alternative could be to include a reference and
hyperlink to the NERC and WECC-approved models lists.\3145\ EPRI also
suggests that if the Commission retains the table, it should consider
revising the description of the DER_A model to add the word
``aggregated'' to the description and also consider adding columns with
the model names from other applicable software tools.
---------------------------------------------------------------------------

    \3143\ EPRI Initial Comments at 20; R Street Initial Comments at
17.
    \3144\ R Street Initial Comments at 17.
    \3145\ EPRI Initial Comments at 20.
---------------------------------------------------------------------------

(7) EMT Modeling
    1648. NERC and EPRI support the EMT modeling proposal in the
NOPR.\3146\ NERC recommends that all non-synchronous generating
facilities perform EMT models prior to interconnection for
consideration by transmission operators and planners.\3147\ NERC
contends that event analysis underscores the value of EMT studies in
helping manage reliability risks of the modern transmission system.
---------------------------------------------------------------------------

    \3146\ Id. at 15, 19; NERC Initial Comments at 21.
    \3147\ NERC Initial Comments at 21.
---------------------------------------------------------------------------

    1649. EPRI agrees that performing EMT studies should be at the
discretion of the transmission provider.\3148\ However, EPRI recommends
collecting validated and appropriately parametrized EMT models during
the interconnection process regardless of whether the transmission
provider performs an EMT study because an EMT study may become
necessary in the future, and the interconnection stage is the best time
to obtain models due to the close coordination between interconnection
customers, consultants, equipment manufacturers, and generating
facility designers. EPRI also suggests that an industry-accepted
generic EMT model could be required in lieu of a validated EMT
model.\3149\
---------------------------------------------------------------------------

    \3148\ EPRI Initial Comments at 19.
    \3149\ Id. at 15.
---------------------------------------------------------------------------

    1650. Clean Energy Associations argue that the Commission should
require submission of an EMT model one year before the scheduled
commercial operation date of the non-synchronous generating facility if
the transmission provider performs an EMT study as part of the
interconnection study process.\3150\ Clean Energy Associations assert
that, if the Commission moves forward with a requirement for
interconnection customers to provide EMT models, it should require the
transmission provider and its consultants to protect these models with
the highest degree of confidentiality because these models contain
proprietary and highly commercially sensitive material that could pose
a reliability risk if obtained by malicious actors.
---------------------------------------------------------------------------

    \3150\ Clean Energy Associations Initial Comments at 68-70.
---------------------------------------------------------------------------

    1651. Several commenters oppose the EMT modeling proposal.\3151\
AES contends that EMT modeling is not yet used widely in the industry
and thus should not be adopted as a minimum standard.\3152\
---------------------------------------------------------------------------

    \3151\ AES Initial Comments at 26; Bonneville Initial Comments
at 24; Invenergy Initial Comments at 57-58; Longroad Energy Reply
Comments at 21; SEIA Initial Comments at 41-42.
    \3152\ AES Initial Comments at 26.
---------------------------------------------------------------------------

    1652. Longroad Energy argues that EMT studies are more expensive
than transient stability studies, require highly specialized
engineering experience to perform, and are limited to modeling a
fraction of a transmission provider's transmission system.\3153\
Longroad Energy asserts that the Commission should continue to allow
transmission providers the discretion to determine where such studies
will meaningfully

impact the interconnection requirements for an interconnection request.
Further, Longroad Energy asserts that the Commission should require
transmission providers to publish studies demonstrating the need for
EMT studies to prevent unnecessarily imposing a costly, time-consuming
step in the interconnection study process.
---------------------------------------------------------------------------

    \3153\ Longroad Energy Reply Comments at 21.
---------------------------------------------------------------------------

    1653. SEIA asserts that EMT models are not yet industry standard
models, require significant processing power compared to RMS models,
and are not necessarily more accurate than RMS models.\3154\ Bonneville
asserts that it has found that EMT modeling studies are rarely
necessary, and therefore any requirement to provide EMT models or
studies should be left to the transmission provider's discretion.\3155\
---------------------------------------------------------------------------

    \3154\ SEIA Initial Comments at 41-42 (citing Summary of the
Joint Generator Interconnection Workshop, at 28 (Aug. 9-11, 2022),
https://www.esig.energy/wp-content/uploads/2022/10/Joint-Generator-Workshop-Summary-1.pdf (Generator Interconnection Workshop
Summary)).
    \3155\ Bonneville Initial Comments at 24.
---------------------------------------------------------------------------

(d) Requests for Clarification
    1654. Invenergy requests that the Commission clarify that, if a
validated EMT model is unavailable at the time of submission of an
interconnection request: (1) whether the interconnection request may
proceed and provide a generic EMT model, if available; and (2) if a
validated EMT model is determined to be necessary, whether the
interconnection customer may submit this information by the time of
cluster restudy, or as soon thereafter as it becomes available from the
manufacturer.\3156\
---------------------------------------------------------------------------

    \3156\ Invenergy Initial Comments at 58.
---------------------------------------------------------------------------

    1655. APS requests clarity from the Commission on the process for
curing deficiencies with respect to information provided by the
interconnection customer, such as the number of times an
interconnection customer is allowed to provide inaccurate data and cure
deficiencies, before an interconnection request is deemed
withdrawn.\3157\
---------------------------------------------------------------------------

    \3157\ APS Initial Comments at 24.
---------------------------------------------------------------------------

(e) Miscellaneous
    1656. ClearPath asserts that the Commission should consider how the
NOPR proposal will align with technological advancements and supply
chain challenges.\3158\ ClearPath explains that the average
interconnection queue wait time is 3.7 years, which may present
opportunities for interconnection customers to adopt newer, more
advanced equipment after they enter the interconnection queue.
ClearPath further explains that supply chain challenges may force an
interconnection customer to change equipment procurement unexpectedly
while in the interconnection queue, and requests that the Commission
explain whether a change in equipment that necessitates submitting new
models and data is considered a material modification.
---------------------------------------------------------------------------

    \3158\ ClearPath Initial Comments at 10.
---------------------------------------------------------------------------

    1657. Consumers Energy notes that NERC is currently in the
interconnection data gathering process, potentially making inclusion of
additional requirements within the rulemaking duplicative and
recommends consistency between NERC and Commission interconnection
improvement efforts.\3159\
---------------------------------------------------------------------------

    \3159\ Consumers Energy Initial Comments at 9.
---------------------------------------------------------------------------

    1658. EPRI states that the NOPR proposal does not specify
information and data that the transmission providers may need to
provide to the interconnection customer during the design stage (e.g.,
acceptable voltage ranges, protection details, short circuit levels,
etc.).\3160\ EPRI asserts that the final rule could consider the list
of data from Annex H of IEEE 2800-2022, which includes definitions that
could help define the combined generating and storage service level MW
of a generating facility referred to in the NOPR proposal, including
the continuous rating, continuous absorption rating, and short-term
rating for IBRs.
---------------------------------------------------------------------------

    \3160\ EPRI Initial Comments at 22.
---------------------------------------------------------------------------

iii. Commission Determination
    1659. We adopt the NOPR proposal to revise Attachment A to Appendix
1 of the pro forma LGIP and Attachment 2 of the pro forma SGIP to
require each interconnection customer requesting to interconnect a non-
synchronous generating facility to submit to the transmission provider:
(1) a validated user-defined RMS positive sequence dynamic model; (2)
an appropriately parameterized generic library RMS positive sequence
dynamic model, including a model block diagram of the inverter control
system and plant control system, that corresponds to a model listed in
a new table of acceptable models or a model otherwise approved by WECC;
and (3) a validated EMT model, if the transmission provider performs an
EMT study as part of the interconnection study process.
    1660. We also adopt the NOPR proposals to: (1) define a user-
defined model as any set of programming code created by equipment
manufacturers or developers that captures the latest features of
controllers that are mainly software-based and represent the entities'
control strategies but does not necessarily correspond to any
particular generic library model, as contained in Attachment A to
Appendix 1 of the pro forma LGIP and Attachment 2 of the pro forma
SGIP; (2) revise Attachment A to Appendix 1 of the pro forma LGIP and
Attachment 2 of the pro forma SGIP to add a table of acceptable generic
library models, based on the current WECC list of approved dynamic
models for renewable energy generating facilities; and (3) revise
section 4.4.4 of the pro forma LGIP and section 1.4 of the pro forma
SGIP to require that any proposed modification of the interconnection
request be accompanied by updated models of the proposed generating
facility.
    1661. Based on the record before us, we affirm the Commission's
preliminary finding in the NOPR that the pro forma LGIP and pro forma
SGIP are unduly discriminatory or preferential because they do not
require non-synchronous generating facilities to provide accurate and
validated models to transmission providers during the generator
interconnection process that provide a comparable degree of accuracy as
the models required of a synchronous generator. The current pro forma
LGIP and pro forma SGIP provisions ensure that synchronous generating
facilities are required to provide accurate, validated models to
transmission providers during the generator interconnection process.
However, the current pro forma LGIP and pro forma SGIP provisions are
insufficient to ensure that non-synchronous generating facilities
submit models with a comparable level of accuracy.
    1662. Additionally, we find that the lack of a requirement for non-
synchronous generating facilities to provide accurate and validated
models to transmission providers in the pro forma LGIP and pro forma
SGIP results in unjust and unreasonable rates. Accurate and validated
models are necessary to minimize study delays and to ensure that
transmission providers conduct accurate interconnection studies that
identify the necessary interconnection facilities and network upgrades
to accommodate the interconnection request. Data issues are commonly
cited as a major source of study delays, which contributes to
interconnection queue backlogs.\3161\ As described above,
interconnection queue backlogs create uncertainty in the timing and
cost of interconnecting to the transmission system and hinders the
timely development of new generation.

Moreover, without accurate models, transmission providers cannot
conduct accurate interconnection studies that identify the appropriate
interconnection facilities and network upgrades, leading to the
inaccurate assignment of interconnection costs and resulting in
Commission-jurisdictional rates that are unjust and unreasonable.\3162\
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    \3161\ See, e.g., ISO-NE Initial Comments at 42.
    \3162\ NARUC Initial Comments at 42; see also EEI Initial
Comments at 23 (explaining that this requirement will improve
transmission provider's ability to identify appropriate
interconnection facilities and network upgrades for non-synchronous
generating facilities); MISO TOs Initial Comments at 33 (stating
that the current lack of accurate modeling means that transmission
providers are unable to fully assess their ability to respond to
system disturbances).
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    1663. Furthermore, many commenters agree that this reform will help
prevent potential reliability concerns if non-synchronous generating
facilities do not perform when in service as modeled during the
interconnection process.\3163\ For example, additional modeling
requirements will significantly improve the accuracy of both
interconnection and reliability studies as well as address concerns
regarding non-synchronous generation disturbance events.\3164\
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    \3163\ APS Initial Comments at 24; CAISO Initial Comments at 39-
40; Clean Energy Associations Initial Comments at 65; NERC Initial
Comments at 9-10; Eversource Initial Comment at 38.
    \3164\ Eversource Initial Comment at 38.
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    1664. NYISO argues that the final rule would be inefficient and
necessitate a rebuild of NYISO's study base case, take longer to ensure
accurate results, and significantly slow the interconnection
process.\3165\ While we will not opine here on the NYISO-specific
compliance with the final rule, we disagree that requiring accurate
dynamic models of generating facilities will make the interconnection
process take longer to ensure accurate results. To the contrary, we
find here that a lack of accurate models is a major cause of study
delays and contributes to interconnection study backlogs.
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    \3165\ NYISO Initial Comments at 53-54.
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    1665. The majority of commenters support the NOPR proposal.\3166\
We affirm that, consistent with this final rule, all interconnection
customers requesting to interconnect a non-synchronous generating
facility must provide the transmission provider with the required
models needed for accurate interconnection studies. We find that the
models required herein contain the details necessary to accurately
model the performance of the non-synchronous generating facility in
response to system disturbances, and we decline to adopt alternative
model proposals put forth by commenters. This reform promotes a
consistent approach among all generating facilities with respect to
modeling, such that all interconnection customers are required to
submit information sufficient to accurately model the behavior of their
proposed generating facilities.
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    \3166\ AEP Initial Comments at 54; APPA-LPPC Initial Comments at
33; APS Initial Comments at 24; CAISO Initial Comments at 39; Clean
Energy Associations Initial Comments at 65; EEI Initial Comments at
23; NERC Initial Comments at 9-10; EPRI Initial Comments at 19;
Eversource Initial Comments at 38; ISO-NE Initial Comments at 42;
MISO Initial Comments at 125; MISO TOs Initial Comments at 33; NARUC
Initial Comments at 42; National Grid Initial Comments at 44; North
Carolina Commission and Staff Initial Comments at 27; NRECA Initial
Comments at 48; NYTOs Initial Comments at 33; Ohio Commission
Initial Comments at 17; OMS Initial Comments at 20; PacifiCorp
Initial Comments at 45; PPL Initial Comments at 25; R Street Initial
Comments at 17; SPP Initial Comments at 27; U.S. Chamber of Commerce
Initial Comments at 13.
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    1666. We decline to adopt AES's request for a 20-day cure period
for model deficiencies.\3167\ Under the proposed provisions, if an
interconnection customer fails to provide the required models above
within the deadlines established in the pro forma LGIP and pro forma
SGIP, its interconnection request will be incomplete and considered
invalid in accordance with section 3.4.4 of the pro forma LGIP and
section 1.3 of the pro forma SGIP. Pursuant to those provisions, if the
interconnection customer does not cure such a deficiency within the 10-
business day cure period, the interconnection request will be
considered withdrawn pursuant to section 3.7 of the pro forma LGIP and
section 1.3 of the pro forma SGIP. In it its request, AES provides no
explanation for why the 10-business day cure period is insufficient.
Moreover, we believe that the existing 10-business day cure period
should be consistently applied to all interconnection request
deficiencies and that having an extended cure period for model
deficiencies would potentially introduce delays in the interconnection
process. We note that interconnection customers may submit their
interconnection requests early in the customer request window, which
will allow for more time to ensure their models are valid.
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    \3167\ AES Initial Comments at 25-26.
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    1667. We disagree with Pine Gate that the revisions to the pro
forma LGIP and pro forma SGIP, as adopted, incorporate requirements
into the pro forma LGIP and pro forma SGIP that are already being
addressed by NERC through the standards development process.\3168\ We
note that NERC supports the NOPR proposal and argues that the existing
interconnection process does not provide sufficiently accurate and
validated models for non-synchronous generating facilities to
transmission providers.\3169\ We find that these modeling requirements
are appropriately addressed in the interconnection context, where
interconnection customers must provide information to a transmission
provider for use in interconnection studies, and thus adopt the
revisions in the pro forma LGIP and pro forma SGIP. In addition, the
pro forma LGIA and pro forma SGIA revisions apply to a wide spectrum of
generating facilities, including newly interconnecting generating
facilities that are currently outside the bounds of NERC's
jurisdiction.\3170\ As such, we find that this reform can holistically
address the identified issues alongside the NERC standards; even if
NERC is taking action, that need not prevent us from taking action
here.
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    \3168\ Pine Gate Initial Comments at 60.
    \3169\ NERC Initial Comments at 18.
    \3170\ But see Registration of Inverter-based Resources, 181
FERC ] 61,124, at P 31, (2022) (``[W]e find it necessary to ensure
that NERC register the owners and operators of those unregistered
IBRs that, in the aggregate, have a material impact on Bulk-Power
System reliability, to ensure those entities are subject to a
relevant set of mandatory and enforceable Reliability Standard
requirements.'').
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    1668. We disagree with ENGIE that the value obtained from the
models in the NOPR proposal is low because of the likelihood that the
study will be outdated as project components are substituted with more
advanced technology.\3171\ We recognize that the project components for
non-synchronous generating facilities may change during the
interconnection process. We find, however, that this does not diminish
the value of a transmission provider receiving the identified
information from interconnection customers requesting to interconnect a
non-synchronous generating facility and receiving models that represent
the best information interconnection customers have available about
their proposed generating facilities because these models will ensure
that the transmission provider can accurately model the impact of the
proposed generating facility throughout the interconnection process. In
addition, proposed section 4.4.4 of the pro forma LGIP and section 1.4
of the pro forma SGIP require that any modification of the
interconnection request be accompanied by updates to the models.
Pursuant to these provisions, the models are required to be updated as
project components are changed. Ensuring that the model of the proposed
generating