Two Southwestern utilities — Arizona Public Service (APS) and Public Service Company of New Mexico (PNM) — are closer to compliance with FERC Order 2023 but still have work to do in response to orders the commission issued April 17.
FERC accepted in part compliance filings from APS (ER24-330) and PNM (ER24-1393), while directing the utilities to submit further compliance filings.
Issued in July 2023, Order 2023 revised FERC’s pro forma generator interconnection rules to help clear backlogged interconnection queues across the U.S. It was followed by a clarifying order, Order 2023-A, in March 2024. (See FERC Updates Interconnection Queue Process with Order 2023.)
The orders require transmission providers to transition from serial interconnection processes to studying interconnection requests simultaneously through cluster studies.
APS Filings
APS submitted an initial filing for Order 2023 compliance in November 2023. FERC accepted it in part but told the utility to submit a filing with further revisions to address requirements in 14 areas.
In its subsequent filing, APS proposed adopting without modification the pro forma interconnection procedures and agreements for large and small generators (LGIP, LGIA, SGIP and SGIA).
In doing so, APS met requirements for the LGIA deposit, affected system study process and modeling, affected system pro forma agreements, co-located generating facilities, availability of surplus interconnection service, and modeling and ride-through.
But APS’ filing also had “unexplained variations” from FERC’s pro forma LGIP, LGIA, SGIP and SGIA. In those cases, a transmission provider that’s not an RTO or ISO must explain how its proposals are consistent with or better than the Order 2023 provisions.
Some of the variations in APS’ filing appear to be typos or minor mistakes, FERC said.
Other variations were deemed to be consistent with or better than what Order 2023 prescribed. On the issue of study deposits, APS proposed a $105,000 deposit that it said better reflected its historical study costs than a FERC-tiered system with deposits ranging from $35,000 plus $1,000 per MW to $250,000.
“We find that [APS’] proposed approach should reduce the number of instances in which an interconnection customer submits an upfront study deposit that ultimately exceeds its actual study costs and APS must then refund those excess amounts,” FERC said in its order.
On the topic of allocating cluster study costs, APS changed the allocation method in its initial filing to a method that’s consistent with Order 2023. APS will allocate half of cluster study costs per capita among interconnection customers in the cluster and the other half of costs pro rata by megawatt.
In other areas, FERC said APS’ proposal partly met Order 2023 requirements but needed further modification. Those include proposals related to site control, commercial readiness and the transition process.
APS’ next filing is due in 60 days.
PNM Filing
PNM submitted its Order 2023 compliance filing in March 2024, with amendments in May 2024 and March 2025.
Similarly to APS, PNM tackled a long list of requirements by proposing to adopt without modification FERC’s pro forma LGIP, LGIA, SGIP and SGIA provisions. That included requirements related to commercial readiness, LGIA deposit, co-located generating facilities and availability of surplus interconnection service, among others.
FERC also spotted typos and minor errors in PNM’s filing that need fixing.
On requirements for the transition process, FERC accepted PNM’s proposal that any interconnection customer assigned a queue position “as of 30 calendar days of the commission-approved effective date of this LGIP” will retain that queue position and may choose to proceed with a transitional cluster study.
FERC said the provision will give PNM’s “existing interconnection requests the option to participate in the transition process.”
“We reiterate here that the provisions of Order No. 2023 are not intended to interfere with the timely completion of in-progress cluster studies,” FERC said in its order.
FERC found that PNM had partly complied with requirements in other areas, including the cluster study process, study deposits and site control.
FERC directed PNM to submit two filings: one within 60 days and the other 60 days before opening the initial interconnection request cluster window.
