FERC has accepted SPP’s compliance with Orders Nos. 2023 and 2023-A in part and directed the RTO to submit a further filing within 60 days of the order (ER24-2026). 

The commission said in its June 26 order that SPP’s proposed tariff revisions amending the commission’s pro forma generator interconnection procedures and pro forma generator interconnection (GI) agreements partly comply with the orders. 

It found that the RTO’s proposal to post the interconnection studies from the close of its definitive interconnection system impact study (DISIS) cluster to the date when the transmission provider provided the completed study, as opposed to from the close of the cluster request window, deviated from the pro forma GI procedures. FERC said SPP’s standard “does not explain how the proposed variation accomplishes the purposes of Order 2023.” 

The commission also found SPP’s revisions did not incorporate a reference to the “surplus interconnection service study” contained in the pro forma large generator interconnection procedures (LGIP) and that the definition of “scoping meeting” in its GI procedures didn’t incorporate the commission’s revisions to the definition. It said the proposal does not incorporate FERC’s removal of the phrase “to determine the potential feasible points of interconnection” and that its pro forma GIA does not include the defined term “cluster.” 

When SPP made its compliance filing May 24, it said it had made several reforms following Order 2023’s issuance, including a three-stage interconnection study process with increasing financial milestones at each stage. It also proposed replacing “cluster study” and “cluster restudy” with “DISIS” and “DISIS restudy.” 

FERC had several issues with SPP’s proposed language on site control. It said the grid operator did not explain the omission of timing requirements when it would notify interconnection customers of a required restudy; it did not fully incorporate the commission’s revisions to the pro forma definition of “site control”; it did not request an independent entity variation for its proposal to retain its existing GI procedures provisions requiring 100% site control at the time of an interconnection request; and it did not address FERC’s requirement for transmission providers to include a narrative description of how they will define regulatory limit. 

The commission ordered SPP to address: 

• • How the following two items meet the purposes of Orders 2023 and 2023-A. Not adopting the commission’s requirement that the transmission provider treat the GIA deposit as part of the security that the interconnection customer must provide for network upgrades and interconnection facilities; and not requiring the transmission provider to explain and estimate the dates at which an interconnection customer must provide additional security for interconnection facilities and network upgrades when the GIA deposit is depleted. 
  • How it will incorporate the requirement that the transmission provider perform affected system restudies within 60 calendar days from the date of notice. 

FERC directed the grid operator to: 

• • Remove certain language regarding the submission of multiple interconnection requests and deposits or further justify its proposal under the independent entity variation standard. 
  • Revise the GI procedure language to specify which enumerated alternative transmission technologies evaluation results are reported in the first two DISIS studies and to clarify when interconnection customers will receive the evaluation results of the alternative transmission technologies. 
  • Reinstate language regarding transitional notice requirements for generating facility replacement in a future Section 205 filing under the Federal Power Act. 

SPP’s filing drew 22 intervenors and protests by the Clean Energy Association, Longroad Energy Holdings and Shell. FERC rejected the majority of the complaints. 

FERC issued Order 2023 in July 2023, seeking to clear backlogged interconnection queues by implementing a first-ready, first-served cluster study process; increasing interconnection customers’ financial obligations; and penalizing grid operators for missing study deadlines. (See FERC Updates Interconnection Queue Process with Order 2023.) 

In 2024, the commission rejected challenges to the interconnection rules under Order 2023 and made several clarifications, minor modifications and an extended compliance deadline with Order 2023-A. (See FERC Upholds, Clarifies Generator Interconnection Rule.)