FERC Order No. 792 (Part 1 of 3): Gains for Solar PV Fast Track Interconnections

FERC Order No. 792 is a major update to the pro forma Small Generator Interconnection Procedures (SGIP) and Small Generator Interconnection Agreement (SGIA). The SGIP and SGIA were created by FERC Order No. 2006 and are components of transmission providers’ OATTs. Distributed generation, especially small solar and energy storage, are the major beneficiaries of Order No. 792. This article is the first in a three-part series on Order No. 792. Part 1 describes how the order helps new solar PV projects. Part 2 will describe how energy storage benefits from the order. Part 3 will discuss potential state adoption of FERC’s new rules for state-jurisdictional interconnections.

Order No. 792 is FERC’s response to the rapid increase in solar PV development and related changes in interconnection technology. Referring to the growth in solar, FERC Chairman Norris described the order as “another great example of how we are making adjustments in policy to accommodate what new technology enables us to do, and remove barriers, and remove costs that are associated with those barriers that enable a new energy source to be provided to consumers more efficiently.”

The order helps all potential interconnection customers by increasing access to transmission grid metrics through pre-application reports. Project developers will have the option of requesting a limited pre-application report of “readily available” specifications for a potential point of interconnection for a fixed fee of $300 (or potentially more). Developers can use these reports to predict the viability of particular sites. Rather than spending considerable time and money on interconnection applications and studies only to discover that the point of interconnection is not even remotely economic, developers can quickly assess a potential site by requesting one of these reports.

A new fast track interconnection option—available only to inverter-based interconnections—is the largest gain for solar PV developers in the order. Before Order No. 792, generators of up to 2 MW could qualify for a fast track process, which allowed them to avoid the lengthy study process and potentially costly upgrades, if the interconnection application passed a set of screens (e.g., generating capacity less than 15% of peak line load). Now, inverter-based interconnections that fail under the old screens can still qualify for a fast track interconnection by passing a new set of screens. Depending on the location (as shown in the table below), solar PV generators of up to 5 MW may qualify for the fast track process if their capacity is no more than the minimum load on the line they seek to connect to. The following table from the order summarizes the criteria for interconnections that are eligible to be evaluated under the new fast track screens.

Fast Track eligibility for inverter-based systems, as adopted in Order No. 792.
Line Voltage
Fast Track Eligibility Regardless of Location
Fast Track Eligibility on a Mainline1 and ≤ 2.5 Electrical Circuit Miles from Substation2
< 5 kilovolt (kV)
≤ 500 kW
≤ 500 kW
≥ 5 kV and < 15 kV
≤ 2 MW
≤ 3 MW
≥ 15 kV and < 30 kV
≤ 3 MW
≤ 4 MW
≥ 30 kV and ≤ 69 kV
≤ 4 MW
≤ 5 MW
1 For purposes of this table, a mainline is the three-phase backbone of a circuit. It will typically constitute lines with wire sizes of 4/0 American wire gauge, 336.4 kcmil, 397.5 kcmil, 477 kcmil and 795 kcmil.
2 An interconnection customer can determine this information about its proposed interconnection location in advance by requesting a pre-application report.

If a generator is eligible for a fast track interconnection under the above criteria, it must then pass a set of screens in order to use the fast track process. The three screens are (1) aggregate generating capacity is no more than 100% of minimum load on the line; (2) voltage and power quality meets certain standards; and (3) safety and reliability are not significantly reduced. Interconnections that do not pass all the screens must interconnect through the normal study process.

An added benefit for solar is that daytime minimum load will be used for the first screen. In other words, a solar PV interconnection will pass the first screen if its generating capacity is no more than the daytime minimum load on the line, which in most regions is higher than nighttime minimum. The impact of the more generous screening criteria will depend on the characteristics of the specific transmission lines. But by some estimates, under the new screens, a given line will be able to accommodate well over twice as much solar PV capacity compared to under the old screen of 15% of maximum load.

Solar and other interconnection customers will also benefit from increased transparency in the study process. Order No. 792 mandates that interconnection customers be “entitled to view the facilities study supporting documentation” and be given the opportunity to “provide written comments on the required upgrades in the facilities study”.

Transmission providers are required to comply with Order No. 792 by filing updated SGIPs and SGIAs with FERC by August 3, 2014.

Lovinger Kaufmann LLP assists solar PV developers and utilities in negotiation, dispute resolution, and rulemaking related to generator interconnections. Lovinger Kaufmann LLP participated in the drafting of the current interconnection rules in Oregon and Washington, which are modeled on the SGIP and SGIA from FERC Order No. 2006.

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