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1、 Generator Interconnection ScorecardRanking Interconnection Outcomes and Processes of the Seven U.S.Regional Transmission System Operators February 2024 Authors|John D.Wilson,Richard Seide,Rob Gramlich,and J.Michael HagertyPrepared for Advanced Energy United with funding from the Advanced Energy Ins

2、tituteWith Contributions FromJohannes Pfeifenberger and Abigail ShermanAcknowledgementsThe authors appreciate the expert review provided by Will Gorman of Lawrence Berkeley National Laboratory(LBNL),staff of Advanced Energy United,Fulin Zhuang of GridBright,and the participants in interviews with in

3、terconnection customers,as listed in the Appendix.1 The authors also appreciate the assistance of LBNL for providing essential data.1 All organization references are provided for identification purposes only.This report reflects the professional findings and opinions of the study authors and no endo

4、rsement of the findings by those recognized for their valuable contributions is implied.CONTENTSExecutive Summary 51|The Purpose of the Generator Interconnection Scorecard 92|The Generator Interconnection Process 103|Approach to Developing the Scorecard 15 3.1.Scorecard Categories and Metrics 15 3.2

5、.Evidence Relied on for Scoring Interconnection Processes 164|Generator Interconnection Scorecard Results 185|Scorecard Detailed Results and Discussion 21 5.1.Interconnection Process Results 21 5.1.1.Speed:Length and predictability of study and network 22 upgrade process 5.1.2.Regional assessments o

6、f interconnection speed 26 5.1.3.Interconnection Costs:Cost uncertainty a larger 31 concern than total costs 5.1.4.Regional assessments of interconnection costs 35 5.2.Pre-Queue Information 38 5.3.Interconnection Study Process 42 5.3.1.Staff resources are inadequate in every respect 43 5.3.2.Transpa

7、rency depends on individual staffers 44 5.3.3.Supply chain and other construction bottlenecks 44 5.3.4.Regional assessments of interconnection study process 45 5.4.Interconnection Study Assumptions,Criteria,&Replicability 52 5.4.1.Affected system studies 53 5.4.2.Modeling criteria and assumptions 54

8、 5.4.3.Evaluation of options to accelerate upgrades 54 5.4.4.Regional assessments of interconnection study assumptions,54 criteria and replicability 5.5.Availability of Attractive Interconnection Alternatives 57 5.5.1.ERIS vs NRIS:ERIS is little used,and impacts incumbent 58 generators 5.5.2.Other i

9、nterconnection alternatives:Meaningful in CAISO 60 and a few other systems 5.5.3.Regional assessments of availability of attractive 61 interconnection alternatives 5.6.Regional Transmission Planning to Facilitate Generator 64 interconnection 5.6.1.Regional assessments of regional transmission planni

10、ng 64 to facilitate generator interconnection 6|Appendix:Interconnection Customer Assessments of 69 Interconnection Timeline and Costs FIGURE 1.The Generator interconnection Process 12FIGURE 2.Generator Interconnection Scorecard Categories 15FIGURE 3.Interconnection Customer Assessment of Relative 1

11、7 Importance for Each Scorecard Category FIGURE 4.Interconnection Agreements Executed Through 2022 for 23 Interconnection Requests Submitted from 2012-2020 FIGURE 5.LBNL Estimate of Interconnection Process for IAs Executed 25 from 2018 to 2022 FIGURE 6.ISO-NE Reported Study Durations,2020-2023(Numbe

12、r of 25 Days from Study Agreement Execution to Study Delivery)FIGURE 7.ERCOT Interconnection Process Timeline Results 26FIGURE 8.CASIO Compared to ERCOT:Interconnection Agreements 27 Executed Through 2022 FIGURE 9.PJM Compared to ERCOT:Interconnection Agreements 30 Executed Through 2022 FIGURE 10.MI

13、SO Contour Map 41FIGURE 11.Interconnection Customer Self-Assessment of Relative 70 Familiarity with Each Region TABLE 1.Generator Interconnection Scorecard Grades 18TABLE 2.Key Drivers of Scorecard Overall Grades 20TABLE 3.Interconnection Process Results Grades 22TABLE 4.Interconnection Agreements E

14、xecuted Through 2022 and 24 Completion Rates TABLE 5.Estimated Average Interconnection Cost,Projects 33 Submitted to Queue 2012-2020($/kW)TABLE 6.Estimated Regional Standard Deviation of Interconnection 34 Cost($/kW)and Coefficient of Variation,Projects in Operation or with Completed Interconnection

15、 Agreements TABLE 7.Pre-Queue Information Grades 39TABLE 8.Interconnection Study Process Grades 42TABLE 9.Interconnection Study Assumptions&Replicability Grades 53TABLE 10.Interconnection Study Assumptions&Replicability Grades 57TABLE 11.ERIS vs NRIS:Cost and Participation,Projects Submitted to 60 Q

16、ueue 2015-2020 TABLE 12.ERIS vs NRIS in MISO:Selected Transmission Providers 63 Project Capacity and Costs;Operational,IA Executed,and Active-in-Queue Projects TABLE 13.Interconnection Study Assumptions&Replicability Grades 64TABLE 14.Amount and Predictability/Consistency of Time in Queue,71 Ranking

17、s from Interviews TABLE 15.Reasonableness and Predictability/Consistency of 71 Interconnection Cost Estimates,Rankings from Interviews GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 20245 EXECUTIVE SUMMARYThere are over two million megawatts of generation and storage projects actively seeking to conne

18、ct to the U.S.transmission grid,a backlog caused in large part by grid interconnection processes that observers have characterized as dysfunctional.These generator interconnection processes have been well-scrutinized over the past few years across the U.S.power system due to the significant delays a

19、nd limits set on new resources seeking to interconnect.Each grid operators interconnection process is different,and the hurdles to improvement vary accordingly.The 2024 Advanced Energy United Generator Interconnection Scorecard is the first-ever attempt to evaluate each of the seven regional transmi

20、ssion system operators(Regions)on their generator interconnection processes.Based on a survey of interconnection customers with experience navigating these processes and analysis of the recent results of the interconnection process,each Region was assigned a grade across six categories,with the over

21、all grades presented in Table ES-1.TABLE ES-1|Generator Interconnection Scorecard GradesOverall Scorecard GradeCAISOBERCOTBISO-NED+MISOC-NYISOC-PJMD-SPPC-The Scorecard confirms the widespread recognition,including by the Federal Energy Regulatory Commission and the Regions,that the generator interco

22、nnection process is not working effectively and efficiently to allow new generation and storage resources access to the transmission network.Need for new resources is being driven by several factors including growing demand due principally to new large loads,electrification of the building and trans

23、portation sectors,project economics,state policies,and climate trends affecting renewable energy and weather-sensitive end uses of electricity such as building heating and cooling.In response to this demand,developers of new resources have requested generator interconnection for many projects,placin

24、g them in queues to be studied,resulting in the identification and construction of transmission facility upgrades.As is widely recognized,and this Scorecard confirms,the progress towards completing those interconnections is slow and puts system reliability at risk.GENERATOR INTERCONNECTION SCORECARD

25、|FEBRUARY 20246The two Regions with the best scores are the Electric Reliability Council of Texas(ERCOT)and the California Independent System Operator(CAISO).ERCOT and CAISO are graded“B”for different reasons,as these two Regions have very different processes for new resources to be reviewed and con

26、nected to an electric transmission system.ERCOT has a relatively fast and consistent interconnection process,with reasonable costs,although challenges to transmission network upgrade construction can slow the process towards the end and result in curtailment of projects that do get built.As large qu

27、eue volumes slowed processing rates across the country,ERCOT was singularly able to maintain a high processing speed and scale up the total capacity that received interconnection agreements and,hence,permission to proceed towards project operation.For projects submitted before 2020,CAISO also had a

28、relatively fast and consistent process.Since then,CAISOs process has been unable to efficiently process applications due to the large increase in the number of new generator interconnection applications.In contrast,ERCOT was singularly able to maintain a high processing speed and scale up the total

29、capacity that received interconnection agreements and,hence,permission to proceed towards project operation.The relatively high grades for ERCOT and CAISO are driven by interconnection process results.This part of the Scorecards evaluation considered the success rate and speed that applications move

30、 to complete the process,as well as the reasonableness and certainty of interconnection costs.As shown in Figure ES-1,ERCOT and CAISO completed interconnection agreements for more capacity of new generators by the end of 2022 for applications submitted in 2018-2022 than the other five Regions.25%20%

31、15%10%5%0%2012-20142015-20172018-2020IA Capacity Executed%of System Peak LoadFIGURE ES1|Interconnection Agreements Executed Through 2022 for Interconnection Requests Submitted from 2012-20202 SPPNYSOPJMISO-NEMISOCAISOERCOT2 Analysis of LBNL,Queued Up dataset.GENERATOR INTERCONNECTION SCORECARD|FEBRU

32、ARY 20247ERCOT also clearly led the other Regions with respect to reasonableness and certainty of costs,since interconnection customers in ERCOT are only assigned certain limited cost responsibilities related to connecting the transmission system.Even though average interconnection costs in CAISO ar

33、e not lower than other Regions,the Scorecard grades for CAISO emphasize the relative certainty of costs for interconnection customers due to transparency practices and the likelihood that much of the interconnection costs will eventually be refunded to the project developer.Much lower grades are giv

34、en to the Independent System Operator of New England(ISO-NE),Midcontinent Independent System Operator(MISO),New York Independent System Operator(NYISO),PJM Interconnection(PJM),and Southwest Power Pool(SPP).While MISO,NYISO,and SPP each received good grades for certain components of their interconne

35、ction process,all five Regions ended up with grades lower than“C.”In addition to evaluation of the interconnection process results(Category 1 in Figure ES-2),the overall Scorecard grade for each of the Regions is based on an evaluation of components of the generator interconnection process grouped i

36、nto four categories(Categories 2-5),and an additionalcategory that evaluates the effectiveness of regional transmission planning in supporting and coordinating with the generator interconnection process(Category 6).All six categories are summarized in Figure ES-2.Availability and Quality of Useful I

37、nformation for Preparing Applications Availability of Transmission Provider to Address Questions Information Provided by Regions to Conduct Pre-queue Injection Modeling Process Structure Process Transparency Staffing and Modeling Resources Construction of Network System Upgrades Attractiveness of En

38、ergy Resource Interconnection Service Opportunity for Interconnection Needs to be Addressed by“Simple”Remedial Action Scheme Ease of Sharing and Transferring Existing Points of Interconnection Region-planned Transmission Supports Interconnection Regional Transmission Planning Considers Upgrades Iden

39、tified Through Interconnection Studies Transparency of Criteria and Assumptions Reasonableness of Criteria and Assumptions Consistency of Modeling Characterization Consideration of Grid Enhancing Technologies Alignment with Distribution Studies Coordination with Neighboring Systems Transmission Prov

40、ider Study is Accurate and Coordinated with Region6 Using Regional Transmission Planning2 Pre-Queue Information3 Interconnection Process Design4 Assumptions,Criteria,Replicability5 Availability of Interconnection Alternatives Success Rate and Speed Cost Reasonableness and Uncertainty1 Generation Int

41、erconnection Process ResultsFIGURE ES2|Generator Interconnection Scorecard Categories GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 20248The Scorecard is not the first report to recognize considerable shortcomings affecting generator interconnection.The Scorecard is being completed during a significa

42、nt transition in interconnection processes in response to the large increase in interconnection requests over the past decade and the resulting delays and other complications in completing the processes.Currently,most of the Regions are undergoing significant efforts to reform their interconnection

43、practices and policies in response to stakeholder concerns and FERC Order No.2023.The Scorecard is not an assessment of those ongoing or recently adopted reforms that have not yet impacted the generator interconnection processes.And further,the U.S.Department of Energy has released a draft roadmap t

44、o address interconnection challenges through its Interconnection Innovation e-Xchange(i2X)process.3 While this report does reference FERC Order 2023 and ongoing reforms,future Generation Interconnection Scorecards may track the effects of those reforms.The Scorecard may be updated periodically,and t

45、his first-ever Scorecard will provide a baseline against which to evaluate the effectiveness of changes implemented to the generator interconnection processes as a result of the current efforts.3 Find updates on the i2X website here:https:/www.energy.gov/eere/i2x/interconnection-innovation-e-xchange

46、GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202491 THE PURPOSE OF THE GENERATOR INTERCONNECTION SCORECARDThe 2024 Advanced Energy United Generator Interconnection Scorecard is the first-ever attempt to evaluate each of the seven regional transmission system operators on their generator interconnect

47、ion processes.Referred to as the“Regions”in this report,the seven organizations graded in the Scorecard are California Independent System Operator(CAISO),Electric Reliability Council of Texas(ERCOT),Independent System Operator of New England(ISO-NE),Midcontinent Independent System Operator(MISO),New

48、 York Independent System Operator(NYISO),PJM Interconnection(PJM),and Southwest Power Pool(SPP).The Scorecard evaluates each Regions interconnection process in its entirety,from the information exchange that occurs prior to submitting an application(pre-queue)to network upgrade construction activiti

49、es that occur after interconnection studies and agreements are complete,which are primarily the responsibility of a transmission provider.The Scorecard assigns a grade to each of the Regions on six categories related to the generator interconnection process.As discussed in Section 3.2,the Scorecard

50、relies on publicly available data and on interviews with 12 generation developers and engineering firms.The resulting grades reflect the generator interconnection processes as they have performed over the past several years it is a look back,not a look forward.The sole exception to this is for the r

51、egional planning category grade;this category also considers activities that are underway to upgrade the transmission system proactively,even if those upgrades have not yet had a direct impact on the generator interconnection process.The Scorecard is being completed during a significant transition i

52、n interconnection processes in response to the large increase in interconnection requests over the past decade and the resulting delays and other complications in completing the processes.Currently,most of the Regions are undergoing significant efforts to reform their interconnection practices and p

53、olicies in response to stakeholder concerns and FERC Order No.2023.The Scorecard is not an assessment of those ongoing or recently adopted reforms that have not yet impacted the generator interconnection processes.The Scorecard may be updated periodically,and this first-ever Scorecard will provide a

54、 baseline against which to evaluate the effectiveness of changes implemented to the generator interconnection processes as a result of the current efforts.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024102 THE GENERATOR INTERCONNECTION PROCESSGenerator interconnection is the process for new electr

55、ic resources,including energy storage,to be reviewed and connected to an electric transmission system.4 It is a highly technical process,and this section of the report explains key components of the process and defines some technical terms necessary to explain the Scorecard grades.While the multi-st

56、ep,multi-year interconnection process varies significantly from one transmission provider to another,there are common elements across all of the processes.With the exception of ERCOT and the federal power marketing administrations,all generator interconnection processes are regulated by the Federal

57、Energy Regulatory Commission(FERC).Many parties are involved in this process,including an interconnection customer(the resource developer),a transmission provider(a transmission operator that is not an ISO,RTO,or ERCOT),and,in much of the country,one(or more)of the Regions.In those parts of the coun

58、try where the transmission system is not operated by a Region,interconnection applications are reviewed by non-RTO/ISO transmission providers,often vertically-integrated utilities.5While interconnection procedures vary by Region,the interconnection process generally involves several key components:1

59、.Pre-queue.The initial project development phase in which an interconnection customer identifies a potential need or market for power,identifies a potential site,and selects a potential point of interconnection to the transmission system.4 Note:There is a separate,state-jurisdictional interconnectio

60、n process followed by resources seeking to interconnect to the low-voltage distribution system.This report is focused on transmission system interconnection and does not consider state distribution system interconnection processes.5 The Scorecard includes occasional discussion of generator interconn

61、ection processes of non-RTO/ISO transmission providers.The large number of such systems precluded a comparable analysis for this report.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024112.Interconnection application.The interconnection customer submits an application to the transmission provider an

62、d,where applicable,the regional transmission system operator.The application contains essential information about the proposed project along with technical models describing its proposed operation.3.Interconnection study process.:The transmission provider and,where applicable,the regional transmissi

63、on system operator,evaluate the impact of the project on the transmission system in a series of studies.These studies include assumptions about the performance of generators on the system as well as electrical load conditions.Prior to recent reforms and especially FERC Order 2023,many study processe

64、s evaluated projects in a serial queue each project evaluated assuming that the earlier queued projects would be put into commercial operation,with costs assigned to the single project that triggered each required network upgrade.Order 2023 requires that all projects be studied in clusters:a group o

65、f projects is evaluated for collective impact,with necessary upgrade costs shared based on the proportional impact of each project.Various points in a study process specify milestone requirements(e.g.,readiness requirements)and deposit amounts.If the milestone requirements cannot be met or the inter

66、connection customer determines that estimated interconnection costs do not justify paying an additional deposit,the project may be withdrawn from the queue.Withdrawals may change the system model sufficiently to require a restudy for other projects in the queue,thus impacting the interconnection cos

67、ts and timing of those remaining projects.4.Interconnection agreement.A generator interconnection agreement is a contract between the interconnection customer,transmission provider,and,where applicable,Region.It specifies the operational terms and cost responsibilities for both interconnection facil

68、ities and network upgrades.These terms and costs are outcomes of the study process,intended to ensure that connecting the generator to the grid does not have adverse effects.The contract may also discuss other related matters such as network upgrade schedules.5.Interconnection alternatives.There are

69、 two key categories of alternatives to manage required levels of network upgrades:(1)the interconnection customer may elect an alternative level of transmission service;or(2)the Region or transmission provider may offer operational solutions or lower-cost(potentially temporary)solutions to transmiss

70、ion limitations.Interconnection alternatives are discussed further below.6.Affected system study process.In addition to interconnection studies by the host transmission provider,projects are often studied by adjacent transmission providers believed to be potentially affected systems.These studies ma

71、y be initiated after the interconnection customer receives a generator interconnection agreement from the host transmission provider.7.Commercial operation.After the project itself,interconnection facilities,and any required network upgrades are built,the transmission provider and,where applicable,t

72、he Region authorize the project to begin commercial operation and deliver power to end-use customers.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202412These steps are illustrated in Figure 1.FIGURE 1|The Generation Interconnection Process64 EXECUTE IA3 ENTER STUDY PROCESS2 SUBMIT REQUEST1 INITIAL P

73、ROJECT DEVELOPMENTCHALLENGESLack of Information Anticipated High Costs,Difficulty Securing Site Control,UncertaintyDecide not to proceedDecide not to Enter Study ProcessDrop Out of Cluster Study(Potentially Subject to Penalty)Fail to Reach Commercial OperationCHALLENGESHigh Interconnection Upgrade C

74、osts in Initial or Subsequent StudiesCHALLENGESSiting&Permitting Financing,EPC,Supply Chain Delay and/or Cost Interconnection UpgradesPROCEEDPROCEEDCHALLENGESNew Info Indicates High Upgrade CostsPROCEEDPROCEEDACHIEVE COMMERCIAL OPERATIONThroughout this report,the term“Regions”applies to the seven re

75、gional transmission system operators graded in the scorecard and also considers the performance of the transmission providers that are members of those Regions.Similarly,the term“interconnection customer”refers to a generic interconnection customer or,when attribution is implied,to the 12 generation

76、 developers and engineering firms that participated in interviews for this Scorecard.Interconnection alternatives:ERIS vs NRISOne important distinction in the level of interconnection service is between projects classified as ERIS or NRIS.Energy Resource Interconnection Service(ERIS)is an interconne

77、ction service that allows delivery of electric generation using the existing capacity of the transmission system on an as-available basis.Network Resource Interconnection Service(NRIS)is an interconnection service that allows integration of all or a portion of a generating facility with transmission

78、 capacity to serve native load customers during hours with high grid stress.Terminology may vary across systems as there are other similar interconnection service level classifications in use.For simplicity,this report uses the terms ERIS and NRIS to represent different levels of interconnection ser

79、vice that are meaningful in an interconnection study.6 Advanced Energy United,Moving Through the Interconnection Queue:How a Project Gets Builtor Doesnt(2023).GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202413Most generators interconnect using NRIS.The more stringent NRIS study requirements are des

80、igned to assure customers who receive power from NRIS projects that sufficient transmission capacity exists to deliver power in the most severe grid conditions.7 In some Regions,NRIS qualifies a resource to participate in the capacity market and receive preferential curtailment treatment during emer

81、gency conditions.The study and upgrade requirements associated with NRIS applications are often summarized as“invest and connect.”For interconnection customers who wish to bypass the stringent study requirements for NRIS,ERIS study requirements do not require deliverability.In exchange for the less

82、stringent study requirements,interconnection customers who select ERIS are ineligible for capacity compensation and are curtailed before NRIS projects during emergency conditions,which results in relatively lower project revenues as compared to NRIS.For example,one technical difference between ERIS

83、and NRIS projects is the use of distribution factor(DFAX).During an interconnection study of a project,the DFAX is calculated to measure the relative change(or sensitivity)of power flows on the transmission system expected to result from the project under study conditions.Regions and transmission pr

84、oviders set DFAX thresholds for purposes that include assignment of cost responsibility for network upgrades identified on a specific transmission asset(e.g.,a transmission line or a substation).A lower DFAX threshold generally increases the probability that a project will be assigned cost responsib

85、ility for a wider scope of network upgrades.DFAX criteria may be used by the Regions in evaluating unaddressed reliability issues,cost allocation with respect to similarly queued projects,and real-time congestion affecting participants in organized energy markets.87 FERC Order 2003,para.755.8 MISO,B

86、ackground and Overview of Distribution Factor(DFAX),presentation to Interconnection Process Working Group and Planning Subcommittee(July 20,2022).GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202414Interconnection alternatives:“connect and manage”Unlike the other Regions,ERCOTs interconnection proces

87、s is often referred to as“connect and manage.”9 The concept is similar to ERIS in that projects are not required to meet the study and upgrade requirements to meet network transmission reliability planning standards.The resulting grid congestion is managed using economic curtailment and congestion p

88、ricing.10Interconnection alternatives:Lower cost practices and technologiesIn addition to alternative levels of transmission service,interconnection agreements may provide for alternatives to costly network upgrades such as operational practices,alone or in combination with lower-cost investments.On

89、e technical term used to describe such an operational practice is a remedial action scheme(RAS).A RAS is an operational practice designed to automatically take corrective actions,such as curtailments,when predetermined system conditions are detected in order to maintain system stability,system volta

90、ge,and other system reliability concerns.11Another key term used to describe alternatives to network upgrades is grid enhancing technologies(GETs).GETs are hardware and/or software solutions that dynamically increase the capacity,efficiency,reliability,or safety of existing power lines,faster and at

91、 lower cost than traditional grid buildout.129 Tyler H.Norris,Beyond FERC Order 2023:Considerations on Deep Interconnection Reform,Duke University Nicholas Institute for Energy,Environment and Sustainability(August 2023).10 In theory,the pricing information is used to identify future transmission sy

92、stem upgrades,but as discussed in Section 5.6,ERCOTs transmission planning is criticized for failing to address these economic upgrades.11 NERC,“Remedial Action Scheme”Definition Development,Project 2010-05.2(June 2014),p.3.12 T.Bruce Tsuchida et al.,Building a Better Grid:How Grid-Enhancing Technol

93、ogies Complement Transmission Buildouts,Brattle Group for WATT Coalition(April 2023).GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024153 APPROACH TO DEVELOPING THE SCORECARD3.1.Scorecard Categories and MetricsAs illustrated in Figure 2,the Scorecard is broken down into six grading categories,and th

94、e grades themselves are shown in Table 1.Each of these grading categories includes several“metrics,”which are qualitative or quantitative topics that informed each categorys grade.The evidence used for grading is discussed in Section 3.2,and an explanation of key terminology used throughout the Scor

95、ecard is in Section 2.Availability and Quality of Useful Information for Preparing Applications Availability of Transmission Provider to Address Questions Information Provided by Regions to Conduct Pre-queue Injection Modeling Process Structure Process Transparency Staffing and Modeling Resources Co

96、nstruction of Network System Upgrades Attractiveness of Energy Resource Interconnection Service Opportunity for Interconnection Needs to be Addressed by“Simple”Remedial Action Scheme Ease of Sharing and Transferring Existing Points of Interconnection Region-planned Transmission Supports Interconnect

97、ion Regional Transmission Planning Considers Upgrades Identified Through Interconnection Studies Transparency of Criteria and Assumptions Reasonableness of Criteria and Assumptions Consistency of Modeling Characterization Consideration of Grid Enhancing Technologies Alignment with Distribution Studi

98、es Coordination with Neighboring Systems Transmission Provider Study is Accurate and Coordinated with Region6 Using Regional Transmission Planning2 Pre-Queue Information3 Interconnection Process Design4 Assumptions,Criteria,Replicability5 Availability of Interconnection Alternatives Success Rate and

99、 Speed Cost Reasonableness and Uncertainty1 Generation Interconnection Process ResultsFIGURE 2|Generator Interconnection Scorecard Categories The first grading category covers the results of the generator interconnection process,specifically the timeline for interconnection and the costs assessed to

100、 upgrade grid facilities to enable the interconnection.Support for these grades can be found in Section 5.1.The next four grading categories,discussed in Sections 5.2 through 5.5,reflect key aspects of the interconnection process that drive the results in the first grading category.If generator inte

101、rconnection were simple,it might be possible to grade based on the results alone,but GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202416the complexity of the process drives many important outcomes that are not captured by the timelines and costs experienced by projects in the interconnection queues.

102、Finally,the sixth grading category,discussed in Section 5.6,assesses the quality of proactive regional transmission planning and its ability to facilitate generator interconnection.As mentioned above,for the regional planning category grade,the grade considers activities that are underway to upgrade

103、 the transmission system proactively,even if those upgrades have not yet had a direct impact on the generator interconnection process.3.2.Evidence Relied on for Scoring Interconnection ProcessesTo develop the Scorecard,the project team reviewed publicly available data on the successes and challenges

104、 facing the generator interconnection processes across the country.As many of the questions studied in the Scorecard are qualitative and require knowledge and perspective of the technical experts at firms that directly experience the generation process,the project team also conducted interviews with

105、 interconnection experts in interconnection customer organizations.The Scorecard grades rely primarily on two types of evidence.First,the team interviewed 12 generation developers and engineering firms.Interview participants are provided anonymity;citations to each interview use a two-letter code.Th

106、e interview evidence was the most heavily weighted evidence in every scorecard category except interconnection process results(Section 5.1).In a few instances,published work by interconnection customers is cited alongside interview evidence and given comparable consideration.Second,the team relied o

107、n Lawrence Berkeley National Laboratorys(LBNL)Queued Up:Characteristics of Power Plants Seeking Transmission Interconnection as of the End of 2022 and related data on generation interconnection costs.13 LBNL supplied the project team with the data used for much of its analysis.This scorecard relies

108、directly on that report and conducts original analysis of the data assembled by LBNL.These data are occasionally supplemented by data obtained directly from the Regions.In addition to those two primary sources of evidence,the scorecard also relies upon other published works,as cited,and the project

109、teams professional experience.As discussed throughout this report,the interviews with 12 generation developers and engineering firms had a substantial impact on the scoring in each section.In addition,when aggregating the six category grades into a final overall grade for each Region,the project tea

110、m took into consideration the relative importance expressed by interconnection customers for the six scorecard categories.We gave the highest weight to the interconnection results grade because it reflects the outcome of the entire interconnection process,and because it considered both interview evi

111、dence and various data sources for corroboration.13 Joseph Rand et al.,Queued Up:Characteristics of Power Plants Seeking Transmission Interconnection as of the End of 2022(April 2023),Lawrence Berkeley National Laboratory;and Joachim Seel et al.,Generator Interconnection Costs to the Transmission Sy

112、stem Summary Briefing(June 2023),Lawrence Berkeley National Laboratory.Findings from Queued Up and the datasets from both reports are referenced henceforth as:LBNL,Queued Up.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202417The other five categories were weighted based on the interconnection custom

113、ers assessment of the relative importance of the five categories,as shown in Figure 3.14 Interconnection customers gave the highest weight to the interconnection process and study assumptions/criteria/replicability.Pre-queue information and regional transmission planning got the next highest weighti

114、ng,with interconnection alternatives weighted least.It should be noted that this weighting reflects interconnection customers prior experience with opportunities to move projects forward from concept to commercial operation,and that it may not reflect the weighting that would be applied to an ideal

115、interconnection process.Interconnection Process DesignStudy Assumptions,Criteria and ReplicabilityPre-Queue InformationRegional Transmission PlanningInterconnection Alternatives Very InterestedInterested Not InterestedFIGURE 3|Interconnection Customer Assessment of Relative Importance for Five Score

116、card Categories02468101214 Interconnection customers were asked to indicate which categories they were interested in discussing during an interview.They were not asked to rank their interest in the first category,interconnection process results,because it is assumed that all parties would rank resul

117、ts as the greatest interest.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024184 GENERATOR INTERCONNECTION SCORECARD RESULTS The Scorecard confirms the widespread recognition,including by FERC and the Regions,that the generator interconnection process is not working effectively and efficiently to al

118、low new generation and storage resources access to the transmission network.Physical need for new resources is being driven by A)growing demand,due principally to new large loads,electrification of the building and transportation sectors,climate trends affecting weather-sensitive end uses of electri

119、city such as building heating and cooling and B)planned generator retirements.The market is also responding to low costs for renewable energy,driven by innovation and federal subsidies,and state climate policies that set requirements for cleaner generation.Developers of new resources have requested

120、generator interconnection for many projects,placing them in queues to be studied,resulting in the identification and construction of transmission facility upgrades.As is widely recognized,and this Scorecard confirms,the progress towards completing those interconnections is agonizingly slow and puts

121、system reliability at risk.As shown in Table 1,ERCOT and CAISO generator interconnection processes score the best,each receiving a B,but for different reasons.ERCOT received high scores for the quantity of resources that completed its interconnection process at a reasonable cost,but the lack of proa

122、ctive regional transmission planning to upgrade its transmission system is a major impediment to development of new generation resources.TABLE 1|Generator Interconnection Scorecard GradesCAISOERCOTISO-NEMISONYISOPJMSPPInterconnection Process ResultsB-ACCDDC-Pre-queue InformationC+CDC+CCC-Interconnec

123、tion Study Process DesignBA-C-D+B-FDStudy Assumptions,Criteria,ReplicabilityAA+C+DC+FCUsefulness of Interconnection AlternativesB+BDB-DDBUsing Regional Transmission PlanningA-DDBC+D+C+Overall gradeBBD+C-C-D-C-GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202419In contrast,CAISO gets high marks for it

124、s proactive upgrades to its transmission system,but is rated lower than ERCOT for its overall interconnection process results due to recent delays in completing interconnection studies and agreements and constructing the necessary grid facilities.The other five Regions received much lower overall gr

125、ades with MISO,NYISO,and SPP each receiving a C-,ISO-NE receiving a D+,and PJM a D-as each suffers from its own particular set of maladies.While we acknowledge reforms are underway in each of the Regions,these low scores highlight the need for significant improvement,almost certainly beyond the scop

126、e of currently contemplated reforms.Because generator interconnection is a process,problems in any one part of the process can negatively impact the overall result.Broad,comprehensive reforms are essential to effective and efficient generator interconnection.The generally poor overall grades that th

127、e current interconnection processes received are not surprising in the context of the increasing demands to interconnect new resources and deal with climate trends that are changing the timing,location,and severity of grid stress events.The Scorecard documents large differences across the Regions in

128、 specific categories that we have evaluated and received feedback on through the interviews.It shows that some of the Regions have elements of the interconnection process that are superior to those of most others.This provides pointers to potential“best practices”that Regions can use to learn from a

129、vailable experience and make more rapid improvements,as highlighted in Table 2.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202420TABLE 2|Key Drivers of Scorecard Overall GradesRegionGradeKey Drivers of Overall GradeCAISOBCAISO gets strong marks for its high rates of studying resources,proactive upg

130、rades to its transmission system,transparency,and cost sharing approach.CAISOs use of mitigation strategies to bring projects into operation until upgrades are constructed is also appreciated by interconnection customers.However,recent delays in interconnection study results have made it more diffic

131、ult to complete CAISOs queue.ERCOTBERCOT gets high marks for processing a high volume of resources on a reasonable timeline and at reasonable costs.However,the lack of proactive regional transmission planning to ad-dress system constraints and resulting high levels of generator curtailment is a majo

132、r impedi-ment to development and deployment of new generation resources.ISO-NED+ISO-NE has a relatively low interconnection volume.Portions of its system are highly con-strained(including Maine and in southeast Massachusetts),making it likely that projects will trigger significant system upgrade cos

133、ts.Those upgrades,as well as planned transmission expansions,are difficult to build,making it difficult to bring projects online.Another criticism is the unique requirement for a high-cost model with the initial application.MISOC-MISOs strongest point is its recent commitment to transmission expansi

134、on both within its system and in coordination with SPP along the seams of the two systems.However,its gap in planning studies has recently left the system with limited available capacity.Another positive is the availability of interconnection alternatives permitted outside of queue order.MISOs inter

135、connection process is considered unreliable and slow with unpredictable cost outcomes.An additional concern includes recent changes to MISOs interconnection business practices to raise impact criteria for new projects.NYISOC-NYISO gets its highest recognition for design of its interconnection proces

136、s,with mostly rea-sonable study assumptions and criteria.However,the process has not produced compelling results,with long timelines and unpredictable costs that come late in the process.NYISOs use of regional transmission planning to expand opportunities for new generation resources has some promis

137、e but is not yet delivering substantial benefits.The availability of interconnection alternatives in NYISO is more limited than in other Regions.PJMD-There are few bright spots for generator interconnection in PJM.Overall,it appears that PJM stuck with a sub-par serial process too long and its trans

138、ition to a cluster process has frozen opportunities for new projects.In addition,PJM has not planned its system to create headroom for new resources,other than its recent process concerning NJ offshore wind.PJM receives a better score than other Regions on its responsiveness to questions.SPPC-SPP al

139、so scores well for its coordination with MISO,but its current transmission planning pro-cess lacks a focus on creating opportunities for new generators.Its process operates closer to official timelines than some other Regions,but the resulting studies are often compromised by frequent restudy and er

140、rors that make the results undependable.While it is difficult to get interconnection alternatives considered in most Regions,SPP has 11 GW of operational ERIS re-sources(with another 26 GW in its queue)yet interconnection customers indicated that scale of ERIS is creating challenges for recent inter

141、connection applications.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024215 SCORECARD DETAILED RESULTS AND DISCUSSIONThe following sections provide details on each of the interconnection process metrics evaluated in the Scorecard.5.1.Interconnection Process ResultsThe grades for interconnection pro

142、cess results consider six factors,as shown in Table 3.Two factors are the perspective of interconnection customers on timeline and cost.As discussed below,interconnection customers are more concerned about the uncertainty of the timeline(particularly as triggered by affected system studies)than by d

143、ifferences in the overall time to complete studies.Similarly,interconnection customers were more concerned about cost uncertainty than overall costs.The remaining four factors are derived from LBNLs Queued Up report(particularly analysis of the underlying data provided by LBNL).These factors include

144、 speed and certainty(Figures 5 and 6),agreements signed(Figure 4,Table 4),average costs(Table 5),and cost certainty(Table 6).An“ideal”grading system for interconnection process results would consider each of the four metrics,as shown in the sidebar.However,neither the Regions nor the interconnection

145、 customers have all the information required to complete an“ideal”evaluation of the results of the interconnection process.As a result,the overall grade for this category is a subjective weighting of the six components shown in Table 3,where the review team placed greater emphasis on certainty and c

146、onsistency rather than the average timeline or average cost of completing the interconnection process.Interconnection Process Results Metrics1.Success rate Capacity(MW)of signed agreements relative to Region peak demand(GW)and capacity submitted2.Speed Total time in queue Predictability and consiste

147、ncy of timelines3.Cost reasonableness Cost per kW Cost variation by transmission provider4.Cost certainty Project-specific changes in estimated network upgrade cost assignment from one study stage of queue to next Consistency of Regions cost estimates with transmission provider cost estimatesGENERAT

148、OR INTERCONNECTION SCORECARD|FEBRUARY 202422TABLE 3|Interconnection Process Results GradesInterconnection Customers15LBNL Data16Overall Category GradesSpeed and CertaintySection 5.1.2Cost CertaintySection 5.1.4Speed and CertaintyFigures 5 and 6Agreements Executed17Figure 4,Table 4Average CostsTable

149、5Cost Certainty18Table 6CAISOCBCBn/an/aB-ERCOTA-A-AAAAAISO-NEBCB-D+DBCMISODCC+CDFCNYISODCC-DFDDPJMFCD+DBCDSPPCDC+D-BBC-5.1.1.Speed:Length and predictability of study and network upgrade processAffected System Studies Overall,the biggest driver of the difference in interconnection customer ratings of

150、 the timeline is affected system studies.An affected system study examines system impacts to adjacent and neighboring systems from projects queued to a host system.These studies are performed under separate timelines and frequently employ different assumptions and modeling methods between the host a

151、nd affected system transmission provider.In interviews,interconnection customers identified the most severe affected system study risks to projects in the MISO,PJM,and SPP Regions,as well as in some non-RTO/ISO transmission provider territories.Affected system studies are a substantial cause of unce

152、rtainty in getting the queue process completed,with new costs and delays being imposed even at the point that a project is about to go into commercial operation.Affected system studies in MISO,PJM,and SPP entail significant electric grid interactions across their borders.This makes the coordination

153、and sequencing of affected system studies essential to the queue process,particularly in the case of restudies.15 See Appendix(Section 5.2)for interconnection customer assessments.16 Analysis of LBNL,Queued Up dataset.17 These grades are aligned with those in the ACEG report.Americans for a Clean En

154、ergy Grid(ACEG),Transmission Planning and Development Regional Report Card(June 2023),Table 19,p.64.18 These grades only consider cost certainty from one transmission provider to another within a Region,which is only one source of variation.The interconnection customer perspective on cost certainty

155、is given more weight in this subjective grading.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202423Agreements SignedERCOTs relatively fast process also helped it take the lead in the overall rate of executing interconnection agreements.Across the seven Regions,the average rate of executing interconn

156、ection agreements submitted in 2018-2020 is about 9%of system peak load.ERCOT and CAISO are the clear leaders,with agreements representing 24%and 17%of their respective system peak loads in 2018-20,as shown in Figure 4.19 Notably,the rate of interconnection agreements in SPP,PJM,and MISO decreased s

157、ignificantly from 2015-2017 to 2018-2020.All three markets had previously achieved interconnection agreement rates similar to CAISO and higher than ERCOT in 2015-2017,but their processes have been slowed by the significant increase in requests and are expected to remain low for projects that have en

158、tered since 2020.Rates of interconnection agreements in NYISO and ISO-NE have remained consistently below 5%of their system peaks over the last decade.FIGURE 4|Interconnection Agreements Executed Through 2022 for Interconnection Requests Submitted from 2012-20202025%20%15%10%5%0%2012-20142015-201720

159、18-2020IA Capacity Executed%of System Peak LoadSPPNYSOPJMISO-NEMISOCAISOERCOTIt is particularly impressive that ERCOT has increased execution of interconnection agreements(Figure 4)while also maintaining a leading interconnection completion rate,as shown in Table 4.Over 40%of capacity in queue submi

160、ssions to ERCOT in the 2012-2020 time period were completed and operational by 2022.(Projects not completed and operational may still be active in the queue,suspended,or withdrawn.)For projects submitted in 2018-2020,the completion rates for four Regions(ISO-NE,NYISO,PJM,and SPP)dropped to less than

161、 10%,because of high queue submissions and slow progress in completing the study process.MISO has recently been able to process the second highest amount of capacity relative to the queue at 28%.Across the entire period,NYISO has the lowest completion rate.19 Data in Figure 6 and Table 4 are present

162、ed in 3-year increments to smooth out less meaningful year-to-year variations and simplify the data.20 Analysis of LBNL,Queued Up dataset.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202424TABLE 4|Interconnection Agreements Executed Through 2022 and Completion Rates21Interconnection Agreements Execu

163、ted Through 2022(MW)Completion RatesExecuted Agreements as Percent of Queue SubmissionsQueue Years2012-20142015-20172018-20202012-20142015-20172018-2020CAISO4,94327,11323,84914.8%38.0%15.2%ERCOT17,88519,86452,74041.3%45.4%42.6%ISO-NE3,7953,5112,78037.3%20.5%9.5%MISO18,50254,73134,80937.5%63.2%28.3%N

164、YISO2,2192,3932,24833.8%16.6%3.5%PJM28,98950,73411,77148.0%46.0%6.3%SPP5,60024,86334038.7%40.1%0.9%All Regions81,932183,208128,5385.6%12.6%8.7%Of course,the objective of a good interconnection process is not to achieve a 100%completion rate.Projects that are submitted and later withdrawn reflect an

165、exchange of information between the transmission provider and the interconnection customer about the prospects for a particular project.However,completion rates below 10%reflect a lack of sufficient upfront information and/or a deficient and burdensome process.The uncertainty and slowness of the int

166、erconnection process creates a perverse incentive for interconnection customers to submit even more proposals,which can create a negative feedback loop.Length of Interconnection ProcessLBNLs report evaluated the length and variability of the interconnection process for projects that completed the pr

167、ocess between 2018 and 2022.As shown in Figure 5,while the mean study period length was around 40 months in each Region other than ERCOT,there was large variability in PJM,NYISO,and CAISO.These data are generally consistent with the observations given by interconnection customers,except that interco

168、nnection customers tended to give stronger weight to recent experiences with projects that remain in the queue.MISO is a particularly good example,where interconnection customers report a recent increase in uncertainty that is not reflected in the LBNL data.21 Analysis of LBNL,Queued Up dataset.GENE

169、RATOR INTERCONNECTION SCORECARD|FEBRUARY 202425FIGURE 5|LBNL Estimate of Interconnection Process for IAs Executed from 2018 to 202222 806040200MeanDuration IR to IA for IAs Executed 2018-2022(Months)PJMSPPNYISOMISOCAISOWestSoutheast ERCOTISO-NE appears to have a shorter timeline than the other Regio

170、ns,although due to differing data sources a clear comparison is difficult.Since LBNL data are not available for ISO-NE(Figure 5),a recent ISO-NE timelines study is shown in Figure 6.This study suggests that ISO-NE timelines averaged around 25-30 months for interconnection agreements executed in 2020

171、-2022.However,significantly longer timelines in 2023 suggest a high degree of variability in duration.FIGURE 6|ISO-NE Reported Study Durations,2020-2023 (Number of Days from Study Agreement Execution to Study Delivery)238007006005004003002001000FSSISFACQ3 20Q4 20 Q1 21 Q2 21 Q3 21 Q4 21 Q1 22 Q2 22

172、Q3 22 Q4 22 Q1 23 Q2 23 Q3 2322 LBNL,Queued Up,p.27.23 Figure reports duration of feasibility study(FS),system impact study(SIS),and facility study(FAC)for projects receiving an interconnection agreement in each quarter.ISO-NE,Interconnection Study Metrics Third Quarter,2023:Processing Time Exceedan

173、ce Report(November 14,2023),p.5.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024265.1.2.Regional assessments of interconnection speedERCOT:Simple process,reliable scheduling24Interconnection applications in ERCOT have progressed more quickly and consistently than other Regions,with interconnection

174、customers reporting that the current study process lasts about 2-3 years and LBNLs data(Figure 5)indicating that average projects take just two years.25 These actual timelines are consistent with ERCOTs published timeline.26 As long as the application is for a project that is ready,interconnection c

175、ustomers believe ERCOT is quick to advance the application.Several interconnection customers have also noted that they have experienced variation in the timing in ERCOT based on which transmission provider is completing the interconnection studies,since ERCOT does not complete the studies themselves

176、.After receiving an interconnection agreement,projects in ERCOT are able to reach commercial operation in about a year,as shown in Figure 7.However,it appears that some projects may have required two years or more to reach commercial operation.FIGURE 7|ERCOT Interconnection Process Timeline Results2

177、72,5002,0001,5001,0005000Cumulative Time in Queue(Days)Milestone ReachedTIME TO REACH ERCOT QUEUE MILESTONES FOR WIND PROJECTSScreening StudyFull Inter-connection StudyInterconnection AgreementCommercial OperationIn ERCOT,the Time Taken to Complete the Full Interconnection Study or Sign an Interconn

178、ection Agreement Typically has the Most Impact on the Time it Takes for a Project to Start Commercial OperationNOTE:Based on Projects that Entered the queue in 2010 and Onward SOURCE:STU Analytic Power View24 Interviews zb,zd,zf,zh,zm,zr.Aaron Vander Vorst and Adam Stern,Plugging In:A Roadmap for Mo

179、dernizing&Integrating Interconnection and Transmission Planning(October 2021),Enel Green Power Working Paper,p.925 One interconnection customer noted that transmission owners in ERCOT used to complete facility studies in less than half a year,but that has significantly increased.26 ERCOT,Resource In

180、terconnection Handbook(March 1,2023),Version 1.94,Appendix D,p.48.27 Trevor Fugita,Waiting in Line:Measuring Generation Queue Durations(June 15,2021).GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202427CAISO:Recent surge in projects has stalled a previously efficient process28CAISO has been using clu

181、sters to process interconnection requests with roughly annual open windows,and is now on Cluster 15.Through Cluster 13 in 2020,interconnection customers report that CAISO kept to a timeline of around two years for processing project applications,with Phase I taking six months and Phase II taking one

182、 year.Even though this is longer than CAISOs official one-year timeline,29 interconnection customers described CAISOs performance during this period as best-in-class,with effective communication on timeline delays.However,when there was a massive increase in requests for Clusters 14(opened in 2021)a

183、nd 15(2023),projects in CAISO have been extremely delayed in their progression through the study process.Delays are expected to be over three years for Cluster 14,the timeline for Cluster 15 is unclear,and new clusters are on hold subject to pending reforms.Evidence of these delays are illustrated i

184、n Figure 8,which shows that CAISOs interconnection capacity execution rate dropped for capacity that entered the queue in or after 2020 reflecting the slowdown for Cluster 14,while ERCOT maintained its pace in 2020 and completed its study of significant capacity that entered in 2021.FIGURE 8|CASIO C

185、ompared to ERCOT:Interconnection Agreements Executed Through 20223035%30%25%20%15%10%5%0%ERCOTCAISOIA Capacity Executed%of System Peak Load20122013201420152016201720182019202020212022Year Project Submitted to QueueBecause deliverability allocations are so important to load-serving entities as a part

186、 of their procurement requirements in CAISO(enabling the satisfaction of resource adequacy),interconnection customers are“parking”projects in the queue while waiting for an allocation.Until system upgrades go through,the queues are stalled.28 Interviews zb,zk,zm,zn,zr.29 Songzhe Zhu,IR Application G

187、enerator Facility Data Form Overview(March 3,2021),p.22.30 Analysis of LBNL,Queued Up dataset.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202428One other positive on CAISOs process is that after the Phase II studies are complete,CAISO has annual restudies and deliverability allocations,which are no

188、t triggered by withdrawals.ISO-NE:Location matters31Timing in ISO-NE depends on the location of the interconnection,and the serial nature of the current process allows for wide variation in outcomes.Overall,the queue in ISO-NE is smaller and thus involves less schedule risk.Interconnection customers

189、 report that in some areas,projects can move through to completion in 2 years,which is consistent with ISO-NEs official timeline.32 However,interconnection customers noted that two areas in ISO-NE can take longer:southeast Massachusetts and Maine.In southeast Massachusetts,the offshore wind project

190、cluster is impacting other projects due to uncertainty about timing or interconnection details.In Maine,the lack of available headroom on the existing system requires additional studies to be completed to identify the required upgrades.As a net exporting state,interconnections in Maine often trigger

191、 upgrades on the limited transmission facilities available for power exports.A unique feature of ISO-NEs queue is the presence of“optional”process steps.33 According to an interconnection customer it is common practice for projects to skip feasibility or facility steps and go directly to receiving a

192、 proposed interconnection agreement based on system impact study-level estimates.This is a voluntary way for projects to reduce study times.MISO:Unreliable and slow study process34 Interconnection customers report that successful interconnection applications in MISO have progressed through the queue

193、 in 2-4 years,a figure confirmed by LBNLs data(Figure 5),but there are many delays,and schedule estimates provided by MISO are inaccurate.MISOs queue process is supposed to take just a year.35 MISOs timeliness challenges have become particularly evident recently,as queue sizes have increased.While M

194、ISO used to share details with interconnection customers on the reasons for delays,over the past two years these updates have become less dependable.Then,once MISO releases model results,interconnection customers have 15 days to do their own modeling analysis to determine whether or not they will re

195、main in the queue.This is challenging,especially because the interconnection customers have no reliable notice as to when that 15-day period will occur so they cannot plan for it and must respond quickly once provided the results.Although MISOs recent study enhancements to limit system impact study

196、duration are intended to reduce queue processing to 373 days,interconnection customers still anticipate that most projects will take 3 or more years to complete,especially in MISO-West.31 Interviews zd,zk,zr.32 Stojan Nikolov,Interconnection Process(February 16,2023),ISO-NE Webex Broadcast,pp.8,73.3

197、3 See:Stojan Nikolov,Interconnection Process(February 16,2023),ISO-NE Webex Broadcast,p.8.34 Interviews zb,zf,zj,zm,zn,zr.35 Sam Hipple,MISO Interconnection Process:Overview,Innovations,Initiatives&Updates(December 5,2023),EUCI Presentation;MISO,Generation Interconnection Business Practices Manual,B

198、PM-015-r26(August 2,2023),p.35.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202429SPP:Backlog 5 years and growing,with no evidence that reforms are making a difference36Successful interconnection applications in SPP have recently progressed through the queue very slowly.Both LBNL data(Figure 5)and i

199、nterconnection customers indicate that projects take 2-4 years to move through the queue(one reports a just-signed agreement that took six years).This is considerably longer than SPPs official timeline,which estimates the process should take less than a year and a half.37 Todays backlog is five year

200、s and growing,with interconnection agreements in 2018-2020 having come to a virtual standstill(Figure 5).A positive note is that schedule estimates provided by SPP are relatively accurate,perhaps due to the adoption of automation.38 Unfortunately,this schedule consistency is undermined by the qualit

201、y of the studies.Several interconnection customers noted that they have received study results with significant errors,and that SPP provides slow responses to inquiries about those errors.In addition to concerns about quality control,interconnection customers identified the dependency of each cluste

202、rs study results on the status of earlier clusters.With 4-5 clusters proceeding in parallel it is difficult to make commercial decisions for projects in the later clusters.This suggests that SPPs attempt to reduce the timelines by using overlapping(or parallel)clusters to speed up processing may not

203、 successfully reduce the backlog.Instead,this approach has simply increased the number of restudy cycles,which overall may just increase the queue processing time.NYISO:Bogged down and not improving39The last cluster(“class year”)is reported as having required 18-24 months before the first study was

204、 completed,and projects that have been in the queue for 3 years do not currently appear close to completion.LBNLs findings(see Figure 5)indicate that NYISO projects usually take longer than 3.5 years to proceed through the queue.In contrast,NYISO aspires to a 1.6-year timeline in its proposed reform

205、,with an additional three months for projects in the“transitional”cluster.40Interconnection customers note that the iterative cost allocation process results in drop-outs at every study stage,which was viewed positively by interconnection customers.A change that was supposed to expedite the process

206、through a more detailed study(at the risk of more required upgrades)did not result in quicker results.36 Interviews zb,zf,zg,zj,zm.37 SPP,Generator Interconnection Business Guide and Practice(September 12,2023),p.8.38 SPP is collaborating with AWS and Pearl Street.See:William Driscoll,“Artificial In

207、telligence Could Speed Interconnection,Says Amazon Executive,”PV Magazine USA(October 17,2022).39 Interviews zk,zh.40 Thinh Nguyen,Interconnection Order No.2023:Proposed Compliance Approach(December 1,2023),NYISO Interconnection Issues Task Force p.8.Note:A comparable graphic for NYISOs current proc

208、ess could not be located.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202430PJM:Complete stop;Longest timelines,most uncertainty41Interconnection customers with experience in multiple RTOs tended to be most critical of PJMs process timelines.As shown in Figure 9,PJMs interconnection capacity executi

209、on rate began to decline in 2017,as the gap between ERCOT and PJM began to grow.FIGURE 9|PJM Compared to ERCOT:Interconnection Agreements Executed Through 20224230%25%20%15%10%5%0%ERCOTPJMIA Capacity Executed%of System Peak Load20122013201420152016201720182019202020212022Year Project Submitted to Qu

210、eueThe most frustrated interconnection customers note that PJMs interconnection study process for new projects has come to a full stop,with the hope that projects from 2019 may complete the process six years later in 2025.One interconnection customer has ceased developing projects in PJM,and other i

211、nterconnection customers are uncertain whether their projects are getting studied or not.One interconnection customer stated that PJM has“no regard for reasonableness and decorum when it comes to communicating deadlines.”Even though PJM has developed new practices that should improve the process goi

212、ng forward,significant delays have been imposed on projects that have been transitioned to the cluster process so there is limited evidence currently about its effectiveness in completing the necessary studies.Interconnection customers also critiqued PJMs now-replaced serial process.One interconnect

213、ion customer described a project that received an interconnection agreement in the serial process in“just”3.5 years the customer was only able to get that agreement by purchasing and terminating projects that were ahead of the project in the serial process queue.LBNLs data validates their experience

214、 as the average PJM project has taken nearly four years to complete.43 41 Interviews zb,zf,zg,zh,zj,zm,zr.42 Analysis of LBNL,Queued Up dataset.43 PJM,PJM Manual 14H:New Service Requests Cycle Process(July 26,2023),p.26.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202431Another interconnection custo

215、mer found some positive things to say about PJM,stating that its now-replaced serial process took 2-4 years.Even this most positive assessment indicates the process takes longer than the nearly two years estimated by PJM.44 They noted that PJM could get an initial study out pretty quickly,albeit wit

216、h results that were not reliable.Overall,however,the interconnection customer still described the process as very inefficient,with lots of time waiting for restudies to be completed,sometimes as many as 5-6 restudies.Non-RTO/ISO transmission providers:Potentially fast,but depends on the utility45Whi

217、le this report does not grade non-RTO/ISO transmission providers,several interview participants are active in those areas and compared those providers interconnection timelines with those of the Regions.One interconnection customer indicates that projects can progress quickly in several non-RTO/ISO

218、providers processes if the project has been selected in a solicitation.Such projects tend not to linger or suspend progress.Another interconnection customer cites positive progression in Idaho Powers queue process,but the need to resolve several affected system impact studies associated with another

219、 request in Bonneville Power Authoritys queue.5.1.3.Interconnection Costs:Cost uncertainty a larger concern than total costsOverall,interconnection customers express concern about interconnection cost uncertainty more so than overall costs.The Regions assign interconnection costs based on impact.The

220、 interconnection costs in many Regions tend to be volatile through the phases of the interconnection study process,such that the total interconnection costs are not known until the end of the multi-year process.A secondary concern with uncertainty is the challenge of marketing projects that are subj

221、ect to dramatic cost swings where it is possible that upgrades increase by twofold and undermine project economics.Such unpredictability inhibits contracting and project success.While it is not unusual for interconnection costs to be a relatively small portion of total costs,interconnection costs ar

222、e significant enough that they do impact project viability.An analysis by Charles River Associates found that network upgrade costs on average represented less than 10%of total project costs in MISO.46 Costs to interconnect are also increasing:as discussed below,as interconnection costs for projects

223、 in operation represent about 4%of total capital costs for solar and wind resources,and for projects with signed interconnection agreements(not yet in operation)interconnection cost estimates represent about 14%of total capital costs.Significant swings in interconnection costs throughout the process

224、 can put projects at risk.An interconnection customer notes that with transmission upgrade costs trending up,those costs are a more important indicator of project viability than they have been in the past.Another interconnection customer explains that even in markets with high average costs,there ca

225、n be good opportunities for development,citing CAISO and ISO-NE as examples.44 PJM,PJM Manual 14H:New Service Requests Cycle Process(July 26,2023),p.26.45 Interviews zd,zp.46 Network upgrade costs as estimated in Phase 3 studies,excluding“TOIF&Affected Systems.”Charles River Associates,MISO Intercon

226、nection Queue:M2,M3 and M4 Security Deposits and Return Procedures(August 26,2023),presentation to MISO,p.11.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202432Background on assignment of system upgrade costs to generator projectsUpgrade costs are assigned to new generation resources differently dep

227、ending on whether the interconnection study uses a serial or cluster process.One approach is demonstrated by PJMs original serial process:upgrade costs were assigned based on the principle of“First to Cause.”When the study process determines that a project requires a network upgrade,the project prov

228、ider is responsible for 100%of the upgrade.Often,this upgrade will provide sufficient benefits so that later projects(those further back in the interconnection queue)will receive lower mitigation costs.Depending on upgrade scope,the policy of First to Cause can render project economics unfeasible fo

229、r a single project to undertake.If that project withdraws from the queue,this can trigger a dynamic that causes the upgrade costs to be reassigned to subsequent projects,potentially triggering a cascade of withdrawals and further reassignments.While reimbursement can occur between initial and subseq

230、uent projects on a limited basis,this cost allocation policy has stifled queue progress and new entry deployment.PJM is changing to a cluster study process as a part of its recently approved queue reform,and FERC Order 2023 directs all transmission providers to do the same.Each project that is studi

231、ed together with other projects in the cluster is assigned costs based on the percentage contribution of individual projects to a common upgrade.This sharing of upgrade costs enables larger transmission system facilities to be financed by the responsible cluster;this is referred to as a Shared Netwo

232、rk Upgrade.Upgrades funded by new generators can also benefit existing transmission system users.For example,in MISO interconnection customers are responsible for 90%of the cost of upgraded facilities with voltages of 345 kV and higher,with existing system users paying the remaining 10%of the cost.4

233、7 With some differences,cluster upgrade funding is now utilized in all Regions except CAISO and ERCOT.While generators pay upfront for interconnection costs in CAISO,project developers are reimbursed up to a capped level subject to their project receiving allocation of firm delivery rights on the sy

234、stem and entering a contract with a load serving entity.CAISOs repayment term is 5 years,with costs recovered from all transmission access customers.48In ERCOT,interconnection customers pay very low interconnection costs,with projects current responsibility limited to certain direct costs of connect

235、ing the generator to the transmission system.The remaining costs are paid by the transmission provider and passed through to retail customers.In several Regions,projects with interconnection agreements are eligible to request long-term Financial Transmission Rights(FTRs)in return for funding network

236、 upgrades and creating incremental system capability.In SPP,the request for financial transmission rights occurs in the queue process.49 While the value provided by FTRs is meant to offset market-based congestion,the specific FTR paths sought by interconnection customers are frequently unavailable o

237、r not feasible.This form of compensation is generally viewed to be suboptimal from a project finance perspective.47 MISO is the only region that uses this approach for allocating the cost of high voltage network upgrades.48 16 TAC 25.195(c).In cases where costs are high,ERCOT conducts further studie

238、s to examine the economic benefit of the upgrades,but any action would be at the discretion of the transmission provider.ERCOT,ERCOT Planning Guide,Section 5.2.3(November 19,2023).49 This replaced SPPs former crediting system(termed“Z2”)in which interconnection customer credits were dependent on usa

239、ge of upgraded facilities.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202433Regional variation in costs and cost certaintyThe average cost of interconnection for projects in operation across five of the seven Regions included in this scorecard is about$58 per kW,and$177.5 per kW for projects with s

240、igned interconnection agreements,as shown in Table 5,based on data from the LBNL Queued Up report.Interconnection costs for projects in operation represent about 4%of total capital costs for solar and wind resources,and for projects with signed interconnection agreements(not yet in operation)interco

241、nnection costs represent about 14%of total capital costs.50 The costs analyzed in Table 5 include costs at the point of interconnection as well as costs for network services,comparing(a)currently active projects in the queue,(b)projects with interconnection agreements but not operating as of 2022(bu

242、t entering the queue in 2013 or later),and(c)operating projects placed in service from 2018-2022.Available data vary by Region and are not available for CAISO or ERCOT.Interconnection customers reported that costs in CAISO are substantially higher than in other Regions due to the high cost of constr

243、uction in CAISO.However,upgrade costs in CAISO are offset by refunds.ERCOT costs are presumed to be nearly zero because interconnection customers are only responsible for certain direct costs of connecting the generator to the transmission system.TABLE 5|Estimated Average Interconnection Cost,Projec

244、ts Submitted to Queue 2012-2020($/kW)51RegionActive Applications in QueueInterconnection Agreement SignedProject In OperationTotalSPP83.452.239.569.0NYISO129.3104.1130.7124.0PJM290.832.025.7184.5MISO258.2322.980.7223.8ISO-NE278.5131.264.3245.3Average$217.4$177.5$58.3$174.6Notes:Data for NYISO does n

245、ot distinguish between interconnection agreements signed and projects in operation.For NYSIO,one 1,020 MW natural gas plant with interconnection costs of$329/kW is excluded from the analysis as an outlier.Including this value significantly increases NYISOs average inter-connection cost for completed

246、 projects.There are several findings evident in Table 5 and related analyses:Interconnection costs for operational projects are substantially lower than forecast costs for active applications.Inflationary pressure related to supply chain constraints and increased project demand is surely a factor si

247、nce operational project costs were established further back than the most recent study cost for an active application.Furthermore,it is likely that 50 Total capital costs for solar and wind are from NREL,2023 Electricity Annual Technology Baseline,available at:https:/atb.nrel.gov/electricity/2023/in

248、dex.51 Average is calculated on a nameplate capacity weighted basis.Analysis of LBNL,Queued Up dataset.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202434projects assigned high costs drop out,causing the reduction in average cost for those that are completed.In exploring possible drivers of cost var

249、iation across Regions,there were no significant factors apparent from the data.The only exception is a difference between interconnection costs for clean energy project costs and those for all energy projects shown in Table 5 for NYISO and ISO-NE.Operational clean energy projects(solar,wind,storage,

250、and hybrid)cost over$175 per kW in those regions,compared to$131 per kW in NYISO and$64 per kW in ISO-NE across all projects.Considering the costs of projects with completed interconnection agreements,PJM and SPP stand out as having had lower costs.Costs in NYISO are higher.However,these average cos

251、ts mask significant variation in costs within the Regions.Table 6 compares the variation in the average cost to interconnect among transmission providers within each Region.52 This analysis was suggested during interconnection customer interviews in which high variation in construction management an

252、d costs was frequently noted.TABLE 6|Estimated Regional Standard Deviation of Interconnection Cost($/kW)and Coefficient of Variation,Projects in Operation or with Completed Interconnection Agreements53As indicated by the coefficient of variation,some Regions have highly variable interconnection cost

253、s.While interconnection costs for completed projects in ISO-NE and SPP have been relatively consistent,there is much higher variation across transmission providers in NYISO and especially MISO.One possible driver of cost uncertainty flagged by interconnection customers is that many Regions and non-R

254、TO/ISO transmission providers use assumptions in their studies that do not reflect likely scenarios for grid operating conditions.Interconnection customers also raised concerns with the cost uncertainty within the study process for each project,and the challenges this creates while completing the pr

255、ocess.This is especially a problem in Regions with large queues that experience high withdrawal rates,as withdrawals of earlier projects in the queue can swing costs either up or down depending on the study outcomes.52 In the case of ISO-NE,transmission provider data are unavailable so the ISO-NE st

256、andard deviation refers to variation across the six states.53 Standard deviation is calculated on an unweighted basis across all transmission providers or,in the case of ISO-NE,states.Analysis of LBNL,Queued Up dataset.RegionCount of Transmission ProvidersStandard Deviation($/kW)Coefficient of Varia

257、tionISO-NE6$57.441%SPP17$21.645%PJM20$24.2123%NYISO8$297.3256%MISO35$422.2425%Note:ISO-NE data are reported by state,not transmission provider.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202435Considering cost uncertainty,interconnection customers are most concerned about affected system studies,as

258、 discussed in Section 5.4.1 below,which also have detrimental impacts on timelines.Affected system studies affect interconnection customers in every Region,as well as those operating in utility service areas outside of the Regions.Interconnection customers provided the most specific concerns about a

259、ffected system studies involving the MISO,PJM and SPP Regions.Affected system studies are a substantial cause of uncertainty in getting the process completed,with new costs or delays being imposed even at the point that a project is about to go into commercial operation.5.1.4.Regional assessments of

260、 interconnection costsERCOT:Low interconnection costs come with high congestion and curtailment risk54The ERCOT process only requires local facility upgrades,resulting in relatively low interconnection costs which are predictable and consistently applied.However,project output may be limited by Gene

261、ric Transmission Constraints(GTCs)imposed by ERCOT on new projects as a reliability backstop.Projects are especially prone to curtailments caused by system outages.While the low cost of interconnection is a positive for interconnection customers,the relative lack of proactive transmission planning i

262、ncreases operating risk,which puts financial pressure on new entrants and long-term project owners.Interconnection customers cannot even volunteer to pay for upgrades because the transmission providers have to take projects to the Texas Public Utilities Commission for approvalthis approval process p

263、uts cost in rate base and is not designed to accept participant contributions.CAISO:Limited upgrades,transparent costs,yet“California expensive”55Interconnection customers report that prior to Cluster 14(2021),CAISO had relatively low interconnection costs for customers with transmission planning de

264、livery,known as“Option A.”56 For projects with transmission planning delivery allocations,interconnection customers receive refunds of their network upgrade costs within 5 years.These refunds are made by the transmission providers,who recover those costs from load(end users of electricity)through CA

265、ISOs Transmission Access Charges.CAISO is also described by interconnection customers as having a reputation for consistent and reliable costs.This consistency is reinforced by rules that require transmission providers to publish per-unit costs for network upgrades that are used in CAISOs interconne

266、ction studies.The Phase II study costs,as allocated to each project,provide the interconnection customer with a maximum cost responsibility for the interconnection agreement.This type of cost protection differs from other Regions,where upgrade estimates are prone to revision through further restudie

267、s.While annual reassessments do result in potentially significant variation in expected upgrade costs prior to signing an interconnection agreement,the reassessments do not often put progress towards interconnection at risk due to the cost cap.54 Interviews zb,zg,zh,zm,zp;project team contribution.5

268、5 Interviews zb,zh,zm,zp.56 Option B is an interconnection request in which the Interconnection customer does not seek an allocation of transmission planning delivery capacity.CAISO,Appendix 1 Interconnection Request,Version RIMS-IR-CLUSTER-V01(March 2020),p.15.GENERATOR INTERCONNECTION SCORECARD|FE

269、BRUARY 202436CAISOs use of Remedial Action Schemes(RAS)helps reduce interconnection costs by identifying operational practices that avoid network upgrades and mitigates the need for re-study when other projects drop out.(See explanation of RAS in Section 2.)However,it cannot be said that CAISOs cost

270、s are low or that cost certainty can be achieved when interconnection studies are stalled.Interconnection customers report that construction costs in CAISO are 2-3 times the cost of the same upgrade in different Regions.Beginning with Cluster 14,the large number of projects in the queue caused Phase

271、 I cost estimates that are much higher and unreliable.Nonetheless,because CAISO refunds network upgrade costs to the project developer,interconnection customers bear relatively little cost risk,despite the high construction costs.Furthermore,once projects are approved for interconnection,many projec

272、ts financially depend on also getting approved for firm delivery(deliverability)necessary for load serving entity procurement.This is a challenge in the current CAISO process that does not provide interconnection customers with a clear path to fund and obtain deliverability,as discussed further late

273、r in this report.ISO-NE:Cost estimates are so uncertain that upgrades can trigger withdrawal from the queue57ISO-NE provides expedited cost estimates,but they are uninformative because they provide an estimate of the total costs with a vague description such as“reconductoring of X line,”with no brea

274、kdown by subcategories or specification of what violations are triggered.Furthermore,ISO-NE does not provide any standardized costing guidance.Considering these two issues,one interconnection customer stated that it was unable to assess the accuracy of ISO-NEs cost estimate and make business decisio

275、ns.According to that interconnection customer,most interconnection customers withdraw projects that trigger a network upgrade because of the lack of confidence in the cost estimates.Furthermore,in ISO-NE,each transmission provider has its own standards and costs,with excessive flexibility for upgrad

276、e costs to exceed estimates.The transmission providers timelines for upgrades are also uncertain,impacting the schedule for bringing a project to operating status.MISO:Costly,especially for ERIS projects58Due to the large queue size in MISO,recent interconnection cost estimates have increased dramat

277、ically.For example,MISO interconnection costs estimates doubled for projects entering the queue in 2020 relative to those entering in 2018.59Cost assignments are also uncertain,as project withdrawals result in costs shifting around.In particular,costs have changed substantially as projects progress

278、from Phase 1 to Phase 2 to Phase 3.According to analysis of the 2017-2020 queue clusters by Charles River Associates,upgrade costs dropped from$232/kW in Phase 1 results to$73/kW in Phase 3 results.60 57 Interview zk.58 Interviews zb,zj,zm,zn,zp,zr;project team contribution.59 Excluding projects tha

279、t have withdrawn from the queue.Analysis of LBNL,Queued Up dataset.60 Charles River Associates,MISO Interconnection Queue:M2,M3 and M4 Security Deposits and Return Procedures(August 26,2023),presentation to MISO,p.9.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202437So while the cost decrease from P

280、hase 1 to Phase 3 is welcome,interconnection customers question whether the Phase 1 cost estimate provides useful information regarding whether or not to proceed with a project.It is not only the project withdrawals that drive cost uncertainty in MISO.One interconnection customer described a project

281、 whose costs increased by 50%with no change in project scope.Interconnection customers report that high costs in early-phase studies were particularly a problem in MISO-West in the 2016 and 2017 queue clusters,but that problem diminished in the 2018-2020 queue clusters,while a similar high-cost issu

282、e emerged in MISO-South.61Project interconnection customers also express concern that these upgrade costs are imposed on both energy-only(ERIS)projects and firm-delivery(NRIS)projects with little distinction in upgrade requirements between the two levels of service.This is further discussed in Secti

283、on 5.5.SPP:Swinging between insufficient and excessive upgrades62Cost uncertainty in SPP is driven by an interconnection study approach that identifies excessive upgrades that result in project withdrawals and the need for re-study,much like MISO.Interconnection customers state that because the stud

284、ies use assumptions that are unlikely to reflect actual operating scenarios,the resulting upgrade requirements and costs drive unnecessary project withdrawals for both ERIS and NRIS projects.The risk of cost reassessments during re-studies inhibits interconnection customers from moving forward with

285、interconnection agreements.On the other hand,a concern raised by some interconnection customers about SPP is that new projects brought online in the past few years have not had sufficient upgrades required,resulting in substantial congestion and curtailments.Curtailments in some cases adversely affe

286、ct existing interconnection customers whose projects requested and paid for firm service prior to these new projects,expecting limited curtailment risks in return.This expectation in SPP contrasts with the ERCOT market where curtailment risk is expected in congested portions of the system due to the

287、 limited interconnection-related upgrades.NYISO:Cost estimates come late,and interconnection customers cannot adjust in response to upgrades63NYISO does not provide full upgrade costs until the end of the“class year”study process is complete.The information provided by NYISO lacks clarity,according

288、to one interconnection customer,making it difficult to identify which upgrade requirements might be avoided if a project was converted from firm delivery(NRIS)to energy-only(ERIS).61 See also:Andy Witmeier,Generator Interconnection Queue Improvements(September 18,2023),MISO Planning Advisory Committ

289、ee(PAC)Special Meeting,p.31.62 Interviews zb,zj,zm,zr.63 Interview zk.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202438PJM:Costly interconnection outcomes64In PJMs process,the costs to interconnect are uncertain,with final upgrades required to interconnect some projects requiring more costly netwo

290、rk upgrades than predicted in earlier studies.65 Interconnection customers said that PJMs new cluster study process so far does not yet inspire confidence in improvements in timeliness or certainty on costs.One interconnection customer commented that in some instances,transmission providers have fou

291、nd errors in PJMs studies that resulted in final costs being much higher than estimated through the interconnection process.Another stated that recently,interconnection cost estimates have become“astronomical,”in their opinion due to the very large queue size.Their observation about costs is corrobo

292、rated by data:As shown in Table 5,operational projects in PJM had relatively low costs of$26 per kW,while active projects in the queue have a much higher cost of$291 per kW,more than a tenfold increase.Non-RTO/ISO transmission providers:More accurate cost estimates,but very costly in much of WECC66O

293、utside of the Regions,one interconnection customer pointed out that costs tend to be more accurate since there are fewer projects in many of those providers queues.However,in WECC,projects tend to have higher upgrade costs than those in the eastern U.S.Even though there are the same number of upgrad

294、es,the higher voltages and longer spans drive up the costs.5.2.Pre-Queue Information67Overall,interconnection customers are dissatisfied with the pre-queue information provided by the Regions to support identification of suitable interconnection locations.For example,neither Regions nor the transmis

295、sion providers facilitate access to necessary data about interconnection facilities such as available substation capacity.Interconnection customers would like to understand available“headroom”at each point of interconnection,but they are unable to obtain this information from either transmission pro

296、viders or the Regions and he interconnection customers are not hopeful that proposed reforms will resolve these challenges.As a result,interconnection customers expect that they will continue to need to enter the queue to gain useful information about constraints on interconnecting at various points

297、 on the transmission system.64 Interviews zb,zd,zh,zm,zr.65 In a serial process,high-cost network upgrades may be uneconomic for interconnection customers,resulting in these costs being passed from earlier to later queued projects as projects drop out due to the cost.This cascading of cost through a

298、 serial queue undermines certainty and decision making by interconnection customers.66 Interview zp.67 Interviews zd,zf,zg,zh,zj,zk,zm,zn,zr.Pre-Queue Information Metrics5.Availability and quality of useful information for preparing applications6.Availability of transmission provider to address ques

299、tions7.Sufficiency of information provided by Regions to conduct pre-queue injection modeling GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202439The limited value of the available pre-queue information is compounded by poor responsiveness by the Regions staff to ad hoc questions.Only MISO was consid

300、ered better than the rest,and SPP was singled out for particular criticism on its refusal to provide key helpful information.TABLE 7|Pre-Queue Information GradesPre-Queue InformationCAISOC+ERCOTCISO-NEDMISOC+NYISOCPJMCSPPC-Even though interconnection customers are dissatisfied with the information n

301、eeded to support locating optimal interconnection points,they are relatively satisfied with the technical information needed to prepare a viable interconnection application.For PJM,MISO,NYISO,SPP,and ERCOT,the quality of pre-queue injection analysis information is sufficient to provide some informat

302、ion about the viability of an application.However,they are generally dissatisfied with non-RTO/ISO transmission providers who do not provide this information.An interconnection customer noted difficulty in replicating or pre-screening ISO-NEs process for modeling deliverability.While the requirement

303、 to make heat maps available is a much-noted feature of FERC Order 2023,interconnection customers are generally not hopeful that heat maps will aid the interconnection process because they expect that there will be too many limitations to their usefulness.Currently,with many Regions having multiple

304、cluster cycles in process at a given time,the high uncertainty driven by future decisions on hundreds of queued projects makes it nearly impossible to get actionable information prior to submitting a request.As one interconnection customer noted,unless the heat maps provide“contractable”quality info

305、rmation,the heat maps will have limited impact on discouraging non-ready projects from entering the queue at impractical locations.Providing“contractable”information in a heat map may be almost impossible given the large queue volumes.68Some interconnection customers are looking forward to heat maps

306、 being made available by non-RTO/ISO transmission providers,because those transmission providers provide virtually no pre-queue information at all,and the heat maps may provide some useful information.Otherwise,interconnection customers were uniformly skeptical that heat maps could provide useful in

307、formation for making informed pre-queue interconnection application decisions.68 This concern also applies to the usefulness of model data for injection studies.GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202440Interconnection customers also expressed general concern related to delays in updating m

308、odels,and noted inconsistencies across the various Regions.One interconnection customer felt that taking six months to update a model after a queue window closes is too long and limits its usefulness.Another noted that the Regions should coordinate and select a single software approach for modeling

309、generation.Ideally,interconnection customers would like to have“ballpark”estimates of costs to interconnect,but this may be a long-term goal given the status of the Regions interconnection queues.Interconnection customers mentioned two specific types of information about substations that they find c

310、hallenging to obtain from the Regions:1)whether a substation has an open terminal bay for new projects(or whether new terminals must be constructed)and 2)whether a substation has an existing fiber connection.Both terminals and new fiber connections are costly upgrades that can substantially affect t

311、he feasibility of a project.Interconnection customers feel strongly that the Regions could and should serve as a clearinghouse for reliable information of this type.In some cases,interconnection customers have sought out this information from the specific transmission providers but have found that t

312、he quality of information provided is dependent on the assigned project manager in each Region,even if the interconnection customer is able to hold a pre-queue scoping meeting.Typically,the Regions provide access to a list of valid generator interconnection applications,and some provide the process

313、time for system integration and feasibility studies.69 CAISO summarizes results from its interconnection studies to help identify portions of its system and points of interconnection with available headroom.The Cluster 13 report shows that there is 43 GW of energy-only headroom(33 GW of which are fi

314、rmly deliverable)on its system,including projects that can either be interconnected with no network upgrades(5.4 GW),proceed with RAS(21.0 GW),or proceed with under development transmission(16.3 GW).70 In other Regions,access to system-wide pre-screening tools varies,but generally appears to be low

315、quality.For example,MISO recommends that customers review its generator interconnection queue map and the contour map.However,the contour map currently available on MISOs website is five years old,as shown in Figure 10.One viewer commented that the resolution of this map makes it not very useful.MIS

316、O also offers a Point of Interconnection Tool to assist with pre-screening,but there is no detailed information available to the public.7169 FERC Open Access Transmission Tariffs(OATTs)for CAISO(Appendix Y,September 1,2022),p.14;ISO-NE(Schedule 22,June 5,2023),pp.38-42;MISO(Attachment X,January 22,2

317、024),pp.48-56;NYISO(Attachment P,April 11,2021),p.14;SPP(Attachment V,December 1,2020),pp.31-32.70 CAISO,Briefing on Resources Available for Near Term Interconnection(December 5,2023).71 MISO,Queue Process Workshop:Generator Interconnection Queue(August 11,2022),pp.8-9.GENERATOR INTERCONNECTION SCOR

318、ECARD|FEBRUARY 202441FIGURE 10|MISO Contour Map7272 MISO,GI-Contour_Map(September 15,2023).GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 2024425.3.Interconnection Study ProcessIn most Regions,the interconnection study processes are complex processes that have not yet adequately adapted to the signifi

319、cant increase in requests for interconnection over the past several years.The one Region where the large volume of requests has not greatly limited the interconnection process is ERCOT.TABLE 8|Interconnection Study Process GradesInterconnection Study Process DesignCAISOBERCOTA-ISO-NEC-MISOD+NYISOB-P

320、JMFSPPDInterconnection customers provided widespread feedback on the challenges that they face with the current processes that are caused by the volume of requests in the queue and materialize in many different ways.With such a large number of projects to study and significant interdependencies amon

321、gst the projects,poor design or execution in one particular component can be closely tied to choices made in other components,making it unclear in many cases what exactly is the root cause of the issue.Interconnection customers identified particular practices or combinations of project standards in

322、each Region that result in unnecessary delays or unhelpful incentives to interconnection customers to remain in or exit the queue.These practices and standards evolved during a period in which the Regions queues were smaller,and they have fared poorly as the queues expanded.In recent policy discussi

323、ons related to the interconnection study process,such as FERC Order 2023,substantial attention has been given to three areas:setting appropriate barriers to entry(e.g.,site control),financial commitments(e.g.,withdrawal penalties),and material modifications(e.g.,small adjustments to size,technology,

324、or point of interconnection as the project gains information through the study process).Overall,interconnection customers believe that in those three areas,the Regions have already or will soon move toward more reasonable policies and practices.This finding should not imply that the Regions have ado

325、pted workable interconnection study process designs as implementation of the reforms will be crucial to their success.Interconnection customers also noted that several aspects of the interconnection process require balancing tradeoffs between competing objectives.For example,setting higher readiness

326、 requirements or financial commitments can limit the amount of entry but,if set GENERATOR INTERCONNECTION SCORECARD|FEBRUARY 202443too high,those requirements could limit access to a wide range of interconnection customers and impinge upon“open access”principles.Similarly,setting more flexible rules

327、 for material modifications could be beneficial to lowering the number of initial queue requests submitted by interconnection customers(because lack of flexibility causes some customers to submit multiple requests for a single intended project),but have the unintended consequence of shifting results

328、 between system impact study phases.Many interconnection customers noted that the existing interconnection study processes have been designed to accommodate first,gas generation and second,wind and solar generation,but are not as well suited to evaluate battery storage projects.735.3.1.Staff resourc

329、es are inadequate in every respect74Interconnection customers expressed widespread concern with the inadequacy of resources applied to the interconnection processes,particularly insufficient staffing levels,lack of training,poor senior talent retention,and leadership turnover affecting most or all R

330、egions.The issue extends beyond the Regions to transmission providers,where resource challenges affect not only engineering staff,but also legal,real estate,and other offices that are critical to the transmission providers responsibilities in completing the interconnection process.Interconnection cu

331、stomers acknowledge that they have contributed to the staff retention issue as they frequently hire staff from the Regions to support the development of their project pipeline due to their particular knowledge of the markets and the often-unwritten methodology employed by each Region for completing

332、interconnection studies.Region staff are extremely valuable to the interconnection customers in large part due to the lack of transparency in the processes and the need to understand the exact assumptions,criteria,and methodologies implemented by the Regions but not memorialized in tariffs or manual

333、s.To support the surge in requests,almost all Regions use consultants to deal with staffing shortages,with some trending towards more use of consultants for deliverability studies.73 Interviews zc,zd,zg,zj,zk,zm,zn.74 Interviews zb,zc,zd,zf,zh,zj,zn,zm,zp,zr.Contribution of project team.Interconnection Study Process Metrics8.Interconnection process structure Entry and readiness requirements Withdr