On April 24, 2020, FERC largely upheld an earlier-issued order imposing additional transparency obligations on Midcontinent Independent System Operator, Inc. (“MISO”), Southwest Power Pool, Inc. (“SPP”), and PJM Interconnection, L.L.C. (“PJM”) (collectively, “RTOs”) regarding the RTOs’ Affected Systems study processes. FERC declined to require holistic alignment of the RTOs’ interconnection study processes, but clarified that, in subsequent compliance filings, the Commission will scrutinize whether each RTO applies the Energy Resource Interconnection Service (“ERIS”) or Network Resource Interconnection Service (“NRIS”) modeling standards in a just and reasonable manner.

On September 19, 2019, FERC issued an order granting in part and denying in part a complaint filed by EDF Renewable Energy, Inc. (“EDF”), finding that revisions to each RTO’s respective tariff and to both the MISO-SPP and MISO-PJM Joint Operating Agreements (“JOAs”) were necessary to bring additional clarity and transparency to generator interconnection customers regarding the Affected System coordination process between MISO, SPP and PJM (see September 25, 2019 edition of the WER). EDF argued, among other things, that inconsistent modeling standards among the RTO Affected System studies—namely, MISO using the ERIS standard to model all service requests, compared to PJM and SPP using the stricter NRIS standard—imposes costly and unnecessary network upgrades. EDF also argued that these study practices were not included in the RTO tariffs or JOAs and had therefore not been reviewed by the Commission. FERC found insufficient evidence to determine the modeling standards were unjust and unreasonable, and determined that there was no need for MISO, SPP and PJM to use the same modeling standard. However, FERC agreed with EDF that the standards were insufficiently transparent, and accordingly, directed revisions to each of the JOAs.

Various requests for rehearing and clarification were filed in response to FERC’s September 19, 2019 order. In general, challengers urged FERC to impose stricter transparency standards and Affected System study coordination requirements on the RTOs.

In the April 24, 2020 Order, FERC rejected all of the requests for rehearing, but clarified that the Commission will evaluate whether the modeling standards applied by MISO, PJM, and SPP in Affected System studies are just and reasonable in the proceedings addressing their individual compliance filings. Otherwise, FERC largely left its September 2019 order intact. Specifically, FERC declined to adopt specific dates or timelines that the RTOs must make the Affected System modeling available, and rejected requests to require additional coordination between the RTOs, explaining that addressing purported timing mismatches would effectively require the RTOs to align their interconnection studies. FERC noted there were significant differences between the process and study times used by the various RTOs and emphasized that each RTO process is regionally tailored and developed through individual stakeholder processes. Finally, FERC declined to require PJM to include Affected System study results with its own interconnection study results. FERC reiterated that generator interconnection study process alignment among the RTOs was unnecessary to ensure adequate time for developers to review Affected Systems studies before making additional financial commitments, and referenced commitments from MISO, SPP, and PJM to provide such review opportunities.

A copy of the order is available here.