Interconnection

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On October 10, 2025, FERC accepted Southwest Power Pool, Inc.’s (“SPP”) proposed revisions to its Open Access Transmission Tariff (“OATT”) to establish a provisional load interconnection process. SPP argued the provisional load interconnection process is driven by an increase in requests for load additions and will improve transmission planning and encourage new generation resources to come online by allowing SPP to study interconnection requests while accounting for planned generation. FERC accepted the tariff revisions subject to further compliance, finding the provisional load interconnection process will allow SPP to better understand the impacts of load requests and identify necessary network upgrades.

On August 25, 2025, the Federal Energy Regulatory Commission (“FERC”) granted NextEra Duane Arnold, LLC (“NEDA”) a waiver of certain sections of the Midcontinent Independent System Operator, Inc.’s (“MISO”) tariff to use MISO’s generating facility replacement process for the recommissioning of the Duane Arnold nuclear power facility (“Project”) in Palo, Iowa. The order also extends the Project’s commercial operation date to December 31, 2029.

On May 27, 2025, FERC addressed arguments raised on rehearing of a January 30, 2025 order, which accepted the Midcontinent Independent System Operator, Inc.’s (“MISO”) proposal to modify its generator interconnection study process by implementing a queue cap and exemptions to that cap (the “Queue Cap Order”). In doing so, FERC reaffirmed that MISO’s proposed queue cap and exemptions align with Order No. 2003’s independent entity variations for regional transmission organizations and independent system operators.

On March 20, 2025, FERC denied Ponderosa Power, LLC’s (“Ponderosa”) complaint alleging that NorthWestern Corporation’s (“NorthWestern”) application of its large generator interconnection procedures (“LGIP”) was unjust and unreasonable or unduly discriminatory or preferential. The dispute centered around NorthWestern’s requirement for Ponderosa to fund approximately $23 million in network upgrades to accommodate the interconnection of its 70 MW wind-powered generation facility located in Musselshell County, Montana (“Project”).

On November 21, 2024, FERC issued an Order partially accepting NorthWestern Energy Corporation’s (“NorthWestern”) compliance filing, effective July 10, 2024.  FERC found that NorthWestern’s filing partially complies with the requirements of Order Nos. 2023 and 2023-A and directed NorthWestern to submit a further compliance filing within 60 days.

On September 10 and 11, 2024, FERC staff held a two-day workshop at its headquarters in Washington, DC on opportunities to further refine the generator interconnection queue process. Panelists and FERC staff discussed potential enhancements to transmission planning and processing interconnection requests over the course of six panels on discrete…

On July 19, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) issued an Order denying Tenaska Clear Creek Wind, LLC’s (“Clear Creek”) challenges to FERC’s orders allowing the allocation of costs for network upgrades.  Southwest Power Pool, Inc. (“SPP”) assigned costs of more than $100 million to Clear Creek to pay for upgrades required on SPP’s system to accommodate the interconnection of Clear Creek’s wind turbine-powered electrical generation project (the “Project”).

Executive Summary

On March 21, the Federal Energy Regulatory Commission (FERC or the Commission) issued Order No. 2023-A (Final Rule), which reaffirmed aspects of Order No. 2023 — the Commission’s landmark order updating its generator interconnection procedures. As detailed further in this summary, the Commission largely upheld Order No. 2023, including some of the more controversial aspects of the order, such as penalties and the transmission capacity “heat map,” and provided further clarity on other aspects.

On January 30, 2024, FERC approved, subject to condition, PJM’s proposal to reform its Reliability Pricing Model, including resource adequacy risk modeling, capacity accreditation, testing requirements for capacity resources, and the Capacity Performance stop loss (“Modeling Enhancements Filing”). In that same order, FERC approved PJM’s proposal to replace its previously effective average Effective Load Carrying Capability (“ELCC”) capacity accreditation method with a marginal approach, effective December 12, 2023. The order directed PJM to submit a compliance filing to make certain revisions to its proposal, which PJM subsequently submitted on February 16, 2024. Additionally, on February 6, 2024, FERC rejected a companion PJM proposal to modify the rules governing its Market Seller Offer Cap and Capacity Performance construct and adopt a forward-looking Energy and Ancillary Service (“EAS”) offset for purposes of calculating the Minimum Offer Price Rule (“MOPR”) and offer cap.

On November 30, 2023, the Commission denied a waiver request and a request for remedial relief from Ridgeview Solar LLC (“Ridgeview Solar”). Ridgeview Solar had sought a waiver or remedial relief from the procedural deadline in section 212.4 of the PJM Interconnection, L.L.C. (“PJM”) Open Access Transmission Tariff (“Tariff”) to post security after the deadline outlined in the section.