On April 19, 2018, the Federal Energy Regulatory Commission (“FERC”) issued Order No. 845 to reform its generation interconnection procedures for large generators above 20 MW. FERC’s order represents the most significant change to FERC’s large interconnection processes since its landmark Order No. 2003 (issued in 2008), and is set to make the interconnection process for large solar resources more transparent, and give developers additional information on transmission provider modeling assumptions and study processes, which greatly impact cost allocations to prospective projects. Order No. 845 impacts all transmission providers under FERC’s jurisdiction, meaning transmission providers in RTOs/ISOs (but excluding ERCOT) and regulated jurisdictions will have to comply with the new rule.

FERC’s proposed reforms fall into three main categories: improving certainty for interconnection customers, promoting more informed interconnection decisions, and enhancing the interconnection process. By requiring transmission providers to post information related to study assumptions and methodologies, project developers will be able to more effectively understand their potential cost responsibility for project-related upgrades. Further, Order No. 845 imposes reporting requirements on transmission providers so that they will now need to publically post statistics related to their performance in meeting deadlines in the LGIP, which they must use “reasonable efforts” to meet (although these deadlines are still not mandatory).

Order No. 845 is set to be an important decision that will hopefully streamline project development timelines and remove uncertainty inherent in utility and RTO/ISO interconnection processes that are present in jurisdictions across the United States.