• Comments of the U.S. Chamber of Commerce on Improvements to Generator Interconnection Procedures and Agreements under RM22-14-000

October 13, 2022

Dear Secretary Bose: The U.S. Chamber of Commerce and its Global Energy Institute (collectively, “the Chamber”) appreciate the opportunity to submit these comments on the Notice of Proposed Rulemaking (“Interconnection NOPR”)[1] issued by the Federal Energy Regulatory Commission (“FERC” or “Commission”) on June 16, 2022. The Interconnection NOPR bifurcates from broad regional transmission planning issues the Commission’s standardized generator interconnection procedures and large and small generator interconnection agreements that were all together addressed in the Commission’s far-ranging Advance Notice of Proposed Rulemaking issued last year.[2] The ANOPR teed up a number of inquiries and potential policy modifications concerning the broad transmission planning, generator interconnection, and associated cost allocation processes overseen by FERC.[3]

In response to the Commission’s separate issuance of a rulemaking focused on regional transmission planning,[4] the Chamber submitted detailed comments on August 17, 2022.[5] The Interconnection NOPR now turns the focus of the Commission and relevant stakeholders to the Large Generator Interconnection Procedures (“LGIP”) and the Large Generator Interconnection Agreement (“LGIA”) – along with their newer counterpart small generator interconnection procedures and agreement – which have governed the process and associated terms and conditions for generator interconnections for nearly twenty years.