TBD – Further Queue Delays?

Amy Jo is Sr. Director of Policy & Market Strategy responsible for leading solar and energy storage policy and regulatory efforts throughout the U.S.  Her current roles includes guiding the Qcells development team with Order 2023 compliance filings made by RTOS and FERC jurisdictional utilities.

What is Order 2023?

Today it has arrived – published in the Federal Register 4/16/24 Order 2023A RM22-14.  This means that Order 2023 compliance filings are due on 5/16/24. On 5/16/24, we will find out if there are more delays to transitional or new clusters across the United States.

What is Order 2023?  Answer:  The most significant change is the move away from Federal Energy Regulatory Commission’s (FERC) historic “first come, first served” serial approach to interconnections in favor of a “first ready, first served” cluster study approach that requires generators to demonstrate commercial readiness to proceed through the queue.  So many other items were addressed in RM22-14 from allocating cluster study costs and cluster network upgrades to heatmaps and so much more.

But as of 4/16/24 – the industry is wanting to know what the final rules will be for the various Regional Transmission Organizations (RTOs) and utilities across the United States that are FERC jurisdictional.  In a matter of 30 days, we will all find out.

Known Queue Delays as of 4/15/24

I personally appreciate FERC not delaying new clusters in both APS and PacifiCorp, specifically:

1. APS – On 2/1/24, APS requested waiver of 2024 cluster in its entirety to open 4/1/25 and not 4/1/24 to avoid creating a backlog (ER24-1209) – FERC rejected 3/21/24 and at 4/11/24 APS Stakeholder Meeting, APS opened Cluster 24 on 4/1/24 for 45 days. Cluster 24 is subject to currently posted OATT even if APS makes additional changes in its next compliance filing. Subsequent changes would apply to later clusters.  The actual study will not start until the transitional cluster study has concluded (4th phase).
2. PacifiCorp – PacifiCorp sought a limited and one-time waiver of its tariff to forgo a 2024 Cluster Study and focus instead on preparing for an Order No. 2023-compliant Cluster Study opening January 1, 2025. The docket number is FERC Docket No. ER24-1273. On March 29, 2024, FERC denied PacifiCorp’s request for a limited and one-time waiver of its tariff to forgo a 2024 Cluster Study (ER24-1273). Therefore, PacifiCorp will proceed to hold its standard 2024 cluster study request window (April 1st – May 15th) under its existing tariff rules. Due to the denial, PacifiCorp will utilize a transitional cluster study as authorized by Order No. 2023-A. PacifiCorp will post its compliance filing once it has been filed with the FERC.

We already know that Midcontinent Independent System Operator (MISO) closed queue in 2023 and reopened on 3/18/24 – 4/18/24.

And right now, we know of these delays in upcoming Order 2023 compliance filings:

• California Independent System Operator (CAISO) – On 2/7/24, CAISO announced CAISO Cluster 16 delay/will not open in 2024 and expected to open Oct 2026.

• Cluster 15 timelines- 10/1-12/1 IR modifications permissible- but must have all aspects of GIR complete by 12/1. 12/31/24 final day to withdraw w/o penalty. 1/1/25-5/1/25 – CAISO to review IPE scoring criteria and determine which projects move on to study. 6/1/25 Cluster 15 cluster study begins.; Order 2023A compliance filing due by 5/16/24.

• New York Independent System Operator (NYISO) –delaying transitional cluster opening from 7/1/24 to 8/1/24.

The clock is ticking and TBD when we see the various ISO/RTO compliance filings start to roll in by 5/16/24 to know where there are further delays to transitional or new clusters. It is time to put the petal to the metal to a faster and cleaner energy transition.

To read more blog posts from Amy Jo Miller, please see her blog here.