On January 31, 2020, PacifiCorp submitted a proposal to FERC that would change its transmission interconnection process. For the last few years, PacifiCorp’s interconnection process has created a significant backlog of applications because its existing process wasn’t designed to handle the volume of applications that PacifiCorp now gets each year. The January 31 proposal came out of a stakeholder process initiated last summer designed to come up with a new interconnection process.
One of the most significant changes would move the “first-come, first-serve” serial queue process for applications to a “first-ready, first-served” cluster review process. PAC’s Notice of Queue Reform Filing provides a high-level summary of the other proposed revisions, found here. The full proposal that PacifiCorp submitted to FERC is here.
FERC issued a Notice of Deficiency letter on March 6, 2020, in response to PacifiCorp’s proposal, requesting additional information related to a number of PacifiCorp’s proposes changes. Notably, FERC asked how the proposed revisions would comply with PURPA, whether PacifiCorp intends to coordinate the proposed revisions and its upcoming RFP, and for additional clarity on what interconnection customers must provide to demonstrate the “readiness” of a project.
During the stakeholder process, PacifiCorp made clear that it intended to implement these changes to the interconnection process before issuing its 2019 all-source RFP, citing as justification a need to avoid a number of issues that arose in the Energy Vision 2020 RFP process. However, whether the two proceedings can actually line up depends on FERC approving PacifiCorp’s proposed changes relatively soon. Given the recent Notice of Deficiency, FERC may not approve these revisions as easily as PacifiCorp had hoped.
The ball is back in FERC’s court to review the application as supplemented by PacifiCorp’s response to the Notice of Deficiency. Unless FERC requests additional information, we should see a decision in the next few months.