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FERC Reforms on Generator Interconnection Procedures and Agreements: Final Rule and Next Steps for Counsel

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, September 20, 2023

Recorded event now available

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This CLE webinar will provide counsel guidance on the final rule recently issued by the Federal Energy Regulatory Commission (FERC) on reforms to generator interconnection procedures and agreements. The changes are intended to address very long queues and related delays that have plagued generation developers seeking to interconnect to the electricity grid. The panel will discuss key items included in the final rule, and practical implications for transmission providers and generation developers.


On July 28, 2023, the FERC issued Order No. 2023, its final rule to revise the pro forma generator interconnection procedures and agreements. Key changes include the shift to a “first-ready, first-served” annual cluster study process, new requirements for generator site control and deposits, tighter timelines for transmission providers to conduct studies and associated penalties for delays, and removal of the “reasonable efforts” standard for transmission providers to meet deadlines for interconnection studies.

The final rule requires compliance filings later this year by transmission providers, including RTO/ISOs and stand-alone utility systems. It also provides transition rules for generation projects already in the queues. Counsel must be prepared to advise transmission providers and generation developers on the changes made by the new rule, and the upcoming transition.

Listen as our panel discusses key items included in the final rule, revisions to pro forma generator interconnection procedures and agreements, "commercial readiness" requirements on new generator interconnection applicants, implications of “independent entity” variations for ISO/RTO interconnection procedures, and other critical provisions under the final rule.



  1. FERC final rule on generator interconnection
    1. Cluster studies
    2. Site control and commercial readiness requirements
    3. Deposits and penalties
    4. Allocation of network upgrade costs
    5. Affected system studies
    6. Co-located generators and surplus interconnection service
    7. Transition provisions
  2. Implications for transmission providers and interconnection customers
    1. Compliance approaches for transmission providers
    2. Independent entity variations for ISO/RTOs
    3. Comparability of interconnection procedures by PMAs and non-jurisdictional transmitting utilities
    4. Opportunities and risks for interconnection customers


The panel will discuss these and other key issues:

  • What are the key provisions of Order No. 2023?
  • What is the impact on transmission providers, including RTO/ISOs?
  • What issues may arise regarding site control and commercial readiness in light of the final rule?
  • Opportunities and challenges under the new regime for timely interconnection studies?
  • Likelihood of future litigation over elements of Order No. 2023 elements.
  • What are the key transition provisions under the final rule?
  • What is the timeline for implementation?
  • Will future legal challenges to Order 2023 disrupt its implementation?


Nelson, Joseph B.
Joseph B. Nelson

Van Ness Feldman

Mr. Nelson has over thirty years of experience providing counsel to clients on electric regulatory and environmental...  |  Read More

Smith, Douglas W.
Douglas W. Smith

Van Ness Feldman

Mr. Smith represents clients on regulatory and policy matters before the Federal Energy Regulatory Commission (FERC)...  |  Read More

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