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Policy and Cost Allocation Considerations for Large Electric Load Interconnections: Emerging Policy Trends in Rate Structures, Interconnection, and Cost Impacts on Other System Users

Load growth in the United States is rapidly increasing: load from data centers alone has tripled over the past decade, and this growth is forecasted to continue accelerating. These and other large electric loads (LELs) promise economic benefits at the state and local level, but their deployment has also led to increasing concerns about grid impacts and potential cost shifts onto other ratepayers. Legislators, regulators, and other stakeholders are increasingly proposing and enacting policies in effort to balance these and other considerations. This white paper reviews state-level legislation, selected utility rate cases, and relevant federal orders in an effort to describe and categorize relevant trends in policies related to LEL cost allocation, interconnection, and deployment. Policy categories identified through this review include tax incentives, rate actions, and requirements related to interconnection, permitting, and reporting. By offering a taxonomy of policies, this white paper aims to offer a resource to policymakers and other stakeholders navigating this transformative moment for the grid.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Small Hydropower Interconnections: Best Practices

Small hydropower projects have been the predominant source of capacity growth of U.S. hydropower for more than a decade, and they present the most cost-effective and environmentally permissible avenues for hydropower growth (DOE 2016; Johnson et al. 2018). However, interconnection to electricity distribution and transmission grids is a persistent barrier due to cost surprises and schedule overruns. As a culmination to research into the status and requirements of small hydropower interconnection across the United States, this paper presents the best practices for setting interconnection standards that can improve the process for small hydropower developers. As part of the analysis, the interconnection costs are compared between small hydropower, solar, and wind. The analysis of the small hydropower interconnection landscape across the United States was carried out by Pacific Northwest National Laboratory (PNNL) and Oak Ridge National Laboratory (ORNL) with support from the U.S. Department of Energy Water Power Technologies Office. The research team was guided by a Technical Advisory Group (TAG) and gleaned data from publicly available sources, such as the HydroSource database (ORNL 2020) and interconnection queues hosted by utilities, balancing authorities, independent system operators (ISOs), and regional transmission organizations (RTOs). The results of this work are shared in a series of papers detailing the state of small hydropower in the United States (“Small Hydropower Interconnections: Small Hydropower in the United States”), the variety of state interconnection processes to connect power generators with the grid (“Small Hydropower Interconnections: State Interconnection Processes”), and an analysis of the interconnection processes (“Small Hydropower Interconnections: Analysis of Interconnection Processes”). In this, the final paper in the series, best practices for interconnection processes (“Small Hydropower Interconnections: Best Practices”) are identified from the solar energy and distributed wind energy industries that are transferrable to small hydropower development. This information will help overcome barriers to future small hydropower development.

13 HYDRO ENERGY↗

A review of United States energy-only generator interconnection service policy and considerations for reform

Grid interconnection has emerged as a significant obstacle to the development of new electricity resources. There is growing interest in energy-only interconnection, which is an interconnection service option meant to allow the interconnection of new generators without ensuring their energy deliverability during all hours through the transmission system to customers. This approach potentially avoids upfront congestion-related transmission upgrades but could increase curtailment risk. Interest in energy-only interconnection is shaped by incomplete understanding of how interconnection policy functions in different jurisdictions, a knowledge gap that makes it difficult to determine how energy-only interconnection might be better used or re-designed. In this paper, we provide a regulatory review of energy-only interconnection in U.S. interconnection policy and practice, identifying jurisdictions in which rules are close to -or farther from-the theoretical concept of energy-only interconnection service. We find substantial jurisdictional differences in how energy-only interconnection is implemented, driven by differences in resource adequacy frameworks, real-time transmission operations, and state-level procurement practices. U.S. regulators have preferred local jurisdictional flexibility over federal prescription of interconnection study methods and procedures, which also contributes to differences among regions. Such findings raise fundamental questions about whether competition policies in electricity markets should extend beyond spot energy markets and into more prescriptive guidelines around interconnection rules and market entry. This paper sheds light on tensions that energy-only interconnection raises in allowing generators to access the transmission system on an as available basis and discusses how controlling thresholds for congestion-related network upgrades may be a barrier to electricity market entry.

Gorman, Will↗

Evaluating the Role of Pre-Application Reports in Improving Distributed Generation Interconnection Processes

Several tools have emerged in recent years to increase data exchange and transparency in the distributed generation interconnection process with the goal of reducing interconnection costs. One example is pre-application reports. These reports are generated by a utility at the request of prospective interconnection applicants to provide technical information about a specific point of interconnection. Formal pre-application report processes have been established in 12 states at the distribution system level as well as at the transmission level by the Federal Energy Regulatory Commission. These reports are a relatively low-cost method of informing applicants of grid conditions and potential interconnection limitations early in the interconnection process. Thus, this information may encourage interconnection in locations with little to no detrimental impact to the grid and low interconnection costs. Increasing transparency of these grid conditions may also enable applicants to better plan for interconnection costs and requirements, such as system modifications and complex engineering studies. By providing these benefits, pre-application reports are expected to reduce the number of canceled interconnection applications. This report evaluates this hypothesis by quantifying the impact pre-application report processes have on application approval rate. To evaluate this hypothesis this analysis uses utility-reported distributed generation interconnection data from four utilities in Massachusetts. The analysis considers a four-year time period before and a five-year period after pre-application report process were implemented. The results indicate that once pre-application reports were required for projects 500 kilowatts and larger the approval rate of applications increased by 24%. This suggests that pre-application reports may decrease the percentage of canceled projects. However, due to data and other limitations, these results do not necessarily connote causation. This analysis is an important first step and a prerequisite for future analyses regarding the impact of pre-application reports. Other potential impacts also recognized during this analysis included reducing sunk costs and reducing the number of projects requiring a complex review. Collection of additional data would allow for forming more robust conclusions about these impacts in the future. Such data include circuit-level data, interconnection cost data, policy and regulatory background, national-level data, and utility and developer attributes. These data provide necessary context to account for interrelated factors while evaluating pre-application reports. Filling such knowledge gaps ultimately aids regulators in applying best practices within the industry. As more and more distributed energy resources are interconnected, these best practices will become an integral aspect of efficiently transitioning to an electric grid capable of meeting the needs of the 21st century.

14 SOLAR ENERGY↗

Generator Interconnection Costs to the Transmission System in non-ISO Balancing Authorities [Slides]

Electric transmission system operators—including Independent System Operators (ISOs), Regional Transmission Organizations (RTOs), and utilities—require proposed power plants to undergo a series of interconnection studies before connecting to the grid. These studies assess what transmission upgrades or new infrastructure may be necessary and assign the associated costs to the project. Lawrence Berkeley National Laboratory has compiled, aggregated, and cleaned interconnection cost data, originally for ISOs/RTOs, and now for five non-ISO Balancing Authorities: PacifiCorp, Bonneville Power Authority, Duke Energy Progress, Duke Energy Carolinas and Duke Energy Florida. Insufficient transparency in interconnection cost data may contribute to rapidly expanding interconnection queues, with active queue capacities tripling between 2020 and 2024 in the studied BAs. Most projects withdraw after receiving high interconnection cost estimates. Interconnection costs have increased since the early 2000s, with average costs for "complete" projects reaching $194/kW between 2018 and 2024. Active queue projects and withdrawn projects incur substantially higher costs, primarily due to rising network upgrade costs. Recent interconnection costs in non-ISO balancing authorities are higher than in ISO regions, potentially due to a greater willingness to pay among developers. Utility-scale solar, wind, and storage projects have interconnection costs that exceed those for natural gas. However, when focusing on projects that do not withdraw from the queue, the interconnection costs for these technologies are more similar to natural gas projects. Other key findings include: (1) Larger generation projects benefit from lower proportional interconnection costs, (2) capacity transmission service (NRIS) often requires additional network investments, and (3) projects with high network upgrade costs are often clustered geographically. The dataset includes results from 2,104 interconnection studies conducted between 2000 and 2024, covering projects that are operational, withdrawn, or still progressing through the study process. The Excel file contains (a) the complete project-level interconnection cost dataset, and (b) seven additional tabs summarizing cost metrics across dimensions such as time, market structure, cost category (point of interconnection vs. broader network upgrades), fuel type, service type (ERIS vs. NRIS), generator size, and geography.

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Small Hydropower Interconnections: Small Hydropower in the United States

Small hydropower projects, which we define as generators below 20 MW in capacity have been the predominant source of hydropower growth over the past decade and create the most cost-effective and environmentally permissible avenues for new hydropower installation in the United States (DOE 2016; Johnson et al. 2018). Small hydropower developers across the United States have found that interconnecting these projects with the grid can be challenging due to unexpected costs and schedule overruns. Understanding the interconnection challenges and improving the process may allow more small hydropower projects to be successful. Noting these challenges, the U.S. Department of Energy Water Power Technologies Office enlisted Pacific Northwest National Laboratory (PNNL) and Oak Ridge National Laboratory (ORNL) to investigate the small hydropower interconnection landscape across the United States. To begin to analyze the existing interconnection processes and challenges facing small hydropower, the state of small hydropower development in the U.S. must first be described to understand the characteristics of the industry. The first in a series, this paper presents the state of small hydropower projects in the U.S. to describe their type, location, and size based on data extracted from the HydroSource database (ORNL 2020). The following papers in the series will detail the variety of state interconnection processes to connect power generators with the grid (“Small Hydropower Interconnections: State Interconnection Processes”), analyze these interconnection processes (“Small Hydropower Interconnections: Analysis of Interconnection Processes”), and present best practices in interconnection processes (“Small Hydropower Interconnections: Best Practices”) that will help overcome barriers to future small hydropower development.

13 HYDRO ENERGY↗

Generator Interconnection Cost Analysis in the Midcontinent Independent System Operator (MISO) territory

Electric transmission system operators (ISOs, RTOs, or utilities) require new large generators seeking to connect to the grid to undergo a series of impact studies before they can be built. This process establishes what new transmission equipment or upgrades may be needed before a project can connect to the system and assigns the costs of that equipment. Berkeley Lab has collected interconnection cost data from interconnection studies for the Midcontinent Independent System Operator (MISO), representing nearly 50% of all projects requesting interconnection from 2010 to 2020. Project-level cost summary data are available for download on this page. We find: -Average interconnection costs have grown as the number of interconnection requests have escalated -Projects that have completed all required interconnection studies have the lowest cost compared to applicants still actively working through the interconnection process or those that have withdrawn. -Broader network upgrade costs are the primary driver of recent cost increase. -Potential interconnection costs for wind, storage, and solar are larger than for natural gas -Larger generators have greater interconnection costs in absolute terms, but economies of scale exist on a per kW basis. -Interconnection costs vary by location Berkeley Lab will publish a series of short analytical papers of generator interconnection costs to the transmission system for MISO, PJM, SPP, ISO-NE and NYISO, which you can find at https://emp.lbl.gov/interconnection_costs.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Interconnection Cost Analysis in the PJM Territory

Electric transmission system operators (ISOs, RTOs, or utilities) require new large generators seeking to connect to the grid to undergo a series of impact studies before they can be built. This process establishes what new transmission equipment or upgrades may be needed before a project can connect to the system and assigns the costs of that equipment. Berkeley Lab has collected interconnection cost data from interconnection studies for the PJM Territory, representing nearly 86% of all new unique generators requesting interconnection from 2000 to 2022. Project-level cost summary data are available for download on this page. We find: -Average interconnection costs have grown as the number of interconnection requests have escalated -Projects that have completed all required interconnection studies have the lowest cost compared to applicants still actively working through the interconnection process or those that have withdrawn. -Broader network upgrade costs are the primary driver of recent cost increase. -Potential interconnection costs for wind, storage, and solar are larger than for natural gas -Larger generators have greater interconnection costs in absolute terms, but economies of scale exist on a per kW basis. -Interconnection costs vary by location Berkeley Lab will publish a series of short analytical papers of generator interconnection costs to the transmission system for MISO, PJM, SPP, ISO-NE and NYISO, which you can find at https://emp.lbl.gov/interconnection_costs.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Interconnection Cost Analysis in ISO-New England

Electric transmission system operators (ISOs, RTOs, or utilities) require new large generators seeking to connect to the grid to undergo a series of impact studies before they can be built. This process establishes what new transmission equipment or upgrades may be needed before a project can connect to the system and assigns the costs of that equipment. Berkeley Lab has collected interconnection cost data for 194 projects in New England from interconnection studies performed between 2010 and 2021. Project-level cost summary data are available for download on this page. We find: -Interconnection costs have grown over time, especially for projects that withdraw. -Interconnection costs are highest for onshore wind, followed by solar and storage. Natural gas and offshore wind projects tend to cost less to interconnect, in comparison. -Economies of scale exist for solar and possibly storage projects, but not for other resource types. -Wind and solar projects requesting capacity network resource interconnection service have higher interconnection costs, despite being evaluated using the same interconnection standard in the analyzed studies. -Low and high interconnection costs can be found throughout the ISO-NE footprint. -Costs are split fairly evenly between investments at the point of interconnection and within the broader network for active and withdrawn projects, while complete projects incur most costs at the point of interconnection.

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Queued Up: 2025 Edition – Characteristics of Power Plants Seeking Transmission Interconnection As of the End of 2024 [Slides]

Electric transmission system operators (ISOs, RTOs, or utilities) require proposed power plants seeking to connect to the transmission grid to undergo a series of impact studies before they can be built. This process establishes what new transmission equipment or upgrades may be needed before a project can connect to the system and assigns the costs of that equipment. The lists of projects in this process are known as “interconnection queues”. In collaboration with interconnection.fyi, Berkeley Lab compiled, aggregated, and cleaned interconnection queue data from >50 transmission grid operators (7 ISO/RTOs and 49 non-ISO balancing areas), which collectively represent ~97% of currently installed U.S. electric generating capacity. The dataset includes requests submitted to queues through the end of 2024, and only includes requests seeking to connect to the transmission grid (not distribution-connected or behind-the-meter projects). The files below include both a PDF report and an Excel data file. The PDF report analyzes interconnection data and metrics through the end of 2024. The Excel data file includes (a) the full project-level interconnection queue dataset through 2024, (b) a codebook (data dictionary) describing each data field, and (c) 35 additional tabs featuring tables summarizing a range of interconnection metrics. Key highlights from the Queued Up: 2025 Edition (featuring data through 2024) include: • As of the end of 2024, there were ~10,300 projects actively seeking grid interconnection in the U.S., representing 1,400 GW of generation and approximately 890 GW of storage. • Historic withdrawal rates alongside relatively fewer new requests resulted in a 12% decrease in total active queue volume compared to the prior year. • Active natural gas capacity (136 GW, +72% year-over-year) increased in 2024, while solar (956 GW, -12%), storage (890 GW, -13%), and wind (271 GW, -26%) capacity decreased. • 408 GW of capacity already has a draft or executed interconnection agreement (IA) but has not yet reached commercial operations. • The time projects spend in queues before reaching COD is increasing. For the regions with available data, the median duration from IR to COD has doubled from <2 years for projects built in 2000-2007 to over 4 years for those built in 2018-2024. • Ultimately, most of this proposed capacity will not be built. Only 13% of capacity that submitted interconnection requests from 2000-2019 had reached commercial operations by the end of 2024; 77% of that capacity had been withdrawn and 10% was still active. • FERC Order 2023 and various other reforms are being implemented. These are important measures to reduce interconnection bottlenecks and enhance grid system reliability, but it is too early to measure and assess their full impact. • New additions for the 2025 edition include: (a) additional detail on data processing and gaps; (b) updates on interconnection reforms; (c) new analysis on interconnection agreements, and more.

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A Guide to Updating Interconnection Rules and Incorporating IEEE Standard 1547

The intent of this paper is to support local authorities in adopting the most current technical requirements for interconnecting distributed energy resources (DERs) to the electric distribution system as specified in the Institute of Electrical and Electronics Engineers Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces (IEEE Std 1547-2018). To create interconnection rules that successfully address policy goals, market trends, and technical requirements, state regulators need to be well informed of DER integration considerations. Interconnection processes and technical issues often overlap; the two are not easily segregated, and they are often considered and evaluated concurrently within the context of interconnection rulemaking. Accordingly, this paper addresses both the technical issues and related process considerations. A lack of uniform and transparent procedures for addressing interconnection rule changes can result in implementation issues or inefficiencies, such as unclear, lengthy, and complicated interconnection rules that can increase distributed generation "soft costs" (i.e., non-hardware costs). This can further delay the deployment of DERs and jeopardize time-constrained national and state policy goals, such as renewable energy targets, or limit participation in emerging techno-economic trends. Additionally, misconstructed interconnection rules are at risk of becoming mired in stakeholder conflicts. This guide addresses the concerns of electric service regulators from both the process and technical standpoints by presenting a structured, step-by-step approach to developing and updating existing interconnection rules. In this document, the process of developing and updating interconnection rules is subdivided into three steps: (1) determining the context (stakeholders and major drivers); (2) developing the rule, including updating technical requirements; and (3) maintaining and revising the rule over time.

14 SOLAR ENERGY↗

Use of Operating Agreements and Energy Storage to Reduce Photovoltaic Interconnection Costs: Technical and Economic Analysis

This report presents an analytical methodology to identify alternative options to manage interconnection costs and streamline interconnection timelines for distribution system-connected photovoltaic (PV) systems not co-located with load. Specifically, the report details the methodology and results of an analysis that: 1. Identifies potential grid violations that would be induced by a PV system requesting interconnection to a distribution circuit; 2. Identifies multiple technically viable options for mitigating the potential violations, including infrastructure upgrades, downsizing the PV system size, curtailment of PV, and addition of battery energy storage; 3. Defines the required technical operating parameters of the system in order to mitigate all potential violations (the "Operating Envelope"); 4. Compares the economics of each option, from the PV developer's perspective. The analysis supports the ongoing evolution of interconnection standards for combined PV and energy storage systems by providing a methodology to define allowable maximum export limits during each hour. The methodology presented could be used by utilities as part of the interconnection study process, to inform negotiations with DER developers and the drafting of mutually acceptable interconnection agreements. The resulting technical operating parameters could be included as part of the interconnection service agreement (ISA) between the system owner and the utility company. The companion report to this analysis, Gill et al. (2022), details the envisioned framework for the implementation of the technical operating parameters.

14 SOLAR ENERGY↗