Miles Farmer

@mfarmer.bsky.social

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clean energy policy, strategy, and law

This proposal is not intended in any way to discourage public utilities from making filings to address these and similar issues under FPA section 205
Thirteenth, there must be a plan to implement these proposed reforms. We seek comment on appropriate transition plans, including the treatment of large load interconnections that are already being studied for interconnection.
Ninth, to the extent the interconnection customer is not the transmission owner, the interconnection customer shall be afforded the same (or equivalent) option to build as currently provided to generator interconnection customers.
Eighth, load and hybrid facilities should be responsible for 100% of the network upgrades that they are assigned through the interconnection studies. We seek comment on whether such costs should be offset through a crediting mechanism and, if so, over how many years.
Seventh, the interconnection study of large loads that agree to be curtailable and hybrid facilities that agree to be curtailable and dispatchable should be expedited. The system operator's ability to control such facilities through curtailment and/or dispatch must be sufficient for the system operator to integrate the facility into both operations and system planning. This ensures the timely and orderly addition of large loads to the transmission system in a safe, reliable, and non-discriminatory manner. We seek comment on whether this should be accomplished through a serial interconnection study process or by some other means. We also seek comment on appropriate deadlines for such an expedited study process, including whether such studies can be completed in 60 days.
Fourth, like generating facilities, load and hybrid facilities should be subject to standardized study deposits, readiness requirements, and withdrawal penalties. These provisions deter speculative projects and provide transmission providers with more useful information to more accurately forecast demand on their systems. We seek comment on the extent to which the existing study deposits, readiness requirements, and withdrawal penalties can be adopted. We also seek comment on whether additional commitments or financial penalties would be appropriate.
Third, to the extent practicable, load and hybrid facilities should be studied together with generating facilities. Such an approach will allow for efficient siting of loads and generating facilities and thereby minimize the need for costly network upgrades.
Second, consistent with the Commission's pro forma LGIP and LGIA, the reforms should only apply to new loads greater than 20 MW and, for hybrid facilities
There are at least four legaljustifications for the Commission's jurisdiction over such interconnections. First, like generator interconnections, large load interconnections are a "critical component of open access transmission servicc'v? that require minimum terms and conditions to ensure non-discriminatory transmission service.
On behalf of the American people, and given the urgency of this issue, I look forward to your consideration and final action (no later than April 30, 2026).
(d) In the performance of their functions, the members, em- ployees, or other personnel of the Commission shall not be respon- sible to or subject to the supervision or direction of any officer, em- ployee, or agent of any other part of the Department.
(i) For the purpose of section 552b of title 5, United States Code, the Commission shall be deemed to be an agency. Except as provided in section 518 of title 28, United States Code, relating to litigation before the Supreme Court, attorneys designated by the Chairman of the Commission may appear for, and represent the Commission in, any civil action brought in connection with any function carried out by the Commission pursuant to this Act or as otherwise authorized by law.
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