FERC Large Load Interconnection Family Portrait

FERC recently issued show cause orders to each of the six regional grid operators regarding the timely and efficient integration of large loads. These documents were labyrinthine, procedural, and legalistic — to an audience that craves tables, FERC prepared a full course of footnotes.

FERC Large Load Show Cause comparison preview. Full access available with Halcyon subscription.

In the orders, FERC requested the RTOs provide information and proposals related to five reform categories: transmission service and study processes, cost shifting and transparency, co-location and behind-the-meter, new transmission services for flexible large loads, and study procedures for electrically proximate generation. FERC requested responses within a 60 day window, allowing for 90 day extensions (which every grid operator took).

How much faster could large load conversations move if all the constituents knew the current state-of-play across all the RTOs/ISOs? FERC has effectively started the race, but provides very little visibility into how the racers are progressing, or how to check.

Instead, the journey of any single large load stakeholder looks something like Joseph Campbell’s Hero’s Journey: a path of false starts and dead ends. Just when they’re about to give up, they find, buried in the footnotes of some arcane document, their needed fact.

That’s just one fact from a single RTO. Pity the poor analyst who has to do it many times over (even for the jurisdictions that don’t have the requisite assets) and again for every committee meeting, and then again for every docket update.

Halcyon’s goal is to use our systems to travel those winding paths for our customers and shorten the distance they have to travel for answers.

Our customers span every spectrum of energy stakeholder, so our large load process starts with asking them: what are your challenges and concerns? We hear very frequently that they don’t know what they don’t know, and don’t want to be blind-sided. They have teams of analysts trying to assemble this information running headlong into the same challenges again and again.

They want a crosswalk that gets them straight to the answers:

• What specific changes are being proposed? And in what documents and forums?
• What stage of the processes are being targeted – from initial readiness screening to eventual real-time grid operations?
• What stage of development is the proposal – conceptual, stakeholder discussions, filed at FERC, operative?
• How are the proposals similar across regions? How, and why, are they different?

Today we're excited to announce our Large Load Show Cause RTO/ISO Comparison — a living analysis of grid operator response to FERC’s five key issues. (All existing Halcyon all-access subscribers and Large Load Tariff Tracker subscribers can download the full analysis now.)

Across the five reform categories FERC proposed, we identified nearly 30 individual solutions, spanning everything from gen-side intake scoring and queue resequencing in CAISO’s Interconnection Process Enhancements initiative to co-location exit policing in Texas. We linked each entry back to its underlying source material, searchable and queryable directly on our platform. You can view these documents now by starting a free trial.

The birds-eye-view brings clarity. ISO-NE, for example, has thirteen conceptual mechanisms (mostly template responses that check FERC boxes) while MISO has seven items already in development, and four flagged as operative.

While these are almost all about better taking advantage of the grid’s existing headroom, the more important point is that the patterns are easy to identify

Before departing, let’s look at the family photo. ERCOT’s Batch Zero process proposes applying its “Self-Limiting Facility” (SLF) concept to large loads, which physically enforces power flow limits at the point of interconnection through breaker logic and reverse-power relays. That’s akin to MISO’s Zero Injection Generator Interconnection Agreement (ZGIA) — a contractual constraint, instead of a physical one — on the co-located generator, which commits to never export power to the grid.

Next, we have the grandfather, SPP’s High Impact Large Load (HILL), giving its operators the ability to remotely disconnect the load and cap its ramp rates. Bearing striking resemblance: NYISO’s conceptual solution capping large load bids at $200/MWH in both the Day-Ahead and Real Time markets (both mandatory as well as market-based) curtailing itself the moment conditions get stressed.

Our family is getting bigger every day, by design. How to deal with misbehavior? SPP is considering  a penalty structure for curtailable large loads that do not follow dispatch instructions. How to get paid? Under SPP’s Price Adaptive Load (PAL) service proposal, large loads would forgo real-time compensation ordinarily paid for demand response in exchange for a lower non-firm transmission rate. How will I find my better half? NYISO’s proposed Partner Program lets load do just that or use NYISO as a match-maker. What recourse does a jilted generator have? SPP has a proposal for how to compensate generators who are brought online to support a large load that doesn’t materialize in real time.

We’re actively cataloging and comparing the entire genealogy. Click here to download a free preview.