Generator Interconnections

BGM has worked with clients for many years to negotiate and secure regulatory approval of generator and transmission interconnection and coordination agreements. Recognizing our unique expertise in this area, the Edison Electric Institute and a number of transmission utilities retained us to respond to FERC’s decision in 2002 to standardize generator interconnection procedures and agreements. One of our attorneys served as lead counsel for transmission-owning electric utilities in FERC’s rulemaking proceedings in 2003-2004 to establish large generator interconnection procedures and in 2005-2006 to establish small generator interconnection procedures. Through this process, we were instrumental in fashioning workable procedures for both utilities and the interconnected generators.

We have worked extensively with transmission owners (both individually and within large regional transmission organizations) to implement standardized interconnection procedures and to negotiate and draft related agreements. This work has included the development of standard interconnection forms such as the generator interconnection application, the feasibility study agreement, the system impact study agreement and the facilities study agreement. We also have represented clients in litigation concerning generator interconnection issues.

We have learned from experience that the generic, nationwide generator interconnection procedures developed as a result of FERC’s desire for standardization do not address all circumstances adequately. In particular, as FERC now understands, the standard interconnection practices may not fit the unique circumstances of geographically-isolated generation resources such as wind and solar facilities. Consistent with our history of staying at the forefront of the industry on such issues, we are working with a number of clients to implement groundbreaking interconnection procedures and agreements that will address the circumstances of renewable resource interconnection requests in a fair and efficient manner.