How DOE’s Proposed Large Load Interconnection Process Could Unlock the Benefits of Load Flexibility

Abstract

On October 23, Department of Energy (DOE) Secretary Chris Wright issued a letter directing the Federal Energy Regulatory Commission (FERC) to consider an Advanced Notice of Proposed Rulemaking (DOE ANOPR) to establish rules for the interconnection of large electricity loads to the transmission system. DOE seeks to ensure that “all Americans and domestic industries have access to affordable, reliable, and secure electricity.”1 Unlike FERC’s primary and longstanding role regulating generator interconnection to the transmission system, FERC has not asserted jurisdiction over load interconnections to date. The DOE ANOPR will therefore set off intense debate on the legal basis for FERC’s jurisdiction over large load interconnections in addition to its substantive proposals.