Commissioner Allison Clements Statement
September 24, 2021
Docket No. ER21-2530-000

I concur with this order because, given the circumstances, CAISO has fashioned a reasonable proposal to process its Cluster 14 interconnection queue as expeditiously as possible.  Nevertheless, it must be acknowledged that the results are far from ideal, with more than a year of delay in CAISO’s interconnection process and no interconnection queue opening in 2022 unless circumstances change.  The sheer volume of generation in CAISO’s interconnection queue, 246 GW, suggests the need for consideration of deeper reform to CAISO’s interconnection and transmission planning process. 

CAISO’s circumstances are not unique.  As of May 2021, there were over 755 GW of generator capacity in interconnection queues in the United States.[1]  Time spent by projects in the interconnection queue has increased in regions across the country, while the percentage of projects reaching commercial operation has declined.[2]  A vast majority of the new supply resources in the interconnection queue are wind and solar, with energy storage resources also making up an increasing percentage.[3]  Interconnection queues over-flowing with these resources have been spurred by the tremendous potential for new, clean resources to provide customers with lower cost power, but customers will only be able to access those opportunities if these resources can be efficiently integrated.  The quagmire that CAISO faces is yet another compelling example of the need to holistically unwind the thicket of challenges posed by current interconnection queues, to arrive at regional interconnection and planning processes that more efficiently integrate new resources into the grid.

A range of potential solutions to these challenges is explored in the Commission’s Advance Notice of Proposed Rulemaking on Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection.[4]  Given that the challenges CAISO faces in this docket are shared by other regions, that is the appropriate forum to examine solutions.  The Commission should press forward without delay.

For these reasons, I respectfully concur.


[1] See Joseph Rand et al., Queued Up: Characteristics of Power Plants Seeking Transmission Interconnection as of the End of 2020, Lawrence Berkeley National Laboratory, May 2021, at 3, available at

[2] Id. at 6, 9.

[3] Id. at 3, 12.

[4] See generally Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, 176 FERC ¶ 61,024 (2021).

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