VALLEY FORGE, Pa. — PJM on March 19 presented the Markets and Reliability Committee with a proposed settlement with several clean energy associations and developers on its site control requirements for new generation projects (ER25-1544, EL25-22).
Filed with the commission March 10, the proposed tariff revisions would codify a set of rules on when developers may add or remove parcels from a project that is less restrictive than the reading PJM has advanced in its Order 2023 compliance filing (ER24-2045). The settlement would resolve a complaint from American Clean Power Association, Solar Energy Industries Association and Advanced Energy United. It also was signed by EDF Renewables, which had raised issues with the compliance filing.
The language in the settlement would replace a PJM proposal to revise Manual 14H to codify its interpretation, which several developers throughout the stakeholder process have argued is overly onerous. The MRC voted by acclamation to defer action on the manual revisions until FERC action on the settlement or 60 days from its meeting, whichever is sooner. (See “Voting on Site Control Requirement Manual Revisions Deferred Pending Settlement,” PJM MRC/MC Briefs: Feb. 20, 2025.)
PJM Director of Interconnection Planning Donnie Bielak said if the settlement is approved, conforming revisions to the manual would be required. If it is rejected, he said the RTO’s preference would be to pursue its originally proposed manual revisions.
Senior Engineer AJ Lambert said the key difference between the manual revisions and the settlement language is that in the latter, PJM would not require site control for parcels no longer needed for a project to be completed. It also would modify the decision point requirements and add clarification where there have been interpretation issues.
Changes to site plans would be permitted under the settlement so long as the developer can demonstrate there would be no impact to the “timing of milestones or transmission owner construction schedule.” By making such a change, the developer would waive the ability to request milestone extensions “related to permits or other land issues.”
Demonstration of site control over parcels no longer used on the site would not be required under the settlement. Any changes to interconnection facilities or switchyards would not be permitted if they would affect system impact or facilities studies.
The tariff currently requires that any changes to a project footprint be adjacent to the parcels included in the original project application, which would be expanded under the settlement to allow easements connecting parcels.
PJM’s proposed manual revisions have been deferred several times since being endorsed by the Planning Committee in December 2024, owing to the settlement negotiations. Discontent over the lack of insight into what was holding up consideration of the language led the MRC initially to vote against another deferral in February, but it reconsidered after PJM and EDF said they were confident an agreement was imminent. (See “Stakeholders Endorse Quick-fix Revisions to Site Control Manual Requirements,” PJM PC/TEAC Briefs: Dec. 3, 2024.)
The revisions would allow parcels to be added to a project at Decision Point 1 (DP1), so long as the land is adjacent to the site or evidence of connecting easements is provided. Parcels also could be removed at this point if the project continues to meet the minimum acreage and energy output defined in the project application.
While there would be no specific requirement to demonstrate site control at DP2, the proposed language would state, “Site control must be maintained throughout the cycle process.” Adding parcels also would be permitted at DP2, with the caveat that a one-year term would be imposed from the end of Phase 2 of the relevant study cycle.
No additions would be permitted at the final DP3, but reductions would be allowed so long as the acreage-per-megawatt and evidentiary requirements continue to be met. Once a generator interconnection agreement is signed, any site control changes would require a necessary study agreement to determine permissibility.
