PJM on June 3 presented a first read of a proposal to revise how it determines whether generation interconnections are subject to state or federal jurisdiction based on voltage or cost-recovery methodology.

The proposal would introduce a “bright-line test” that would designate generators interconnecting to facilities below 69 kV as being under state jurisdiction and thus required to obtain a wholesale market participation agreement (WMPA). Resources connecting to higher-voltage assets would be designated as under federal jurisdiction and required to obtain a generation interconnection agreement.

The proposal also includes a “backstop” where a point of interconnection could be classified as federal or state jurisdiction independent of the voltage depending on how the transmission owner, FERC or relevant electric retail regulatory authority has determined the cost-recovery paradigm.

Presenting to the Planning Committee, PJM Associate General Counsel Thomas DeVita said the aim of the proposal is to maximize the hours staff spend processing the more complicated studies needed on resources connecting to transmission assets while still maintaining visibility on distribution-level interconnections. He said it takes staff substantially longer to process a GIA application compared to a WMPA.

Under the status quo “first use” model for determining jurisdiction, the first resource interconnecting to a distribution facility for the purpose of participating in wholesale markets is classified as being under state jurisdiction and required to obtain a WMPA. All subsequent resources using that point of interconnection are considered “dual use” and considered under FERC jurisdiction. DeVita said PJM’s model follows FERC’s approval of an ISO-NE proposal to disclaim jurisdiction over all distributed energy resources. (See FERC Approves Changes to ISO-NE DER Interconnection Process.)

PJM Vice President of Planning Jason Connell said system impact studies for a generator pursuing a WMPA are completed by electric distribution companies rather than the RTO and produce a simpler agreement for it to process.

Exelon Director RTO Relations and Strategy Alex Stern said it makes sense to make improvements to the interconnection process that have been demonstrated to be beneficial in other RTOs and could carry benefits for developers as well.

“Developers interconnecting at the distribution level might have less responsibilities at the regional grid level and in fact avoid certain responsibilities entirely, which could perhaps be a benefit to them on top of less process with PJM,” he said.

The proposal includes a dispute resolution process, beginning with the developer attempting to resolve issues directly with TOs and EDCs. If PJM determines a dispute involves its governing documents, the conflict could be arbitrated through the RTO’s tariff-defined resolution process.

If granted by the commission, DeVita said PJM is planning a go-live date in 2026 and anticipates that the Planning Community online portal could be updated to allow members to select facilities and determine whether a generator interconnecting at that site would require a GIA or WMPA.