PJM Proposes Effort to Respond to Interconnection Volume
PJM is proposing work for the rest of 2021 to address challenges caused by increasing interconnection queue volume.
Jason Connell, director of infrastructure planning for PJM, provided a first read of a problem statement and issue charge at last week’s Planning Committee meeting. Members have been working on the interconnection issue since October, Connell said, identifying 69 concerns and 135 suggestions covering 12 categories, including transparency, cost responsibility and dispute resolution.
Connell said the interconnection queue volume has more than tripled over the past three years, with PJM going from accepting around 400 projects per year to more than 1,000 in 2020 and even more slated for 2021.
On-time rates of feasibility and system impact studies have continually improved, Connell said, but the backlog of requests has increased, causing concern for PJM and its stakeholders as the RTO has had to divert resources to get the studies done on time.
PJM proposed several key work activities, including opportunities that can “positively impact the interconnection queue backlog,” Connell said. He added that about 1,600 projects are currently active in the queue and close to 2,000 could be in the queue by the end of March.
He said PJM is deciding whether to use a task force for reporting to the PC or scheduling special sessions of the PC to deal with the interconnection issue. The committee will be asked to approve the issue charge at its April meeting. Work on the initiative is expected to take place throughout 2021.
New Service Requests
Stakeholders questioned PJM’s proposal to extend its deadline for responding to new service requests, which the RTO said is necessary because of the large number of requests filed at the end of the queue window.
Connell provided a first read of the problem statement and issue charge and draft tariff language outlining the RTO’s proposed “quick fix.”
PJM processes new service requests under several parts of the tariff, Connell said, with the RTO administering two new queue windows each year — one from April 1 to Sept. 30 and another from Oct. 1 to March 31.
Connell said the current tariff provisions establish “tight time frames” requiring PJM to review a new service request and issue a notice of any deficiencies within five business days.
PJM typically receives 50% or more of the total number of new service requests during the last month of a queue window, Connell said, with most of the requests submitted during the last week or on the last day of the window. He said the short window impacts the ability of PJM employees to perform reviews on time, leading the RTO to seek waivers from FERC to extend the deadline.
As an example, in the last queue window ending in September, 340 of the 563 new service requests were filed in the last week, including 247 on the last day.
“It’s just not physically possible for our staff to process that [number] of requests,” Connell said.
PJM’s proposed solution is to change the five-day deadline to 15 business days, or to “use reasonable efforts to do so as soon thereafter as practicable.”
The proposed solution would also provide PJM 15 business days to review the interconnection customer’s response to the deficiency notice.
Some stakeholders questioned whether PJM’s proposal would fix the problem.
Paul Sotkiewicz of E-Cubed Policy Associates acknowledged the manpower challenges caused by the “tremendous” number of requests the RTO is receiving. But he said if the notification timeline is extended, it could impact the period in which studies can successfully be completed. He said that “squeezes” both PJM and the transmission owners and leaves developers in limbo regarding the start of construction on a project.
Sotkiewicz said he would like PJM to rethink the proposal and find ways to incentivize stakeholders to get projects into the queue earlier.
“I fear that what’s being proposed here will do nothing to solve the problems,” he said.
Alex Stern, director of RTO strategy for PSEG Services, said he shared Sotkiewicz’s concerns and that PJM’s solution might do more harm than good. Stern said the solution seems to be “trading a today problem for a tomorrow one.”
“I’m concerned this quick fix could set us all up for failure and would not be sustainable,” Stern said.
PJM said it will evaluate stakeholder feedback and revise its problem statement and issue charge for the April PC meeting.
Interconnection Construction Service Agreement
Mark Sims, manager of infrastructure coordination for PJM, provided a first read of a problem statement and issue charge addressing pro forma interconnection construction service agreements (ICSAs).
Sims said two sections in Attachment P of the tariff dealing with ICSAs have caused PJM “increased administrative burden” as the number of interconnection queue requests has increased.
Section 1 of Attachment P does not contain pro forma language that considers when an ICSA supersedes an already effective ICSA, Sims said.
He added that the tariff provides for automatic termination of ICSA upon the occurrence of certain conditions, which can occur without PJM’s knowledge. The conditions include completion of construction of all interconnection facilities, a transfer of title, final payment of all costs or delivery of final as-built drawings to the transmission owner.
Sims said PJM wants to revise the tariff language to make any termination contingent upon PJM receiving notice of the conditions from the TO. From there the RTO would take steps to cancel the ICSA with FERC, making the termination more of an “active process.”
Stern asked PJM to consider a “friendly amendment” imposing on the RTO a reciprocal obligation to provide notice to the TO that the ICSA has been canceled with FERC. PJM said it would consider incorporating the amendment.
PJM will seek endorsement of the issue charge at the April PC meeting.
Transmission Expansion Advisory Committee
Generation Deactivation Notification
Phil Yum of PJM provided an update on recent generation deactivation notifications, including PPL’s request to deactivate the Martins Creek Power Plant Unit 4, a 17.3-MW oil and gas generation unit on the Delaware River in Northampton County. The deactivation is scheduled to take place by May 31, 2022. PJM is still conducting a reliability analysis of the potential deactivation, Yum said. The analysis will be updated at the committee’s April meeting.
NEET Supplemental Project
A proposed supplemental project by NextEra Energy Transmission (NEET) in Indiana prompted questions from stakeholders regarding its impact on adjoining transmission lines.
Kshitij Shah, NEET director of development, presented the needs for the NEET MidAtlantic IN, a 20-mile, 345-kV double-circuit transmission line in northwest Indiana consisting of 115 galvanized steel lattice structures. NEET purchased the transmission line from Commonwealth Edison in October, becoming a transmission owner in PJM.
Shah said the transmission lines were built in 1958 and increased failures are expected because of the age of the components. He said the structures are showing “significant deterioration,” including corrosion, foundation wear and missing structural components.
The potential solution calls for rebuilding the line with monopoles and new conductor on the existing right-of-way. Shah said the estimated project cost is $63.4 million, and the projected in-service date is January 2023.
“Our goal is to keep it simple from a construction standpoint, and we’re going to try our best to do a structure-for-structure replacement,” Shah said.
Greg Poulos, executive director of the Consumer Advocates of the PJM States, said the project has received attention because of the new transmission acquisition and its location between other TOs, including ComEd and American Electric Power (AEP). Poulos said the $63.4 million price tag has also “raised eyebrows” among advocates.
He asked if PJM or NEET has had conversations with AEP and ComEd on how the project will impact their existing transmission lines.
Shah said those conversations have not taken place yet. He said NEET has convened with Northern Indiana Public Service Co. because the lines connect to two NIPSCO substations.