By Rory D. Sweeney

While the deadline for compliance filings on FERC Order 845 remains at least three months away, PJM is making sure it’s prepared.

During an Oct. 16 conference call, PJM staffers Susan McGill and Michelle Harhai outlined 10 reforms included in the order, six for which the RTO has already drafted Tariff changes. The remaining four are in progress.

The order, expected to remove even more barriers to storage interconnection, explicitly revises the definition of a generating facility to include storage, permits interconnection customers to apply for interconnection service lower than the capacity of their generating facilities and requires transmission providers to provide interim interconnection agreements for limited operation of generating facilities prior to completion of the full interconnection process.

FERC on Oct. 3 granted an extension of the compliance filing deadline to 90 days while it considers multiple requests for rehearing of the order.

Takis Laios of American Electric Power said his company is finishing proposed revisions of PJM’s governing documents that it plans to submit for consideration.

PJM’s Pauline Foley said the revisions should be submitted “sooner rather than later” and cautioned Laios that because it’s a compliance filing, staff are trying to keep revisions “within the scope of [the order].”

“Anything beyond that would really be better handled in the stakeholder process,” she said.

Foley also noted that part of the challenge is marrying FERC’s order, which make assumptions about what’s already in grid operators’ tariffs, with what’s actually in PJM’s Tariff.

“The commission presumes that certain provisions are included in our Tariff, and a lot of the provisions when we originally made our 2003 compliance filing were not exactly as pro forma,” she said. With the expanded rules that FERC ordered, “we need to confirm that all of the provisions FERC presumes are there are actually there,” she said.

In response to a stakeholder question, Foley added that while “it’s not really practical to implement the order” before it’s fully been approved, interconnection customers can seek mutual agreements with transmission owners to utilize some of the impending rule changes.