FERC on Wednesday approved a PJM proposal to add about $925 million in transmission projects to its Regional Transmission Expansion Plan (RTEP), the bulk of which would address the retirement of the 1,295-MW Brandon Shores generator outside Baltimore (ER23-2612). 

The 25 projects the commission signed off on include the $796 million Grid Solutions Package, which was determined to be an immediate-need reliability project to address the Brandon Shores deactivation, as well as $134 million in changes to existing projects — namely the New Jersey State Agreement Approach (SAA) projects — and a $4.69 million cancellation of a previously approved project.  

PJM and Talen Energy are in talks to arrive at a reliability-must-run contract to extend Brandon Shores’ operations beyond the June 1, 2025, requested deactivation date; the approved RTEP projects have an in-service date of Dec. 31, 2028. 

PJM’s proposal was protested by the Maryland Public Service Commission, the state’s Office of People’s Counsel and the Organization of PJM States Inc. (OPSI), each of which pushed against including the Grid Solutions Package. They argued the RTO improperly designated it to be an immediate need and therefore not holding a competitive process for a solution. The OPC asked FERC to reject the proposal and direct PJM to conduct a “transparent and thorough review of alternatives as well as to engage in a competitive project proposal window, where feasible, for some or all the segments of the Grid Solutions Package.” 

The commission determined its review of cost allocation filings is limited to whether the relevant tariff language has been followed, which it found that PJM had, making the protests out of scope. Responding to the argument that OPSI and the PSC made that PJM’s planning process doesn’t adequately account for potential reliability risks posed by generation deactivations, the commission said the RTO and stakeholders are making encouraging steps to consider changes to generation deactivation and transmission planning processes. In recent months, stakeholders have begun discussions at the Deactivation Enhancements Senior Task Force and the Long-Term Regional Transmission Planning Workshop. 

Commissioners Mark Christie and Allison Clements each concurred with the order, agreeing the protests were out of scope but noting they raised important issues. 

Citing PJM’s “Resource Retirements, Replacements & Risks” report — which raised concerns there will be a significant number of generation deactivations through 2030 that will not be met by currently planned resources — Clements questioned whether there are additional retirements looming that will put ratepayers in a similar bind. She suggested PJM’s Multi-Driver Project planning process could be used to be more proactive and meet potential reliability risks posed by generation deactivations while providing economic benefits and keeping costs low. 

“I wonder whether PJM’s extensive reliance on immediate-need reliability solutions such as those at issue in this proceeding is in part a symptom of the failure of the region to carry out proactive, scenario-based multi-value planning,” Clements wrote. “The record in response to the commission’s regional transmission planning proposal suggests that while some local and reliability needs may persist even with greater use of proactive planning, proactive multi-value planning processes can be leveraged to replace or defer reliability projects that would otherwise be needed, at significant value to customers.” 

Christie wrote that the growth of state policies and legislation prompting the shuttering of generators raises cost allocation questions for neighboring states in the RTO that may be saddled with a portion of the cost to build transmission necessary to meet demand in the absence of those units. He suggested that such deactivations may be better viewed as public policy projects akin to the transmission being built to interconnect offshore wind under the New Jersey SAA. 

“If the resulting transmission projects under protest in this RTEP filing are caused more by Maryland’s policy choices than by organic load growth and economic resource retirements, then a salient question that may be asked is whether these transmission projects are more accurately categorized as public policy projects, essentially the same as the transmission upgrades caused by New Jersey’s offshore wind projects,” he wrote. 

While the concerns raised in the protests are valid, Christie said the commission’s hands were tied by the need to prevent potential reliability violations once Brandon Shores goes offline. 

“So while I am deeply sympathetic to the concerns expressed by the Maryland PSC, OPSI and the OPC as to the impact on consumers, there is really no practical choice for us but to approve this filing. We simply cannot risk the potentially catastrophic consequences laid out by PJM in its filing. But the states in OPSI, as well as all states in multistate RTOs, may want to consider the broader questions this filing raises, as I have described above,” he wrote. 

The Grid Solutions Package comprises a new 500-kV line between the Peach Bottom and Graceton substations and a 230-kV line from Graceton to a new 230-kV Batavia Road substation outside Baltimore. The project also includes one new 500-kV substation. The PJM Board of Managers approved the projects during its July 10 meeting. 

The Brandon Shores deactivation is also being addressed by projects included in PJM’s recommended package of proposals submitted during the third competitive window of the 2022 RTEP, which is scheduled to go before the Transmission Expansion Advisory Committee for a second read Dec. 5. The $5 billion proposal also would address increasing data center load in Northern Virginia. (See PJM Recommends $5B in RTEP Transmission Projects.)