FERC issued a deficiency letter Tuesday seeking more information on PJM’s proposed overhaul of its interconnection queue process (ER22-2110).
With a ballooning backlog in its interconnection process and a sharp increase in new service requests, PJM is seeking to switch from its current “first come, first served” system to a “first ready, first served” queue. The proposal would cluster service requests together for both interconnection studies and cost allocation and advance applications making demonstrable progress toward operability. (See PJM Files Interconnection Proposal with FERC.)
The Aug. 30 letter from FERC’s Office of Energy Market Regulation asks for further information on several points of the tariff revision, largely having to do with how the new procedures would operate and comply with past FERC orders. A response is due from PJM within 30 days.
The letter questions if grouping all applications from Oct. 1, 2021, with those received through the processing of the first new cycle could create a risk of the first wave of projects evaluated under the new system becoming “unmanageably large” and how the RTO would address that possibility.
The removal of two sections of the tariff related to reporting and penalties for PJM should it fail to complete a set percentage of transmission service request studies within a certain timeframe caught FERC’s attention, with the commission seeking an explanation of how the removal would be “consistent with or superior to” the current requirements under Order 890.
The letter also seeks more information on the RTO’s plan to consolidate interconnection procedures for both small and large generators.
Staff also asked the RTO to explain how it will determine whether a request for long-term firm service can be studied as part of the planning process for bulk transmission supply in PJM or whether special impact studies must be completed.
And it asked for clarification of PJM’s proposal to allow a project developer to change the project site from one location to an “adjacent parcel,” asking whether they must be contiguous or merely in the same geographic area.
Tariff Revisions Supported by Stakeholders
The revisions to PJM’s tariff were submitted to FERC June 14 after receiving strong endorsement from the RTO’s stakeholders in April.
The RTO has stated that its proposal is comparable to the interconnection processes employed by SPP, MISO and PacifiCorp. The new system would add multiple decision points at which applicants would be required to make readiness deposits and meet other requirements to continue.
Currently, less than 20% of applications make their way through the queue and become operational.
Not all projects drop out because of the length or difficulty of the process. Many projects are speculative “price discovery” requests submitted to determine where interconnection costs are least expensive.
