FERC approved revisions to PJM’s tariff to streamline the process for the owners of a deactivating resource to transfer its capacity interconnection rights (CIRs) to a new unit at the same point of interconnection (ER26-403). (See PJM Preparing Alterations to Rejected CIR Transfer Proposal.)
Replacement resources would qualify for replacement generation interconnection studies in lieu of the full slate of network impact studies new resources must undergo. The replacement resource cannot exceed the maximum output of the retiring unit, and it must interconnect at the same substation bus and voltage. The studies are expected to take 180 days to complete.
Since the CIRs for the deactivating resource already have been studied and the unit included in PJM’s system modeling, the commission wrote it is not necessary for a replacement to undergo the full suite of studies to ensure deliverability. The creation of a parallel queue would not constitute queue jumping because the CIRs already have been studied and determined to be deliverable, while the network impacts of a greenfield project are unknown.
The filing is PJM’s second crack at creating a fast track for replacement resources after the commission rejected its first proposal in August 2025 because of two carveouts from the proposed requirement that projects be capable of entering service within three years. Those provisions would have created a one-time extension of the in-service date requirement and an exception for resources with long development timelines, which the commission wrote would undermine the purpose of PJM’s proposal: bringing replacement resources online faster (ER25-1128).
“PJM’s proposal permits milestone extensions only in certain circumstances, and only for up to a specific amount of time, which will help ensure that the replacement generation interconnection process results in the timely and efficient replacement of generating facilities. Unlike the prior proposal that allowed replacement generation project developers to unilaterally extend the commercial operation date for their project without restriction, the instant proposal allows PJM to ‘reasonably extend’ the in-service date or other milestones under specified conditions,” the order states, adding that if a developer requires a longer extension, a waiver can be requested from the commission.
Those milestone extensions would be permitted only for “delays not caused by the project developer and that could not have been remedied through the exercise of due diligence,” PJM wrote in its transmittal letter. Milestone extensions would be capped at three years past the original commercial operation date.
PJM wrote the proposal is one of several changes to PJM’s planning and interconnection processes intended to allow resources to come online more quickly as the RTO seeks to ward off a looming resource adequacy shortfall. Other efforts include the Reliability Resource Initiative, which allowed 51 resources that could quickly add capacity to be inserted into Transition Cycle 2, and expanded eligibility for surplus interconnection service. (See FERC Approves PJM’s One-time Fast-track Interconnection Process.)
“At a time when PJM needs additional capacity resources in the near term to meet serious resource adequacy challenges, the expedited processing of replacement generation interconnection service requests claiming a deactivating facility’s CIRs can yield significant reliability benefits by facilitating the timely addition of new capacity while promoting the efficient use of existing infrastructure,” PJM wrote.
The Independent Market Monitor protested the filing, arguing it would divert planned resources from the cluster-based interconnection queue to a less efficient serial study process and further slow development by creating an incentive for resource owners to withhold CIRs until they can be sold to a developer.
During the stakeholder process that led to PJM’s filing, the Monitor proposed a model under which the CIRs associated with a deactivating resource would be made available to all resources on the grid as transmission headroom. It reiterated the argument that CIRs should not be for sale in its protest. (See “Voting on CIR Transfer Proposals Deferred to October,” PJM PC/TEAC Briefs: Sept. 12-13, 2024.)
“The basic purpose of the process is to permit existing generators to sell their CIRs to the highest bidder rather than to identify the best replacement resource. The proposal is inconsistent with open access and the purpose of CIRs. A proposal to truly reform CIRs would terminate CIRs immediately at the time a resource deactivates, and thereby avoid undue discrimination, promote competition and facilitate the rapid entry of needed new generation,” the Monitor wrote.
The commission wrote the proposal would not implicate market power as the ability to transfer CIRs already is codified in the tariff.
“This filing simply establishes an expedited review process for replacement generation resources interconnecting at the same location as a deactivating generating facility that would not change the voltage or maximum generation output at that location. Nothing in the instant filing would modify the existing rights to transfer CIRs or the transfer process,” the order states.

