Interconnection Process Reform

On Nov. 29, FERC issued an order conditionally approving PJM’s interconnection process reform filing, subject to two compliance filings, one of which has already been submitted by PJM. The filing constituted a comprehensive reform of the PJM interconnection process, designed to more efficiently and timely process New Service Requests by transitioning from a serial “first-come, first-served” queue approach to a “first-ready, first-served” cycle approach. The interconnection reforms are set forth in FERC Docket No. ER22-2110.

Pursuant to the Commission’s order, PJM’s new Tariff Parts VII and IX have an Effective Date of Jan. 3, 2023; these Tariff provisions have already been merged into PJM’s Tariff. However, the Jan. 3, 2023, Effective Date is different from the interconnection reform established Transition Date. As set forth in the new Tariff, Part VII, Definitions, the Transition Date is the later of: (i) the effective date of Transmission Provider’s Docket No. ER22-2110 transition cycle filing seeking FERC acceptance of this Tariff Part VII (i.e., Jan. 3, 2023) or (ii) the date by which all AD2 and prior queue window Interconnection Service Agreements (ISAs) or wholesale market participation agreements (WMPAs) have been executed of filed unexecuted.

PJM is currently working on tendering agreements to projects under study with particular focus on those in our AD2 and prior queues.

The Interconnection Process Subcommittee (IPS) is the forum in which PJM will be discussing process implementation and providing updates on progress toward the Transition Date.

Developer FAQ

For Project Developers with projects already submitted to PJM’s interconnection process, or those who are looking to do so, please read the section(s) below that pertain to your situation.

Projects in the AD2 Queues and Earlier

Today

It is PJM’s top priority to complete any remaining studies and issue all final agreements for these projects.

Transition

All AD2 queued and prior projects must execute a final agreement, file an unexecuted final agreement or withdraw prior to the transition.

What You Need To Know

Continue to work with your PJM project manager for project updates.

Projects in the AE1 Through AG1 Queues

Today

PJM is working with Transmission Owners to complete studies and issue final agreements for as many projects as possible prior to the transition. Projects are prioritize based on queue order, number of violations, scope of facilities study, etc.

Transition

Within 60 days of the Transition Date (to be announced at a later date), projects that have not been tendered a final agreement by the Transition Date will be required to post a Readiness Deposit of $4,000/MW and Site Control for an additional year from the Transition Date. Those that do so will be retooled and divided into a “fast lane” for expedited processing and Transition Cycle #1 (TC1).

What You Need To Know

Your PJM project manager will reach out to you when they have a meaningful status update or need more information from you to move your project forward. Due to higher than normal volume, PJM cannot accommodate all requests for meetings to walk through individual projects. Project managers will work with Project Developers on items that are actionable.

Project Developers are encouraged to attend the Interconnection Process Subcommittee meetings for more details on the process and timing. You should also familiarize yourself with the fast lane criteria, as well as the readiness requirements, in case your project needs to enter the transition.

FAQs

Q: What case(s) will PJM use to determine fast lane eligibility?
A: Projects will be retooled on their original case years to determine fast lane eligibility.

Q: If I go into TC1, and my retool runs clean, can I go into the fast lane?
A: No, projects that do not meet fast lane criteria based on the initial transition retool will not be able to move to the fast lane.

Q: Can projects that are initially in the fast lane be bumped into TC1?
A: Yes, if an upgrade is identified and a project in the fast lane has cost allocation or is first to cause an upgrade over $5 million, they will be moved into TC1. This could also be an updated project cost provided by the Transmission Owner as they perform facility study-level engineering on a network upgrade.

Q: Can the uprate for a project qualify for the fast lane, if the base project does not?
A: No. If a project is an uprate (project relies on the Interconnection Facilities of a prior project) whose base project does not qualify for the expedited process, the uprate also will not qualify for the expedited process, regardless of analysis results.

Q: When can I make equipment changes (inverter/turbine model)?
A: For projects that fall into TC1, Project Developers can make permissible technology changes at Decision Point #1 (DP1) and Decision Point #2 (DP2).

Q: Why can’t PJM guarantee that I will get my final agreement prior to the transition?
A: PJM needs full clarity on required network upgrades and cost allocation. This requires load flow, short circuit, and stability analysis to be complete, along with any facilities studies done by the Transmission Owner for physical interconnection or reliability-driven upgrades. The serial nature of the current queue process can prevent projects from getting their final agreements if there are more senior queue positions that have yet to make necessary decisions on network upgrades.

Projects in the AG2 and AH1 Queues

Today

Studies for these queues are currently paused.

Transition

Project Developers will need to resubmit their applications under the new requirements. These projects will be part of Transition Cycle #2 (TC2). The application deadline will be announced at the conclusion of Transition Cycle #1 (TC1), Decision Point #1 (DP1). For these projects, Project Developers must choose one point of interconnection from their primary and secondary options. Technical changes are permitted, but projects cannot increase their maximum facility output or capacity interconnection rights.

What You Need To Know

It is suggested that you become familiar with the readiness deposit and site control requirements for the new process. Project Developers should attend the Interconnection Process Subcommittee meetings for more process details.

FAQs

Q: When are readiness deposits and site control due for TC2 projects?
A: Readiness deposits and site control for TC2 projects are due by the TC2 application deadline (date to be announced). They are not due at the Transition Date.

Q: When can I make equipment changes (inverter/turbine model)?
A: For projects that fall into TC2, the developer can make permissible technology changes prior to the Application Deadline, and at DP1 and DP2.

Q: Will I be notified when it’s time to reapply?
A: Yes, the application will be announced at the IPS and communicated to Project Developers via email. Please ensure your main contact listed in Queue Point is up to date, so the right person receives the communication.

Projects in the AH2 and Later Queues

Today

Project Developers may continue to submit projects in the open window, but studies are currently paused. Project Developers may waive their kickoff calls until after the transition.

Transition

Project Developers will need to resubmit their applications under the new requirements. These projects will be part of New Cycle #1. The Application Deadline will be announced at the conclusion of Transition Cycle #2, Decision Point #1.

What You Need To Know

It is suggested that you become familiar with the Readiness Deposit and Site Control requirements for the new process. Project Developers should attend the Interconnection Process Subcommittee meetings for more process details.

FAQs

Q: Will I be notified when it’s time to reapply?
A: Yes, the Application Deadline will be announced at the IPS and communicated to Project Developers via email. Please ensure your main contact listed in Queue Point is up to date, so the right person receives the communication.

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