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PJM’s proposal to largely retain its existing interconnection process without changes fails to meet key requirements of FERC Order 2023, according to trade groups and others.
After approving PJM’s “first-ready, first-served” interconnection reform plan in late 2022, FERC last year issued new interconnection requirements through its landmark Order 2023.
In a compliance plan filed with FERC on May 16, PJM said its new interconnection process meets the objectives of Order 2023, and in areas that may not meet specific FERC requirements, it should be granted “independent entity variations.”
In response to PJM’s proposal, clean energy trade groups and environmental organizations said the grid operator’s existing interconnection process doesn’t fully comply with Order 2023 and its requested exemptions go too far.
“PJM stretches the meaning of the independent entity variation beyond any reasonable interpretation or application,” ACP, AEU and SEIA said. “PJM is asking for an exception that would effectively swallow the rule.”
The groups said PJM’s proposal fails to meet various FERC requirements regarding: the length of the interconnection study processes; the consideration of alternate transmission technologies; assumptions for energy storage projects; exemptions from penalties for withdrawing from interconnection queues; studies on how interconnections may affect PJM’s neighbors; penalties if PJM fails to meet deadlines; scoping meeting requirements; use of surety bonds; and interconnection customer rights to extend the commercial operation start date of their projects by up to three years.
PJM, for example, wants to maintain its existing 480-day impact study process instead of following the rule’s requirement to complete the studies in 150 days, with an additional 150 days for restudies, according to the groups.
Environmental organizations said PJM should refine its process to comply with the order’s other objectives, including: reducing interconnection study timelines; implementing binding deadlines; studying technologies that can make network upgrades more affordable; “realistically” studying the charging behavior of storage resources; and holding transmission providers accountable for study delays, they said.
In addition, PJM failed to justify continuing its pause on taking new interconnection requests, which is expected to end in 2026 at the earliest, according to the June 20 filing by environmental groups, which also include the Environmental Law and Policy Center, Illinois Citizens Utility Board, Penn Future, Union of Concerned Scientists and Sustainable FERC Project.
The New Jersey Board of Public Utilities objected to PJM’s request for an exemption from requirements to allow energy storage resources to interconnect to the grid without paying for transmission upgrades needed to support charging during peak load periods. FERC already rejected PJM’s arguments for being allowed to assume energy storage projects will charge to their maximum capacity during peak load periods, the BPU said.
PJM’s unrealistic assumption about the charging behavior of energy storage resources — that they would draw power off the grid during peak periods when it is most expensive — will unnecessarily drive up costs for New Jersey ratepayers, the BPU said.
Protests were also filed by EDF Renewables, EDP Renewables North America, Longroad Energy, the WATT Coalition, Leeward Renewable Energy and RWE Clean Energy, and Shell Energy North America (US), Shell New Energies US and Savion.
Meanwhile, PJM on May 20 said it is making strides in clearing its interconnection queue backlog under its reformed process.
PJM expects to process about 72,000 MW in projects by mid-2025 and 230,000 MW over the next three years, the grid operator said.
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The law also requires the company to proactively invest in distribution upgrades to reduce interconnection delays for distributed energy resources.
Other trends include an increase in inflation-adjusted costs for storage attachments, decreases in average system size and notable market share growth among the state’s top installers.
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The law also requires the company to proactively invest in distribution upgrades to reduce interconnection delays for distributed energy resources.
Other trends include an increase in inflation-adjusted costs for storage attachments, decreases in average system size and notable market share growth among the state’s top installers.
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