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.

The Transition Date will be July 10, 2023. As set forth in PJM Tariff, Part VII, within 60 calendar days after the Transition Date, valid AE1-AG1 projects, other than Upgrade Requests, that have not either executed or received for execution a final Interconnection Service Agreement or Wholesale Market Participation Agreement as of the Transition Date will have to demonstrate readiness pursuant to Tariff, Part VII, Subpart B, section 303, in order to move forward in the interconnection transition process.

See the Transition Readiness Checklist PDF for a summary of these requirements and the Transition Readiness Education Video WEB for more guidance.

The Interconnection Process Subcommittee (IPS) is the forum in which PJM will be discussing process implementation and providing updates throughout the transition.

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 AE1 Through AG1 Queues

Transition

Within 60 days of the Transition Date, July 10, 2023, 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

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.

FAQs

Q: Can I make a change to my project’s fuel type at any of the TC1 Decision Points?
A: No, fuel type changes are not considered permissible technology changes. Hybrid projects may remove a fuel type at TC1, Decision Point #1 (DP1).

Q: Can I reduce my project size after I am notified whether or not my project is eligible for the fast lane?
A: Projects that fall into the fast lane will not be able to reduce. Projects that fall into TC1 must wait until Decision Point #1 (DP1), where they can only reduce by the allowable Tariff limits.

Q: Can I change my project’s POI after the transition?
A: Projects that fall into the fast lane will not be able to change their POI. Projects that fall into TC1 must wait until Decision Point #1 (DP1), where they can make limited POI changes, as outlined by the Tariff.

Q: Will offshore wind projects need to provide site control for the onshore substation at the transition?
A: No, the onshore substation is not considered part of the Generating Facility.

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: Can I make a change to my project’s fuel type when I reapply? How about at any of the Decision Points?
A: No, fuel type changes are not considered permissible technology changes for TC2 projects.

Q: Can I reduce my project size when I reapply? How about at any of the Decision Points?
A: Yes, projects may reduce when reapplying in TC2. They may also reduce with the allowable Tariff limits at Decision Point #1 (DP1) and Decision Point #2 (DP2).

Q: Can I change my project’s POI when I reapply? How about at any of the Decision Points?
A: Projects reapplying in TC2 may choose only between their primary and secondary POI options. They may then make limited POI changes, as outlined by the Tariff, at Decision Point #1 (DP1).

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: If I apply before the Transition Date, should I use the old deposit structure or the new one?
A: Project Developers applying prior to the Transition Date should use the old deposit structure. However, when reapplying in New Cycle #1, the new deposit amounts will be required.

Q: Can I make a change to my project’s fuel type when I reapply? How about at any of the Decision Points?
A: AH2 and later projects may change their fuel type upon reapplication. However, fuel type changes are not permitted at any Decision Points. 

Q: Can I reduce my project size when I reapply? How about at any of the Decision Points?
A: Yes, projects may reduce when reapplying in New Cycle 1. They may also reduce with the allowable Tariff limits at Decision Point #1 (DP1) and Decision Point #2 (DP2).

Q: Can I change my project’s POI when I reapply? How about at any of the Decision Points?
A: Projects reapplying in New Cycle 1 may change their POI. They may then make limited POI changes, as outlined by the Tariff, at Decision Point #1 (DP1).

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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