PJM alone had 2,700 projects, representing more than 250 GW, in its interconnection queue as of May 2022. 9 As of the end of 2021, the nation’s interconnection queues were clogged with over 1,400 GW of planned generation and storage, 10 which far exceeds both the plausible capacity of the transmission system or peak load requirements for the foreseeable future. The deadlines for completing interconnection studies are aspirational at best, and are routinely missed by months or years. 8 But interconnection delays have become an increasingly severe problem in generator development. Clogged and backloggedĪ transparent, efficient process for generator interconnection is critical to an open access transmission model, and has been the de facto driving force behind transmission expansion. However, in keeping with its status as a NOPR, FERC defers a number of details to the rulemaking process, inviting comment from affected parties before crafting a Final Rule. 2003 to be unjust and unreasonable 7, and mandates not only a shift to a cluster study process, but a range of other changes intended to streamline the interconnection process and offer more alternatives to developers. It preliminarily finds the interconnection processes and pro forma agreement set forth in Order No. The Interconnection NOPR, initiated by FERC under Section 206 of the FPA 6, is more ambitious and not as fully developed. It is narrowly focused on implementing a shift from a serial study process to a cluster study process, and almost all of its design features support that transition. The PJM Proposal, which PJM seeks to implement as is, was filed under Section 205 of the Federal Power Act (“FPA”) 5 and is a “fully-baked” revision of PJM’s OATT. But it is a major change for PJM and, by releasing a NOPR, FERC is signalling its intent for the cluster study process to be mandatory for all FERC-jurisdictional transmission providing utilities.īoth proposals set forth a similar approach to interconnection queue management and interconnection studies, but are different in scope and level of detail. and Midcontinent Independent System Operator, Inc., have already adopted a cluster study process. The cluster study model is not new-a number of transmission providers, including Independent System Operators and Regional Transmission Organizations (“ISO/RTOs”) such as the California Independent System Operator Corporation, Southwest Power Pool, Inc. 2003 4, to a first-ready/first served cluster study process. 3īoth PJM and FERC propose a transition from the first-come/first-served serial interconnection study process established almost two decades ago in FERC’s Order No. 1 Two days later, during its June Open Meeting, Federal Energy Regulatory Commission (“FERC” or the “Commission”) announced a Notice of Proposed Rulemaking (the “Interconnection NOPR”) 2 that proposes to overhaul the Commission’s pro forma interconnection procedures and agreements across the U.S. (“PJM”) filed a “ comprehensive reform” of the interconnection process set forth in its Open Access Transmission Tariff (“OATT”).
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