![]() Network upgrade costs are borne by the first energy generation project to trigger the need for an upgrade. In the serial process model, each generator’s interconnection application is processed independently for its own impacts on the network in the order it enters the interconnection queue. PJM currently processes these requests and network upgrade needs in what is known as the serial process model. Moreover, the influx of interconnection requests requires network upgrades to the grid. Each application to connect to the grid requires PJM to conduct numerous studies to ensure grid reliability before interconnection. The growth of clean, renewable energy generation projects, which tend to generate less power per project than traditional fossil fuel generators, has resulted in a dramatic increase in interconnection requests. The backlog PJM seeks to address is a result of several factors. As more clean energy projects enter the development pipeline, a serious backlog of generators waiting to interconnect to regional electric transmission systems to carry the power they produce to customers in densely populated areas is frustrating developers, utilities, and grid operators alike. Utility-scale renewable energy generation projects tend to be developed further away from end-users than traditional fossil fuel generators. ![]() The Problem: The serial process model, participant funded “first to cause” cost allocation, and PJM understaffing If Democrats lose the Senate in November, these vital FERC reforms may die on the vine. Recent criticism of FERC by Senator Joe Manchin (D-WV) suggests that Glick’s confirmation is uncertain. However, FERC Chairman Richard Glick’s term ends in June, and he must be confirmed by a deeply partisan Senate to be appointed for a second term and see the rulemaking process through to the finish line. Meanwhile, the Federal Energy Regulatory Commission (FERC), which regulates RTOs and ISOs, issued an Advanced Notice of Proposed Rulemaking (ANOPR) in July 2021 to begin the process of overhauling its rules regarding transmission planning, network upgrade cost allocation, and generator interconnection processes. Roughly a third of those projects have been in the queue for more than 500 days, and 166 of them have been waiting for more than three years. As of the end of 2021, there were 288,609 MW of potential power generation projects in PJM’s interconnection queue, the vast majority of which were solar projects and 95% of which are renewable or hybrid renewable/battery resources. It regulates wholesale power markets across thirteen states and the District of Columbia. PJM is the largest of the federally regulated regional transmission organizations (RTOs) and independent service operators (ISOs) that operate the regional electric transmission systems in the United States. (PJM), is preparing to transition to a new, more streamlined, and more equitable generator interconnection process by October 2023. This article was originally published in Law360’s Expert Analysis.
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