Our work with PJM Interconnection, L.L.C. (PJM) on comprehensive reform of its generator interconnection process led to a Federal Energy Regulatory Commission (FERC)  order issued on November 29, 2022. The order accepted PJM’s reform filing, subject only to two ministerial compliance requirements. The approved tariff revisions aim to process requests to interconnect generating facilities with the PJM system more efficiently and quickly by moving from a serial “first-come, first-served” queue approach to a “first-ready, first-served” cycle approach. FERC’s order found that these reforms “should provide PJM with the ability to reduce the current backlog more quickly than possible under its current rules and ultimately result in the more efficient and timely processing of New Service Requests.”

We advised PJM during their stakeholder process where the interconnection reforms were developed, helped to draft new and revised tariff provisions for FERC approval, and assisted with filing the proposed package at FERC and defending it against protests. Since FERC accepted the interconnection reforms, we have been advising PJM on the transition to the new process and implementation of the new rules and service agreements. We also assisted PJM with comments on FERC’s notice of proposed rulemaking on “Improvements to Generator Interconnection Procedures and Agreements,” PJM’s request for rehearing of the final rule (Order No. 2023), and PJM’s compliance filing for Order No. 2023.