We successfully represented PJM Interconnection, L.L.C. (PJM) in defending the filing of unexecuted interconnection-related agreements against a protest from a project developer.  These agreements facilitate the interconnection of a 150-megawatt solar generating and battery storage facility in Indiana to the PJM transmission system. The project developer claimed that it should be allowed to remove all battery storage units from the originally proposed project without this change being considered material. 

PJM argued that removing the battery storage components would indeed constitute a material change from the agreed-upon terms for the project’s interconnection because a change such as this would affect PJM’s transmission system.  PJM further argued that its material change determination aligns fully with the rules of its tariff. The Federal Energy Regulatory Commission agreed with PJM and accepted the agreements as filed.