With more than 250 GW of renewable energy and storage capacity waiting in PJM’s interconnection queue, states served by PJM have unanimously called on the grid operator to expedite the processing of interconnection requests and move to a “cluster study” process.

PJM’s grid operator won’t begin processing new interconnection requests until 2026, and then it will take two years to complete each interconnection study under the proposed timeline, the Organization of PJM States (OPSI) said in comments to the Federal Energy Regulatory Commission. (FERC). Both of these terms are “too long,” the organization said.

Calling for PJM’s timelines to be an “absolute upper limit,” in comments to FERC’s interconnection rulemaking, OPSI said it supports implementing PJM’s proposal as an “improvement on the status quo” and as “critical to reducing the interconnection backlog, ensuring markets remain competitive, and that states are able to achieve their public policy goals.”

But OPSI told FERC that “ideally” FERC’s final interconnection rule “should increase” the processing speed of PJM’s interconnection requests “and reduce” PJM’s transition to a first-in, first-served cluster process. The organization, reiterating concerns it had previously expressed, said “the possibility that today’s queued resources may not reach commercial exploitation until almost 2030” is “disturbing”.

Seven OPSI members have 100% clean electricity, according to Alliance of Clean Energy States: District of Columbia, Illinois, Maryland, Michigan, New Jersey, North Carolina, and Virginia. Other members of the organization are Delaware, Indiana, Kentucky, Ohio, Pennsylvania, Tennessee and West Virginia. All member states are wholly or partially within PJM’s service area.

OPSI’s remarks were unanimously supported by its members.


PJM has many interconnection requests a total of more than 250 GW of renewable energy and storage, as shown in the figure above, in more than 2,700 projects, as shown in the adjacent table prepared by Lawrence Berkeley National Laboratory (LBNL) for the OPSI presentation, along with figures for other regions networks.

PJM paused for two years, a review of 1,200 projects in its queue of interconnection, mainly solar energy. Year-over-year capacity additions to PJM’s queue this year are much lower than last year, as shown in the figure next to LBNL. In its presentation to OPSI, LBNL asked if this year’s drop could be related to PJM’s announced queue reform.

In the PJM network region, according to Bloomberg News the report Last month, “24% of fossil-fired generators that have applied since 2017 have been approved to connect to the grid, compared to 0.4% for renewable energy projects, according to BloombergNEF.”

Cluster studies

OPSI said it supports cluster studies for interconnection requests to speed up processing and minimize first-step disadvantages where a project has to pay for a major network upgrade that then benefits subsequent projects. OPSI said FERC should analyze whether a region-wide annual cluster “in a large region like PJM” could benefit from more well-defined subclusters and evaluate methods for grouping generating facilities based on “geographic and electrical significance.”

Annual clustering is superior to PJM’s “less structured proposal, which (would) open new cluster windows only after a certain stage of the previous cycle has been completed,” OPSI said. PJM’s approach “will introduce timeline uncertainty” into the interconnection process, he added.

Timelines, batteries

OPSI asked FERC, “if it is clear that the cluster process is more efficient than the status quo process,” to “strongly consider the use of the cluster process as soon as possible in the transition” from the traditional sequential process, and to “analyze whether the opportunity for customers relationships to use a transitional sequential process can significantly delay the transition’ to cluster research.

PJM’s proposed interconnection study schedule is 710 days (about 2 years), compared to FERC’s proposed requirement, including re-studies, which would take a maximum of 555 days, OPSI said. The organization said it is “optimistic that PJM will be able to continue to shorten its interconnection process to at least the timelines” proposed by FERC “and hopefully to even shorter timelines like those already implemented by other regional transmission organizations.”

Comments from the PJM Organization of States to FERC are available through FERC docket search web pageunder registration number RM22-14-000.

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