PJM Discusses Order 845 Compliance Requirements


PJM provided a brief overview of its implementation of Federal Energy Regulatory Commission Order 845 at a special session of the Planning Committee on Oct. 16.

Susan McGill, manager – Interconnection Analysis, and Michelle Harhai, senior counsel, reviewed the Notice of Proposed Rulemaking compliance requirements and the actions PJM has undertaken.

In issuing the final rule, the Commission said that it found the current interconnection process may hinder the timely development of new generation, especially in light of the changing industry. It also said that it found the interconnection study process may result in uncertainty and inaccurate information.

PJM has drafted a number of tariff changes that address those concerns and discussed the proposed revisions at the meeting.

There is no current timetable for filing. Harhai pointed out that on Sept. 24, the Edison Electric Institute, on behalf of its members, submitted a motion requesting an extension of the compliance deadline. The Commission granted the request on Oct. 3 and extended the compliance date to within 90 days of the Commission’s issuance of an order addressing the multiple pending requests for rehearing of Order 845.  

Improving Certainty for Interconnection Customers          
Reform Proposed in the NOPR Status Order Implementation Progress
Interconnection customer’s option to build Adopted Tariff changes drafted
Dispute resolution Adopted Tariff changes drafted
Identification and definition of contingent facilities Adopted Tariff changes drafted
Transparency regarding study models and assumptions Adopted Tariff changes drafted
Definition of generating facility Adopted Tariff changes drafted
Interconnection study deadlines Adopted Tariff changes drafted
Requesting interconnection service below generation facility capacity Adopted PJM work in progress
Provisional interconnection service Adopted PJM work in progress
Utilization of surplus interconnection service Adopted PJM work in progress
Material modification and incorporate of advanced technologies Adopted PJM work in progress

Harhai reviewed the dispute resolution, and the identification and definition of contingent facilities.

The current dispute resolution process in PJM’s governance documents needs to be modified to include interconnection customers. The FERC requires the ability for a party making an interconnection request to unilaterally request non-binding dispute resolution.

The new non-binding dispute resolution procedures provide an additional step specifically for interconnection request and interconnection procedure disputes.

For the reform that requires identification and definition of contingent facilities, PJM currently identifies all constraints and contingent facilities in the system impact study reports, including baseline upgrades, network upgrades and supplemental projects that may impact the interconnection requests. PJM will add methodology and clarify existing language.

McGill said that PJM will ask for new interconnection study deadlines: six months instead of quarterly. This will better reflect PJM’s six-month queue cycle and give PJM greater visibility of the projects in the queue.

In addition, PJM will decrease the possible number of late or backlogged projects. If more than 25 percent of projects are listed as late or backlogged, it will initiate a formal reporting requirement to the Commission for at least one year.

Of the four issues still outstanding, McGill said the utilization of surplus interconnection service will look at the interconnection facilities as actually built, not as studied.