PJM Previews Key Topics of ANOPR Filing


Proactively planning for the future grid, examining cost-allocation options for interconnection projects, and identifying reforms to enhance resilience are among numerous topics PJM will address in its filing to the Federal Energy Regulatory Commission (FERC) in response to an Advance Notice of Proposed Rulemaking on regional transmission planning.

Dave Souder, Executive Director – System Planning, presented a high-level view of PJM’s approach to the filing at the stakeholder Interconnection Policy Workshop Session 6 on Sept. 30.

Souder’s talk followed a separate presentation on stakeholder feedback that is helping inform PJM’s comments, which are due to the Commission Oct. 12.

FERC issued the Advance Notice of Proposed Rulemaking (ANOPR) to seek input on how to improve electric regional transmission planning, project cost allocation and generator interconnection as the growth of new resources with differing characteristics creates new demands on how such resources are integrated into the grid.

The ANOPR solicits feedback in three areas:

  • Reforms for longer-term regional transmission planning and cost-allocation processes that take into account more holistic planning, including planning for anticipated future generation and future generation deactivations
  • Rethinking cost responsibility for regional transmission facilities and interconnection-related network upgrades
  • Enhanced transmission oversight over how new transmission facilities are identified and paid for

Souder said interconnection queue process reform is needed, and the ANOPR should not interfere with related stakeholder process reform efforts already underway.

In addition to the Interconnection Policy Workshop series, which kicked off May 18 with comments from FERC Chairman Richard Glick, the Interconnection Process Reform Task Force is working to devise a proposal of PJM-specific process changes to submit to FERC.

“We really do need some clear guidance from FERC as to what factors we should be considering to order new transmission or not to order new transmission and how the new transmission should be cost-allocated,” Souder said.

An analysis – perhaps in collaboration with labs and industry – to evaluate transfer capability between regions also would be helpful in determining an appropriate amount of transmission capacity. “That will then drive a future criteria for interregional planning that we can all align to,” he said.

Regarding cost allocation, PJM will include in its filing six options, which were reviewed with stakeholders this summer.

As to FERC’s suggestion of creating an independent transmission monitor, akin to the role of an independent market monitor, PJM does not see the need.

“We see that as our role, as an independent body, similar to the FERC’s and the states’ role as well,” Souder said.

If such a role were created, Souder said, it would be critical that it be technically qualified in the way that PJM is a registered entity with the North American Electric Reliability Corp.

“Another key message is we need to make sure RTO areas and non-RTO areas are treated equally, and there is stakeholder participation and transparency,” Souder said.

The filing also will address grid-enhancing technologies, including the importance of PJM’s advanced technology pilot program.

System reliability issues presented by a changing resource mix will be highlighted, along with reforms to enhance resilience.

Souder said PJM also will respond to several inaccurate perceptions of PJM’s process. For example, he said:

  • The planning process is not siloed.
  • Queue-based generation locations are less than 100 miles from load centers.
  • Both load and generation pay for and receive benefits from transmission upgrades in the form of headroom.

The ANOPR will be further discussed at the next Interconnection Policy Workshop, scheduled for 3–5 p.m. Nov. 2.