PJM filed comments with the Federal Energy Regulatory Commission Tuesday in response to an Advance Notice of Proposed Rulemaking on regional transmission planning.
In its filing, PJM specified guiding principles, addressed key facts, provided recommendations and responded to the Commission’s various inquiries.
Guiding principles that should govern planning reform include:
- Facilitating decarbonization: While ensuring a reliable, resilient transmission grid, planning processes should accommodate the nation’s move toward a more decarbonized future by effectively implementing local, state and federal policies as well as the desire of customers for reduced carbon electricity.
- Grid resilience: It is imperative the Commission put in place a common working definition of resilience, as well as resilience-based industry planning drivers to ensure the grid is prepared to withstand or quickly recover from events that pose operational risks.
- Protecting consumers: Any cost allocation method changes must not result in an unreasonable shift of cost or risk to consumers.
- Equitable treatment of RTO and non-RTO regions: Any planning reform should be implemented consistently across the nation and should not create disincentives for transmission owners to participate in RTOs.
PJM also clarified several key facts that the Commission should keep in mind as it evaluates potential reform.
For example, at least in the PJM footprint, the overwhelming majority of new resources, including renewables, are not locating far from load centers.
And, it noted that the planning process is not “siloed.” All projects, regardless of driver, are incorporated into a single annual Regional Transmission Expansion Plan.
PJM offered a number of recommendations, among them:
- Reliability: Any proposed rule should account for challenges associated with the increased penetration of renewable resources to ensure that the current level of system reliability is maintained or enhanced to preserve resource adequacy and system stability.
- Resilience: PJM urges the Commission to adopt a common definition of resilience applicable to the industry, as well as a specific Commission-directed resilience planning driver of transmission upgrades applicable to all planning regions.
- Planning for future generation: PJM outlines recommendations for an enhanced long-term planning process and requests specific Commission guidance on decision-making parameters that would drive the planning authority to direct the construction of new transmission consistent with those documented needs.
- Interconnection reform: PJM urges the Commission to make clear that the ANOPR is not intended to interfere with RTOs/ISOs moving forward on interconnection queue process reform.
- Cost allocation: PJM provides six cost allocation options for FERC’s consideration that could substitute for the present “cost-causer pays” rule. These options were developed with stakeholders through the PJM Interconnection Policy Workshops.
- Interregional planning: PJM explains why a move from “interregional coordination” to “interregional planning” – despite its surface appeal – would not work, given the disparate market models among regions.
- Independent transmission monitoring: FERC should not require RTOs to have independent transmission monitors.
PJM notes in the filing that, given the obstacles presented by siting new transmission facilities, optimizing existing transmission resources and corridors will be essential to a quick, low-cost transition to clean energy.
PJM has identified interconnection queue reform as a priority and last year began engaging stakeholders in a series of workshops to explore potential improvements. That effort led to the creation of the Interconnection Process Reform Task Force, which is working on a proposal of PJM-specific process changes to submit to FERC.
Simultaneously, PJM and stakeholders are examining related improvements through the ongoing Interconnection Policy Workshop series.
FERC issued the ANOPR July 15 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.
Stakeholders will be further discussing PJM’s comments at the Nov. 2 meeting of the Interconnection Policy Workshop.