PJM Talks Long-Range Planning at FERC Technical Conference

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Ken Seiler, Vice President – Planning, presented PJM’s perspective on long-range planning Monday at a technical conference called by the Federal Energy Regulatory Commission to explore “Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection.”

The conference was held as FERC considers its Advance Notice of Proposed Rulemaking (ANOPR) on regional transmission planning.

PJM’s interconnection queue has quadrupled over the past four years, Seiler said, making the interconnection process a focus for improvement.

Commissioner Mark Christie asked Seiler to share efforts underway at PJM to address the queue backlog and what FERC can do to help and not get in the way.

PJM and stakeholders have been exploring interconnection process reform for about a year, Seiler responded, looking for ways to speed projects through the queue and provide better cost certainty. 

This includes ensuring “we have real generation in the queue and not speculative generation, as we oftentimes do today,” Seiler said.

Stakeholders are largely in agreement on the future interconnection process changes and are now discussing the transition to the new process, he said, adding that new cost allocation methods also are under consideration.

“Our ask of FERC is you continue to allow us to move forward with the interconnection reforms and the changes we need to meet our stakeholders’ needs, as well as working with us on any future policy changes that may be required in order to accommodate additional generation to meet federal or state goals,” he said.

Christie then asked if PJM saw an issue with FERC moving forward on its ANOPR, or if that would disrupt the reform going on.

“We are close to having solutions here,” Seiler said. Issuing a rulemaking in the short term could prove problematic, he said, but the middle or end of next year would dovetail with changes PJM intends to file with FERC.

Planning transmission for an uncertain future is risky and can’t simply rely on predictions that certain generation might retire but must account for state and federal policies as well as a documented record of industry trends, Seiler said in his submitted statement for the panel, titled, “Consideration of Longer-Term Futures Scenarios in Regional Transmission Planning Processes.”

In its comments on the ANOPR, PJM outlined the concept of developing a 15-year forward Master Plan with regular reviews by planners and regulators. The Master Plan would be developed using scenario planning and analyzing associated transmission needs as well as reviewing customer trends and needs, Seiler said.

“We would urge the Commission to provide support for requiring this kind of initiative by all planning authorities with the specific details to be addressed to meet each region’s needs,” he said.

However, Seiler cautioned FERC against requiring such plans without addressing three fundamental questions:

  • After all the scenarios are laid out, who decides which scenario (or set of scenarios) should be chosen by the RTO as the basis to order construction of new transmission?
  • Once the final decision-maker is identified, what criteria should be used to determine whether the chosen scenario is the one upon which customer money should be pledged in the form of new transmission?
  • What kind of regulatory affirmations and processes can be established along the way to course-correct for changing circumstances without running the risk of prudence reviews, growing abandonment costs and the difficulties of withdrawing a previously approved transmission line where siting and the exercise of eminent domain may well be underway?

The “who decides” issue is particularly challenging, especially in a multistate RTO like PJM, where state policy choices differ, Seiler said.

To that point, PJM suggests that FERC have that responsibility – but only after taking into account all of the views of states and stakeholders and the expert analysis of independent planning authorities.

Policy goals, including FERC’s, can change radically and quickly, injecting risk into mandating long-term plans without first addressing the above questions, Seiler said.

“The ground is littered with past transmission projects that were developed around well-intended future forecasts that were proven not to be long lasting due to changing conditions,” he said in the statement.

PJM encouraged the Commission to back planning drivers that go beyond the traditional reliability and market efficiency criteria to address resilience.

“The record developed through a Master Plan, coupled with a Commission-directed planning driver to increase interchange capability and resilience, will ensure that the development of future transmission will withstand the challenge of changing policies and policymakers while remaining anchored in serving the needs of customers in the region, including their desire for cleaner renewable generation options,” Seiler said in the statement.

Joining Seiler on the panel were:

  • Aubrey Johnson, Executive Director of System Planning and Competitive Transmission, Midcontinent Independent System Operator, Inc.
  • Jay Caspary, Vice President, Grid Strategies LLC
  • Natalie McIntire, Technical and Policy Consultant, American Clean Power Association and Clean Grid Alliance
  • Kamran Ali, Vice President of Transmission Planning and Analysis, American Electric Power Co.
  • Karen Onaran, Vice President, Electricity Consumers Resource Council
  • Adam Stern, Manager, Regulatory Affairs, Enel North America, Inc.
  • Bryce Nielsen, Director of Transmission Planning, Strategy & Development, Salt River Project