Dear Wholesale DG Working Group,

On April 30, 2012, FERC issued an order regarding a proposal by PJM to modify its interconnection rules to, inter alia, create a separate queue for projects 20 MW or less (copy attached).   SEIA intervened as a party and filed comments pointing out that the PJM proposal provided little assurance to project developers regarding timing, because the study deadlines weren’t binding.  SEIA suggested that binding deadlines be established and the transmission provider make a showing of good cause for any delay upon request from the customer.   FERC agreed:

However, we cannot find the proposal just and reasonable without the provision of further study deadlines and assurances that such deadlines will be binding.  PJM’s primary queue tariff language provides deadlines for feasibility and system impact studies, provides that PJM shall use due diligence in meeting these deadlines, and requires that, if additional time is needed, PJM supply an explanation.  PJM’s alternate queue proposal, which stipulates that it is transmission owners who will conduct the necessary studies, does not appear to provide parallel protections, and specifies only that the studies be conducted in a “timely manner.”  SEIA and the New Jersey Board assert that this proposed evaluation process allows for too much flexibility.  We agree.  We therefore find that PJM must include in its alternate queue language deadlines similar to those for PJM’s primary queue; a defined role for PJM in approving any delays in the interconnection studies by transmission owners; a requirement that a showing of good cause for any delay be made upon request from the customer; and further detail regarding how PJM intends to “monitor and coordinate” the completion of any studies required.  We anticipate that the addition of these deadlines and assurances will help alleviate the New Jersey Board’s concern regarding the interplay between state interconnection rules and PJM interconnection rules.  To the extent the New Jersey Board finds that further reform in this area is necessary, we expect PJM and its stakeholders to continue to discuss the New Jersey Board’s concern.  If the New Jersey Board is not satisfied with the results, it can seek remedy from this Commission with an appropriate filing.

If you have questions or concerns, please contact me.  And a special shout out to Jim Torpey of SunPower for bringing this to my attention and suggesting that we focus on making the study deadlines tighter. Thanks Jim.

Best,

Dan Adamson