![]() ![]() The basic approach under both the PJM proposed tariff and FERC proposed rule is the same: transition will switch from the current first-come, first-served approach to a first-ready, first-served approach. All of this means the FERC final rule is unlikely to be implemented before 2024. FERC will also have to allow a reasonable period for each RTO and utility to make a compliance filing to amend its interconnection tariff consistent with the final rule. A final rule would probably not be issued before the end of the first quarter of 2023, with a right for parties to seek rehearing of the final rule. Not only is there a reply comment period following the issuance of the final rule, but FERC's proposals are more far-reaching than PJM's proposals and contain requests for suggested alternative solutions to a number of elements. On the other hand, the FERC process will take more time to complete. The effective date is important for reasons discussed in more detail below. PJM has proposed that FERC accept its proposal by October 3, 2022, to become effective January 1, 2023. The window for public comments on the PJM proposal closed in mid-July, and PJM recently provided responses to those comments.įERC is collecting comments on its proposals until late September. To the extent that a utility or RTO (a regional grid operator like PJM) has in place an interconnection tariff that is equivalent to or better than the tariff requirements that FERC requires ultimately in its final rule, that utility or RTO can keep its tariff provisions in place. The ERCOT grid is not subject to FERC jurisdiction. However, the FERC proposal would not apply to entities in Texas. In addition, all municipal and cooperative utilities not regulated by FERC would be subject to the rules to the extent they use any transmission system of a FERC-regulated public utility under a so-called reciprocity tariff requirement. On the other hand, the FERC notice of proposed rulemaking, or NOPR, would apply to all regional transmission organizations, including PJM, and all investor-owned public utilities outside of regional transmission organizations. The PJM proposal, which was overwhelmingly approved by PJM stakeholders, would apply only to PJM interconnection requests. The goal of each is to accelerate interconnection studies and the execution of interconnection agreements by weeding out speculative projects and allowing projects more likely to proceed to commercial operation to leapfrog other projects in line. The Federal Energy Regulation Commission proposed new rules in June to revamp the way interconnection requests are processed, and PJM, the electricity grid in the mid-Atlantic states and parts of the Midwest, made proposals of its own. ![]()
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