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FERC Docket Nos. ER20-1851, ER21-936, ER21-1633 and ER20-714

Paul Dumais's picture
CEO Dumais Consulting

Owner and CEO of Dumais Consulting ( which provides expert ratemaking services to energy companies. Dr. Dumais is a ratemaking and regulatory expert who specializes on...

  • Member since 2018
  • 157 items added with 120,597 views
  • Aug 12, 2022

On July 15, 2022, in Docket Nos. ER20-1851, ER21-936, ER21-1633 and ER20-714 (consolidated), FERC determined that the four solar generating plants physically located on the distribution system of the interconnecting transmission owners are not eligible for reactive power compensation. 

Four solar generating facilities seek compensation under Schedule 2 of the PJM OATT.  This consolidated proceeding considers a single issue that has been severed from all others in the underlying cases: whether the Facilities are eligible to receive compensation under PJM Schedule 2.   In this Initial Decision, the ALJ first found that Schedule 2 contains two eligibility criteria for generation facilities: (1) that the facility must be under the control of PJM, and (2) that the facility must be operationally capable of providing voltage support to PJM’s transmission facilities such that PJM can rely on that generation facility to maintain transmission voltages. The ALJ then found that a preponderance of the evidence in all four cases supports a finding that the Facilities do not satisfy the second criterion. 

First, PJM explained that it cannot rely upon the Facilities for voltage support because they are not directly connected to the transmission system. PJM’s view on this matter warrants substantial weight because PJM operates the transmission system and is responsible for maintaining transmission voltages pursuant to Schedule 2.  Next, record evidence establishes that (1) PJM does not control the distribution buses to which the Facilities interconnect and (2) systems on those distribution buses may counteract any voltage support the Facilities provide. PJM explained that “[i]t is industry practice to avoid voltage regulation conflicts by directing voltage regulation to the nearest electrical interconnection.” There is therefore adequate reason to conclude that voltage regulation conflicts would arise were PJM to call upon the Facilities for voltage support. Next, according to PJM, “[g]enerators that are connected at a high electrical distance from the closest BES bus have greatly reduced utility for direct voltage support of the BES as compared to an identical asset directly connected to the BES.”  There is sufficient evidence to conclude that the electrical distance may impair the Facilities’ capability to provide voltage support to PJM. Last, the power flow modeling conducted by Applicants’ witnesses does not outweigh the contrary evidence on the record. While the power flow modeling suggests that the Facilities may impact transmission voltages in some circumstances, it does not establish that the Facilities are operationally capable of providing voltage support to PJM’s transmission facilities such that PJM can rely on the Facilities to maintain transmission voltages. Moreover, the modeling evidence must be discounted because it does not address PJM’s concerns with voltage conflicts and because of the apparent errors that Trial Staff identified.


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