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Rao Konidena's picture
Independent Consultant Rakon Energy LLC

Rao Konidena found Rakon Energy LLC because Rao is passionate about connecting clients to cost-effective solutions in energy consulting, storage, distributed energy resources, and electricity...

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  • Nov 16, 2020

After MISO and SPP revised their generator interconnection procedures recently, its PJM's turn now.

PJM claims more than $1 billion in benefits in integrating efficient resources. As more and more renewables queue up to interconnect to PJM's transmission system, it remains to be seen if PJM adopts a "cluster" process like MISO. In a clustering process, all the generator interconnection requests received by a certain date are studied together.

MISO is still studying requests from 2018 April window. Some of the interconnection customers are dropping out due to upgrade costs in this late stage of MISOs Definitive Planning Phase (DPP). This DPP is MISO's pathway for serious project developers who are willing to put money ($5,000 per MW) down. Once developers drop out, the ones behind the queue # are potentially liable for upgrade costs.

One of the challenges of RTO interconnection queue processes is, RTOs have to treat every resource the same. So, even if solar makes up a bulk of interconnection requests now - PJM RTO would still have to wait until the request window closes, and then, study all the requests in a certain state/region together - if PJM adopts the clustering process. As a result, a 5 MW solar project will be treated the same way as a 20 MW storage project. On a large generator interconnection size, off shore wind and utility scale solar will be bunched together.

Will PJM follow a similar process? Or, will PJM come up with something different? For now, PJM is covering the bases by asking stakeholders. Expect some FERC tariff filing in spring 2021.

Matt Chester's picture
Matt Chester on Nov 16, 2020

Expect some FERC tariff filing in spring 2021.

As FERC starts becoming a bit more and more political with each passing year, do you expect the change in Administration will impact the upcoming actions of FERC in this regard compared with the position of the body over the recent years? 

Rakesh  Sharma's picture
Rakesh Sharma on Nov 16, 2020

Hey Matt, Curious: why do you think FERC becoming political is a recent development? Don't you think that an agency whose commissioners are appointed by the President will be stacked with people who toe or, at least, subscribe to his/her views? 

Matt Chester's picture
Matt Chester on Nov 16, 2020

While the commission is of course appointed by political actors meaning there's a degree of partisanship to it, they've long had to keep up an apolitical position-- similar to how the head of EIA is selected by the political actors, but it's required to be an independent and non-partisan body. Here's a good article from a few years ago talking about the descent into more deliberate partisan positioning by FERC commissioners:

Bob Meinetz's picture
Bob Meinetz on Nov 16, 2020

Matt, what evidence do you see the appointment of Pugliese or either of his successors has led to "more deliberate partisan poitioning by FERC"?

"'Those two resources — coal and nuclear, specifically — have a lot resilient attributes that, from a national security perspective, are hard to deny,' he said."

Either that's a A) political statement, or B) a kneejerk attack by renewable energy supporters who refuse to face the fact it's true.

Rakesh  Sharma's picture
Rakesh Sharma on Nov 17, 2020

I am with Bob on this one. I really don't see any evidence of Pugliese's partisan positioning. He simply made incendiary remarks that generated a news cycle by instigating ire from renewable energy advocates. Forget the noise. If you look at FERC orders under the Trump administration, I think you will find that they hewed to economic priorities. I doubt if the agency has a "fiercely guarded independence" as the article claims.

Under the first term of the Clinton administration, the agency did not have a single commissioner associated with the oil and gas industry, even though fossil fuels accounted for the overwhelming majority of electricity generation. Does that amount to partisan positioning? I think so.  

Bob Meinetz's picture
Bob Meinetz on Nov 16, 2020

Matt, though many wind and solar developers view it that way, FERC isn't becoming more "political". It's recognizing a lack of federal oversight since 2005 has contributed to unreliability and anti-competitive practices seeping into what was supposed to be a wholesale electricity market. Commissioners are discovering when different states have different environmental and financial priorities, operating a truly-free marketplace in electricity is difficult, if not impossible.

As in any market, complexity is exploited by participants to favor their own products. It's in accountants' interest to promote ultra-complicated market rules that would make a seasoned analyst's eyes glaze over - a skill they've honed to perfection.

Unlike the pre-2005 SEC, FERC has neither the resources nor the authority to hold energy holding companies with $20+ billion in revenue accountable. As usual, electricity customers pay the price.


Joshua Aldridge's picture
Joshua Aldridge on Nov 16, 2020

Thank you for explaining exactly what the "cluster" process entails. While it seems to drag the process out longer than necessary, I'm not sure of any viable options that could help things transpire more smoothly. Are you aware of any? 

Rao Konidena's picture
Rao Konidena on Nov 16, 2020

I would make a plug for "fast track" projects that are less than 5 MW for instance. Because interconnection engineers are looking at reliability impact on the grid, when the entire interconnection amount is injected - we can all agree that a 5 MW injection is not going to have the same impact as a 50 or 100 MW interconnection request for example.

Rao Konidena's picture
Thank Rao for the Post!
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