PJM Interconnection and Regulatory Advisory Services

Navigating PJM’s current proceedings on behalf of project developers, asset owners, and investors

The combination of significant load growth from data centers and generator retirements has resulted in record high PJM capacity auction clearing prices, placing PJM under considerable external pressure to bring on new generation resources as quickly and cost effectively as possible. PJM is also facing calls to reform its governance and stakeholder processes to meet these new challenges.

Tangibl has extensive experience and expertise with all facets of the PJM stakeholder process and FERC-related matters, and can provide valuable assistance to project developers, generation asset owners, and investors in navigating both the current processes and any changes to them. Our longstanding relationships across PJM and the broader stakeholder community provide clients with the insight and access needed to anticipate changes and make informed decisions. The following are high-focus areas where Tangibl can provide valuable assistance.

PJM Interconnection Support Services

Expedited Interconnection Track

As part of the effort to interconnect new large loads such as data centers to the PJM grid without jeopardizing overall PJM grid reliability, PJM established an Expedited Interconnection Track (EIT) for new large interconnection projects that meet certain requirements. Such projects are able to take advantage of a streamlined interconnection study process of approximately 10 months. EIT projects must be at least 250 MW UCAP in size and must achieve commercial operation within three years of EIT application submission. The maximum number of EIT applications approved is 10 per year for two years, at which time the EIT program will sunset.

Tangibl has an experienced team of interconnection experts who have successfully navigated numerous projects through the PJM interconnection queue from application submission to commercial operation. We can help interested project developers move successfully through both the EIT and regular PJM interconnection queue process.

During its involvement with IMG Midstream, Tangibl led 30 project requests through the PJM interconnection queue, successfully negotiating and executing 15 interconnection agreements and seeing six projects through to successful commercial operation. Tangibl was also an active participant in the PJM Interconnection Process Reform Task Force (IPRTF), influencing and helping to formulate key areas that were eventually integrated into the new PJM interconnection cycle process.

Surplus Interconnection Service

Many project developers and asset owners are expressing increasing interest in applying for Surplus Interconnection Service, especially for adding battery energy storage to existing standalone solar and wind generating facilities. There also exists the potential for further reforms that would make applying for PJM Surplus Interconnection Service even more economically attractive.

Tangibl’s extensive and successful experience with the PJM interconnection queue process enables us to help interested project developers and asset owners navigate the PJM Surplus Interconnection Service request process.

PJM Regulatory Advisory Services

PJM Governance and Stakeholder Process

FERC has announced a technical conference on PJM Governance and Stakeholder Reforms. While the full scope of outcomes remains to be determined, this technical conference could bring significant changes to the PJM Governance and Stakeholder Process, which will affect all PJM stakeholders, including project developers, generation asset owners, and investors.

Tangibl has vast and longstanding experience in being actively involved in both the PJM stakeholder process and FERC-related matters. We can provide valuable assistance to project developers, generation asset owners, and investors in navigating both the current process and any potential changes to it, given our extensive network of contacts at PJM and with the broader PJM stakeholder community.

Reliability Backstop Procurement and Connect and Manage

Due to the combination of generation retirements and increased demand from new large loads such as data centers, PJM found itself with a reliability shortfall after its last capacity auction, and is conducting a Reliability Backstop Procurement (RBP) to eliminate this capacity deficit. PJM is also implementing a Connect and Manage (C&M) mechanism that will allow data centers to interconnect to the PJM grid without jeopardizing overall PJM grid reliability.

Tangibl is closely following these PJM developments, and has broad experience and expertise with this and other important PJM and FERC-related matters. Tangibl also has extensive contacts within PJM to help clients get the information and answers that they need on these and other vital issues.

PJM Market Design

As a complement to the Reliability Backstop Procurement and Connect and Manage, PJM has released a whitepaper outlining a holistic review of PJM wholesale markets, laying out three potential paths forward for PJM’s wholesale market structure to tackle the issues and pressures it faces in the current environment of new large load demand. PJM is in the process of convening Market Design Workshops to begin discussion on these important issues, and there is a strong possibility that PJM will look to begin a formal PJM stakeholder process to reform its wholesale markets.

Tangibl is an active participant in these discussions, and our deep knowledge of every facet of the PJM stakeholder process enables us to help project developers, asset owners, and investors navigate these evolving issues, which will affect both individual project economics and portfolio asset values going forward.

An example of this was Tangibl’s involvement as IMG Midstream’s PJM stakeholder representative, where our knowledge of the most salient issues to IMG Midstream helped IMG maximize its overall individual asset and portfolio value.

Author: Kenneth Foladare

Ken Foladare is Tangibl Group's Director of RTO and Regulatory Affairs, with deep expertise in PJM interconnection processes, ISO/RTO stakeholder representation, and power project development. He has participated directly in PJM's Interconnection Process Reform Task Force (IPRTF) and CIFP proceedings.

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