On May 13, 2024, FERC issued Order 1920 to advance long-term regional transmission planning. Order 1920 focuses on regional long-term transmission planning to identify transmission needs, and cost allocation methods for facility upgrades. FERC Order 1920 compliance filings and proposed tariff revisions are due in mid-2025.
PJM’s compliance plan will involve several stakeholder meetings, including outreach to states. For example, PJM will hold a series of special Transmission Expansion Advisory Committee (TEAC) meetings to discuss the compliance filing with members. PJM has also indicated its intent to begin scenario development for the first Long-term Regional Transmission Planning (LTRTP) cycle.
PJM has scheduled three meetings in September for stakeholder presentations seeking feedback on the following topics:
- Scenario Development: structure, policy modeling, and non-policy retirements
- Benefit metrics
- Alternative transmission technologies
- Project selection criteria
- Use of multiple scenarios: for need identification, evaluation, and selection
Other Order 1920-related topics remain open but were not specifically highlighted by PJM.
MAREC Action (along with Advanced Energy United) participated in the September 6th TEAC meeting and focused on least-regrets planning; state policy considerations; and coordination of planning and generator interconnection studies. This article outlines comments in each of these three areas.
Least Regrets Planning
Our comments centered on the theme of least-regrets planning—identifying a portfolio of projects that serve a range of scenarios and outcomes. PJM’s least-regrets transmission planning identifies the potential regret of a project not being cost effective in the future, as well as the potential regret of customers facing excessive costs.
PJM’s current focus remains on Order 1920 compliance, but the Order faces legal challenges. The outcome of FERC Order 1920 is uncertain, but long-term transmission planning is still sorely needed considering the region’s load growth, fossil fuel plant retirements, and increased renewable deployment. PJM, stakeholders, and states must work toward a holistic, practical transmission planning regime that ensures reliability and supports economic growth.
State Policies
Another key issue is determining which state policies should be incorporated into the scenarios and to what extent. It would not be advisable for PJM to rely solely on its own discretion to decide which state policies are included. Instead, PJM should collaborate with states to develop a clear framework and criteria for including state, county, and city goals or policies in the Long-Term Regional Transmission Planning (LTRTP) process. PJM should not act as the sole decision-maker in this process. Instead, there should be a transparent and structured approach to these decisions. This framework should cover all types of policies, both related to generation and demand, not just clean energy goals, and could also account for factors like permitting and siting. Doing so would provide legislators with clear guidance on how to craft new laws, ensuring that transmission infrastructure will be in place to support their goals. States and PJM must collaborate to develop a practical and effective solution.
Generator Interconnection
A final area of interest for MAREC Action is the relationship between the Long-Term Regional Transmission Planning (LTRTP) process and generator interconnection. FERC highlighted the significance of this topic by dedicating a separate section to interconnection and transmission planning. Under Order 1920, PJM is required to account for network upgrades resulting from the generator interconnection process within its Order 1000 framework, and consequently, its existing Regional Transmission Expansion Planning (RTEP) process. Order 1920 outlines specific criteria for including network upgrades in RTEP:
- The upgrade was identified in at least two cycles over the previous five years
- It involves at least 200kV and $30 million
- The upgrade is not yet developed and is not part of an executed Generator Interconnection Agreement
PJM is currently transitioning from a serial study interconnection process to a cluster study approach, with three clusters set to be processed over the next 3-5 years. These clusters are substantial and continue to grow, each ranging from 60 to 80 GW. The associated network upgrade costs will be significant, exceeding what many projects can afford. However, these upgrades will offer benefits beyond those gained by the interconnecting generators. The current transition clusters that PJM is working through can provide valuable input for the Regional Transmission Expansion Planning (RTEP) process, including insights into where new energy resources are likely to be located. Incorporating this information and the associated upgrade projects into RTEP will significantly strengthen the robustness of the planning process.
Order 1920 permits PJM to integrate the generator interconnection, Order 1000, and LTRTP processes into a unified planning framework. While this could be a complex undertaking, stakeholders urge PJM to enhance coordination among these processes. Interconnection studies should feed into the RTEP, which should then guide the LTRTP, with clearly defined criteria for when upgrades transition between these stages. A logical starting point for PJM would be to analyze the results of the forthcoming cluster studies.