Docket No. EL24-18-000
ROSNER, Commissioner, concurring:
I concur in today’s order denying Urban Grid’s complaint because I agree that PJM did not violate its Tariff when it removed Urban Grid from the interconnection queue for not posting security on time.[1]
I write separately to emphasize that this outcome defies all reasonable explanation for anyone not steeped in the details of PJM’s Tariff.
So, in plain English, what happened? After waiting in PJM’s queue for over five years, Urban Grid needed to pay a security deposit to hold its spot in line. But Urban Grid misunderstood the dollar amount it needed to send to PJM. Because banks were closed when Urban Grid found out about its mistake, Urban Grid committed to send $10.64 million—the full amount—to PJM as soon as banks reopened that next morning. Unfortunately, PJM’s then-effective Tariff included an immovable deadline, which Urban Grid had missed by only a few hours. So, PJM’s Tariff required PJM to send Urban Grid and its 900 MW of capacity to the back of the line at a time when PJM is raising dire warnings regarding resource adequacy.
How did we get here? Interconnection processes should be fast, efficient, and user-friendly. Instead, today’s queues often resemble administrative minefields. We must do better. Otherwise, we risk exacerbating the resource adequacy problems emerging in PJM and other regions. Outcomes like this, where nobody wins, are unacceptable and defy explanation.
Fortunately, to that end, it is not all bad news. PJM’s reformed interconnection process (which, unfortunately, does not apply to this case) explicitly provides interconnection customers with opportunities to cure mistakes, as Urban Grid made here.[2] Additionally, to comply with Order No. 2023, PJM will implement tariff changes that will address many root causes of today’s remarkably slow interconnection queues.
But no one should claim victory until interconnection processes are fast and interconnection bottlenecks are in the rearview mirror. I am committed to working with my fellow Commissioners to do everything that we can to achieve this goal.
For these reasons, I respectfully concur.
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David Rosner
Commissioner