Commissioner Rosner's Concurrence Regarding Hickory Wind, LLC under ER25-1594

Docket No. ER25-1594-000

I concur in today’s order denying Hickory Wind LLC’s (Hickory) requested waiver because I agree that Hickory has not satisfied the Commission’s waiver criteria.[1]

I write separately, however, to highlight the latest disappointing outcome to result from an antiquated interconnection process:  a project ready to provide badly needed generation must now start over despite having entered PJM’s queue nearly nine years ago.

Consider the facts:  Hickory entered PJM’s queue in 2016.[2]  Six years later, in 2022, it executed a generator interconnection agreement with PJM and the local transmission owner, ComEd.  Since then, Hickory acquired land and commenced construction, including work on a substation and other facilities.[3]  Despite these efforts, a local zoning ordinance enacted in 2023—seven years after Hickory first requested interconnection service—now prevents Hickory from using its original point of interconnection to the grid.  Hickory proposed to resolve this zoning conflict by moving the project’s point of interconnection less than two miles away.  PJM’s response was that Hickory’s alternative location would require re-study, and that Hickory must submit a new interconnection request, placing the project all the way at the back of the line.[4]

This story may well have ended differently if PJM had fully embraced the efficiencies of new technologies that use automation to reduce the time to study—and notably in this case, re-study—projects.[5]  To be clear, the Commission has approved rules restricting modifications to projects after an interconnection agreement has been signed for good reasons.  Principally, this practice is intended to protect other project developers based on the assumption that there will be delays and uncertainty during the weeks to months that it takes to re-study a changed project.  But this assumption is increasingly becoming an outdated one that grid operators and transmission owners have the tools to overcome.  These new automation tools reduce the time it takes to study an interconnection cluster from years (or months or weeks for re-studies) to days.[6] 

Put simply, innovation has the potential to rescue us from the stagnation that has afflicted interconnection queues across the country.  Although today’s victim is a wind project in PJM, backlogged queues are fuel-neutral, plaguing generation of every type, and affecting grid operators in many regions.  I recently highlighted how grid operators are beginning to use automation to drastically reduce system impact study—and re-study—times without compromising accuracy and with no need for additional regulation from this Commission.[7]  There is also the prospect of further expanding the suite of automation tools to encompass not just power flow studies, but the full range of studies required in each phase of the generator interconnection process needed to ensure that new resources can safely connect to the grid.

Additionally, automation efficiencies are not limited to faster technical studies.  They extend to more boring—but essential—workflow management systems, through automated queue management platforms.  These solutions provide centralized, integrated, and fully transparent dashboards that allow grid operators, transmission owners, and interconnection customers to avoid cumbersome, error-prone email-based processes, which risk a single miscommunication setting a project back years, as happened to another PJM project in Urban Grid.[8]  Finally, artificial intelligence has the potential to further accelerate and enhance the suite of available interconnection automation tools, and I am glad that PJM recently announced its plans to explore that possibility.[9]

Here, with automated study processes, PJM might have been able to give Hickory a GIA years sooner, perhaps allowing the project to be in operation today.  Even if not, with a more automated process, PJM might have been able to assess Hickory’s proposal to change its point of interconnection without significant delay or harm to other interconnection customers, and without requiring Hickory to start all over.

Today, more than ever, we cannot afford to leave any available tool in the toolbox, especially one as promising as interconnection automation.  I urge PJM and grid operators across the country to fully leverage the potential of automation to improve all phases of the interconnection process, alongside other efforts to make queues faster and more efficient.  I am confident that the Commission will continue to support such initiatives.  As I have said before, consumers deserve nothing less.

For these reasons, I respectfully concur.