2025 – The Year of “How Do We Move Even Faster”

Originally posted via LinkedIn

It was supposed to be Order 2023 that moves the generation interconnection queues from a serial study to cluster study to make the queue processing time faster – but in the end that is now not enough. Many places across the United States are still awaiting FERC to rule on Order 2023 Compliance filings such as APS, PAC, PSCo, and most RTOs. Thus, 2025 is the year of “make the queue processing event faster” which also means create a new queue option.

Just last week, PA Governor Shapiro said PA might leave PJM since “…it has proven over the last number of years, too darn hard to get enough new generation projects off the ground because of how slow PJM is.”

While we await FERC to rule on Order 2023, FERC has already approved PJM’s RRI (Reliability Resource Initiative) that offers one-time application window for projects to join Transition Cycle #2 for 50 selected projects through a set of scoring criteria.

MISO and SPP are making their own “fast queue rules” now (ERAS). For MISO, ERAS stands for Expedited Resource Addition Study and SPP’s ERAS stands for Expedited Resource Adequacy Study. MISO and SPP defer from PJM in the sense that there is not a cap to the number of projects allowed in the “fast track”.

Both PJM and MISO claim that existing projects in the queue will not be delayed due to these fast tracks as arguments are being made about queue jumping, etc. However, an argument could be made that PJM’s proposal is the least harmful to projects in the existing queue since this a one-time process of only 50 projects. Currently, SPP’s rules are a one-time event but with no cap on the number of projects.

One could argue that MISO’s ERAS with a sunset date of 12/31/28, or upon the completion of the 2027 Definitive Planning Phase (DPP) queue cycle, whichever occurs first is the most detrimental to projects in existing queue since this is more than a one-time event.

We await the actual filings to FERC for MISO and SPP to see final proposals. Within the meanwhile, PJM’s submission window for RRI opened last week. The horse has been let out of the gate with a new world of an additional queue option to speed up the amount of generation available to serve native load as well as anticipated load growth from data centers and AI.

To read more blog posts from Amy Jo Miller, please see her blog here.