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Clearing the US clean energy logjam Conference

May 29, 2024

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

I'm excited to moderate today's event, Clearing the U.S. Clean Energy Logjam: What's Next for the Grid? I know a lot of you are keen on getting right into today's topic. But before we do, just a few housekeeping items. First of all, the engagement tools that you see on your screen are resizable and movable, so you're welcome to move them around to get the most out of your monitor space. I want to stress that this is an interactive session, so please do submit any questions that come up through the Q&A widget at the bottom of your screen. Starting about halfway through the presentation, we'll make sure to leave time for those at the end. Please note, this webinar provides closed captioning in English. If you need closed captioning, please click on the CC icon on the media player below to activate it.

You can check out the related content widget for more background on today's topic. We'd love to get your feedback after the webinar through a short survey. The survey takes less than one minute to complete, and the results help us improve these free public events. Finally, you can chat with us by clicking the chat icon at the bottom of the screen to schedule a private meeting with one of our product specialists. For example, you're welcome to request a demo of our machine learning-powered Nodal Forecasting tool, which allows users to simulate how different assumptions in power markets, policy, and technology could impact your power plant or portfolio evaluations. A quick disclaimer before we start. Please note that the activities of S&P Global Commodity Insights are independent and separate from S&P Global Ratings.

S&P Global, S&P Global Ratings maintains a separation of analytical and commercial activities. Please also note that our external speakers on this webinar represent only themselves and or their respective organizations, and their views may differ from S&P Global's. Thanks again for joining us. With that said, I'm excited to introduce our great lineup of speakers today. Stacey Burbure is Vice President of FERC and RTO Strategy for American Electric Power Company, or AEP. AEP owns the largest electric transmission system in the U.S., totaling more than 40,000 miles. We also have Manuel Esquivel, Manager of Regulatory Affairs at Enel North America. Enel North America is a leading developer and long-term owner of renewable power generation facilities in the U.S., with more than 11 gigawatts of operational capacity across nine states.

Enel also has a significant amount of planned wind, solar, and battery storage capacity in PJM Interconnection. And then finally, I'm sure a lot of our audience members are looking forward to hearing from Donnie Bielak, PJM's Director of Interconnection Planning. As many of you already know, PJM operates the largest organized wholesale power market in the U.S., with approximately 65 million customers, with a footprint that covers all or part of 13 Mid-Atlantic states and the District of Columbia. PJM also oversees transmission planning and operations for the Mid-Atlantic region's power grid. Donnie is responsible for PJM's entire generator interconnection process, which we'll get into later during the discussion. So it's a real pleasure to have three speakers who represent a diverse set of industry perspectives as we dive into the topic of the day: generator interconnection queue reform.

So, a quick rundown of what's on tap for today's webinar. I'm going to provide a brief, high-level overview of the current state of U.S. interconnection queues, followed by a quick explainer on FERC's Order 2023. As many of you also probably already know, Order 2023 is a rule finalized by the Federal Energy Regulatory Commission last year and affirmed in March of this year, which is aimed at clearing what has truly become a huge nationwide backlog of proposed clean energy projects. Then we'll move into a panel discussion focused on the challenges and opportunities presented by Order 2023 implementation and PJM's own ongoing key reform efforts. So first of all, as noted, this is an interactive webinar, so we already have our first audience polling question here.

I just wanted to get a sense of how familiar folks are with today's topics. So I'll give the audience a few seconds to respond here. What is your current level of experience with FERC's interconnection policies? So deeply familiar or industry practitioner. If you know what FERC's eLibrary is or how to use it, this could be you. Somewhat familiar is also an option or beginner. So I'll just give folks a few seconds to respond here. Okay. Great. We have some newer folks, some folks who are somewhat familiar, and then a few industry practitioners. That's great. All right, so moving on. So here we have a snapshot of proposed power generation capacity in the U.S. as of April 2024.

This data was compiled by S&P Global Commodity Insights Energy Research Division as part of an annually updated analysis. As we can see, the US has over 2,200 gigawatts of proposed capacity seeking to connect to the grid. This is across all 7 FERC jurisdictional organized wholesale power markets and 19 major utilities operating outside of those markets in the West and Southeast. Hybrid projects, mostly comprising solar plus battery storage resources, are the clear leader. Overall, renewables, including battery storage, account for 94% of cumulative capacity. We're also seeing growing interest in hybrid projects from developers, with a 16% increase in proposed hybrid capacity, totaling about 111 gigawatts, since last year's analysis.

At the same time, proposed natural gas-fired capacity grew 17% year-over-year, signaling a continued interest in what's known as dispatchable generation, or power generation that can ramp up or down as needed, as utilities seek to meet growing customer demand from sources like data centers, for example. So why is all this an issue? Well, that's more than double the current amount of installed generation capacity operating in the U.S. today. And not all of this capacity, in fact, most of this capacity, will never get built, and in many cases, some of these more speculative projects are delaying more commercial-ready projects. So when is all this capacity actually looking to connect to the grid? Quite soon, actually.

Over 1,300 gigawatts of proposed capacity is seeking in-service dates by the end of 2026, with nearly 94% of that capacity coming from renewables. An additional 844 gigawatts of capacity is scheduled for interconnection between 2027 and 2030. That represents a 37% increase from last year's projections. Overall, renewables account for at least 94% of annual scheduled capacity additions through 2023. Another quick audience question here. I'm just going to pause briefly here to give folks a chance to let us know if, if they're interested in learning more about our U.S. power sector data and energy regulatory research. All right, thanks. Moving on again. It's important here to note that interconnection queue processing times remain relatively long, and they vary across grid regions.

So for example, projects in PJM, on average, have proposed online dates extending out 38 months from when they first entered the queue, according to our data, and in the Southwest Power Pool region, that figure is 71 months. Our research team also identified nearly 700 proposed projects across the U.S. with postponed online dates, with those projects seeking an average extension time of 44 months. Additionally, Commodity Insights identified over 50 extension requests exceeding 100 months. That's more than 8 years. So again, not every project that enters an interconnection queue will ultimately get built. As of April 2024, our data shows that roughly 16% of the listed capacity has an approved interconnection agreement, which is an absolutely crucial step for a project to proceed to construction.

That's actually up 7% from the analysis conducted around the same time last year. And here's a look at projects with signed interconnection agreements by year, with our data showing that about 45% of that capacity, or 159 GW, has proposed in-service dates between 2024 and 2026. Then we start to see the numbers taper off and then a slight jump in the 2030 timeframe. And nearly half of that, 159 GW, is located in the Electric Reliability Council of Texas grid region, with another 29% located in New York State. Another quick polling question here. Just curious to know which grid region you are located in. If you don't know, that's okay, but if you can...

If you can see the grid region where you're located here on this list of options, we'd love to know. We'd love to know where you're coming from. So just give audience members a few seconds to answer here. I'm based in Washington, D.C., for example, so I'm in the PJM footprint. All right, let's see what we've got. Okay. So about a quarter of the audience in PJM, and then things look pretty even actually for the rest of the country. So we're glad to have you all here. All right, so all of that brings us to Order 2023. Again, a final rule FERC issued last year. 2023 was FERC's year of interconnection, as some would say.

FERC also affirmed this rule in March by responding to requests for rehearing and clarification. And at a very high level, FERC's order requires a range of key reforms to help ease this backlog that we're seeing. First of all, it requires transmission providers to move from a first-come, first-served interconnection approach, where projects are studied on a serial basis, to 150-day cluster studies designed to identify any system impacts that require transmission network upgrades. Projects that make it through a cluster study cycle will then proceed to a facility study, which covers all of the design work necessary to begin construction on any grid upgrades needed to accommodate an interconnection request. If a project has successfully navigated that whole process, then they can ultimately execute an interconnection agreement.

Any re-studies, which can be triggered by interconnection queue withdrawals, must be completed within 150 days, and affected system studies, which identify impacts on neighboring transmission systems, are also subject to 150-day deadlines. Study costs are allocated according to a project's proportional impact, which is determined on a per megawatt basis. And importantly, Order 2023 provides for transitional cluster studies that allow for penalty-free queue withdrawals, essentially providing an off-ramp for developers who feel they can't meet the order's new requirements. So key requirements for developers under Order 2023. To cut down on the number of speculative projects that we've been seeing, the rule also imposes more stringent financial readiness and site control requirements for developers.

Required study deposits are $150,000 for projects between 80 MW to less than 200 MW, and deposits are $250,000 for projects 200 MW or larger. The rule also requires developers to demonstrate 90% site control at the time of the interconnection request and 100% site control at the facilities study stage. The rule also imposes harsher penalties for queue withdrawals that impact lower queued projects within a study cluster. On the flip side, the rule also includes some tough new requirements for the transmission providers responsible for conducting these interconnection studies. Transmission providers were previously held to a reasonable effort standard when performing studies, meaning they did not face any penalties for study delays. But FERC limited that...

eliminated that standard with Order 2023 and introduced its first-ever penalty regime for transmission providers who fail to meet their study deadlines. Although, those penalties can still be appealed. Order 2023 also requires transmission providers to publicly post interconnection data for what FERC has dubbed heat maps that can help developers estimate a project's transmission network upgrade costs before they enter the queue. The rule also aims to standardize the affected system study process by requiring what's known as Energy Resource Interconnection Service, meaning projects with projected impacts on neighboring systems. They don't have to show that their capacity is fully deliverable, essentially a lower bar to clear. And importantly, transmission providers must now model hybrid resources or co-located resources that will share the same point of interconnection as a single facility.

Lastly, the rule requires the consideration of alternative transmission technology, technologies. These are technologies that can squeeze more capacity out of the existing transmission system, often at a fraction of the cost and time required for traditional network upgrades. Annual reports on how these an alternative transmission technologies were considered must, must be submitted to FERC. I'll pause here briefly again just to let audience members let us know if they'd be interested to learn how they can simulate the interconnection of a power plant using machine learning Nodal Forecasts for more accurate projections. All right, great. With all of that said, let's turn to our panel discussion.

Just a reminder to please submit your questions via the Q&A widget on your screen, and we'll do our best to get to them toward the end of the hour here. So Stacey, turning to you first. As a transmission provider, what elements of Order 2023 does AEP specifically support? Are there any reforms you'd want to highlight as particularly consequential from a transmission owner's perspective?

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

Thanks, Zack, appreciate the question. So as you noted, the queue backlog is significant, and many of the projects currently in the queue will never be built. So AEP is very much supportive, not only of the specific reforms in Order 2023, but also the overall objective, right? Finding a way through the queue, in essence. So, but in particular, I would emphasize that we really support the first ready, first-serve, cluster study approach, and believe that that will... Is a consequential development industry.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Great. So, Manuel, on that same note, how is Enel viewing Order 2023, and how do you see the rule playing out on the ground from a developer's perspective? What kind of impact do you expect the new commercial readiness and site control requirements to have on development? And are there any new requirements for transmission provider, or sorry, for developers, that you see as particularly helpful or concerning?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah, thank you for the question. So we're very excited about what's going on. It's very consequential. We're living in a very important moment to get to transition the grid to the grid of future. We are very excited about the two sort of major aspects. One is getting the projects ready, getting through the queue and getting through the backlog quickly, and then establishing a system that can also remain new projects that come through the queue after a transition, can clear the process quickly as well. So of course, Order 2023 came out last year, and so compliance, you know, expected in April of this year. Then Order 2023, as you explained, came out, and so compliance was pushed a little bit.

A few RTOs, and I'm most familiar with PJM, had already started a process for the transition. So that's sort of when you, when you say what we're seeing on the, on the ground, it's really two things: seeing sort of what the implementation of the order itself is gonna look like and the compliance filings, and how each RTO is going to be able to integrate all the important aspects of these orders. But then also the experience that we're seeing with those that are currently on their way. And from a PJM perspective, you know, we're excited to see how it's been working. Overall, I think PJM has been doing a great job at going through the different cycles of the transition.

The devil's in the details, and so we're gonna be, you know, sort of hoping and expecting to be able to work collaboratively with PJM, to be able to iron out some details that were not foreseen as the transition was put into place. And now that we're actually in the middle of a transition, you know, how can we collaborate between the RTO and the developers, to be able to, to get to the common goals?

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Stacey, on FERC's order on rehearing clarification, AEP was one of dozens of transmission owners to request rehearing clarification. What were some of the key issues AEP sought rehearing clarification on, and how did FERC respond to those requests? And then also, are there any further reforms that you feel FERC should pursue on interconnection?

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

Sure. Thanks, Zack. So we submitted a very limited request for rehearing and clarification, and that was limited to three main issues. So the first issue was really the elimination of what is known as the reasonable effort standard, and the imposition of penalties on transmission providers. So the second issue was the absence was something that FERC actually didn't do, that we thought was necessary, and that is generator retirement and replacement processes, which are not present in all RTOs. So we encourage FERC to go further and implement additional reforms. And the third issue is simply a timing issue. There was a limited 90-day timeframe provided for transmission providers to comply with the final rule.

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

So in large part, FERC did not respond to any of those three issues, but for the timing issue, which of course, was the least of the three. But we have continued to advocate, for that reform of generator retirement and replace processes, because we see that as critical in order to enable future reliability.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Understood. Thanks. One more question for Manuel before we have Donnie dive into PJM's key reform efforts. Manuel, what are some of the other headwinds for developers outside of Order 2023 compliance that you're seeing? How would you rate challenges like supply chain bottlenecks and local permitting concerns in comparison to getting more cost certainty for network upgrades and the lengthy queue processing times that we've been seeing?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah, thanks for the question. That obviously is a very important consideration as we move through the queue and get through the logjam. Really, what's important here is to consider a lot of the moving parts that are part of this process. You know, you mentioned different challenges that have been faced by our industry, but other industries as well, the supply chain, permitting in general, and those have definitely been challenges that we've had to face. But there was a study recently by a group led by Abe Silverman at Columbia University looking at non-technical challenges that are being faced in the transition to clean energy.

And what that study shows through, you know, surveying a lot of developers, is that the main challenges continue to be the interconnection queue itself and how long the queue has been. And so it's important to consider that as we look at the other aspects and the challenges. You know, a big reason for facing a lot of the other challenges is because the queue has taken so long. The project's sitting for a really long time, once they're ready, then face a very different climate and context than when they first in, went in, with an application. And so looking into the future, I think the faster we're able to get from initial application to the review process, we're gonna definitely start seeing how those challenges are minimized.

During the transition, it'll be important to consider all of that context. Also, you know, sort of understand that we are still a few years out of a global pandemic, so there's still some things that are going to be felt from those aspects. But as we see the projections into the future, that's getting... All of those challenges are getting minimized, and things will be improving. When looking at projects that have an agreement and are getting started with construction, it's also important to dissect that number a little more and just sort of think through how long ago you got those permits. And sometimes when you present a number, right, that might be projects that just very recently got some of those permits.

And so dissecting a little bit the number and seeing the reality of how many projects are actually delayed versus which ones are going through the normal cycle now into construction, I think, is a pretty important aspect to consider there.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Mm-hmm. And, Donnie, so zooming in on PJM, can you just give us a brief overview of PJM's recent key reform efforts over the last few years and kind of bring us up to speed on where PJM is at in that process? How is PJM previously processing its queue, and how is that changing with PJM's transition, transitional cycles and the shift to its new first ready, first served process? Or-

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Sure. Thank you, Zack.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Yeah.

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

So previously, PJM had a first come, first served approach to its generation queue, and those projects were studied serially, one after another. This was developed when we were interconnecting a smaller amount of large, typically thermal units, and that worked very well for what it was designed for. However, this process ultimately showed to be less than optimal, and we encountered a change in the interconnection landscape, which is now a large amount of generally smaller-sized interconnection requests. So in response, PJM and its stakeholders jointly developed a new first ready, first served cluster approach, interconnection process, in which, a large amount of interconnection requests can be studied simultaneously to do a better job to identify system impacts and streamline the process as a whole. We're now transitioning to this new process.

So our interconnection process is, it's proceeding as planned. New service requests for generation resources are moving through the process as designed and promised, with more than 200,000 megawatts of projects to be studied over the next two years, to help states advance their energy policy goals. In December of last year, we identified over 300 projects totaling about 26,000 megawatts, which were eligible for our expedited process or fast lane. We have been working on executing these agreements throughout 2024 and expect to make significant progress through the end of the year, with the goal of processing all of them.... Once the generator project signs their GIA or Generator Interconnection Agreement, they are eligible to start construction.

Last week, we announced the completion of phase 1 of system impact studies for 306 proposed generator projects as part of our transition cycle number 1, and that's part of PJM's new interconnection process. Transition cycle number 1 totals over 45,000 megawatts of energy and projects, and that have now been studied. Project developers now have until June 20th to decide whether to proceed with their new service request into the new- the next study phase of TC 1. The projects are part of this transition cycle are expected to clear PJM's study process and be ready for construction by mid-2025.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Great. PJM's queue reform efforts, these are obviously ongoing. Manuel and Stacey from Enel and AEP's point of view, in your view, what is PJM getting right with its new queue approach? And do you see any specific areas for further improvement?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah. So we definitely see Order 2023 and this interconnection process as a big step, but it's a big first step, and there's other things that need to go sort of together with it. We're excited about other developments that are happening at the same time. The FERC recently some technical panels, technical sessions on Interconnection Process 2.0. There's a lot of sort of details that can and other topics that can continue to develop further to achieve two things: provide greater information at the outset of a process, so the developers going into the queue continue to be as prepared and as complete as possible.

It can then help our RTOs, in this case, requests about PJM, or it can help PJM be able to, stay on track with, those studies and not have surprises at the different, stages, with projects having to drop off the queue. So we're excited about sort of next steps and continue to improve on the interconnection process. We're also excited about the recent, transmission orders, as those will continue to have an important interplay with, interconnections. One detail that's coming in the transmission order is, you know, any upgrades that have caused multiple interconnection projects from dropping from the queue because the, upgrades are just simply too large, need to start getting integrated into long-term regional transmission planning so that they can be considered, by the grid.

And, you know, you start to use that data and those connections there, to make improvements on the, on the project. So we're excited about other things that need to happen in this order, just as an initial first step. Like I said earlier, too, I think a pretty important aspect of the next few months is gonna be collaborating with PJM, so that... 'cause this is new for everyone. The amount of renewables that we're gonna be seeing coming into the grid are new, and how developers in the renewable industry works is new to everyone, including RTOs. And so understanding the realities of the developers that we're seeing and how an investment decision happens is, and collaborating on those is gonna be pretty important.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Great. And-

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

I'll echo. Thanks, Zack.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Yeah.

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

I'll echo Manuel's excitement and appreciation of PJM's leadership in this space. In particular, I would urge PJM to continue development of a more efficient retire and replacement process as exists in other RTOs. And I'll also express appreciation for PJM's recognition that the elimination of the Reasonable Effort Standard and the imposition of penalties is very fraught from just a practical perspective, you know, in terms of who is responsible and is much more likely to lead to litigation than to faster interconnection. And so very much appreciate, you know, PJM appealing that issue to the D.C. Circuit, along with several other issues. But certainly from an RTO perspective, they have been a leader, as Manuel noted, in the interconnection space, and did not wait, right?

Did not wait for Order 2023 to be issued, and have sort of stepped into this space in order to solve the backlog. So very much appreciate those efforts.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

And so, Donnie, back to you. What are some of the overarching lessons learned through PJM's queue reform process? And, can any of these be applied more broadly, perhaps in other regions? Have you identified any best practices that appear to be working especially well so far?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Sure. I think actually everything I'm about to cover will probably be applicable to the larger industry. But the largest lesson that we learned from the previous queue process was that we need to move away from that serial approach and move to the cluster approach just to handle the large amount of requests that are now coming in for interconnection. This allows us to study and process these requests much quicker. So the cluster approach in general looks good so far, but we definitely need to see how it plays out because it is still pretty early. Another lesson learned that we're making pretty good strides on is addressing being able to provide more upfront and transparent information to developers in order to reduce speculative projects.

This leads to what I would probably call a best practice for us, which is our continued advancement of our Queue Scope tool. The original Queue Scope was first made available in December 2022, and it had a tabular format of informational display. You were able to see what your potential impacts would be for your interconnection year on the transmission system, because you need to know if you have room on the transmission system to be able to interconnect. Previously, you really didn't have that, which led to a lot of speculative projects being put into the queue. We do have a new version, which was released in December of last year, and it's a integrated heat map of the PJM system.

So users can now actually visualize how their generator projects may impact congestion within the PJM system. And then maybe also help identify potential upgrades that might be needed if they were to submit them. And, you know, this Queue Scope tool is I would say it's really able to allow developers to better visualize the viability of their potential projects to actually go commercial. And then they can do that before they even enter PJM's interconnection process, and thus be quicker to be first ready, and thus, first served.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Excellent. And, I'll tee this next question up for Manuel first, but, then open it up to anyone else who'd like to add anything. Just curious, what are some of the key dates or milestones in terms of next steps for Order 2023 implementation? And what will you be watching for as FERC begins to issue, its compliance orders?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah, thanks. So, compliance with Order 2023- A is sort of the next step, and so we're starting to see the compliance filings from the different RTOs from that aspect. And then there's gonna be the typical comment period and, you know, FERC responding to those compliance filings. And so something we'll be looking at is for those RTOs that didn't already have a type of process of their own, what their compliance filing is going to look like, and, you know, whether it contains all of the aspects of Order 2023 that are important. Likewise, for those RTOs like PJM, you know, we'll be looking to see those additional aspects of Order 2023 and 2023- A. They're not currently part of the process.

What's the plan for integrating those aspects into them? We definitely appreciate, as Stacey was saying, PJM's leadership in this space, right? And being one of the first ones to come up with an interconnection reform. But there are aspects from Order 2023 that are pretty important that are missing and will be important to integrate into the process. And so sort of seeing how that will play out with the current process will be what we'll be looking for next.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Thanks. And, anyone else want to jump in on that one, or?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Zach, this is Donnie. I can comment a little bit about 2023 here and PJM's perspective.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Sure.

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

You know, PJM's tariff already substantially complies with the final rule, which parallels many of the reforms that PJM has already been implementing through its interconnection process reform effort. So, we actually just filed our compliance filing, and for the most part, we either found that we were already compliant directly with the order, or in instances where we may not have been directly compliant with it, we were certainly meeting the intent of what FERC was ordering. And because all of those aspects of the order really kind of play together, if you change one, it's gonna almost affect one or more other aspects.

So we went out ahead and we identified all those, and we explained our reasoning and our rationale as to why our current tariff would already be compliant.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Gotcha. And Donnie, just staying with you, what are the stakes for getting interconnection queue reform right in PJM, in terms of grid reliability impacts?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Yeah, that's a great question, Zack. Up until about a couple of months ago, I spent my entire career in PJM system operations, the majority of it directly in the control room. So obviously, my perspective on this is going to be very reliability based. But you know, demand on the system is increasing. When I first started here, which was close to 20 years ago, we typically had about a 2%-3% steady growth. We then actually started to see demand level off, which was you know, we were going into a recession. And then we started to see demand reducing because of energy efficiency projects.

But now we're seeing a very sharp, very immediate uptick as we see an economic boom, a return to industry in the United States, and also computing power needed for data centers, cloud storage, AI, what have you. So and then also, we've had a lot of, you know, new electrification. When you look at electrification of cars. A lot of residences are going to more electric ranges, electric heat pumps. That's all going to be pulling on the electrical grid now and in the future, and that's being worked into all of our projections. So we're, you know, we're actually looking at potential growth of more than 40,000 MW over the next 15 years at these current rates.

In order, and in order to meet those demands, we have to, we have to increase our demand. Sorry, our supply. We're going through the interconnection reform right now, and we're trying to interconnect as much as we possibly can to meet these demands. And not only at the same time are we doing that, but we're seeing increased generator retirements. There's a lot of generators on the system now that are just approaching end of life. Not only do we need to keep pace with the demand trends, but also the generator retirement trends. You know, we've cleared about 40,000 megawatts of projects right now that are sitting, waiting to be built. They have signed interconnection agreements.

Unfortunately, they haven't been able to start construction for a variety of reasons. So we've got that. Hopefully, we can get some of those built. We've got our fast lane, which is gonna be clearing out projects throughout this year. We're gonna be doing our transition cycles, so we're gonna be clearing a lot of megawatts very quickly and also focusing on what's going to be first ready, so we can start getting the iron in the ground to meet the demands of the system.

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

Zach, I'll add that while your question was specific to PJM, SPP is considering a 36% planning reserve margin for winter, effective as early as 2026 and 2027. You know, as your slides showed, with a queue that takes 71 months for a project to get through, you know, the stakes from a reliability perspective have never been higher.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Yeah, understood. So, staying with you then, Stacey, and then open this up to everyone. Zooming back out, a few weeks ago, FERC finalized its long-awaited rule on regional grid expansion and cost allocation, known as Order 1920. The rule required more holistic transmission planning at least 20 years in the future, among other things. Compliance will obviously be a years-long process, and it will vary across regions. But with that said, how do you see Order 1920 affecting the generator interconnection landscape, assuming that the rule is upheld and effectively implemented? Are there any aspects of the order you'd want to highlight in relation to interconnection?

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

Thanks, Zach. So we agree that FERC did the right thing with picking up Order 2023 first and having Order 2023, sort of as the foundation for what was needed in terms of reform. Order 1920 is sort of the next building block, and what it does is ensure, you know, as you noted, that there's longer-term planning, and scenario-based planning so that it's more holistic, and RTOs and regions are able to take more information into account as we look further out. Now, of course, the further out you look, the more speculative it is. But our hope is that with implementation of Order 1920, we will avoid the sort of just-in-time planning that led to these sort of extreme backlogs, in the generator interconnection queue.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Donnie or Manuel, anything, anything else to add there?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Well, I think we're excited about the interplay between the interconnection process and the transmission order. Like I said, there's gonna be items that will make the process, the interconnection process, a lot more efficient as well. Items like cost allocation, cost sharing, really looking at areas of the grid that require more transmission upgrades, not just through for the regular development process. So that interplay there and those two moving together is gonna be pretty exciting.

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Yeah, and Zack, I can add on to that. You know, I've already talked about a lot of these items here, but I could definitely say that, you know, both PJM's reform process and the final rule really do focus on and meet the same objectives: streamlining the generator interconnection process, improving processing efficiency, and then also providing more actionable information to project developers to facilitate the interconnection of viable projects to the electrical grid.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Got it. Great. Well, yeah, I think we can open it up to audience Q&A now. Thanks, everyone, for your questions. Let's go with Donnie first. We have a question. We have a question here, asking: Which sectors will demand the most clean energy in the next five years, and can the grid respond fast enough to meet these demands?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Yeah, it's a good question. Thank you very much. So one of the largest drivers for the switch to clean energy really is state policy and legislation. That's what we're seeing, at least in the PJM footprint. So we're working very closely with the states in order to work with them to meet their demands. And yes, we're working very quickly, and I think that we are going to definitely be able to respond fast enough to meet those demands and do so reliably.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

And then, we also had a question, maybe Stacey can take this one, asking: Can the panelists explain how ERCOT's approach differs from, say, PJM, and why ERCOT's approach may not be replicated easily in other regions? ERCOT is often held up as an example of a process that is effective. I believe it's called a connect and manage approach, but it's fundamentally different from other markets.

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

Thanks, Zack. So there are actually two ERCOT questions, and I'll start with the easier one. So the earlier question was about ERCOT and whether this new grid situation changed the way that ERCOT has its own grid, meaning connecting more with others. And so the short answer to that one is that Order 2023 does not change the fact that ERCOT is non-FERC jurisdictional. So Order 2023 will not have any sort of direct impact on ERCOT, because, again, they're not subject to FERC jurisdiction. But of course, we've also seen that sometimes you can take advantage of that and sort of take see where ideas play out in practice and/or improve other portions of your sort of interconnection system based on how that is playing out in the real world.

With respect to the other question on Connect and Manage, I think it is often held out as a model for other RTOs, and there was a lot of discussion on that as a concept in the Order of 2023 comments. It's sort of a question of how you consider the upgrade costs. Now, cost allocation in ERCOT is very different and is sort of an easier answer there. But I'll just pause there and see if my other panelists had anything that they wanted to add based on their experiences with respect to that question.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Manuel, anything to add there, or... Okay, so, Manuel, here's a question that looks like it's in your wheelhouse: How do vehicle-to-grid, DERMS, virtual power plant technologies, et cetera, play into the ability to meet increased demand?

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah, thanks for that question. We are at a point where we need to explore all of the solutions. You know, we talked about it, the interconnection reform, talked about transmission, transmission order. All of those other topics are equally as important. We need to be using all the tools that we have at the distribution level as well. Virtual power plants, all types of distributed energy resource systems. And, you know, a company like Enel has the visibility. We have both, as you presented in the introduction, the utility scale. We also have behind-the-meter solutions. And we're seeing all of those as a pretty important interplay as we transition into a clean grid, as we see the load growth as well.

Some of these loads, like data centers, what part of the... not just the load growth, can they play, but what are the other aspects that they can also contribute with, right? Demand response, and being able to have a robust demand response that values fully the value to the grid that these customers and these loads can bring. So those are absolutely part of the equation.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Donnie, anything to add there?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Yeah, actually, this would be a great opportunity. I think these are all very good technologies, and, you know, we were focusing a lot on supply-side technologies, but we shouldn't discount demand-side technologies either. FERC had the Order 2222, which was for DER aggregations, and PJM has put together and filed what we think is a fantastic framework to facilitate the interconnection of these demand-side responses in order to meet the growing demands on the system in the future.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Another question that looks like it's for you, Donnie. Can you elaborate on the efficiency improvements you previously mentioned? Is it new technologies such as simulation tools, more labor, hiring third-party consultants, things like that? Over to you.

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

I would say yes, all of the above. We have to look at every way where we can improve our efficiency in getting through the queue. One of the biggest things is the technology that we're able to use. There was a lot of manual processes that were still legacy from our original serial queue approach. But again, those were fine. You could do that. You could devote more time per project because there were less projects that accounted for more megawatts. Now we're using a lot of technology as far as either just getting data from the developers, building our models, putting together our impact reports and getting that all submitted.

Contractor use is obviously something that is typically an option for just about everybody as far as you know, labor augmentation is concerned. There are only a set amount of qualified individuals that can do this type of work. But we have been able to get just that right amount of mix of labor and technology to get through everything.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Great. And then, looks like another question here for you, Donnie. Audience member asking, "It sounds like PJM is having success moving more projects through the queue. Is there a way to quantify the difference between how many projects are moving through the queue over the last, say, 12 months versus 3 years ago? How much faster are projects moving through the queue?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Unfortunately, I do not have those statistics in front of me. We do have some of them publicly posted. I know they were actually covered today at a committee meeting. We have the IPS, or the Interconnection Process Subcommittee. That's publicly posted, so I'd recommend you go to PJM.com, look up the IPS, and you can find some of those metrics there.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Great. And then, this may be the last question we have time for. At a high level, this is up for anyone to answer: Will there be a trend of delayed power plant retirements to ensure reliability during the energy transition and intense electricity demand?

Donnie Bielak
Regulatory Affairs and Market Policy, PJM Interconnection LLC

Zack, I'll jump in. I can answer this one probably. So, it's possible. I mean, there's a lot of things that come into play in determining whether a power plant remains online or not, and the biggest of which is, is it economically viable? So from a PJM perspective, we're sending the appropriate price signals in both our energy markets and our capacity markets to incent whether generation should stay online or if it should retire. Obviously, the generation owners have to balance out whether or not the upgrades are required for their operations and maintenance are worth the compensation that they're gonna receive by staying online. So I would say, it's hard to really predict, but PJM is definitely getting the appropriate pricing signals out there to manage that.

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

If I can add-

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Oh, yeah. Manuel, please.

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Yeah, just to add real quick, I think an absolute sort of focus of this should be getting the projects that are in the queue or looking to enter the new cycles after the transition goes through is extremely important. There's a lot of renewables, and then there's also a lot of storage that's in the queue that can start providing a lot of services to the grid. And so accelerating all of that and starting to get familiarized with the grid of the future as soon as we can is gonna be extremely important to be able to, you know, continue that transition and learn from that process as well. And so I wanna say just last is, you know, focus should not just be getting through the queue as quickly as possible.

It's getting through the queue, especially during the transition, working with industry, so that those projects that can be successful are successful and are not bogged down into details that might not matter, so that those resources that are important for the RTO and the grid do come online fast enough to be able to provide the needed services.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

And Stacey, any closing thoughts on that question?

Stacey Burbure
VP of FERC and RTO Strategy, American Electric Power Company Inc

No, nothing to add. Thanks, Zack.

Zack Hale
Editor of Energy News and Research, S&P Global Commodity Insights

Okay, gotcha. Well, I think that that's all the time we have for today. So I just wanna thank everyone again for joining us. Please fill out the brief audience survey at the end. And we look forward to seeing you at future events. So thanks again, everyone.

Manuel Esquivel
Manager of Regulatory Affairs, Enel North America Inc

Thank you.

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