On November 18, 2019, Anbaric Development Partners, LLC (“Anbaric”) filed a complaint against PJM Interconnection, L.L.C. (“PJM”) alleging that PJM’s transmission interconnection procedures deny meaningful open access interconnection service to merchant transmission projects designed to connect remote generation resources, including offshore wind generation, to the PJM transmission system (“Transmission Platform Projects”). Anbaric requested that FERC: find that the PJM Tariff is unjust, unreasonable and unduly discriminatory or preferential because it does not provide Transmission Platform Projects the opportunity to obtain material interconnection rights; direct that Transmission Platform Projects be given the opportunity to obtain material interconnection rights; and order PJM to modify its Tariff to include a new category of Transmission Platform Projects to connect remote renewable generation facilities to the PJM Transmission System. Anbaric also requested that any order from FERC apply to all of Anbaric’s projects with positions in PJM’s interconnection queue as of the date of its complaint.

Anbaric’s complaint focused on two provisions of the PJM Tariff, which it alleges deny transmission developers the right to obtain meaningful and material interconnection rights to the PJM transmission system unless the project: (1) connects to another control area outside of PJM, and (2) is either direct current or controllable alternating current. Anbaric explained that because its Transmission Platform Projects are connecting remote offshore wind generation to the PJM transmission system rather than connecting the PJM transmission system to another control area, PJM processes and studies these projects assuming that they have no ability to inject power onto the PJM Transmission System. In so doing, Anbaric alleges that the PJM interconnection procedures make the development of Transmission Platform Projects impossible because they cannot offer offshore wind generators the ability to inject their power into the PJM Transmission System.

By contrast, Anbaric alleges that the PJM Tariff allows for proposed interconnection transmission facilities that are bundled with offshore wind generation facilities to be studied and provided with meaningful and material interconnection rights. According to Anbaric, PJM will study bundled projects’ estimated power injections into the PJM transmission system based on hypothetical wind turbines (if the actual turbines have not been ordered or procured at the time of the study) to identify the upgrades necessary to accommodate the interconnections. As a result, these bundled projects obtain material interconnection rights that the associated offshore wind generation facilities can rely on to inject power into the PJM transmission system. The complaint goes on to explain that there is no technical reason for PJM’s differential treatment of bundled versus transmission-only projects in this context.

Finally, Anbaric alleges that PJM’s denial of interconnection service to Transmission Platform Projects is precluding PJM coastal states from obtaining Transmission Platform Projects as an efficient and cost-effective means of interconnecting large amounts of offshore wind resources to onshore grids and harming these states’ ability to meet ambitious offshore wind mandates.

PJM’s Answer to Anbaric’s complaint is expected December 19, 2019, and Anbaric’s complaint is available here.