I represent PJM Interconnection in Virginia on Executive and Legislative matters, I am writing to provide technical comments on the proposed guidance memo 22-2012 that was published in the Virginia Register on August 1, 2022. The comments are limited to the first full paragraph at top of page 44 of DRAFT Guidance Memo No. 22-2012 - Stormwater Management and Erosion & Sediment Control Design Guide
The following technical changes shown in red below are recommended to clearly specify the applicable document that is referenced from the current interconnection approval process at PJM as well as to accurately track the proceedings underway at the Federal Regulatory Management Commission (FERC) regarding approval of the new queue process proposed by PJM and the NOPR FERC has issued regarding the interconnection processes used by PJM and other RTO’s around the country. The proposed technical changes are as follows:
To provide further guidance, "Interconnection Approval" can be demonstrated by the issuance of (1) the System Impact Study as defined in the PJM Manual 14a: New Services Request Process, Section 4.3 (Revision:29, Effective Date: August 24, 2021 or as may be amended thereafter), or (2) an equivalent study by PJM under any process approved by FERC that results from the PJM Interconnection Reform Process or (3) an equivalent study by PJM under any process approved by FERC as a result of the Notice of Proposed Rulemaking (NOPR) that was issued by FERC on June 16, 2022 regarding expediting the interconnection approval process. "Interconnection Approval” can also be demonstrated by the issuance of a Small Generator Interconnection Agreement for projects that go through the state interconnection process.
I am also advised that given the time it will take for FERC to approve and PJM to put into effect their proposed or any other new interconnection process ordered by FERC, it is highly unlikely that any project that does not receive a system impact study under (1) above, the current PJM process, will receive an “equivalent” study from PJM prior to the December 31, 2024 deadline established in this section of the proposed guidance.
I hope you find this information to be helpful and please contact me if you have any questions on this.
Sincerely,
Philip F. Abraham
Director and General Counsel
The Vectre Corporation