At the July meeting of the PJM IPS, stakeholders gathered to continue work on refining PJM’s first-ready, first-served queue reform process and improving the transparency, speed, and accountability of project development. The session covered updates on Transition Cycle progress, upcoming milestone requirements, and refinements to interconnection and surplus capacity policies.
Transition Cycle 2 Updates and Interim Deliverability Reminders
PJM opened with a review of the current interconnection cycle schedule, emphasizing that Transition Cycle 2 (TC2) remains on track. Stakeholders were reminded of approaching deadlines for interim deliverability confirmations — a key requirement to retain queue position. Failure to meet these deadlines could result in project withdrawal, signaling PJM’s heightened enforcement of readiness criteria under the new process.
The discussion also included expectations for Final Agreement Negotiations and Decision Point III (DP3), the last major checkpoint before interconnection agreements are executed. PJM emphasized the importance of sponsor responsiveness and timely submission of required materials. These procedural steps reflect PJM’s broader intent to ensure that only viable, committed projects move forward.
New Focus on Construction Performance Metrics
To reinforce accountability beyond the queue, PJM introduced new construction performance tracking tools. These will enable both PJM and stakeholders to monitor how quickly interconnection customers follow through on their commitments after executing agreements. The aim is to provide visibility into systemic delays and ensure that planned capacity additions are realized on time — an essential measure given the growing volume of clean energy projects in the queue.
An overview of the proposed construction metrics framework was shared, which included milestones, timelines, and mechanisms for regular status reporting. The metrics are expected to evolve based on stakeholder feedback in the months ahead.
Surplus Interconnection Service Process Enhancements
One of the most notable updates from the meeting was PJM’s rollout of changes to the Surplus Interconnection Service (SIS) process. These revisions allow developers to leverage unused capacity from existing interconnection rights, aligning PJM’s approach more closely with FERC Order 2023. Previously, SIS agreements required the reuse of capacity at the same Point of Interconnection and for the same facility. Under the new approach, developers can tap surplus capacity even when proposing new or hybrid facilities.
This update is expected to be particularly beneficial for storage and co-located renewable projects, where flexible interconnection solutions are critical to project economics. PJM also clarified that the SIS process will run in parallel with standard queue cycles, reducing administrative bottlenecks and expediting project review.
Stakeholder Feedback and Process Adjustments
Throughout the meeting, PJM actively solicited feedback on the experience of developers participating in TC1 and TC2. Stakeholders expressed concerns about the clarity of milestone definitions, fairness of decision point enforcement, and perceived rigidity in deadline extensions. A developer’s perspective was provided, emphasizing the need for more nuanced treatment of projects facing interconnection or permitting challenges beyond their control.
PJM acknowledged the challenges and indicated that further refinements to the TC process and milestone structure are under consideration. The open exchange reflected PJM’s commitment to stakeholder engagement as it iterates on reform implementation.
Next Steps: First Use Criteria and Design Package Proposals
Looking ahead, PJM plans to continue developing a design package focused on eliminating the “First Use” criteria — a longstanding component of the interconnection process that has added complexity to upgrades and deliverability assessments. Draft recommendations are expected in upcoming IPS meetings, with final consensus proposals targeted for fall 2025.
PJM also confirmed its intention to formalize policy design packages that address additional reform areas, including optionality for certain study paths, enhancements to project modification requests, and revised penalties or withdrawals for non-performance.
As PJM continues to implement its interconnection process reform, the stakes are high for developers and grid planners alike. These procedural changes are designed to move projects through the queue more quickly, increase interconnection certainty, and improve system reliability — all essential as the region integrates more renewables, storage, and load growth from data centers and electrification.
The IPS continues to serve as the forum where this complex reform work takes shape, balancing the urgency of grid transformation with the need for procedural fairness and transparency.
Stay Ahead of the Curve
At Zero Emission Grid, we specialize in helping developers interpret policy shifts, meet decision point requirements, and accelerate project timelines. If your team is preparing for PJM’s Transition Cycles or needs support with deliverability, surplus capacity strategy, or milestone planning, we’re here to help.
Contact ZEG today to accelerate your path to a resilient, decarbonized power grid.
View Meeting Materials here.
