FERC 2023 Decision on PJM’s Compliance Filing

On July 24, 2025, FERC issued its decision on PJM’s compliance filing for Order Nos. 2023 and 2023-A, partially accepting PJM’s proposals while directing additional revisions within 60 days. FERC found that PJM’s filing relied too heavily on “conceptual proposals” rather than fully incorporating required changes into its Open Access Transmission Tariff (OATT).  

FERC approved several elements of PJM’s existing process, including its three-stage cluster study design, interconnection application windows, site control rules, study deposit structure, readiness deposit framework, withdrawal penalties, and transition process. PJM was also permitted to retain certain tariff provisions around milestones, such as minor point-of-interconnection changes and one-year extensions. These approvals provide PJM continuity in running its interconnection queue while aligning with key parts of FERC’s Order 2023. 

However, FERC rejected PJM’s proposal to rely on “reasonable efforts” for reviewing interconnection requests and study timelines, instead requiring stricter accountability measures and study delay penalty structures. Additional directives included adopting FERC’s required definitions for network upgrades, changing the allocation of study costs, allowing surety bonds, and ensuring transparency of interconnection data. FERC also ordered revisions on affected system studies, storage resource operating assumptions, co-located generation, surplus service, and alternative transmission technologies.  

Overall, while PJM preserved flexibility in several areas, FERC made clear that substantial OATT revisions remain necessary for full compliance. 

Key Takeaways: 

• FERC partially approved PJM’s compliance filing but directed further revisions within 60 days. 
• PJM retained its cluster study process, application windows, deposit framework, and withdrawal penalties. 
• FERC rejected PJM’s reliance on “reasonable efforts” for timelines and directed stronger accountability measures. 
• Major revisions are still required on many aspects of PJM OATT tariff such as study costs, network upgrades, storage assumptions, co-located facilities, and transparency rules. 

Next Steps: 

On August 4, 2025, PJM requested a 30-day extension to file its compliance with FERC Order, moving the deadline to October 22, 2025. FERC granted the request, and PJM is now expected to submit its compliance filing by that date. 

How EPE Can Help 

Navigating such changes in the midst of two ongoing transitional clusters is not an easy task. With compliance being filed later in the fall, it is expected to be approved and effective for the upcoming Cycle 1 application window. 

Contact our team using the form below to find out how we can help you stay prepared and mitigate interconnection risk in the upcoming window.