When a generator intending to participate in PJM markets physically interconnects to a distribution facility for the first time, it does so pursuant to state/local rules, and receives a PJM Wholesale Market Participation Agreement (“WMPA”). However, any subsequent interconnections to the same distribution facility by generators intending to participate in PJM markets are subject to FERC jurisdictional interconnection rules (i.e. go through the PJM interconnection process resulting in a Generation Interconnection Agreement (“GIA”)).
Because PJM staff spend significantly more time processing GIA interconnection requests, as opposed to WMPA interconnection requests, the first use test creates a situation where PJM staff must divert time and resources to processing GIA requests on distribution facilities, as opposed to transmission facilities.
Recent developments at FERC indicate that the Commission may be receptive to elimination of the “first use” test in PJM at this time