Capacity Archives | Citizens Utility Board https://www.citizensutilityboard.org/blog/category/capacity/ Fight utility rate hikes, promote clean energy, and advocate for consumer protections in Illinois. Wed, 17 Dec 2025 23:11:35 +0000 en-US hourly 1 https://wordpress.org/?v=6.8.2 https://www.citizensutilityboard.org/wp-content/uploads/2020/09/cropped-CUB_LogoBadgeAlt-32x32.png Capacity Archives | Citizens Utility Board https://www.citizensutilityboard.org/blog/category/capacity/ 32 32 CUB statement: Capacity market prices reflect need for data center reform https://www.citizensutilityboard.org/blog/2025/12/17/cub-statement-capacity-market-prices-reflect-need-for-data-center-reform/ Wed, 17 Dec 2025 23:03:56 +0000 https://www.citizensutilityboard.org/?p=44301 The following is a statement from CUB Executive Director Sarah Moskowitz on the results of PJM Interconnection’s 2027-28 capacity auction, announced Wednesday, Dec. 17 (Read the full statement here.) After a third straight auction marked by unacceptably high prices, it is painfully obvious that our capacity market is breaking under the weight of data center demand and a dysfunctional interconnection queue. Even worse, since the auction results fell below the reliability requirement, consumers are getting the worst of all worlds: paying more money for reduced electric reliability, while existing generators get a windfall. These results ramp up the urgency for decisive action from both PJM Interconnection and individual states, such as Illinois, to rein in runaway data center-related energy demand and protect customers from future price spikes. Data center companies are among the wealthiest in the world, and it is simply unconscionable that customers should pay unbearably high power costs to foot the bill for data center energy guzzling. This is a historic moment that requires action and leadership from PJM and the states in defense of electric customers. What’s good for reliability is good for affordability: Data centers must be held accountable for their own costs. Without real reforms, in just a few years 67 million electric customers in the PJM footprint could face rolling blackouts and an escalation of power bills that make the current price spikes seem tame. While there is a long list of actions that are required, these reforms are at the top of the list: PJM should extend the lower price cap to protect customers, and eliminate any price floor. PJM and states should require data centers to bring their own new clean energy. States should require that data centers operate under maximum energy efficiency and assign data centers into a special rate class to make sure those facilities, and not everyday customers, are paying for data center-related upgrades to the distribution system. –CUB Executive Director Sarah Moskowitz Background: On Wednesday, Dec. 17, PJM Interconnection, a “Regional Transmission Organization,” announced the results of an auction to determine the price for reserve power, or “capacity.” PJM is the largest grid operator in the country, serving 67 million customers across all or parts of 13 states and the District of Columbia (including Commonwealth Edison’s 4.2 million customers). The auction (technically referred to as the “Base Residual Auction”) was held Dec. 4-10. It set a capacity price of $333.44 per Megawatt-day, which will be in effect from June 1, 2027 through May 31, 2028. Capacity costs are payments consumers make to power generators–the companies that own power plants. These costs are a key component (roughly 20 percent) of the price ComEd customers pay for electricity. ComEd has not yet announced how this will impact its supply price in June of 2027. Like last year, the capacity cost hit a price cap negotiated by Pennsylvania Gov. Josh Shapiro. The price is more than 11 times higher than what the price was for 2024-2025. That price cap is set to go away after this auction, when a status quo, higher price cap is reinstated. Capacity auction prices in recent […]

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CUB Q&A: PJM’s Critical Issue Fast Path (CIFP) Policy Proposal on Data Centers https://www.citizensutilityboard.org/blog/2025/11/13/cub-qa-pjms-critical-issue-fast-pass-cifp-policy-proposal/ Thu, 13 Nov 2025 16:12:51 +0000 https://www.citizensutilityboard.org/?p=44048 What’s happening? On Wednesday, November 19, PJM members will vote on how to integrate data centers into the grid. As we’ve detailed elsewhere, data centers require massive amounts of electricity and drive up consumer costs. Some, but not all, proposals would ensure that data centers only connect to the electric system if we maintain reliability and affordability. Who is voting? PJM has 5 different types of members, Generation Owners, Transmission Owners, Electric Distributors, Other Suppliers, and End Use Customers (big industrial users of electricity and consumer advocates, like CUB). If you’re noticing how much power big monied interests have, and how little consumers have, you’re not wrong. Do state lawmakers have a vote? No. Does anyone represent the public interest? Only the 14 voting consumer advocate offices. Big tech companies like Google, Amazon, and Meta are not yet PJM members. How does the vote work? What are they voting on? There are 20 proposals! They all fall on a spectrum of doing next-to-nothing to protect reliability and affordability, to actually making data centers take responsibility for themselves. PJM Members can vote “yes” on multiple proposals. The vote is advisory, which means the PJM Board does not have to follow its results. However, proposals getting a significant amount of votes will certainly attract the PJM Board’s attention. What are the issues important to consumers? CUB is evaluating proposals based on the following criteria: -Require data centers to bring their own new generation or demand response for consistent service. Stealing existing generation doesn’t count. -…if data centers don’t bring their own generation or demand response, then they are required to act flexibly or be interruptible (can turn them off as needed). Data centers must never cause blackouts for the rest of us. -Improve the load forecast to make sure that PJM doesn’t double-count speculative data centers. -Overall, prevent data center capacity, energy, and transmission costs from falling on consumers. Which proposals meet CUB’s criteria? CUB has joined in with consumer advocates from Maryland and Pennsylvania on a proposal, called the Joint Consumer Advocates proposal. The proposal protects consumers from high capacity costs, limits energy costs, improves load forecasting, extends the price cap for two years, and starts a new stakeholder process to prevent data centers from increasing our transmission costs. The proposal was carefully developed with consumers at the forefront. Other proposals that meet CUB’s criteria include proposals by the Independent Market Monitor, the Legislative Collaborative/NRDC, and Silverman/Glatz. What are the stakes? Rolling blackouts and spiking bills. If nothing is done, we are looking at an average monthly increase of $70 on our monthly electric bills by 2028. By 2033, it could be $163 billion across all of PJM. That’s unacceptable. Read our other WatchBlog articles about reining in data center costs: How data centers are raising our bills in Illinois–and what we should do about it Data center distress: CUB, NRDC experts warn PJM states could get hit with forced blackouts, $163B in electricity capacity costs

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How data centers are raising our bills in Illinois–and what we should do about it https://www.citizensutilityboard.org/blog/2025/08/19/how-data-centers-are-raising-our-bills-in-illinois-and-what-we-should-do-about-it/ Tue, 19 Aug 2025 17:24:27 +0000 https://www.citizensutilityboard.org/?p=43479 The post How data centers are raising our bills in Illinois–and what we should do about it appeared first on Citizens Utility Board.

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CUB Q and A: Another capacity auction, more bad news–so what happened?  https://www.citizensutilityboard.org/blog/2025/07/31/cub-q-and-a-another-capacity-auction-more-bad-news-so-what-happened/ Thu, 31 Jul 2025 23:43:19 +0000 https://www.citizensutilityboard.org/?p=43409 By Clara Summers Manager, CUB’s Consumers for a Better Grid Campaign You may have seen a flurry of news about electric bill increases due to something called a “capacity auction.” Or worse, you opened your June ComEd bill and saw a sharp uptick. You can learn more about PJM’s capacity market and this year’s price spike in our previous blog, and by visiting our Help Center.  Sadly, there’s more bad news. Prices are going up yet again–next June. Let’s break it down.  So what’s happening to ComEd bills? The price spike we are experiencing now was set in stone last July. That’s when PJM held its auction for 2025/2026 to determine what we pay for reserve electricity, or capacity. It was bad enough when prices reached record highs for that auction, but PJM just set another record for its 2026/2027  auction, which will go into effect on June 1, 2026. The auction price jumped 22 percent, increasing from $269.92 per Megawatt-day to $329.17 per MW-day. That doesn’t mean your bill will go up 22 percent–capacity is only one component of ComEd’s supply price for electricity–but it does mean your bill will increase.* ComEd initially said bills will go up by about 2 percent next year–on top of the spike consumers are feeling now–but we won’t know final estimates until sometime next May.  Did anything change since the last auction? After last year’s devastating auction results, advocates sprung into action. Environmental organizations filed a complaint at the Federal Energy Regulatory Commission (FERC) about how PJM made ratepayers pay extra for otherwise retiring coal plants, but then ignored them in the capacity auction, falsely reducing supply. Consumer advocates supported that complaint and added our own, where we argued, among other things, that PJM wasn’t counting the contribution of many renewables either. PJM changed its rules for the better in response to these complaints. Gov. Shapiro of Pennsylvania also brought a complaint to FERC, saying that the normal price cap of $500 per MW-day should be lowered until the interconnection queue starts working again. (Remember, a major factor for these high prices is PJM’s interconnection queue delay). PJM and Gov. Shapiro agreed on a regional price cap of $329.17 per MW-day for the next two auctions. While there were other parts of the agreement that raised consumer advocate concerns, we supported the price cap.  The most recent auction, setting prices that will take effect next June, hit the price cap negotiated by Gov. Shapiro. PJM did an analysis of what the clearing price would have been without the new price cap, and holding all else equal, the price cap saved consumers an estimated $2.9 billion. As a consumer advocate, we are relieved that there was a price cap that protected ratepayers from even worse outcomes, but are still frustrated that we got here in the first place. Why is the capacity price going up even more? Significant increases in demand, combined with a restriction in supply (the frozen interconnection queue), cause prices to go high.  The biggest contributor to the price spike in this auction was large loads, such as data centers. They […]

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PJM Capacity Auction Leads to Record Price Spike for Second Straight Year, Threatens Even Higher Com Ed Bills in 2026-27 https://www.citizensutilityboard.org/blog/2025/07/22/pjm-capacity-auction-leads-to-price-spike-for-second-straight-year-threatens-even-higher-com-ed-bills-in-2026-27/ Tue, 22 Jul 2025 21:24:13 +0000 https://www.citizensutilityboard.org/?p=43352 CUB released the following statement: While we are relieved that the negotiated price cap prevented capacity costs from soaring even higher, this record price spike is unacceptable. CUB is deeply concerned that ComEd customers will continue to bear painfully high costs for another year, largely because of policy shortcomings from PJM. The power grid operator’s policy decisions too often favor outdated, expensive power plants and needlessly block low-cost clean energy resources and battery projects from connecting to the grid and bringing down prices. This extended price spike was preventable. It ramps up the urgency of implementing long-term reforms at PJM and comprehensive energy legislation in Illinois, such as the Clean and Reliable Grid Affordability Act, to protect customers from price spikes that serve only to give power generators windfall profits. –CUB Executive Director Sarah Moskowitz Background On Tuesday, July 22, PJM Interconnection, a “Regional Transmission Organization,” announced the results of an auction that determines the price for reserve power, or “capacity.” Capacity costs are a key component of the price Commonwealth Edison customers pay for electricity. PJM is the largest grid operator in the country, serving 67 million customers across all or parts of 13 states and the District of Columbia (including Commonwealth Edison’s 4.2 million customers). The auction (technically referred to as the “Base Residual Auction”) was held July 9-15. It set a record-high capacity price of $329.17 per Megawatt-day from June 1, 2026 through May 31, 2027. The capacity cost hit a cap negotiated by Pennsylvania Gov. Josh Shapiro and is about 22 percent higher than the price that was set last year for ComEd territory and about 11 times higher than what the price was two years ago. Capacity costs are payments consumers make to power generators–the companies that own power plants–and they have a key impact on the supply price ComEd customers pay. ComEd’s price spiked on June 1 of this year because of high capacity costs, and, because of the latest auction, it will again in June of 2026. (ComEd has not yet announced what the supply price will be next June.) The 2024 capacity auction set a then-record price of about $269.92 per MW-day, about 830 percent higher than the $28.92 per MW-day capacity price set in the auction the year before. Following the price spike in the last auction, consumer and environmental advocates pushed for several changes: RMR reform: Environmental advocates successfully pushed for changes in the way PJM handles Reliability Must Run (RMR) arrangements. RMRs allow PJM to funnel extra consumer money to an otherwise retiring plant to keep it open past its closure date. Under previous PJM policy, the electric capacity of an RMR plant was NOT included in the capacity auction. Consumers thus ended up paying double: first for the price of the RMR contract, and then again because of the high capacity prices that result from not counting the RMR plant. For example, the Independent Market Monitor estimated that not including Brandon Shores and Wagner–two RMR fossil fuel plants near Baltimore, Maryland–in the last capacity auction increased the cost by as much as 40 percent. Changes made since the last […]

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ComEd’s Hourly Pricing: How to calculate your capacity charge https://www.citizensutilityboard.org/blog/2025/06/13/comeds-hourly-pricing-how-to-calculate-the-customer-capacity-charge-2/ Fri, 13 Jun 2025 17:27:11 +0000 https://www.citizensutilityboard.org/?p=25828 Want to estimate your capacity charge before signing up for ComEd’s Hourly Pricing program? Here’s how to calculate it: 1. Go to this page:  https://secure.comed.com/MyAccount/MyService/Pages/UsageDataTool.aspx, choose “View Summary Data Online,” and “Add” your ComEd account number. 2. Click “View Usage Data” and it’ll take you to a results screen showing vital stats. The “Capacity PLC” at the top is a calculation that is unique to each customer. (PLC stands for “Peak Load Contribution,” and according to ComEd it represents your expected energy usage during high-demand hours on hot summer afternoons. The PLC is your households electricity usage averaged over 10 system peak periods the previous summer. ) 3. Once you find your “Capacity PLC,” you multiply the following four figures: The “Capacity PLC” (unique to your account) The “scaling factor” (1.00712) The “forecast pool requirement” (0.9380) The monthly capacity charge rate ($8.331 per Kilowatt-Month) 4. The product of those four numbers is your capacity charge. For more information, check out CUB’s Hourly Pricing fact sheet.

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PJM broke the capacity auction–but here’s how they can fix it https://www.citizensutilityboard.org/blog/2024/11/06/pjm-broke-the-capacity-auction-but-heres-how-they-can-fix-it/ Wed, 06 Nov 2024 22:28:26 +0000 https://www.citizensutilityboard.org/?p=41761 By Clara Summers, Campaign Manager Consumers for a Better Grid (a project of CUB) The electricity price for Illinois’ largest power utility, Commonwealth Edison, will go up significantly next summer because of a recent auction to secure reserve power. Grid operator PJM announced that its recent “capacity” auction sent prices skyrocketing from $28.92 per Megawatt-day to a record $269.92 per MW-day.  Such capacity costs make up a portion of the price of electricity, so this is expected to cause ComEd bills to increase starting in June of 2025.  Why are the prices so high? The Market Monitor for PJM said “the [] prices do not solely reflect supply and demand fundamentals but also reflect, in significant part, PJM decisions about the definition of supply and demand[.]”  But if supply and demand weren’t to blame, what was? Well, it’s complicated: There are multiple root causes–and  each demonstrates a different failure of PJM leadership.  But just as the causes are in PJM’s hands, so are the solutions… Root Cause 1: A Perfect Storm of Interconnection and Auction Delays PJM’s capacity market is supposed to operate under a “three-year forward” mechanism. That means PJM holds auctions to buy reserve electricity three years in advance of when it’s needed. So when lower supply sparks higher auction prices, generators will then have ample time (three years) to respond to that signal and build new power plants.  Unfortunately, 2018 was the last time PJM held a three-year forward auction. Today, auctions happen on a drastically compressed schedule.  For example, PJM’s July auction secured reserve power for just 11 months into the future, June 2025–not enough time for new generating resources to build and connect to the grid.  That would be true even if PJM  were quick to get resources online–but it’s not, and that’s the other problem. PJM is infamous for having one of the nation’s slowest interconnection queues. The “queue” is the waitlist for new electric resources seeking review and approval by PJM so they can be connected to the grid.  Unfortunately, there are more renewable resources waiting in line than all of the resources currently powering PJM’s vast 13-state region.  As it processes this massive backlog, PJM isn’t renewing any new interconnection applications until 2026, at the earliest. Some projects have sat in the queue for so long (5 or more years) that they have lost financing or site permissions, and so they drop out of the process before PJM even reviews them.  In this frustrating situation–with a key part of the clean energy transition on hold–everyday electric customers will pay for higher capacity prices on their electric bills without  getting any benefit for those payments. High prices + failure to get resources online quickly = bad news for ratepayers. What does PJM need to do? Get back on schedule and bring more generation online. First, PJM should fully comply with FERC Order 2023, which laid out new standards for interconnection processing. PJM has been foot-dragging on compliance, asking for exceptions to a number of these standards, including realistic treatment of battery storage, a technology that could be a huge help in easing these […]

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$10.3B renewable energy transmission project long-term response to capacity shortage https://www.citizensutilityboard.org/blog/2022/07/27/10-3b-renewable-energy-transmission-project-long-term-response-to-capacity-shortage/ Wed, 27 Jul 2022 15:28:46 +0000 https://www.citizensutilityboard.org/?p=34726 The power grid operator for Central and Southern Illinois has approved a $10.3 billion transmission line project that in the long term will bring more clean energy to the region and help prevent problems that have slammed electric customers with skyrocketing power bills this summer. The project, approved by the Midcontinent Independent System Operator (MISO) on July 25, will add 18 major transmission lines around the central United States and support 53 gigawatts of renewable energy expected to come online starting in 2028. Just one gigawatt is enough energy to power about 750,000 homes, and an MIT study found that interstate transmission coordination and expansion could half the costs of decarbonizing the electrical grid by 2040.  The MISO project is the first of an effort of the grid operator’s Long-Range Transmission Planning (LRTP). Fellow consumer advocates say building out transmission is key to grid reliability while transitioning to clean energy. The renewable energy project will help make up for about 50 gigawatts of coal-fired power plants and other aging resources that are shutting down, explains Aubrey Johnson, vice president of system planning and competitive transmission at MISO. The last major transmission buildout MISO approved was its 2011 multi-value transmission initiative.  Central and Southern Illinois consumers have seen a 120 percent increase in their power prices this summer, partly because of a dip in electricity supply that sparked a huge jump in the price of capacity–what consumers pay to have enough reserve power when demand is high.  Recently, CUB joined with the Illinois Clean Jobs Coalition to hold a news conference urging MISO to fast-track 34 renewable energy generation projects that are awaiting approval by the grid operator. The coalition said MISO’s approval of the transmission project was a step in the right direction.  “Today’s action to increase grid reliability and integrate more renewable energy and battery storage in MISO North is a desperately-needed positive step, but MISO must act faster to speed the conversion from dirty, expensive fossil fuels to clean, less expensive renewables,” the Illinois Clean Jobs Coalition said in a statement. “That starts with moving much more quickly to approve 34 solar and wind projects presently sitting in MISO’s queue.”  In other power grid news, the Illinois Commerce Commission (ICC) called for a cost-benefit analysis of Ameren Illinois shifting from MISO to the PJM Regional Transmission Organization, or RTO. (Read CUB’s Capacity Market Explainer for background on RTOs.)  CUB is pleased the ICC is doing a cost-benefit analysis, and the consumer watchdog group looks forward to seeing the results to determine the best option for Ameren Illinois’ 1.2 million electricity customers.   For more information about high energy prices, please visit www.CUBHelpCenter.com.

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With energy prices skyrocketing, advocates urge power grid operator to stop delays on new generation https://www.citizensutilityboard.org/blog/2022/07/22/with-energy-prices-skyrocketing-advocates-urge-power-grid-operator-to-stop-delays-on-new-generation/ Fri, 22 Jul 2022 17:14:56 +0000 https://www.citizensutilityboard.org/?p=34693 Illinois legislative leaders and CUB are urging the power grid operator in Central and Southern Illinois to fast track renewable energy projects that could reliably power 4.5 million homes and help relieve energy problems in the region. At a news conference July 21, legislative leaders criticized the Midcontinent Independent System Operator (MISO), the multi-state entity that manages the generation and transmission of electricity across Central and Southern Illinois. The region is suffering through a price spike currently, connected to global issues and a huge jump in the price for reserve power (also called capacity costs) that MISO blamed on an increase in electricity use and a dip in power supply. (See the TV coverage of the news conference, and watch it yourself.) But there currently are 34 solar and wind projects capable of generating more than 6,000 megawatts of energy awaiting approval in MISO’s queue. That’s enough to power 4.5 million Illinois homes. MISO’s foot-dragging could keep these projects languishing for years, the leaders said. MISO has been slow to act, and has instead raised the possibility of controlled power outages if there’s not enough electricity available. Ameren Illinois, the electric utility, has responded that it’s optimistic it will be able to keep the lights on this summer. Still, fossil fuel interests and their allies have used MISO’s comments as an opening to wrongly blame these problems on the Climate and Equitable Jobs Act (CEJA) and push for re-opening the nation-leading clean energy bill. “The answer to capacity and price issues is not to reopen CEJA, but rather to move quickly to implement it and get existing renewable projects online faster. That starts with MISO ensuring we get those 34 projects capable of generating 6,000 megawatts of renewable energy on the grid. If Ameren customers ever find themselves in the dark, MISO’s inaction is to blame. They are asleep at the switch,” said State Senator Cristina Castro, the chief Senate sponsor of CEJA. “Rather than quickly bringing new energy resources on to the grid, MISO is now trying to shift blame, warning of potential power outages this summer in Central and Southern Illinois, an apocalyptic and misleading view that even Ameren disputes. Fossil fuel interests and entrenched energy lobbyists are jumping on MISO’s blame game and calling for a return to the days when coal and gas generated most of Illinois’ electricity, even as fossil fuel prices skyrocket, emissions pollute our communities, and the planet burns,” said State Representative Ann Williams, chief House sponsor of CEJA. “Going back to coal and gas is like pouring gasoline on a fire in terms of hiking energy prices and polluting our communities,” Williams added. Advocates pointed out that MISO has known the transition from dirty, expensive fossil fuels to clean, less expensive renewables has been coming since at least 2007, when Illinois passed its first Renewable Portfolio Standard (RPS) that has only been accelerated by other initiatives. “For years, MISO has known this transition was coming, through the advent of the renewable portfolio standard and multiple rounds of legislation, including the Future Energy Jobs Act in 2016 and CEJA in 2021,” said Jim Chilsen, director of communications […]

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CUB fights for consumers before the nation’s largest power grid operator https://www.citizensutilityboard.org/blog/2022/07/19/cub-fights-for-consumers-before-the-nations-largest-power-grid-operator/ Tue, 19 Jul 2022 14:42:25 +0000 https://www.citizensutilityboard.org/?p=34638 UPDATE: The proposal to require one PJM board member to have clean energy expertise was rejected 52-21 after Dayton Power and Light and NRG requested a suspension of the rules to make the vote anonymous.  CUB Executive Director David Kolata said “It’s illuminating that fossil fuel generators pushed to make this vote off the record. That’s because clean energy is popular and nobody wants to publicly oppose it. We will continue to work for positive reforms like this, because such changes are inevitable as we work to fight climate change and build a clean, affordable energy future.”  The original story follows: For years CUB has been advocating for consumers at the Illinois Commerce Commission (ICC) and at the State Capitol, and now it’s taking the fight for clean and affordable energy to the nation’s largest power grid operator. As a regional transmission organization (RTO), PJM Interconnection coordinates the movement of wholesale electricity across Northern Illinois and 12 other states–and it has a major impact on the electricity prices that 65 million customers pay.  Knowing that regional and national energy issues impact how clean our energy is and how much we pay for it, CUB launched a project called Clear RTO, to advocate for more consumer-friendly policies for all electric customers served by PJM, including northern Illinois. Albert Pollard, a former Virginia legislator, who heads up Clear RTO, says the mission is  “to foster wholesale energy markets that benefit consumers and are fair to the 21st-century energy production, all while maintaining excellent reliability and promoting transparency.”  To that end, at the most recent PJM Stakeholders Meeting, CUB and Clear RTO proposed a change to the operating rules to ensure that at least one of the nine members of the RTO Board of Managers has expertise in clean energy.  Allocating one board membership seat to clean energy would help PJM better understand clean energy resources (including nuclear, wind, solar, distributed generation) and better utilize them in the power grid. This is increasingly important, as renewable projects to be added to the power grid often wait up to 5 years to be connected to the grid. The resources in the interconnection queue are overwhelmingly solar, wind, hybrid and storage power.   With these grid queues there is a backlog of capacity as grid planners continue to rely on expensive and polluting power sources simply because they’re connected. This comes at the expense of consumers who have to pay more per kilowatt for dirty power than clean energy.  PJM is aware of the issue too–the 2022 PJM Grid of the Future Report says, “Increasing public demand for cleaner sources of electricity, combined with public policy standards and goals, is driving unprecedented growth in renewable sources.”  With a clean energy expert on PJM’s Board, the nation’s largest RTO could potentially move more strategically toward renewables and make a more significant impact on carbon emissions. This would help meet the clean energy commitments of both transmission owners and state governments, while also opening the door to lower electricity bills through expanded capacity.  However, Kolata stressed that the overall goal is ensuring reliability, and “not to provide preferences […]

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