THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the PJM Operating Agreement. The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. As the GSG Order directs,14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller under the PJM Operating Agreement.15
