Quick fix: Why FERC should approve the SOO Green transmission project

PJM and its market monitor never agree, but they agree on the topic of treating SOO Green as an external capacity. SOO Green is a High Voltage Direct Current (HVDC) merchant transmission project that aims to bring Midwest renewable resources to PJM. SOO Green’s uniqueness is that it is all underground and uses the Canadian Pacific rail right-of-way. PJM is contrasting SOO Green’s capacity as external compared to PJM’s internal renewable capacity.

Projects like SOO Green are a quick fix for FERC because they are inter-regional, use existing right-of-way, and meet the renewable energy demand. FERC should approve this SOO Green line.

Courtesy: SOO Green

Recent history of SOO Green line

Rock Island was the first conception of SOO Green and was initially proposed as “a 500-mile, ±600 kV HVDC transmission line and associated facilities capable of delivering up to 3,500 MW from renewable energy projects” located in the Midwest.

But, due to public opposition in the Midwest and an Illinois court rejection, this overhead Rock Island line is now underground, called “SOO Green.” SOO Green is under the open solicitation process seeking to match “capacity subscriber (“Shippers”) with upstream suppliers and downstream buyers.” The benefit for anchor shippers is a steady price for buying renewable energy like a PPA, but the flip side is, individual state commissions like Iowa Utilities Board must approve these anchor tenant transmission lines.

FERC approved SOO Green’s application for negotiated rates on July 23rd, 2020. FERC Docket # ER20-1665. SOO Green “is owned 80% by Copenhagen Infrastructure III K/S (CI III), 10% by Jingoli Power Transmission, LLC (Jingoli), and 10% by Siemens Energy, Inc”. PPL Electric Utilities, a Transmission Owner in PJM, recently acquired an ownership interest in SOO Green. PJM and the PJM Market Monitor oppose SOO Green, citing concerns with the line’s impact on PJM’s capacity market.

PJM market monitor concerns

PJM’s market monitor Monitoring Analytics is well respected in the industry. PJM and its Independent Market Monitor (IMM) always have diverging opinions, which is good for the industry since stakeholders benefit from diverse points of view. For example, the IMM protested at FERC the revised July 30th, 2021 PJM Minimum Offer Pricing Rule (MOPR) proposal. Due to the even split FERC Commissioners, this revised PJM MOPR became the law.

On the SOO Green line, the IMM’s objections are in sync with PJM, an outlier. In its FERC comments, the IMM had strong language: “SOO Green proposes to subvert the PJM Capacity Market by permitting an inferior product.” IMM’s main objection is that SOO Green suppresses PJM’s capacity prices and undermines reliability. It is not clear how SOO Green harms PJM’s capacity market prices because if more capacity resources compete for the same PJM consumers, the consumers benefit.

PJM’s concerns are valid about the deliverability of SOO Green capacity

The primary concern of PJM is SOO Green seeking preferential treatment for its capacity compared to PJM’s internal capacity resources. As a market operator administrating a capacity market, PJM seeks dispatchability over all the market resources. PJM ensures that dispatchability by studying interconnection requests for deliverability. SOO Green is bypassing that interconnection lane because it is a transmission project.

If SOO Green is bringing capacity already studied for deliverability in the MISO market into PJM, PJM’s concern is that SOO Green capacity is “external” capacity compared to PJM’s internal capacity studied for deliverability in the PJM market. FERC should weigh on this issue because if each RTO treats its internal resources as qualified capacity and external support as unqualified capacity, it leads to watering down the benefits of regional and inter-regional planning.

If FERC approved MISO’s narrow definition of Storage As a Transmission Only Asset (SATOA), why shouldn’t FERC approve SOO Green? FERC’s 2017 policy statement on storage is cited as one of the reasons for MISO’s SATOA filing. In that policy statement, FERC guided that electric storage resources can seek costs from rate recovery (like SATOA) for transmission services in addition to receiving market-based revenues for providing market services.

PJM consumers would benefit from the SOO Green transmission line

PJM capacity markets are the most lucrative because they attract resources from both supply and demand sides. Many PJM states (New Jersey, Maryland, Virginia) are leading offshore wind (OSW) mandates and goals in the US, and PJM’s interconnection queue is bursting at the seams. Hence the interconnection process reform is underway. All these factors point to PJM needing transmission to interconnect renewables.

SOO Green is located right there to bring that transmission to interconnect renewables. PJM has nothing to fear from Midwest renewables because OSW has the higher capacity factor. And PJM capacity market would provide the market signals for any future SOO Green like transmission projects.

SOO Green is a Quick Fix solution for FERC in the ANOPR context

FERC has received hundreds of comments in its Advanced Notice of Proposed Rulemaking (ANOPR) on transmission planning and generator interconnection. While FERC staff is sorting out solutions that are quick to implement, i.e., the “quick fix” solutions such as mandating Dynamic Line Ratings (DLRs) and RTOs implementing Grid Enhancing Technologies (GETs), approving SOO Green line should be a top priority for FERC.

SOO Green has already done all the work. Any transmission project that cuts across RTO boundaries is deemed “inter-regional.” SOO Green would be an inter-regional transmission project. FERC does not receive a lot of inter-regional projects for cost allocation from the RTOs.


PJM and Monitoring Analytics, its market monitor, should consider the benefits of the SOO Green merchant HVDC transmission project. By approving the treatment of SOO Green as a transmission line, PJM would benefit PJM’s consumers by keeping transmission rates lower. FERC should weigh in on this issue sooner than later because it is a quick fix for FERC and dragging FERC’s approval longer for SOO Green means a delay in consumer benefits.

Once all approvals are in place, SOO Green starts construction in 2023.