PJM Transmission Owners voted Wednesday to seek FERC approval for Tariff amendments governing end-of-life (EOL) projects.
Jeff Stuchell, manager of FERC & transmission technical support for FirstEnergy and chairman of the PJM Transmission Owners Agreement-Administrative Committee (TOA-AC), said the committee approved a Federal Power Act Section 205 filing of the Attachment M-3 amendments following the consultation and voting procedures detailed in the Consolidated Transmission Owners Agreement (CTOA).
[UPDATE: The amendments were filed with FERC on Friday (ER20-2046).]
Wednesday’s vote came a little more than a week after stakeholders challenged the TOs’ amendments during a special session of the TOA-AC on June 1 and two weeks after a vote at the May 28 Markets and Reliability Committee meeting in which a “joint stakeholders” proposal from American Municipal Power (AMP), Old Dominion Electric Cooperative (ODEC) and others regarding EOL projects was narrowly defeated. (See PJM TOs Outline End-of-life Tariff Amendments.)
The joint stakeholders will try again to win approval of their plan at the June 18 Members Committee meeting.
Concern Addressed
One revision was made to the TOs’ amendments after a stakeholder raised a concern that EOL projects could potentially remove FERC Form 715 planning criteria from PJM planning under Schedule 6 of the Operating Agreement and cause them to be planned by the TOs under Attachment M-3.
To address those concerns, TOs added to the definition of “Attachment M-3 Project,” revising it with the following clause: “‘Attachment M-3 Project’ does not include a project to address Form No. 715 EOL Planning Criteria.”
“This addition should put to rest the concern that the proposed Attachment M-3 amendments change the responsibility for planning Form No. 715 transmission projects,” the TOs wrote.
Stakeholder Responses
Leading up to Wednesday’s vote, the TOs solicited stakeholders’ comments on the proposed amendments.
The Organization of PJM States (OPSI) proposed several edits, including requiring the TOs to provide annual EOL project lists to OPSI and PJM.
The Joint Consumer Advocates wrote that the proposed amendments are “unjust, unreasonable and otherwise not permissible on procedural and substantive grounds,” saying a May 8 notice filed by the TOs did not comply with provisions of the CTOA. The advocates took exception to new definitions in the amendments and what they said was an improper “expansion and reliance on inapplicable FERC precedent regarding asset management.”
“The PJM TOs, and PJM, have a responsibility to work constructively with all stakeholders to endeavor to develop proposals that are broadly supported and meet FERC standards for an open and transparent planning process,” the advocates wrote.
In joint comments, Old Dominion Electric Cooperative (ODEC), American Municipal Power (AMP), LS Power and the PJM Industrial Customer Coalition (ICC) echoed the Advocates’ remarks, saying the proposed revisions are not supported by a majority of PJM members. The stakeholders encouraged the TOs to continue discussions with members to ensure that EOL planning is conducted by PJM.
Ed Tatum of AMP said he was discouraged by Wednesday’s vote, saying it was a “subset” of the TOs in the TOA-AC who decided to draft the amendments. “I’m disappointed the TOs would take this action,” he said.