Critical Infrastructure Stakeholder Update

PJM stakeholders heard a first read of the RTO’s packages for mitigating and avoiding critical infrastructure under NERC rules.

Christina Stotesbury of PJM reviewed results from a survey on the proposed packages and background on the Critical Infrastructure Stakeholder Oversight issue at last week’s Planning Committee meeting.

The issue originally came to a head at the Markets and Reliability Committee meeting last year when incumbent Transmission Owners asked for feedback on a proposal establishing a process for vetting transmission system enhancements designed solely to reduce the number of critical assets identified under NERC’s CIP-014 standard. Fewer than 20 of them exist within the PJM footprint.

The D.C. Office of the People’s Counsel proposed an issue charge in December responding to TOs’ decision to file a new Tariff Attachment M-4 for the planning of CIP-014 mitigation projects. (See “Critical Infrastructure Mitigation,” PJM PC/TEAC Briefs: Dec. 12, 2019.)

An updated issue charge was approved at the May 12 PC meeting. Exelon’s redline of the issue charge, originally endorsed by stakeholders in December, was approved by a 61% vote. (See “Changes Approved to CISO Issue Charge,” PJM PC/TEAC Briefs: May 12, 2020.)

Stotesbury said 11 special session meetings were held to provide education and propose solutions for mitigation and avoidance.

In a recent poll, stakeholders were asked if they could support the PJM package on CIP-014 contingencies for mitigation, Stotesbury said, with 83% responding in the negative.

When asked for feedback, stakeholders said confidentiality and protecting highly sensitive information were major concerns. Some stakeholders also considered it an overreach of PJM authority.

Stakeholders were asked if they could support the PJM package on the “Cascading Trees” analysis for avoidance, Stotesbury said, with 98% responding they would be supportive. “Cascading Trees” is PJM’s visualization tool that considers the potential impact to the grid of extreme events and analyzes probabilities of what issues such events could cause.

Feedback on the package included a request for additional discussion as confidentiality concerns remain and that the Cascading Trees analysis must replicate TO methodology for consistency.

Stotesbury said other concerns included opposition to treating non-CIP-014 facilities with the same level of confidentiality as CIP-014 facilities and that neither proposal is modeled after FERC approved Tariff Attachment M-4, which should be the framework for addressing mitigation or avoidance.

Mike Herman of PJM presented the first read of both proposals. Among the many components is a stipulation that if a proposed project in the Regional Transmission Expansion Plan fails resilience criteria requirements, PJM will communicate failure and analytical results to the proposing entity only.

Sharon Segner, vice president of LS Power, said her reading of that component indicates that bidders on a project could be disqualified based on information to which they don’t have access. Segner said LS Power has “grave concerns” about that aspect of the package and requested PJM examine different language in the proposal.

“It’s not fair to disqualify bidders when they don’t have access to the information,” Segner said.

Herman said PJM will take it under consideration and continue to discuss the issue.

Manual 14C Endorsed

The committee unanimously endorsed by acclamation changes to Manual 14 C as part of the biennial cover-to-cover review.

Mark Sims, PJM’s manager of infrastructure coordination, provided a second read of changes to Manual 14C: Generation and Transmission Interconnection Facility Construction.

Sims said minor changes were proposed to Manual 14C, including an update of the latest Tariff provisions clarifying the filing process for title transfers and associated title documentation in Section 5.

New sections on cost tracking for baseline projects and another for supplemental cost tracking are also being proposed, Sims said.

Load Forecast Model Development

Andrew Gledhill, senior analyst in resource adequacy planning for PJM, discussed proposed load forecast model changes, which he acknowledged had come under criticism at recent meetings regarding forecasting methods. He said he and the entire load forecasting team have always encouraged open dialogue about the forecasting methods with stakeholders.

Gledhill highlighted three issues: model complexity; a contention that the forecast deviates from the historical trend; and that PJM should be using a 10-year estimation period in modeling for the residential, commercial and industrial sectors.

PJM agrees that the modeling has become more complicated in recent years, Gledhill said, but the complexity has been “born out of necessity.” He said there are more factors influencing load trends than there have been historically, including energy efficiency and behind-the-meter solar.

“These affect different parts of the PJM footprint in varying magnitudes, and it’s important to refine model techniques over time to understand these trends and to seek improvement and accuracy,” Gledhill said.

Last year PJM identified models broken up by sector — residential, commercial and industrial — as an improvement that would help understand trends over the last decade. Gledhill said sector models lead to more accurate load forecasting but makes the overall model more complicated.

Gledhill said PJM does not agree with the contention from some stakeholders that weather-normal load has been declining for more than a decade. He said the cause of trends from 2010 to 2019 was because of “significant headwinds to growth” through energy efficiency and behind-the-meter solar investment.

PJM uses a 10-year historical estimation period throughout load forecasting except for the sector models, for which it uses Energy Information Administration data dating to 1998.

Gledhill said PJM has concerns that using only the most recent 10 years of data would add instability in the model or produce results inconsistent with economics.

James Wilson, a consultant to state consumer advocates, said he was unaware of any stakeholders who proposed using 10 years of data. Wilson said he requested a sensitivity analysis on 10 years, while other stakeholders have requested using an alternative estimation period of 15 years or less.

Wilson said he would like to see PJM further evaluate an even historical time period instead of using “stale data” that skews the models.

“I would encourage you to apply a consistent estimation period throughout the modeling,” Wilson said.

Transmission Expansion Advisory Committee

Dynamic Line Ratings Implementation Plan

David Quier of PPL presented his company’s strategy for implementing dynamic line ratings (DLRs).

Quier said PPL is currently in the process of a heavy rebuild of transmission lines and the strengthening of physical generation plants. He said PPL is discovering that the transmission grid isn’t very “smart.” There is a dependence on people and manual operations with little automation, Quier said.

PPL has started to look at how to build the grid of the future, focusing in on projects like 100% smart relays and devices, prediction of failures before they occur and grid-enhancing technologies that include smart wires and traveling wave relays.

“We want to reduce maintenance, reduce costs to customers and increase reliability,” Quier said.

PPL’s next step, Quier said, is the installation of DLRs, which can measure wind speeds, ambient temperatures and conductor temperatures.

Quier said PPL is currently deploying DLRs on its Juniata-Cumberland and Harwood-Susquehanna line. He said PPL is seeking additional lines to install the technology.

“We are looking forward to working with PJM to fully utilize this technology,” Quier said.