Critical Infrastructure Stakeholder Update

PJM officials last week postponed a Planning Committee vote on the RTO’s proposals for mitigating and avoiding critical infrastructure designations under NERC rules, saying they needed more time to consider potential language changes in response to FERC’s order last month on the issue.

PJM attorney Pauline Foley reviewed the commission’s Nov. 19 order rejecting arguments raised in a rehearing request of its March order approving the Transmission Owners sector’s critical infrastructure mitigation plan (ER20-841). (See FERC OKs PJM TOs’ Critical Tx Process.)

Foley said PJM is reviewing the impacts of the commission’s order on the proposed packages for avoidance and mitigation. FERC rejected several arguments that it erred in its order, including the determination that CIP-014 mitigation projects are supplemental projects subject to local planning by TOs.

Dave Souder, director of operations planning, said some changes to the PJM package could be needed to make sure it reflects FERC’s feedback. Souder said PJM plans on completing the review of the packages within a week.

The PC heard a first read of the RTO’s package at last month’s meeting, which followed 11 Critical Infrastructure Stakeholder Oversight (CISO) sessions. (See “Critical Infrastructure Stakeholder Update,” PJM PC/TEAC Briefs: Nov. 4, 2020.)

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

Mike Herman of PJM reviewed the RTO’s proposal to address avoidance of future CIP-014 facilities, including a first read of associated language in Manual 14B and Manual 14F. Herman conducted a first read of PJM’s avoidance and mitigation packages last month.

The changes to Manual 14B include the addition of a new subsection describing the process related to maintaining reliability. It also added avoidance to the list of transmission planning activities.

The RTO would add text to Manual 14F detailing the process by which it may modify a proposal submitted through the competitive planning process. It would also add resilience to the list of reliability criteria evaluated in a proposal window in both manuals.

Greg Poulos, executive director of the Consumer Advocates of the PJM States, said his members have indicated they would not support PJM’s package without the mitigation and avoidance components being voted on together.

“We’ve always seen them together as a package,” Poulos said.

Sharon Segner, vice president of LS Power, urged PJM to pay close attention to FERC Commissioner Richard Glick’s dissent in the Nov. 19 order in which he said CIP-014 projects “have the potential to benefit the region as a whole” and “should be planned by PJM.” Segner said changes at FERC following President-elect Joe Biden’s inauguration could throw some of the commission’s decisions into question, including planning of CIP-014 facilities.

New Jersey BPU State Agreement Approach

Joe DeLosa, of New Jersey Board of Public Utilities staff, briefed stakeholders on the state’s request for PJM to integrate its offshore wind goals into the RTO’s Regional Transmission Expansion Plan (RTEP) process under the “state agreement approach.” The move would make New Jersey the first state to use the approach since it was approved by the FERC under Order 1000. (See NJ Asks PJM to Seek Bids for OSW Tx.)

The approach allows states to pursue transmission solutions to meet public policy needs, while the costs of the upgrades are allocated to state ratepayers. (See PJM Dusts off ‘State Agreement’ Tx Approach.) DeLosa said New Jersey officials understand that bearing the cost is a definitional requirement of the approach, but he pointed out that the BPU’s agreement to execute a study agreement with PJM has not committed the state to pay anything right now.

“We’re very cognizant of making sure that we get what we pay for,” DeLosa said.

The BPU wants to foster potential transmission expansion beyond New Jersey, he said, opening facilities to other parties if they want to help fund the upgrades. DeLosa said the state is guarded against “free riders” taking advantage of transmission capacity funded by New Jersey ratepayers.

Segner said she has been following the developments in New Jersey with “excitement and interest” and was particularly pleased to see the BPU’s focus on cost-containment provisions in the PJM Tariff. She said it was also exciting to see New Jersey embracing the competitive windows in Order 1000.

She asked if operational control of the transmission facilities would be turned over to PJM after they were completed.

DeLosa said the BPU envisions them as open-access PJM transmission facilities.

Stakeholders asked about the overall timeline for the state agreement approach.

DeLosa said the timeline is still under consideration and that the BPU is cognizant of PJM’s RTEP timelines.

“We are looking to slot ourselves into one of the existing RTEP cycles,” DeLosa said.

Planning Committee Charter

Stakeholders unanimously endorsed the committee’s charter by acclamation vote in an annual review.

PJM’s Souder reviewed the charter, saying no changes were being considered to the existing language. He said PJM received no stakeholder feedback for recommended changes, and RTO staff had no suggested changes.

Transmission Expansion Advisory Committee

Public Policy Objectives in RTEP

Stakeholders are asking for more discussions to take place in the Transmission Expansion Advisory Committee in 2021 regarding state public policy requirements and objectives across PJM territory.

Segner presented a proposal regarding the consideration of public policy objectives in RTEP studies and analyses. She said LS Power sees public policy planning as a major issue in 2021 and that it’s time for PJM and its members to discuss planning the grid of the future.

LS Power officials looked at the PJM Operating Agreement language, Segner said, and began examining actions that could be done in 2021 under existing language to start planning for public policy. She said the OA defines public policy objectives as referring to requirements and initiatives of state or federal entities that have not been codified into laws or regulations but may have impacts on long-term planning considerations.

Segner said the proposal requests specific TEAC agenda items, including providing the opportunity for stakeholders to submit public policy objectives. The proposal also calls for TEAC discussions on “public policy planning sensitivity studies, modeling assumption variations and scenario planning analyses related to public policy objectives and multi-driver planning” considered by PJM in the 2021 RTEP.

“There’s an opportunity with the start of the 2021 RTEP for there to be a greater focus and more in-depth discussions in the TEAC,” Segner said.

John Brodbeck, senior manager of transmission at EDP Renewables North America, said he was supportive of Segner’s proposal. He said that when Order 1000 was first developed, PJM made the decision not to include interconnecting regions in the planning process, a decision that would have potentially excluded the OSW discussion currently happening in New Jersey.

Brodbeck said expanded TEAC discussions could be an opportunity for stakeholders to look at the different criteria that go into public policy.

“We do need to bring in some more issues to the planning process in PJM,” Brodbeck said.

Ed Tatum of American Municipal Power said he was also supportive of the proposal and that the OA clearly states the different issues that should be discussed in the TEAC. However, Tatum said the TEAC is a “non-decisional” committee and was intentionally set up that way so stakeholders would not be voting on project planning.

“PJM is the planner, and I think that authority was recognized,” Tatum said.