PJM stakeholders last week heard another first read of the RTO’s proposals for mitigating and avoiding critical infrastructure designations under NERC rules, with some members questioning the stakeholder processes that led to the language in them.

Mike Herman of PJM presented a proposal on avoidance at last week’s Planning Committee meeting. PJM had postponed a vote on the proposal at the committee’s December meeting, saying it needed more time to consider language changes in response to a FERC order in November (ER20-841). (See “Critical Infrastructure Stakeholder Update,” PJM PC/TEAC Briefs: Dec. 1, 2020.)

The commission rejected rehearing requests of its approval in March of planning procedures for transmission projects that mitigate the risk associated with critical infrastructure, as defined by NERC Critical Infrastructure Protection standard CIP-014. Such projects would also allow transmission owners’ existing infrastructure to avoid being designated by NERC as critical.

Herman went through a summary of the proposed changes to Manual 14B and Manual 14F that came out of the Critical Infrastructure Stakeholder Oversight (CISO) special sessions beginning in November 2019. He said that based upon stakeholder feedback, PJM made “slight tweaks” to the redline language.

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. PJM also plans to 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.

Sharon Segner, vice president of LS Power, said the Manual 14F language in appears to create resilience criteria without specifically defining it. Segner said the proposal seems like an “end run around” to creating resilience criteria without making changes to PJM’s Operating Agreement, which she said FERC had directed in November.

“The rehearing order from FERC was very explicit that the planning criteria needs to be in the Operating Agreement,” Segner said. “You’re calling this resilience analysis, but at the end of the day, it’s creating standards, and that needs to be in the OA.”

Segner also said she was concerned about the stakeholder process regarding discussion of the package and PJM putting it on the agenda as a first read, when a PC special session scheduled for the week before and designed to examine the proposal language more closely was canceled. Segner said LS Power had materials and edits of the proposal language that she was planning to present at the meeting.

Dave Souder, director of operations planning for PJM, said that if Segner felt the issue required OA language, the RTO would take that into consideration and see if more stakeholder discussion is needed. PJM’s Aaron Berner noted that the OA does not define all the aspects of reliability criteria and that the information is normally detailed in the manuals.

Alex Stern, director of RTO strategy for PSEG Services, disagreed with Segner’s interpretation of FERC’s directive. The commission said, according to Stern, that TOs have not transferred the authority to plan CIP-014 mitigation projects to PJM and that it should not be in the OA for that reason.

But Stern also said he would like to see LS Power’s proposed OA language so that it can be reviewed in advance and considered. “I wouldn’t mind seeing this Operating Agreement language so that we have some time to process it within the stakeholder process,” he said.

Erik Heinle of the D.C. Office of the People’s Counsel said he was confused with the process going forward on the PJM proposal, with the first read being held at the PC. Heinle noted another CISO special session scheduled for Friday and asked if a second “first read” would be held at the committee’s February meeting if there were additional changes or edits to the manual language.

“I just hoped we weren’t getting too far ahead of ourselves with the first read,” Heinle said.

Souder said PJM’s intention is to move forward with the second read and endorsement at the PC’s February meeting. The RTO will take stakeholder feedback on the need for a second first read into consideration, he said.

“We want to make sure whatever product is coming out of the Planning Committee is ready as we bring it to the” Markets and Reliability Committee, Souder said.

After the presentation on avoidance, Herman discussed the mitigation issue with a package of proposals coming out of the CISO. He said OA language is currently under development by PJM for the mitigation portion of the package.

Herman pointed out some of the changes to the language since it was last reviewed at the November PC meeting. (See “Critical Infrastructure Stakeholder Update,” PJM PC/TEAC Briefs: Nov. 4, 2020.)

The major change was the addition of a definition for substation contingency resilience planning criteria: “analyses performed to ensure system resilience based on a study of select substation contingencies, which are based upon TPL-001-4 Extreme Contingency Analysis. The analysis evaluates the loss of load and potential cascade events which may result from power flow analysis. Due to the sensitive nature of the analysis, identified substations and results require confidentiality consistent with established processes and good utility practice.”

“A lot of the meat of this package hinges upon this definition,” Herman said.

Heinle asked if the definition will be included in the final OA language.

Herman said the definition would have to be included for documentation.

Heinle said he would like to see the avoidance and mitigation issues tied more closely together. He said he is concerned that the two “interrelated issues” are going on different rails, with avoidance language in the manual and mitigation language in the OA, which could lead to issues at FERC in the future.

“You can’t really have avoidance and not have a mitigation option as well,” Heinle said. “And you can’t really have mitigation if you don’t first try to avoid the issue.”

On Monday, Segner told RTO Insider that LS Power had provided PJM its proposed OA language and that it will be available for review before Friday’s special CISO session.

TO/TOP Matrix

Mark Kuras, chairman of the Transmission Owners/Transmission Operator (TO/TOP) Matrix Subcommittee, presented proposed changes to version 15 of the TO/TOP Matrix.

The matrix is an index between the PJM manuals and governing documents and NERC reliability standards that are applicable to the RTO as the TOP. It includes a column of “tasks” required by PJM under the documents. Kuras said version 15 of the matrix adds references for reliability standards, including TOP-001-5.

Some of the revised tasks include:

• COM-001-3 R4.3, which was revised from a comment received from ReliabilityFirst;
• TOP-001-5 R9, which added time frames for reporting com equipment outages; and
• VAR-001-5 with changes for new eDART voltage schedule reporting.

Kuras said stakeholders will be requested to provide a recommendation to the Transmission Owners Agreement Administrative Committee (TOA-AC) to approve the draft TO/TOP Matrix at the February PC meeting, and the endorsed changes will then head back to the TOA-AC for final approval. He said PJM would like to have the new matrix in place by April.