Critical Tx Infrastructure Proposals Endorsed

Stakeholders last week endorsed PJM’s packages of proposals for mitigating and avoiding designating projects as critical infrastructure under NERC reliability standards after more than a year of work on the issues.

The Planning Committee endorsed the avoidance package, including associated manual language, with 77% support at its meeting last week. In a separate vote, the package won 61% support over maintaining the status quo.

The committee also endorsed PJM’s mitigation package with 61% support and 60% preferring it over the status quo.

Dave Souder of PJM thanked members for their work on the proposals and for the endorsements. He said PJM will take at least a month to finalize Operating Agreement language to be included with the mitigation portion, with a first read at the Markets and Reliability Committee’s meeting March 24.

“We’re not done yet, but we’re on the right path,” Souder said.

Mike Herman of PJM presented the proposals to the committee. The changes to Manual 14B include the addition of a new subsection describing the process related to maintaining reliability and added “avoidance” to the list of transmission planning activities.

PJM also added text to Manual 14F detailing the process by which it may modify a proposal submitted through the competitive planning process. Herman said PJM removed the term “resilience” from all the manual language edits in favor of the term “critical substation planning analysis” in response to stakeholder feedback at the January PC meeting. (See “CIP-014 Update,” PJM PC Briefs: Jan. 11, 2021.)

Other changes included new text detailing the process by which PJM may modify a proposal submitted through the competitive planning process and includes examples of proposal modifications that would and would not be deemed “limited in scope.”

Paul Sotkiewicz of E-Cubed Policy Associates pointed out that the term “resilience” was still included in at least one section in Manual 14F and should be corrected by PJM before endorsement.

“I think consistency is really important in the language, especially when it comes to the transmission planning between the different manuals,” Sotkiewicz said.

PJM’s Aaron Berner said it appeared the existence of the “resilience” terms in the manual language was an oversight and would be corrected.

The RTO will hold a special PC meeting on Feb. 19 to go over the proposed OA language for the mitigation portion of the package. Herman said the major language 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.”

Robert Taylor of Exelon said he appreciated the work that went into the packages and that it was “a long road to get here.”

“I personally believe we’ve landed in a good place that balances a lot of competing interests in how to address this,” Taylor said.

Capacity Interconnection Rights

Jonathan Kern of PJM provided a first read of the problem statement and issue charge to address the capacity interconnection rights (CIRs) of variable resources.

Kern said the recent adoption of effective load-carrying capability (ELCC) highlighted the need to investigate the topic. Stakeholders endorsed a revised joint stakeholder proposal at the September MRC and Members Committee meetings to use the ELCC method to calculate the capacity value of limited-duration, intermittent and combination (limited-duration plus intermittent) resources. (See ELCC Method Endorsed by PJM Stakeholders.)

ELCC, which is already used by MISO, NYISO and CAISO, evaluates reliability in each hour of a simulated year and compares a resource mix with limited resources against one with unlimited resources.

Kern said CIRs for new wind and solar resources are administratively set for several years at the average expected outputs for the summer period unless developers can supply weather data to support higher outputs. CIRs for new limited-duration resources such as storage are administratively set based on the amount of energy that can be supplied over a 10-hour period, he said.

CIRs are not included in ELCC calculations or in determining accredited unforced capacity (UCAP). Kern said sizing the grid for CIRs based on outputs below maximum summer values may result in curtailments because of insufficient transmission, and resource adequacy performance and accredited UCAP may be overstated unless CIRs are considered.

Kern said PJM’s goal is to hold a series of monthly discussions with the PC and to develop and propose changes to the applicable manuals and governing documents by the end of the year. He said PJM will hold educational sessions and discuss and develop proposals from April to October and ideally present a proposal to the MRC in November.

Gary Greiner, director of market policy for Public Service Enterprise Group, said PJM’s presentation seemed “a little bit off” from what he expected to be discussed and that it’s not good to have stakeholder discussions “start on second base.” Greiner said there needed to be more foundational education pieces on the CIR issue, focusing on CIRs and what their rights and purposes are in traditional and intermittent resources, not diving into specifics from the beginning.

Greiner said the only point he’s comfortable with in the key work activities and scope on the issue charge is education on the status quo policies for CIRs.

Kern said PJM’s intention is to give a “good foundation” on the status quo policies of CIRs during the educational sessions.

Sharon Midgley of Exelon said she had additional questions on the issue charge. She pointed to subject areas deemed to be out of scope in the issue, including provisions for unlimited resources.

Midgley said Exelon realizes the CIR effort is to look at variable resources, but it wants to make sure there is “equity” in the rules between variable and unlimited resources. She asked PJM to strike the unlimited resources subject area from the out-of-scope section.

Kern said PJM wants to achieve the objectives in the allotted time, so a topic like unlimited resource CIRs would be considered out of scope. He said there may be other issues identified during the discussion that warrant a separate problem statement and issue charge.

“In the end, we want to find an equitable solution that works for all resources,” Kern said.

Midgley said she doesn’t want to have to bring forward another problem statement and issue charge “to fix something that might be inequitable” that emerges from the process. She said she would rather change the current problem statement and issue charge to leave the opportunity to examine unlimited resources if it’s needed.

Sotkiewicz said he agreed with the concerns raised by Greiner and Midgley. He said there are already issues he anticipates that will be brought up in the way CIRs and dispatch are done that will create inequitable outcomes among different resources.

He said there are too many issues that are “left to the imagination” that need to be spelled out more clearly in the problem statement and issue charge and that too many of the issues are “open ended.”

“I think the issue charge as it stands today is not ready for prime time,” Sotkiewicz said.

PJM encouraged stakeholders to provide redline language before the next PC meeting to address concerns in the problem statement and issue charge.

TO/TOP Matrix v15

Stakeholders unanimously endorsed a draft version 15 of the TO/TOP Matrix to be provided to the Transmission Owners Agreement-Administrative Committee (TOA-AC). Mark Kuras, chairman of the Transmission Owners/Transmission Operator (TO/TOP) Matrix Subcommittee, presented the proposed changes.

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.

The endorsed changes will head back to the TOA-AC for final approval at its April 22 meeting.

Transmission Expansion Advisory Committee

Technological Pilot Project

Exelon is looking to test an experimental coating for overhead conductors to improve capacity. Koushy Nareshkumar of Exelon presented a need for supplemental projects in the Potomac Electric Power Co. (PEPCO) region.

Nareshkumar said Exelon is testing the “innovative technology” of E3X Technology, a coated conductor, to increase circuit rating. Conductors with the coating have shown to have increased emissivity and lower absorptivity. The technology allows for operation with a cooler conductor at higher ampacity, the maximum current a conductor can carry continuously without exceeding its temperature rating.

Erik Heinle of the D.C. Office of the People’s Counsel asked if Exelon’s project was being introduced through a state initiative or if it was just looking to test the technology. He also asked if the technology had been used anywhere else by Exelon.

Nareshkumar said Exelon was taking the initiative to test the technology themselves and that it was the first time E3X was being utilized. She said Exelon is still in the process of determining what line will be used for the project, but it will be on one of its 230-kV lines in PEPCO.