Markets and Reliability Committee
CISO First Read
PJM highlighted confidentiality in its proposals for mitigating and avoiding critical infrastructure projects under NERC reliability standards.
Mike Herman of PJM reviewed the proposed solutions and manual language changes, including Manual 14B and Manual 14F, to address the mitigation and avoidance of future CIP-014 facilities during a first read at the Markets and Reliability Committee meeting March 29. At the February Planning Committee meeting, stakeholders endorsed the avoidance package, including associated manual language, with 77% support and endorsed the mitigation package with 61% support. (See “Critical Tx Infrastructure Proposals Endorsed,” PJM PC/TEAC Briefs: Feb. 9, 2021.) Stakeholders will vote separately on the avoidance and mitigation proposals at the April MRC meeting.
In his presentation, Herman pointed to passages from existing NERC CIP-014 standards on confidentiality, including measures for maintaining “need to know” employees, who have access to the confidential information, and preventing the release of information on critical infrastructure units outside the physical site of the transmission owner. Herman said PJM obeyed the NERC standards in its proposals and sought to strike a “balance” to implement transparency where possible.
“We wanted to point out some of the difficulties that PJM and stakeholders had working through a process where confidentiality is so highly required,” Herman said.
He said it “can be difficult to navigate” confidentiality and transparency simultaneously.
Under its avoidance proposal, PJM will study proposed projects, and if one creates a new critical substation, the RTO will work with the proposing entity to determine if the project needs to be modified.
Confidentiality and transparency are equally important under the mitigation proposal but even more complicated because of the processes involved in planning, Herman said.
“Confidentiality associated with mitigation is even above and beyond that of avoidance due to the nature of the identified facilities,” Herman said.
PJM is proposing to conduct a request for proposal window to solicit mitigation solutions.
Herman said mitigation on a project is only available in states where a process has been established to maintain confidentiality of the need associated with the critical substation.
Calpine’s David “Scarp” Scarpignato said he was impressed with the amount of feedback PJM took from stakeholders to amend the proposals.
But he said the RFP competitive solicitation window sounds “infeasible” because of the confidentiality of the substation that needs to be corrected. He asked if the competitive transmission owners agreed with PJM’s proposals.
Herman said PJM had “good engagement” on the issue from the competitive transmission owners and stakeholders involved in the competitive process.
Sharon Segner, vice president at LS Power, said her company’s role as a competitive transmission developer has kept them “very engaged” in the process of developing the proposals, and that it was appreciative of PJM’s efforts to make changes to language in the manual and Operating Agreement.
Segner said LS Power is “not at the point yet” to support the proposed OA language but were “very close” with some tweaks.
Alejandro Bautista of PJM reviewed the proposed OA language from the proposals, saying the updated language incorporates changes based on stakeholder feedback over the last two months.
“We think it was constructive to refine the draft OA language,” Bautista said.
PJM attempted to put together a “transparent process” in the language that protects the confidentiality of the critical units, Bautista said, while also allowing incumbent transmission owners and other developers to compete.
Some “substantial changes” in the OA included creating a new section, 1.5.11 Critical Substation Planning Analysis (CSPA) Project Process. The new section describes the CSPA process and its purpose, including allowing PJM to “identify, develop and select the more efficient or cost-effective solution to address potential reliability violations stemming from the contingency loss of a critical substation.”
Bautista said the CSPA process will be conducted annually by PJM and will include the estimated costs of a project.
Segner said there were several “outstanding issues” in Section 1.5.11 that would keep LS Power from endorsing the OA language, including measures to make costs of projects more transparent to consumers. Segner said some of the OA language appears to define what is a competitive process and what is not, lending itself to more clarity.
“Our hope is next month that LS will be able to support the package,” Segner said.
ICSA First Read
Stakeholders have provided recommendations to PJM’s proposal for changes to the superseding language and automatic termination provisions of the interconnection construction service agreement (ICSA).
Mark Sims, PJM manager of infrastructure coordination, reviewed a proposed solution and associated tariff revisions addressing the RTO’s concerns associated with the pro forma ICSA’s lack of superseding language and current automatic termination provision. Sims first presented the issue at the March Planning Committee meeting. (See “Interconnection Construction Service Agreement,” PJM PC/TEAC Briefs: March 9, 2021.)
He said the catalyst for dealing with the issue is the overwhelming generation interconnection queue volume.
“In this environment, we have to remain focused on efficiency, and we’ve identified two areas of the tariff we can improve on,” Sims said, denoting two sections of Attachment P of the tariff that deal with ICSAs.
Section 1 of Attachment P does not contain pro forma language that considers when an ICSA supersedes an already effective ICSA, Sims said.
The tariff provides for automatic termination of ICSA upon the occurrence of certain conditions, he said, which can occur without PJM’s knowledge. The conditions include completion of construction of all interconnection facilities, a transfer of title, final payment of all costs or delivery of final as-built drawings to the transmission owner.
Sims said PJM is asking the transmission owners to notify them when the conditions have been met but is not looking to “shift burden” to the TOs.
The RTO received little stakeholder feedback regarding the superseding language, Sims said, but concerns were raised regarding the automatic termination proposal.
Alex Stern, director of RTO strategy for PSEG Services, provided a friendly amendment to the proposed tariff language. The amendment proposes that the notification obligation be “reciprocal” so that PJM will provide written notice to the interconnected TO and customer generator that the ICSA has been canceled with FERC.
Stern said the TOs and customer generators must make quarterly report filings at FERC that provide detailed interconnection agreement information, including termination of agreements. Stern said the TOs must rely on PJM to provide notice to comply with FERC obligations.
“As long as we’re making this refinement, it seemed to make sense to do as much as we can to help one another with our respective compliance obligations,” Stern said.
Stakeholders will vote on the proposals at the April PC and MRC meetings.
HVDC Senior Task Force Update
Lisa Krizenoskas, senior lead engineer with the interconnection projects group of PJM, provided an update regarding the status of the High Voltage Direct Current Senior Task Force.
The opportunity statement and issue charge for the task force were approved at the May 2020 MRC meeting, with stakeholders investigating the technical and tariff issues associated with the participation and integration of HVDC converter resources in the PJM capacity market. (See HVDC Initiative Endorsed by PJM Stakeholders.)
The task force met four times in 2020, Krizenoskas said, receiving education on Direct Connect’s SOO Green HVDC Link — a 350-mile, 2,100-MW, 525-kV underground transmission line that would deliver renewable energy from upper MISO to Illinois and the PJM grid, primarily along existing rail rights of way.
Work at the task force also included education on internal and external PJM capacity resources, pseudo ties and dynamic schedules. Interest identification and design components were also developed for the matrix since the task force’s last meeting on Oct. 19.
Krizenoskas said stakeholders continue to meet with PJM to discuss potential proposals, but no formal design options or proposals have been developed.
Carl Johnson of the PJM Public Power Coalition said several stakeholders asked for clarification when the task force discussed ways to address the HVDC issue. Johnson said major changes are already under consideration for PJM’s entire resource adequacy construct, and that the timing regarding changes to the rules to new units like HVDC would be “extremely challenging” to address.
“We’re increasingly challenged to find a way that this would fit into the current construct and how the anticipated proposal would work,” Johnson said.
Calpine’s Scarp said he agreed with Johnson’s opinions, and that stakeholders should consider closing the task force at the next MRC meeting. Scarp said the information and education on HVDC will become “stale” if there continues to be delays as the task force has been on hiatus for nearly six months, canceling the last six scheduled meetings.
SOO Green’s attorney, Ruta Skučas of Pierce Atwood, said she was “surprised” to hear stakeholders talking about closing the task force. Skučas said SOO Green has been working with PJM for several months to try to come up with a proposal regarding HVDC implementation.
Scarp said the stakeholder process is “not a one-off, side-off PJM process,” and that conversations need to be brought back to the membership body for open discussions.
Skučas said SOO Green’s intention was to go through the full stakeholder process to address the HVDC issue but felt it needed to talk to PJM first.
“We were hoping to work through PJM’s concerns first and then bring something that was at least acceptable to PJM,” Skučas said.
Consent Agenda Items
Stakeholders unanimously endorsed several manual updates:
- Revisions to Manual 02: Transmission Service Request from a periodic cover-to-cover review, including correction of grammatical errors, updated links and added language for an alternative method for simulating transfers. (See “Manual Changes Endorsed,” PJM Operating Committee Briefs: March 11, 2021.)
- Revisions to Manual 11: Energy & Ancillary Service Market Operations, resulting from the periodic review, that provide clarification of existing processes, removing outdated rules and terminology, and correcting spelling and grammar mistakes. (See “Manual 11 Revisions,” PJM MIC Briefs: March 10, 2021.)
- Revisions to Manual 37: Reliability Coordination, resulting from a periodic review, that feature fixing broken hyperlinks, updating reference document names, and the consolidation and relocation of two subsections of the manual. (See “Manual Changes Endorsed,” PJM Operating Committee Briefs: March 11, 2021.)
- Revisions to remove the transmission loading relief (TLR) buy-through congestion process from Schedule 1 of the Operating Agreement. (See “TLR Buy-through Quick Fix,” PJM Operating Committee Briefs: March 11, 2021.)
Members Committee
Manual 34 Revisions
Members raised questions regarding proposed revisions to the stakeholder process at the Members Committee meeting March 29.
John Horstmann of AES Ohio presented the proposed Manual 34 revisions that are aimed to address motions and amendments. The revisions, which were under review for more than a year at the Stakeholder Process Forum, modify three sections in Manual 34.
“This has been reviewed quite a few times,” Horstmann said.
The group that worked on the issue was trying to ensure that no member has “undue influence” over the stakeholder process, Horstmann said, and they wanted to clarify when members can bring an issue directly to the MC for a vote and bypass the full stakeholder process.
Adrien Ford of Old Dominion Electric Cooperative said she was supportive of the proposed changes, and that it will “enhance the stakeholder process” for all members.
Scarp said he was also supportive of the changes.
“It’s important that things get full vetting in the lower committee before they come up to the higher-level committee,” Scarp said.
Segner said she was concerned some of the manual changes are “potentially broad ranging” and wanted to know what problem they were addressing.
Horstmann said the consensus-based issue resolution process is intended to be the place where issues are raised and discussed by stakeholders. Without the changes, an issue that was never discussed in the lower committees could be brought forward as an amendment at the MC for a vote.
Segner said some of the proposed language seemed to “add a new test” to the process to define what is germane to an issue being discussed. She said what currently defines whether something is in scope on an issue are the words in the issue charge and problem statement. A “good amount of time” is spent on writing those documents, she added.
“I just wonder if there’s going to be some unintended consequences here and at the MRC where we’re going to be voting on procedural issues,” Segner said.
Stakeholders will vote on the manual revisions at the April MC meeting.