PJM stakeholders last week endorsed a proposal and corresponding manual and Operating Agreement revisions to allow facilities to avoid being designated as critical infrastructure under NERC reliability standard CIP-014.

With an acclamation vote at the Markets and Reliability Committee’s meeting Wednesday, the proposal passed with two objections and one abstention. A corresponding piece on the mitigation of CIP-014 facilities will have a vote at a future MRC meeting, PJM officials said, after some stakeholders objected to the corresponding manual changes.

Mike Herman of PJM’s transmission planning department reviewed the proposed solution and manual language changes, including Manual 14B and Manual 14F, to address the avoidance of future CIP-014 facilities. Herman said the stakeholder process conducted on critical infrastructure stakeholder oversight (CISO) was a “significant work effort” over the past 18 months after the issue charge was first approved at the December 2019 Planning Committee meeting. (See “Critical Infrastructure Mitigation,” PJM PC/TEAC Briefs: Dec. 12, 2019.)

Stakeholders originally endorsed the avoidance package, including associated manual language, with 77% support at the February PC meeting. (See “CISO First Read,” PJM MRC/MC Briefs: March 29, 2021.)

Herman said one of the biggest challenges throughout the stakeholder process on CISO has been balancing the need for transparency versus the need for confidentiality on the projects. The avoidance solution includes the study of proposed Regional Transmission Expansion Plan (RTEP) projects to ensure that no new critical facilities are created, he said. PJM sees the avoidance portion proposed as a “very valuable process.”

Under its avoidance proposal, if a project creates a new critical substation, PJM will work with the proposing entity to determine if the project needs to be modified. Herman said the avoidance proposal hasn’t changed in eight months of stakeholder discussions.

“This is the proactive approach to ensure that we’re not creating any new critical facilities,” Herman said.

The mitigation portion, which would create a process for PJM to address facilities that can not avoid being designated as critical, will be further discussed at the PC, Herman said. PJM saw the avoidance and mitigation portions of CISO as separate processes since the inception of the stakeholder process on the entire issue, Herman said.

Erik Heinle of the D.C. Office of the People’s Counsel thanked PJM staff and stakeholders for their work ever since his organization first brought the issue charge forward in 2019. Heinle called the process a “long and winding path” to get to a solution on the avoidance portion of the issue.

While getting the avoidance portion completed was an important step, Heinle said he wants to see work continue on the mitigation portion because the two sides go together. “We’re hopeful that mitigation will be up in front of the MRC as quickly as possible.”

New Service Requests Approved

Members unanimously approved the proposed solution and tariff revisions to address deficiency review requirements for new service requests. PJM proposed to change new service application deadlines to better manage the large number of requests in the queue. (See “New Service Requests,” PJM MRC/MC Briefs: April 21, 2021.)

Jason Connell, director of infrastructure planning for PJM, reviewed the problem statement and issue charge of the proposal, which received 100% support in a sector-weighted vote. Connell said PJM staff process new service requests under several parts of the tariff and administer two new queue windows each year: one from April 1 to Sept. 30, and another from Oct. 1 to March 31. Strict timelines established by the tariff require PJM to review a new service request and issue a notice of any deficiencies within five business days.

PJM’s solution changes the five-day deadline to 15 or to “use reasonable efforts to do so as soon thereafter as practicable.” During discussions, several stakeholders encouraged PJM to move up the closing of the queue by about three weeks to allow staff more time to review applications.

Paul Sotkiewicz of E-Cubed Policy Associates said he continues to have the same concerns on the issue he first presented at the PC, calling PJM’s solution a “short-term fix at best” that won’t accomplish the goal of spreading out staff’s work. Sotkiewicz said he understood that something needed to be done on the issue to satisfy FERC, but he couldn’t support the proposed solution.

Sotkiewicz suggested PJM examine instituting a sliding scale on the cost to review projects, with companies turning in a new service application earlier in the window receiving a discount. He said the sliding scale would provide an incentive to get requests into the queue earlier.

“The way to solve this is to use a good mechanism design to provide the right incentives to get those in early, and this mechanism simply doesn’t do it,” Sotkiewicz said.

ICSA Addressed

Mark Sims, PJM manager of infrastructure coordination, provided a second first read of the proposed solution and associated tariff revisions addressing the RTO’s concerns associated with the pro forma interconnection construction service agreement’s (ICSA) lack of superseding language and current automatic termination provision.

Sims first presented the issue at the March MRC meeting, with stakeholders providing recommendations to PJM’s proposal. (See “ICSA First Read,” PJM MRC/MC Briefs: March 29, 2021.) Stakeholders officially endorsed the ICSA provisions at the May PC meeting. (See “ICSA Endorsed,” PJM PC/TEAC Briefs: May 11, 2021.)

Stakeholders’ concerns led the RTO and members to make changes to address the growing interconnection queue volume, identifying improvements in two areas of tariff Attachment P that deal with ICSAs, Sims said. Section 1 of the attachment does not contain pro forma language that considers when an ICSA supersedes an already effective agreement, which he said happens “fairly frequently.” The solution involved a simple revision of tariff language.

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 wants to revise the tariff language to make any termination contingent upon PJM receiving notice of the conditions from the TO.

“I feel the posted language today represents a good solution for all of us,” Sims said.

Manual 14 First Read

Nick Dumitriu of PJM provided a first read of proposed revisions to Manual 14B: PJM Region Transmission Planning Process and Manual 14F: Competitive Planning Process. The conforming manual language, resulting from tariff revisions accepted by FERC in December (ER21-162), was unanimously endorsed at this month’s PC meeting. (See “Manual 14F and 14B Updates,” PJM PC/TEAC Briefs: May 11, 2021.)

PJM had proposed to include capacity constraints as inputs to the market efficiency analysis for market efficiency projects in the RTEP and to clarify when capacity benefits of market efficiency projects are calculated.

Dumitriu said the Manual 14B conforming language includes adding Reliability Pricing Model (RPM) constraints to a list of constraints having an economic impact and clarifying the definition for the total annual enhancement benefit. Manual 14F changes include adding information regarding the window type and duration for RPM economic constraints in the proposal window overview, Dumitriu said. They also would add language regarding the expected in-service date for projects addressing RPM constraints in the reliability criteria project evaluation section.

The manual changes will have a final endorsement vote at the June MRC meeting.

Consent Agenda

Several manual changes were endorsed in an acclamation vote on the consent agenda:

• Manual 03: Transmission Operations, with revisions resulting from a periodic cover-to-cover review. Stakeholders endorsed the changes at the May Operating Committee meeting after complaints PJM didn’t provide the updated language for the first read. (See “Manual 03 Changes Endorsed,” PJM Operating Committee Briefs: May 14, 2021.)
• Manuals 11: Energy & Ancillary Services Market Operations, 14D: Generator Operational Requirements and 18: PJM Capacity Market, with revisions addressing public distribution microgrids. The OC unanimously endorsed new rules in December, and the MRC received a first read at its meeting the same month. (See “Public Distribution Microgrids,” PJM MRC/MC Briefs: April 21, 2021.)
• Manual 21: Rules and Procedures for Determination of Generating Capability, with revisions resulting from a periodic cover-to cover-review. Stakeholders unanimously endorsed the minor changes at the May PC meeting. (See “Manual 21 Updates Endorsed,” PJM PC/TEAC Briefs: May 11, 2021.)
• Manual 36: System Restoration, with revisions resulting from a biennial review. The changes were unanimously endorsed at the May OC meeting. (See “Manual 36 Changes Endorsed,” PJM Operating Committee Briefs: May 14, 2021.)