VALLEY FORGE, Pa. — Stakeholders at last week’s Planning Committee meeting pushed PJM to expand its scope on several transmission-related issues, but staff resisted the effort in an attempt to keep a tight focus on specific rule revisions.

Stakeholders endorsed manual changes to revise PJM’s processes for new interconnection requests, but Ryan Dolan of American Municipal Power said the changes should go further.

The endorsed changes are part of a larger effort to replace an initial transmission study in the interconnection process with a more detailed feasibility study before moving to a costlier impact study. PJM’s Ed Franks said market participants won’t know the limiting elements on a line until a meeting later in the process, but Dolan argued they should be able to determine that information before submitting a project into the queue.

“I have no way of predetermining if a switch or another element [or] an entire line might be limiting me,” Dolan said.

“It’s relatively impossible to put that in the case. I think you can understand that,” PJM’s Aaron Berner said. “That’s a much broader topic.”

There were also concerns regarding PJM’s proposed Manual 14B changes because the RTO’s analysis found they would affect two flowgates, but Dolan argued the impact was potentially much greater and requested an analysis of the potential change to equipment.

“I fully understand the system is a dynamic system, but ultimately I think what we can only request be done right now is we at least take a snapshot of what we know currently of the system and how its topology is laid out, and we can make our decision based off of what is currently in our models,” he said.

Staff agreed to delay the endorsement vote for a month to provide that analysis.

Steve Huntoon, of Energy Counsel LLP, raised concerns about proposed changes to Manual 14A, which he called “overbroad and likely to result in a lot of confusion.”

“When I read the magnitude of this … there are some sweeping statements throughout here, and I’m very concerned about the implications of them,” he said.

Dolan also questioned the changes, voicing concerns about ratepayers being charged for more than their responsibility for necessary upgrades.

Berner again attempted to rein in the conversation.

“I think we’re straying from the manual here. The issues here are around how we process and handle our studies,” he said.

Berner suggested PJM provide participants additional education on the issue because some appear to be conflating withdrawal service and transmission service. Dolan said the education would be helpful because “now what I’m seeing here is they’re being grouped together here in one study process.”

“I just want to make sure that everybody at this committee is aware that non-firm transactions are contributing to overloads in the assessments,” Dolan said.

The Manual 14A revisions are planned to go for an endorsement vote at next month’s meeting.

PJM Proposes POI Solutions

Staff is proposing three options for resolving issues with points of interconnection (POI) for grouped generation projects, though none provides a perfect solution.

The first option would require a generation developer to sign on to the Tariff as a transmission owner for the line and a wires-to-wires POI where the gathering line connects to the grid.

John Brodbeck with EDP Renewables argued that FERC Order 807 creates ways for developers to avoid becoming TOs, but PJM’s David Egan disagreed.

“If you want the flexibility you’re asking for, you’re asking to have the TO construct,” Egan said. “The fact that you’re subdividing and doing whatever you want for your financing, really that’s your issue.”

Dayton Power and Light’s John Horstmann raised the concern that such requirements would change project calculations. For one thing, the developer would have five years to use up all the capability on a line it built or be required to open access to other developers.

“It’s a huge impact on the project,” Horstmann said.

The second option would require the local TO to assume control of the transmission infrastructure up to the connection point for the individual projects.

A third option would require the developer to combine all the projects into a single entity so it can sign a single interconnection service agreement.

“We currently have situations like this … and we typically have handled this as a shared facilities agreement,” Brodbeck said.

He asked if that was still an option or “if we’re becoming a TO, I assume … we get to vote as a TO, we get to walk around as a TO, and all these other things, right?”

Staff said they are working on splitting the manuals to pull out generator-specific revisions into a separate manual.

Capacity Factors

PJM is proposing several Manual 21 changes based on a review of data regarding generator performance.

Staff plan to shorten the summer generation testing period by one month, limiting it to July 1 through Aug. 31. They are also proposing to use the median capacity factor instead of the average capacity factor for both wind and solar resources, along with relying on the actual five-minute settlement values to estimate what output would have been absent curtailments of wind by PJM operations.

PJM’s Jerry Bell reviewed staff research showing that average solar capacity factors are similar to median capacity factor results, but average wind capacity factors are quite different from median results. The study analyzed both summer and winter performance for both generation types.

The data analysis also found that five-minute settlement values for wind resources, which are available to the generators, are very similar to state estimator results, which they don’t have access to.

Finally, an analysis of testing data showed that generators tend to test during the best possible conditions, or test early and then retest if conditions improve.

“I’m not saying there’s any malicious intent here, but there may be things that we don’t see because we can’t get a view of the energy balance,” Bell said.

Roseland Conflict

PJM staff made it clear early during the discussion on the Roseland–Branchburg–Pleasant Valley Corridor that they intended to wrap up the months of discussion about the project.

“Our intent would be to not bring this back to the TEAC after this point,” Berner said.

However, AMP wanted to outline its concerns. Dolan brought up the results from a recent FERC decision that showed the cost to rebuild the line has nearly doubled.

PJM staff said past estimates were based on the amount of time it had to produce the numbers and were done using different methodologies. They defended the decision to install a double-circuit structure but only string a single circuit because the cost of expanding to a second circuit in the future would be “significantly” higher than the 10% adder included in the current estimate.

Staff also defended their rejection of simply not replacing the line based on the initial results of their analysis of that plan.

“What we see here is enough to conclude that’s a bad idea,” PJM’s Mark Sims said. “Just doing the first round of analysis gives us a severe enough of a result.”

— Rory D. Sweeney