By Rich Heidorn Jr.

American Municipal Power contended Thursday that PJM’s limited review of transmission owner projects is not rigorous enough to ensure the RTO is avoiding unnecessary costs or that TOs’ evaluation of other stakeholders’ proposed solutions are accurate and unbiased.

AMP’s Ryan Dolan noted that Manual 14B prohibits PJM from evaluating supplemental projects as part of the Regional Transmission Expansion Plan, meaning the plan can’t capture whether a supplemental project creates or alleviates economic issues. “We can’t assure an optimized build-out of the system,” said Dolan, who presented a list of proposed rule changes at Thursday’s Planning Committee meeting.

Dolan said PJM’s limited review was not a problem in the past but that the RTO should provide more scrutiny now, because supplemental and other TO projects represented 88% of RTEP spending last year.

“There’s information that PJM has that the TOs don’t have, that we [stakeholders] don’t have,” said Dolan, who said the RTO should tap all available expertise in its analyses.

‘Do No Harm’ Reviews

Dolan spoke after Aaron Berner, PJM manager of transmission planning, explained the RTO’s “do no harm” reviews of baseline upgrades, supplemental upgrades and new service requests. The review is intended to identify any reliability issues caused by new upgrades, determine if the upgrades should be more or less “robust” and assess the cost efficiency of packages of upgrades needed to correct reliability violations.

The testing required depends on the scope of the upgrade, not the type of upgrade, Berner said. No analysis is required for direct in-kind replacements, while minor changes to impedances or ratings undergo “minimal analysis.” Significant changes to impedances, ratings or new topology may require “significant” review — load-flow, short-circuit and stability analyses.

AMP wants PJM to vet supplemental projects to identify interdependencies with baseline projects and quantify the impacts of TO proposals on previously approved economic projects or whether they eliminate previously approved reliability projects or change cost allocations.

Dolan said many TOs create their own base cases with generation dispatch and load profiles that differ from PJM’s practice, but the RTO’s analysis is only applied on its own models. “There are no checks and balances to ensure that the [TO’s] process is being followed and that [that] process is consistent,” he said.

Dolan also expressed concern about the large number of TO projects submitted at the end of the RTEP cycle, saying PJM should establish start and stop dates for TOs to submit needs and proposed solutions, aligned with competitive windows.

He also called for standardizing the data reporting requirements for all project submissions and requiring reporting of all scenarios, models, standards and documentation used to justify and size project facilities; and a process that allows for formal submission and PJM review of alternative proposals.

Alex Stern, manager of transmission strategy and policy at Public Service Electric and Gas, said AMP’s proposals were “misplaced.”

“My initial reaction is the PJM stakeholder process might be the wrong forum” for AMP’s proposal, said Stern, noting FERC’s Feb. 15 ruling, which he said accepted PJM’s current role and declined to mandate it do more (EL16-71, ER17-179). (See FERC Orders New Rules for Supplemental Tx Projects in PJM.)

“FERC just advised that it doesn’t believe there is any modification needed to PJM’s analysis. It confirmed the acceptability and appropriateness of PJM’s role with respect to planning for supplemental projects and specifically declined to require greater PJM involvement in planning for and selecting supplemental projects.

“The stakeholder process probably shouldn’t be discounting FERC on this,” Stern added.

“They weren’t saying [PJM] couldn’t do more,” Dolan responded. “They were just saying, ‘It’s OK.’”

Internal Discussions on Sharing More Info on Tx Projects

Earlier in the meeting, Berner described the RTO’s internal discussions about how it can respond to requests for more information on proposed transmission projects.

Berner said PJM is developing a tracking mechanism for identifying information shared without disclosing critical electric infrastructure information. The RTO is considering making more information available through the Planning Community portal launched in September.

The RTO expects to share its proposals within “a couple months,” Berner said. Some information requests to the RTO indicate it should offer additional education on its study process, he added.

TOs Answer Questions at TEAC

At the Transmission Expansion Advisory Committee meeting later Thursday, officials of Baltimore Gas and Electric and Commonwealth Edison answered questions Dolan had posted on supplemental projects brought up for a second read. BGE, for example, said that circuit breakers slated for replacement at its Jericho and Howard substations are 47 and 27 years old, respectively, and have been the subject of expensive repairs.

Dolan appeared pleased to be receiving responses, smiling in the room when the BGE representative spoke up on the phone. He had posed the questions to Berner, who said PJM was still in collecting the necessary information and determining how to respond, but BGE then volunteered the responses. When Dolan later brought up his questions about replacing a transformer and installing two breakers at ComEd’s Wayne substation, Berner deferred to a ComEd representative on the phone, who provided responses.

Earlier in the TEAC, stakeholders received first-read presentations on eight supplemental projects: six by American Electric Power totaling $163.4 million and two by Dominion, totaling $860,000. (See table.) When discussing an AEP project to replace two breakers at its Jefferson station, Berner told Dolan he didn’t have answers to questions AMP had submitted and wasn’t planning to bring the project back to a subsequent meeting to review the responses “unless something changes.” Dolan argued that AMP had submitted questions within the timeline laid out in the TOs’ recently proposed Tariff Attachment M-3, which they developed to codify the “additional detail and transparency regarding the process for planning supplemental projects” they’ve agreed to. It is currently circulating for review and comments.

In a discussion on a $53 million project to replace aging transformers at AEP’s Wyoming substation, Dolan asked whether stakeholders would be permitted to review maintenance records on the transformers. “There’s a discussion about whether maintenance records need to be made available,” said Berner.

Vice President of Planning Steve Herling said PJM’s reading of FERC’s February order is that stakeholders should be able to replicate the TO’s planning studies, “not replicate asset conditions.”

“As we’ve been discussing, we’re trying to change the progress of the supplemental upgrades as they come to PJM,” Berner said at one point. “It’s going to take us a little bit of time to get those specifications of the required upgrades to a point where we can present them all in a fashion that would allow identification of the issues earlier in the process, but there are a number of issues out there right now that need to be addressed. We can’t delay that.”