By Rory D. Sweeney

VALLEY FORGE, Pa. — After nearly two years of intractability, FERC’s order last month on supplemental transmission projects — and PJM’s subsequent compliance filing — have reshuffled the deck in the RTO’s Transmission Replacement Process Senior Task Force (TRPSTF).

The order and filing require transmission owners to change how they plan and represent supplemental projects but also give them greater control over defining that process. They forced stakeholders at last week’s TRPSTF meeting — the first since submitting the compliance filing — to reconsider how they approach topics that have remained largely unchanged since the task force was proposed in January 2016.

PJM’s Steve Herling reviewed the process changes proposed in the filing, which delineate a structure for stakeholder engagement on supplementals and define deadlines for input. Developed internally by TOs through their “local” transmission plans, supplementals are not driven by PJM criteria. They’re included with baseline and market efficiency projects in PJM’s Regional Transmission Expansion Plan to allow staff to identify possible reliability or operational performance issues, but they are not subject to staff oversight or approval. All stakeholders are supposed to have opportunities to provide “meaningful” input on them, and FERC’s order determined that TO procedures weren’t allowing that. (See Group Contests ‘Supplementals’ Ruling as PJM, TOs Advance.)

Is Anything Ever Final?

Herling said projects tend to be submitted in “bunches” near the beginning and end of the year.

“I don’t know that PJM would be able to second-guess the timing of those decisions,” he said when asked to explain the reason for the bunches. He said the focus is to “get the solutions accepted, lock them down and move on so we don’t have surprises in the RTEP process.”

The deadlines in the compliance filing drew criticism from American Municipal Power’s Ed Tatum, who said they might not provide enough time to fully vet projects and receive answers. He asked when local plans are finalized so that stakeholders can comment on them in their entirety.

“The only way I can answer that is to refer to the RTEP. The RTEP is never finalized,” Herling said. “I don’t know what it means for the RTEP to be finalized, so I would suggest that I also don’t know what it means for the local plan to be finalized. … I don’t have a problem with putting a flag in the ground and saying, ‘We’re done.’ … I don’t know what the significance is from a planning perspective because every year we finish an RTEP, we start another one.”

Mark Ringhausen with Old Dominion Electric Cooperative said it seems like “there really isn’t a local plan; there’s just approval of supplemental projects.”

Resolving the Task Force’s Work

The TRPSTF went on a 10-month hiatus in response to FERC’s show-cause order on the issue, and TOs remained reticent to engage even after the task force resumed meeting late last year at the urging of load-side interests, citing the lack of FERC direction. The order and compliance filing clear the way for resolving the task force’s assignments, but how that’s accomplished remains to be seen. PJM is hoping the details contained in the order and filing can be accepted by everyone and set aside from debate on the remaining components, but AMP isn’t convinced.

“All we’re suggesting is we leave the parts that were filed on the table assuming they’ll be approved,” Herling said.

Tatum suggested having stakeholders propose solution packages and voting on them at an upcoming meeting as is common in other task forces.

“We have been doing nothing for 16 months. … We’re still getting ready to try to see if anyone is willing to have a discussion with us,” he said. “We’ve got to finish this group. We’ve got to stop meeting like this.”

Exelon’s Gary Guy questioned an all-inclusive approach.

“We’re not debating the pros and cons of a commission-issued order,” he said. “Once the commission has issued an order, we don’t have anything to debate.”

While the order undoubtedly has an impact on the task force, the question remains how much. The order is specific to TOs’ implementation of Order 890 regarding supplementals, but the TRPSTF is charged with addressing the processes for determining and replacing infrastructure that has reached the end of its usable life. The task force’s problem statement, issue charge and charter make no mention of Order 890. PJM’s Fran Barrett, the TRPSTF administrator, said he will research any potential overlap.

Stakeholders have proposed components that they believe are necessary for any solution, and Barrett asked if PJM staff could analyze them to pull out the parts that have been addressed by the order and filing.

“Could we clean up the past without throwing it away?” he asked.

TOs didn’t object to the plan, which would have PJM present an interpretation of what is explicitly addressed by the FERC order, but PPL’s Frank “Chip” Richardson pointed out that TOs remain in litigation on some of the TRPSTF’s topics and are unable to negotiate on them. Tatum and AMP’s Lisa McAlister said they want to maintain the right to go through their proposal and make their own modification interpretations. They didn’t see any benefit to PJM’s interpretation.

“We’re pretty good with what’s in the order and the compliance filing,” McAlister said. “I’m not sure it’s that helpful.”

Guy said he would object to any proposed alternatives to what’s in the commission order and said PJM should rule them out of the bounds of the discussion.

“That would be running amok here in complete disregard of what just took place at the commission,” he said.

“Discussion is one thing,” said Ruth Ann Price, who represents the Delaware Division of the Public Advocate. “Implementation is another. … I’m not sure you have any ability to stop us, the rest of the stakeholder body, going forward.”

“Just because we put it out there, doesn’t mean there’s an affirmation on this,” Barrett explained.

He attempted to point to improvements that have been made to the process since the task force began, but Tatum wasn’t convinced.

“We are not encouraged by the changes that have been made. We see some progress, but we also see a lot of pullback,” he said. “There are certain things that PJM doesn’t think about regarding end-of-life projects … so we’re going to seek to have those things addressed, as we already have. … There’s a lot of things we need to work on. We’re very serious about it.”

Barrett said subregional RTEP meetings have evolved in response to the task force’s work.

“They’re not the same calls they used to be,” he said.

The TRPSTF’s next meeting is scheduled for April 30. Tatum said he hoped that proposed solution packages could be finalized and ready to be voted on by then.