By Rory D. Sweeney

VALLEY FORGE, Pa. — After years of intractability, can PJM’s Transmission Replacement Process Senior Task Force play nice? The RTO is hoping it can be forced to.

PJM’s Fran Barrett, who administers the task force, told stakeholders at last week’s meeting that transmission owners and customers must agree on a common definition of “end-of-life facilities” to move forward. He said that at its next meeting on Feb. 1, stakeholders will vote to approve a working definition that would apply only to discussions within the task force.

“We’re going to put an end to the end-of-life discussion at the next meeting,” he said.

The directive came after transmission owners declined to endorse a definition developed by Mark Ringhausen of Old Dominion Electric Cooperative. Stakeholders had debated the meaning of the term at previous meetings, and Ringhausen offered to develop a proposed definition.

The task force has made little progress since it was chartered in May 2016 to “develop alternatives for providing more transparency and consistency in the communication and review of end-of-life projects in the Regional Transmission Expansion Plan.” FERC issued a show cause order in August 2016 questioning whether PJM TOs’ procedures for planning supplemental projects provided stakeholders opportunity for “early and meaningful input and participation,” as required by Order 890 (EL16-71). That precipitated a 10-month hiatus of the task force, which ended in July. (See Softer Rhetoric as PJM Members Seek Replacement Rules Accord.)

Supplemental projects are proposed by TOs to meet local needs, but they are not required by PJM’s reliability, economic efficiency or operational performance criteria. Their costs are paid by the TO zone and are not regionally allocated, unlike baseline upgrades resulting from the RTEP.

The commission’s show cause order directed the TOs to file rule revisions, or counter with evidence that they were already in compliance with Order 890, within 60 days. The TOs responded Oct. 25, contending that the PJM Operating Agreement already complies with the order, but also proposed a Tariff amendment, Attachment M-3, that they said would improve transparency. Attachment M-3 would add more specificity to annual stakeholder reviews of TOs’ assumptions and methodology, along with TO presentations of their views on local transmission needs and proposed solutions.

FERC, which was without a quorum between February and August, has not ruled on the filing despite promising it would act within about three months of the TOs’ response.

Endorse or Propose

At last week’s meeting, TOs were divided on Ringhausen’s proposal. PPL’s Frank “Chip” Richardson said it “helps define it for me as to what are we really talking about in this task force,” but others hesitated to support it. Tonja Wicks of Duquesne Light said she had not received approval to endorse a definition and asked that the vote be deferred until her company could review it.

“This is a recommendation by one stakeholder of a definition, not the task force definition,” she said.

“And what I’m asking the task force participants: Can you march under this flag for purposes of this discussion to say this is the end-of-life definition?” Barrett said.

“Duquesne is okay with this definition being an ODEC-represented definition,” Wicks said. “We haven’t agreed on any of terms in the definition.”

“That doesn’t help us very much,” PJM’s Steve Herling responded. “We’re trying to have a set of boundaries for the conversation this group needs to have.”

“We can use those words any way you define them, as long as we’re not committing that we agree with those definitions,” Exelon’s Gary Guy said.

Barrett agreed to the deferral requested by Wicks but told stakeholders to come prepared to endorse the definition or propose an alternative.

“One thing that I do not want to get involved in is … trying to parse every component [at a transmission facility] to justify whether it falls within this definition,” Herling warned. “If it has to be replaced, it has to be replaced.”

Analysis Details

Earlier in the meeting, Ed Tatum of American Municipal Power asked PJM to detail its procedures for analyzing projects proposed by TOs.

“With regards to the baseline projects, the narrative is very clear as to what PJM is going to be looking at and thinking about,” Tatum said. “With regard to projects that are not in [FERC] Form 715 and/or are not part of PJM’s baseline — in other words end-of-life and/or supplemental projects — we do not have a narrative evaluation or assessment about how these things work.”

“That actually seems like a fairly trivial thing to fix because the level of analysis that we do is the same, so we can memorialize that somewhere,” Herling said, adding that the analysis is consistent with other studies PJM performs to determine whether retiring a facility will cause a reliability violation. “That’s based on all the tests we do in the RTEP. … I don’t see [that] there’s a documentation issue, but we can make it more clear if people are concerned.”

Tatum continued, asking how certain Form 715 filing requirements are met for supplemental projects, which are submitted by TOs and aren’t necessarily individually vetted by PJM.

“I don’t think that the filing requirements are specific to each facility on the grid individually,” Herling responded. “We don’t try to demonstrate that every facility individually satisfies some criteria. We show the system is reliable and that we have done the appropriate analysis.”

PJM agreed to review its documentation to address both of Tatum’s concerns.

Design Component Changes

AMP also reviewed additional proposed revisions to the task force’s design components. AMP’s Lisa McAlister said the group felt it had “moved” substantially to include TO feedback.

Herling questioned some of the details AMP proposed.

“Some of that level of specificity, we’re going to have to figure out does that actually make sense in the direction that we’re trying to take the [Transmission Expansion Advisory Committee], which is to more dynamic communication, not focused on monthly meetings. Once we see what the proposals are and how they fit together, then we’ve got to figure out is that undoing some of what we’re trying to accomplish with the TEAC.”

Barrett asked that stakeholders begin reviewing the proposed language and formulate positions on what to include in a final supportable package.