Manual 14D Endorsed

PJM stakeholders unanimously endorsed manual updates related to behind-the-meter generation (BTMG) business rules on status changes developed in special sessions of the Market Implementation Committee.

Terri Esterly, senior lead engineer in PJM’s markets automation and quality assurance department, reviewed Manual 14D: Generator Operational Requirements updates to appendix A during last week’s Operating Committee meeting. Stakeholders endorsed related changes to Manual 14G at the Aug. 31 Planning Committee meeting. (See “Manual 14G Updates Endorsed,” PJM PC/TEAC Briefs: Aug. 31, 2021.)

Esterly said PJM made no changes to the updates since she first presented the manual changes at the August OC meeting. (See “Manual 14D Updates,” PJM Operating Committee Briefs: Aug. 12, 2021.)

The updates to Manual 14D were intended to address conflicts with the Reliability Pricing Model must-offer requirement and “removal from generation capacity resource status” business rules, Esterly said. Updates included addressing performance obligation impacts, clarifications to business rules regarding load impacts from status changes, and participation in PJM’s load response.

In a section on designating capability as a generation capacity resource and/or an energy resource, PJM added a business rule to make it clear a new service request must be submitted for the designation, Esterly said. Another rule was made to clarify the process to request a change from BTMG status to generation capacity resource status.

In the section on participation in PJM load response, Esterly said the RTO added the process to indicate that a BTMG unit is participating in PJM load response by providing on-site generator data.

The manual updates now go to the Sept. 29 Markets and Reliability Committee meeting for a first read and endorsement at the Oct. 20 MRC meeting.

Manual 01 Changes

A manual attachment created last year in the wake of COVID-19 emergency protocols is set to become permanent and changed to address other emergency situations.

Chris Moran, senior lead analyst with PJM’s NERC compliance team, provided a first read of updates to Manual 01 Attachment F: Control Center and Data Exchange Requirements regarding the RTO’s market operation centers being able to conduct remote operations.

Moran said attachment F of Manual 01 was originally developed and implemented at the start of the COVID-19 pandemic to provide guidance for remote operations “should imminent risk of COVID-19 start to affect staffing” in PJM’s market operation control centers. The temporary attachment, which became effective in April 2020, was set to expire on Dec. 31 of this year.

As the pandemic has progressed, Moran said, it has “become apparent” to PJM that attachment F needs to become a permanent part of Manual 01. Several stakeholders also had suggested making the attachment permanent at a previous OC meeting. (See “COVID-19 Update,” PJM Operating Committee Briefs: June 10, 2021.)

Moran said PJM wanted to make attachment F broader so that it doesn’t simply apply to COVID-19. The language changes include replacing COVID-19 with “exceptional circumstances,” which include severe weather, natural disasters, civil unrest and other pandemic events.

PJM’s definition for exceptional circumstance says, “an event or effect that can be neither anticipated nor controlled, including but not limited to any act of a public enemy, war, insurrection, riot, fire, severe weather, natural disaster, flood, civil unrest, explosion, pandemic or other public health emergency, as reasonably determined by PJM.”

The attachment changes also include updating NERC compliance contact information for PJM.

The OC will vote on the manual changes at its October meeting.

COVID-19 Update

Becky Carroll of PJM provided an update on the RTO’s response to COVID-19, saying staff is reviewing Occupational Health and Safety Administration rules regarding vaccinations recently announced by the Biden administration.

Carroll said PJM is “still evaluating” the new rules that would require vaccinations or a weekly negative COVID-19 test for any company over 100 employees. She said PJM will be communicating more details to its employees and stakeholders following consultation with the RTO’s legal counsel, its epidemiologist and the executive team.

“As we’re thinking about this new rule, we’ll be taking the safety and wellbeing of PJM staff into account, given that’s paramount,” Carroll said.

Some PJM stakeholders have been arguing for several months that the RTO should mandate vaccinations for all its employees. (See “COVID-19 Update,” PJM Operating Committee Briefs: Aug. 12, 2021.)

Ken Foladare of Tangibl Group said he understands that PJM must consult with its legal counsel over the regulations, but he said other large organizations already had mandated vaccines for their employees to come back to the office. Foladare said he found it “disappointing” that PJM had not taken similar measures to mandate vaccines.

Mike Bryson, PJM’s senior vice president of operations, said the RTO “continues to appreciate” the positions of stakeholders. Bryson said PJM CEO Manu Asthana has had discussions with senior leadership of member companies about their stance on vaccinations.

“We continue to evaluate the way our posture has been in the interest of protecting staff that has to come on campus,” Bryson said.

Adrien Ford of Old Dominion Electric Cooperative asked if there has been any change in PJM’s plan to have staff return to the Valley Forge campus given the rising cases of COVID-19. Staff were originally scheduled to start coming back to the campus by Sept. 1.

Carroll said PJM is evaluating the plan to return to campus “on a two-week basis” and have delayed the return until the middle of September. She said staff will receive another update on Sept. 13 to determine if they can return to campus or delay it for another two weeks.

“We are going to continue to evaluate on a two-week cycle,” Carroll said.