By Christen Smith
Stakeholders are insisting PJM should manage critical infrastructure planning, telling the Board of Managers that a proposed Tariff attachment from incumbent transmission owners would violate the RTO’s governing documents.
LS Power and American Municipal Power are leading the chorus of dissent arising among stakeholders over Attachment M-4, which would establish a confidential process for mitigating the risks related to transmission facilities on NERC’s CIP-014-2 list — a subset of supplemental projects with regional implications that some members believe belong under the purview of PJM.
“PJM is a creature of both its Operating Agreement and Tariff, and PJM must pursue sound public policy consistent with the legal confines of both its Operating Agreement and Tariff construct,” LS Power wrote in a letter to the board Wednesday. “The proposed M-4 proposal construct has glaring inconsistencies with the existing regional planning process and the PJM Operating Agreement, which is controlled by the members of PJM, not the transmission owners.”
CIP-014-2 requires TOs to identify and protect transmission stations and substations whose loss or sabotage could result in widespread instability, uncontrolled separation or cascading outages. In August, incumbent TOs proposed outlining a process for vetting transmission projects in order to remove the assets from the list.
Competitive transmission developers, consumer advocates, state commissions and other load interests argue the attachment is riddled with flaws that ultimately guarantee incumbent TOs control over a subset of complex supplemental projects with RTO-wide impacts, all under the guise of NERC-required confidentiality. (See PJM TO Tariff Filing Stirs Up Transparency Concerns.)
“Given the importance of these substations to regional and possibly interregional operations, there can be little question that the planning of those substations would be conducted through the PJM-administered regional transmission planning process,” AMP said.
PJM proclaimed its neutrality in the debate and only committed to the mutual agreement among all sectors that transmission planning should aim to eliminate the assets deemed critical within the RTO’s footprint, of which incumbent TOs say less than 20 exist. (See PJM Remains Neutral in CIP-014 Debate.)
But staff’s refusal to take sides hasn’t stopped stakeholders from taking their concerns straight to the board.
“We wish to emphasize that we can protect our critical energy infrastructure and maintain our national security, while also opening up the processes to build or upgrade such regional infrastructure to competition,” Securing America’s Future Energy (SAFE) said in a letter dated Oct. 3. “Contrary to the claim by the TOs, national security and market competitiveness are not mutually exclusive.”
SAFE further described a separate process for vetting CIP-014 projects as unnecessary and rejected the argument “that such transmission lines cannot or should not be allowed to be bid through a competitive process.”
In a Sept. 24 letter, the Organization of PJM States Inc. (OPSI) said that TOs should bring state commissions deeper into the CIP-014 planning process and specify how many critical facilities exist within each zone. The group also wants to know when these projects get factored into PJM’s Regional Transmission Expansion Plan and suggested TOs develop an assessment that balances cost and consequence reduction associated with each project.
The recommendations channel a problem statement and issue charged sponsored by the D.C. Office of the People’s Council that encourages stakeholders to develop a CIP-014 process inclusive of all sectors. The Planning Committee voted on Oct. 17 to postpone voting on the proposal pending a TO-led webinar to address questions. (See “Critical Infrastructure Vote Delayed,” PJM PC/TEAC Briefs: Oct. 17, 2019.)
Beyond PJM’s Control
The issue intersects with stakeholders’ overall concerns about supplemental project planning, which PJM insists it has little authority over. (See PJM TOs Sign off on Supplemental Project Deal.) Board Reliability Committee Chair Dean Oskvig said on Oct. 4 that the managers’ review of supplemental projects concluded that the RTO’s role “can be expanded in some areas but also remains appropriately constrained in others.”
“PJM does not have the authority or expertise to assume responsibility for asset management decisions or to determine when a facility is at the end of its useful life or otherwise needs to be replaced,” he said, referencing a failed AMP-sponsored problem statement and issue charge that wanted to open up these projects to regional planning. “Those decisions are the sole responsibility of the transmission owner.”
According to the Oct. 31 agenda for the Markets and Reliability Committee, AMP will present its failed problem statement and issue charge for a first read. (See “PJM Says No to End-of-Life Transparency Discussion,” PJM PC/TEAC Briefs: Sept. 11, 2019.)
Interim CEO Susan Riley echoed Oskvig’s sentiments in response to Consumer Advocates of the PJM States over what the organization called the unfettered growth of supplemental projects in comparison to necessary system upgrades planned by PJM.
“It is important for the PJM community to remain cognizant of where PJM’s authority and technical capabilities are positioned in relation to the planning and implementation of supplemental projects,” she said. “Identifying and verifying the need for supplemental projects, determining what goes into a transmission owner’s planning criteria and authorizing supplemental projects are responsibilities that extend beyond where PJM is situated as the regional transmission planner.”
In multiple responses addressing the CIP-014 process exclusively, Riley said the board understands the profound implications of these projects and said stakeholder comments provide constructive feedback for TOs in the ongoing development of their proposal.
“CIP-014 mitigation presents unique challenges related to the balance between significant risks imposed on customers and the transparency that has been at the foundation of the PJM planning process,” Riley told OPSI in a letter dated Oct. 8. “We discussed this matter at our last board meeting and commit to work with all stakeholders to develop a process that will allow the transmission owners to mitigate the risk associated with these critical facilities with PJM oversight.”