By Rory D. Sweeney

VALLEY FORGE, Pa. — A planned vote on a proposal to expand PJM stakeholder input on end-of-life (EOL) transmission projects was revised to a second “first” reading last week after it was agreed that revisions to the plan since it was initially discussed made it substantially different than originally proposed.

American Municipal Power and Old Dominion Electric Cooperative developed the proposal to give stakeholders “meaningful input” in transmission owners’ planning of baseline and supplemental projects for EOL facilities. It was introduced after members agreed, at AMP’s suggestion, to terminate the Transmission Replacement Processes Senior Task Force at the July Markets and Reliability Committee meeting. (See PJM Stakeholders End Tx Replacement Task Force.)

Since last month, however, proponents abandoned enough of the proposal that they agreed to reintroduce it. The proposal no longer requires alternative dispute resolution (ADR) before a project can go forward or that the stakeholder process occur prior to TOs finalizing their budgets. Also eliminated is the requirement for additional meetings outside the TOs’ approved processes, or detailed-criteria examples and how they would be applied.

The revised proposal presented to the MRC would require TOs to explain their criteria for determining EOL projects, provide details about the asset and its condition, and make them available for PJM to post 30 days before the first applicable meeting of the Regional Transmission Expansion Plan cycle. It would also define the EOL processes and offer three choices for where to include TO-specific procedures in PJM’s governing documents.

“We are concerned about the transparency … as well as the ability once we have that transparency to comment in a timely manner,” AMP’s Ed Tatum said. “We think [TOs] are doing a pretty good job when it comes to assessing your systems.”

In response to a question from LS Power’s Sharon Segner, he acknowledged that the proposal could “not really” halt a project.

“If a TO is bent on getting a project built, I’m not sure how any of this could stop it,” he said. “I think what it does is it gives the opportunity to fully discuss the need for a project.”

TOs “may not wish to respond” to input on a project and “we honor that,” he said.

The opportunity for ADR before projects are finalized was removed, he said, because “it’s very clear to me that PJM did not want that part of our proposal to be memorialized.”

It was proposed as manual changes, he said, because he felt that he wouldn’t be able to get the two-thirds majority approval necessary for including it in the Operating Agreement.

“We think this is the best we can do. That’s all I got,” he said.

“While we would like to get it in the OA, we’re not sure that it’s necessary,” AMP attorney Lisa McAlister said.

Consensus

PJM’s Ken Seiler said the RTO is optimistic that TOs and their opponents may be reaching consensus after a nearly two-year stalemate created by FERC ruling that TOs weren’t properly complying with their obligations under Order 890 to provide stakeholders with adequate information on supplemental projects — transmission expansions or enhancements not required for compliance with reliability, operational performance or economic criteria. PJM and its TOs submitted compliance filings in March, which they are implementing now, and refused to engage AMP and others in additional negotiations on the issues.

“We’re certainly committed to transparency around the entire process, and that’s including supplementals,” Seiler said.

AMP and PJM “have certainly moved much closer to where we think we need to be,” and they’ve also “closed the gap” with the TOs, he said. “We’re not there yet.”

PPL’s Frank “Chip” Richardson asked for patience as TOs implement their plan for complying with FERC’s show cause order earlier this year requiring them to increase stakeholder engagement in the development of supplemental projects. (See “TO Supplementals Discussion,” PJM PC/TEAC Briefs: Aug. 9, 2018.)

TOs plan to initiate stakeholder processes in the first and third quarter next year to review the implementation of the TOs’ new M-3 Tariff attachment, an outline of TOs’ responsibilities that had formerly been in the Operating Agreement. He suggested that the “appropriate place” to continue analyzing the process is in the Planning Committee, although a special session of the MRC was announced for Sept. 13 to discuss transmission replacement processes.

Seiler confirmed that the new processes under M-3 will begin their transition into the RTEP in September, but that it will take some operating experience with it before integration can be improved. He noted that supplemental, aging infrastructure and EOL projects are often incorrectly used interchangeably, which obscures meanings.

“We’ve got to get a little tighter with the words, a little more consistent with the words,” he said.

Exelon’s David Weaver reiterated calls for consensus. “We really got into a stalemate in the TRPSTF, [but] the TOs really do want to provide additional transparency,” he said.

Despite Weaver’s conciliatory words, not all TOs appear ready to support the AMP-ODEC proposal.

Duquesne Light’s Tonja Wicks criticized the proposal as having “a number of flaws” and said it’s “inappropriate to ask stakeholders to vote on specific language rather than concepts when the language isn’t defined.”She took issue with what she saw as the proposal imposing additional requirements and obligations on TOs through the manuals and outside of the OA, the latter of which she noted would require FERC approval to be implemented.

She accused Tatum of “forum shopping” for the proposal, a remark he dismissed as “a pejorative comment.”

“And it was,” she shot back.

Can High-voltage Still be Supplemental?

PJM Vice President of Planning Steve Herling indicated the potential for supplemental projects involving high-voltage lines to go through the RTEP analysis because they will likely become eligible for regional cost-sharing. (See DC Circuit Court Rejects PJM Tx Cost Allocation Rule.)

“It doesn’t tell us what to do, so we have to wait until FERC decides,” he said of the D.C. Circuit Court of Appeals’ decision to remand back to the commission its denial of cost sharing for high-voltage lines in PJM’s territory. “I believe that’s been FERC’s general direction, and we do whatever FERC tells us to do.”