PC Delays Critical-Infrastructure Issue Charge

Sectors agree item will be informed by Nov. 22 transmission owner webinar


The Planning Committee voted Nov. 14 to wait until its Dec. 12 meeting to consider an issue charge to examine how PJM’s planning process should incorporate the removal of highly critical substations.

By an acclamation vote, with three objections and two abstentions, the committee decided that the item should be delayed until after a Nov. 22 webinar sponsored by PJM Transmission Owners (TOs). The webinar, set for 3–5 p.m., will provide education about the TOs’ Aug. 12 notice of intention to file a new Attachment M-4 to the PJM Tariff for the planning of certain mitigation projects.

The planning involves no more than 20 facilities that have been identified as highly critical under the North American Electric Reliability Corporation’s (NERC) Critical Infrastructure Protection guidance. These facilities, “if rendered inoperable or damaged as a result of a physical attack could result in instability, uncontrolled separation or cascading within an interconnection.”

Mitigating the critical nature of these facilities is the responsibility of the TOs. However, stakeholders representing other sectors point to PJM’s obligation to engage in an open and collaborative regional transmission planning process in requesting transparency in their planning.

Transmission Projects – a Hot Topic

The conversation dovetails with a larger discussion about which transmission projects should be open to competitive developers under Order 1000 from the Federal Energy Regulatory Commission instead of assigned to incumbent TOs.

The issue charge, brought by the Office of the People’s Counsel for the District of Columbia, is designed to consider whether changes should be made to PJM’s manuals, Tariff or Operating Agreement regarding the planning of current and future so-called CIP-014 projects.

It recognizes the sensitivities inherent in projects requiring a physical security plan, but suggests a balance may be achieved between confidentiality and member collaboration. In addition, the accompanying problem statement notes the importance of preventing the creation of future critical facilities.

“While the Aug. 12 notice states that the number of [critical mitigation projects] is currently no greater than 20 facilities, absent appropriate planning, future threat assessments, as well as changing NERC requirements, could mean that additional facilities will be subject to existing or future expanded NERC criteria,” the problem statement reads. “Therefore, it is appropriate for the stakeholders to hold discussions focused on ensuring that the appropriate planning protocols are put in place.”

Ken Seiler, Vice President – Planning, said the Nov. 22 meeting would be educational, potentially informing modifications to the issue charge and/or the TOs’ M-4 filing.

“We would certainly support a modified problem statement around this, looking at preventing these issues occurring the future,” he said. “The webinar will clarify any remaining questions out there – ideally, how to prevent these issues from occurring, and how do we fix the issues we have?”

New Proposal Fee Structure Endorsed

Also at the Nov. 14 meeting, the Planning Committee endorsed a new fee structure for proposed transmission projects as PJM embraces a new cost commitment evaluation process initiated by members in May 2018.

Currently, PJM employs a flat-fee structure, charging $5,000 for projects from $20 million to $100 million and $30,000 for proposals greater than $100 million.

“The fees that we take in do not cover the evaluation costs and will not cover evaluation costs going forward,” Mark Sims, Manager – Infrastructure Coordination, told the committee.

The change to the Operating Agreement calls for a $5,000 deposit for all projects, except those expected to cost less than $5 million. PJM will estimates the costs of project studies and invoice the sponsor, keeping them apprised of any cost increases along the way. At the end of the evaluation, PJM will issue a final invoice or refund.

The new structure was endorsed by an acclamation vote with one objection.

Comparative Cost Framework Added to Manual 14F

In a related item, members endorsed adding a new section, Comparative Cost Framework, to Manual 14F: Competitive Planning Process.

The new language, which needed a simple majority to be endorsed, was favored by a vote of 77 percent, following a lengthy discussion over the role of the independent market monitor in the competitive transmission planning evaluation process.

Planning, Operating Committees Swap Meeting Days

Also announced at the meeting was a new 2020 meeting day for the committee.

In the new year, the Planning and Transmission Expansion Advisory committees will meet on Tuesdays. The Operating Committee will move its meetings to Thursdays.