PC Roundup: PJM Updates Stakeholders on FERC Orders

End-of-Life Issue Rejected at Planning Committee

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Planning Committee members received an update Sept. 12 about two recent, related Federal Energy Regulatory Commission orders that will change how PJM administers a particular category of transmission projects that are planned to address local planning criteria included in the transmission owner’s FERC Form 715.

Each transmission owner is required annually to submit its local planning criteria in the FERC Form 715 report.

First, in the order acting on remand from the U.S. Court of Appeals for the District of Columbia, FERC rejected a PJM Tariff revision that allocates the cost of Form 715 projects to a single transmission zone. In its order on remand, FERC determined that Form 715 project costs should be allocated regionally, consistent with other reliability projects.

As directed in the order, PJM is in the process of refiling changes to cost-responsibility assignments back to May 25, 2015, for the FERC 715 projects.

Associate General Counsel Pauline Foley said this is a complex undertaking, for which PJM plans to request a 30-day extension beyond the 30 days prescribed in the order.

Foley said she had no details yet on how any potential refunds identified in the reallocation process would be addressed.

Second, in the order to show cause issued, FERC reasoned that if the cost of a project is allocated more widely than a single transmission zone, it should not be exempted from PJM’s competitive proposal process. FERC asked PJM to either show cause why the proposal window exemption should remain, or remove it.

Foley said PJM will respond to the order to show cause to remove the exemption in order to plan Form 715 projects like other reliability projects. That means that Form 715 projects will be included in the competitive project proposal window, as appropriate, or will be subject to the same exemptions that apply to reliability projects. Those exemptions include projects that are: (i) of an immediate need – three years or less – without enough time to conduct a proposal window; (ii) 200 kilowatts or fewer; or (iii) needed to address substation improvements.

End-of-Life Issue Fails

Also at the meeting, members rejected a problem statement and issue charge brought to standardize the process used by transmission owners when deciding to remove or replace assets approaching the end of their operational life.

Despite having spent several hours discussing the issue at the August Planning Committee meeting, and tweaking the proposal following a robust discussion at the Sept. 12 meeting, only 39 percent of members voted in favor of the item. A vote of more than 50 percent is needed to move an item on for consideration by the Markets & Reliability Committee.

Comparative Cost Framework Progresses

Mark Sims, manager – Infrastructure Coordination.

Mark Sims, manager – Infrastructure Coordination, shared the latest updates on a comparative cost framework to help guide PJM planners in deciding among competitive transmission project proposals. The directive to develop the framework was initiated by stakeholders in 2018.

PJM held two workshops to present the new framework since the previous Planning Committee meeting, and decided to hold off from asking members to perform an official first read of proposed manual language until October, in order to have time to incorporate feedback.

PJM transmission owners, however, shared their preferred language, which will be considered in tandem with PJM’s proposal in October, when the issue will be on the agenda for a first read. In addition, the IMM also has proposed redlined manual language.

Sims did, however, present for a first read a revised fee structure for all competitive projects, regardless of whether they include voluntary cost cap provisions submitted by the developer.

No deposit would be required for projects expected to cost $1 million or less. All other projects would require a $5,000 non-refundable fee, plus additional project-study costs.