PJM files resilience response at FERC


PJM today filed its response to the Federal Energy Regulatory Commission administrative proceeding (AD18-07) to examine resilience on the bulk electric system through regional transmission operators and independent system operators.

Through its response, PJM outlines the considerable steps it and its stakeholders have undertaken (or are actively developing) to enhance the resilience of the PJM bulk electric system.

The comments detail specific actions that the FERC (in some areas working with other federal and state agencies) could undertake to enhance overall resilience of the bulk electric system, not just in the PJM region but potentially across the nation.

Key Themes of PJM’s Response

  • PJM asked the FERC to refine its proposed definition of resilience and to continue to focus on efforts that address planning for and mitigating potentially disruptive high impact low frequency events.
  • PJM will have a leadership role in identifying potential risks to the resilience of the regional electric system and in planning for and mitigating (including enhanced restoration activities) the effects of such disruptive events.
  • PJM asked FERC:
    • For a process to verify and authenticate its vulnerability and threat assessments based on information available to the federal government, but which cannot necessarily be disclosed given national security concerns.
    • To clarify that resilience can drive planning upgrades under regional transmission organization/independent system operator (RTO/ISO) planning processes and to provide additional processes for improving resilience through changes to transmission planning, emergency operations, and market design.
    • For a period of stakeholder engagement to develop new criteria and a timeline to submit these changes to the FERC.
  • While PJM acknowledges there has been progress in electric-gas coordination, there is still room for improvement in increasing communication and coordination. For example, greater cooperation in real time modeling the impact of disruptions would be beneficial, as well as greater coordination in planning for restoration.
  • The resilience of wholesale electricity supply is best addressed through markets.

Definition of Resilience

In its broadest sense, resilience involves preparing for, operating through, and recovering from events that impose operational risk, including but not limited to high-impact, low-frequency events.

The likelihood of high-impact, low-frequency events is generally unknown or extremely difficult to quantify. In addition, the consequences or impacts of high-impact, low-frequency events – although assumed to be intolerably high in terms of both human and economic costs – are difficult to quantify.

Prudent resilience efforts to address verifiable vulnerabilities and threats are still worthwhile despite the uncertainty and can be effectively and efficiently managed thorough through a range of complementary analyses and strategies.