PJM s Do No Harm Analysis Process: PJM Planning Committee Discussion. American Municipal Power March 8, 2018

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PJM s Do No Harm Analysis Process: PJM Planning Committee Discussion American Municipal Power March 8, 2018

PJM s Changing RTEP Costs Structure Project drivers have changed. Is our process adequately dealing with this change?

Why Are We Interested in PJM s DNH Process & Analysis? Concerned that the increase in Supplemental projects is impacting PJM s RTEP process and scope Generally, consumers are able to rely on the PJM transmission planning process as set forth in the Operating Agreement and Manuals, to ensure a cost effective build out Not so with Supplemental Projects Absent additional analysis, PJM and its members are not able to ensure we are achieving efficient and economic transmission solutions There is concern that Supplemental Projects may preclude competitive transmission projects and/or generate baseline criteria violations in the near term planning horizon Appropriate to evaluate additional DNH analysis to ensure PJM continues to meet its transmission planning process and scope.

Mission PJM Mission Statement As the primary task, to ensure the safety, reliability and security of the bulk electric power system. Create and operate robust, competitive and non-discriminatory electric power markets. Understand customer needs and deliver valued service to meet those needs in a cost-efficient manner. Achieve productivity through the efficient union of superior knowledge workers and technology advances

Manual 14B RTEP Scope Highlights Manual 14B Highlights: (Page 58) The RTEP will: (Note: Not shown completely)

Manual 14B RTEP Scope Highlights Manual 14B Highlights: (Page 58-59) The RTEP will not:

PJM Do No Harm Assessment Current Process PJM s Current Analysis: Supplemental & Baseline proposals are assessed to ensure the proposal does not result in new criteria violations on the system. What happens if it does create an overload that PJM identifies? Assessment ensures adherence to PJM & TO s FERC 715 planning criteria. Applies bright line thresholds. Thermal Loading, Voltage Magnitude & Voltage Deviations, etc Only tests on PJM developed cases Powerflow analysis accounts for the following: Summer peak conditions, Light Load conditions, Winter peak conditions Established Firm Point Point Transmission Service Established Firm TWR s & TIR s Established CBMs ASPEN analysis is conducted on 2 & 5 year out cases Includes FSA units?

Concerns With Current Process When there were fewer Supplemental Projects, the current Do No Harm was sufficient With the proliferation of Supplemental Projects not planned by PJM, we are not getting a comprehensive understanding of Supplemental Project impacts Applies to TO Local Baseline & Supplemental projects Analysis is only applied on PJM developed models Lack of Transparency Models not assembled by PJM TO developed models with no review process Generation dispatches differing from RTEP models Load profiles differing from RTEP models Projects only reviewed for Do No Harm can impact the RTEP s ability to meet its scope. Avoiding unnecessary duplication of facilities? Avoiding unreasonable costs? Providing alternative means for meeting region needs?

Concerns With Current Process Bright line analysis does not assess a project s total impact to the system PJM DNH process cannot enable consumers to see that TO s assessments of stakeholders alternatives are accurate or unbiased. Analysis provides no insights to the appropriate sizing of a facility. This could potentially impact PJM s Resilience efforts. http://cigre-usnc.tamu.edu/wp-content/uploads/2017/10/2-cigre-grid-of-the-future- Cascading-Trees-EB1.1.pdf Analysis cannot enable consumers to see consistent application of individual TO criteria or need identification Analysis does not always align with PJM RTEP windows No deadline or cutoff dates RTEP window length is predetermined TO Issues not always disclosed prior to PJM windows Does not account for economic impacts

Process Improvement Considerations Standardize timelines for TO Local area project needs and proposal submissions: Clearly establish start and stop dates for TO needs & proposal submissions. Align start and stop dates to ensure coordination with competitive windows Will aid in preventing supplemental projects from preventing competition in the PJM open window process. Standardize the data reporting requirements for all project submissions Require reporting of all scenarios and models used to justify and size project facilities. Including considerations not covered by TO FERC 715 documentation. Include reporting of applicable TO & PJM standards & documentation used in project justifications. PJM process that allows for formal submission & PJM review of alternative proposals Ensure a non-biased third party reviews the proposed alternative solutions. Process for stakeholders to report criteria violations & solutions for PJM to analyze. None competitive windows (Stakeholders not interested in owning the alternative project)

Process Improvement Considerations Process to verify the project is addressing the criteria/needs outline in its justification Not verifying need, verify the solution to the need PJM verification that projects are assigned based on FERC accounting rules Slide 31 & 32 (Distribution transformer being booked as transmission) http://www.pjm.com/~/media/committees-groups/committees/srrtepw/20180309/20180309-reliability-analysis-update.ashx Initiate a way for Stakeholders to obtain a list of limiting elements associated with a facility Lists will increase transparency about what is overloading and what needs to be done to address that overload. Stakeholders can clearly understand what might limit their proposal and the cost associate with addressing the limit.

Considerations for Analysis Improvements Cross vet baseline and supplemental drivers/needs for interdependence Example: Line A is overloading for contingency X. An adjacent Line B needs rebuilt due to condition. Rebuilding Line B to double circuit could eliminate overload on Line A. Reporting facilities loading below 100% of thermal or interrupting capability: Identify & report highest loading FERC 715 scenario Identify & report the load of facilities being directly impacted by a proposal Example: Transmission line being replaced due to performance, condition, and/or risk Identify & report the loading of area facilities that could be indirectly impacted by a proposal Example: Transmission line loading changing by a defined % and/or increasing to a % of its maximum capability Extend analysis to economic studies & modeling Quantify & report impacts of proposals on previously approved economic projects Assess proposals for impacts to the cost allocation of previously approved projects Analyze impacts to production cost, load energy payments, capacity cost, load capacity payments

Considerations for Analysis Improvements Conduct a Look Back Analysis to determine if reliability driver is not longer a issue. Determine if a proposal would eliminate previously approved Reliability violation driven projects. Assess proposals for impacts to the cost allocation of previously approved projects Identify and report any FSA resources (generation, storage) that addresses the need for a proposal Similar to generation sensitivities (page 64) process outlined in Manual 14B Consider in FSA generation in alternative analysis Identify storage resources that could be applied as transmission to resolve a need