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PJM Immediate Need Exception to Competitive Transmission Process

Paul Dumais's picture
CEO Dumais Consulting

Owner and CEO of Dumais Consulting ( which provides expert ratemaking services to energy companies. Dr. Dumais is a ratemaking and regulatory expert who specializes on...

  • Member since 2018
  • 149 items added with 114,544 views
  • Jul 8, 2020

FERC recently investigated the immediate need reliability exceptions to competitive processes in the OATT of ISO-NE, SPP and PJM.  FERC found that ISO-NE and SPP are compliant with their OATTs and that there is no reason to change the immediate need exception.  Though finding no need to change the immediate need exception for PJM, FERC found that PJM has not been operating consistent with the OATT criteria for the immediate need exception.  FERC found that:

  1. PJM does not comply with the requirement that it separately identify and then post an explanation of the reliability violations and system conditions for which there is a time-sensitive need, with sufficient detail of the need and time-sensitivity.  FERC ordered PJM to provide the reliability violations and system conditions for which there is a time-sensitive need, with sufficient detail of the need and time-sensitivity.  For example, PJM may provide details regarding the specifics of the violation; why the violation arose; when it first occurred; the implications of the violation in terms of generation, load, congestion, etc.; the severity of the problem; and expectations for the violation’s severity in the future (i.e., will the problem get worse or have a cascading effect at a later point in time);
  2. PJM does not comply with the requirement that it must provide to stakeholders and post on its website a full and supported written description explaining:  (1) the decision to designate an incumbent transmission owner as the entity responsible for construction and ownership of the project, including an explanation of other transmission or non-transmission options that the region considered; and (2) the circumstances that generated the immediate reliability need and why that need was not identified earlier.  FERC ordered that PJM expound on its description to support the designation of its immediate need reliability projects, specifically addressing the time-sensitive nature of the need, why the incumbent transmission owner was selected, alternatives considered, and why the need was not identified earlier.  For additional transparency, PJM could also describe how it is making its determination that a full or shortened proposal window is infeasible by fully explaining how it considers the nature of the reliability criteria, the nature and type of potential solution required, and the projected construction time for a potential solution to the type of reliability criteria to be addressed.  PJM could also explain the urgency of the violation and compare it to the typical timeline of a standard or shortened competitive proposal window, explaining how the proposal window would delay the solution further.
  3. PJM does not comply with the requirement that stakeholders must be permitted time to provide comments in response to the project description, as providing three days for stakeholders to review immediate need reliability project materials before providing comments at stakeholder meetings is not sufficient.  FERC ordered PJM to designate a specific time period greater than three days for stakeholders to provide comments in response to the project description.  FERC also ordered PJM to post on its website all stakeholder comments and answers, whether provided in writing or submitted verbally at TEAC meetings, regarding immediate need reliability projects.

FERC order PJM to file a compliance filing addressing these findings. 

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