UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`One-Time Informational Reports on
`Extreme Weather Vulnerability
`Assessments
`
`Climate Change, Extreme Weather, and
`Electric System Reliability
`
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`)
`)
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`)
`)
`
`Docket Nos. RM22-16-000
`
`AD21-13-000
`
`JOINT INFORMATIONAL REPORT OF
`PJM INTERCONNECTION, L.L.C. AND
`PARTICIPATING PJM TRANSMISSION OWNERS
`ON EXTREME WEATHER VULNERABILITY ASSESSMENTS
`
`Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”)
`
`Order No. 897,1 PJM Interconnection, L.L.C. and certain participating transmission owning
`
`members of PJM2 hereby jointly submit this Informational Report on Extreme Weather
`
`Vulnerability Assessments (“Joint Informational Report”). As explained in Order No. 897, an
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`extreme weather vulnerability assessment is “any analysis that identifies where and under what
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`conditions jurisdictional transmission assets and operations are at risk from the impacts of extreme
`
`1 One-Time Informational Reports on Extreme Weather Vulnerability Assessments Climate Change, Extreme Weather,
`and Electric System Reliability, Order No. 897, 183 FERC ¶ 61,192, at PP 47-50 (2023) (“Order No. 897”).
`2 For purposes of this Joint Informational Report, the “Participating Transmission Owners” include the following: The
`Dayton Power and Light Company d/b/a AES Ohio (“AES Ohio”); AMP Transmission, LLC (“AMP Transmission”);
`Dominion Energy Services, Inc. on behalf of Virginia Electric and Power Company d/b/a Dominion Energy Virginia
`(“Dominion”); Duquesne Light Company (“Duquesne” or “DLC”); East Kentucky Power Cooperative (“EKPC”);
`Exelon Corporation on behalf of its affiliates Atlantic City Electric Company, Baltimore Gas and Electric Company,
`Commonwealth Edison Company, Delmarva Power & Light Company, Potomac Electric Power Company, and PECO
`Energy Company (collectively, “Exelon”); FirstEnergy Service Company, on behalf of its affiliates American
`Transmission Systems, Incorporated, Jersey Central Power & Light Company, Mid-Atlantic Interstate Transmission
`LLC, West Penn Power Company, The Potomac Edison Company, Monongahela Power Company, Keystone
`Appalachian Transmission Company, and Trans-Allegheny Interstate Line Company (collectively, “FirstEnergy”);
`Linden VFT, LLC (“Linden VFT”); NextEra Energy Transmission MidAtlantic (“NEET MidAtlantic”), Old
`Dominion Electric Cooperative (“ODEC”); PPL Electric Utilities Corporation (“PPL EU”); Public Service Electric
`and Gas Company (“PSE&G”); Rockland Electric Company (“RECO” or “Rockland”); Silver Run Electric, LLC
`(“Silver Run”); Southern Maryland Electric Cooperative, Inc. (“SMECO”); and Wabash Valley Power Association,
`Inc. d/b/a Wabash Valley Power Alliance (“WVPA”).
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`weather events, how those risks will manifest themselves, and what the consequences will be for
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`system operations.”3
`
`The Commission directed transmission providers to file a one-time informational report on
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`whether, and if so how, they establish a scope, develop inputs, identify vulnerabilities and exposure
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`to extreme weather hazards, and estimate the costs of impacts in their extreme weather
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`vulnerability assessments, as well as how they use the results of those assessments to develop risk
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`mitigation measures.4 The Commission further stated that “a transmission owner member of [a
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`Regional Transmission Organization (“RTO”)/Independent System Operator (“ISO”)] and an
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`RTO/ISO may satisfy its reporting requirement by filing a joint one-time informational report
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`without needing to also file separate one-time informational reports.”5 Accordingly, PJM and the
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`Participating Transmission Owners submit this Joint Informational Report.6
`
`I.
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`JOINT INFORMATIONAL REPORT
`
`Q1) As a threshold matter, state whether the transmission provider conducts extreme weather
`vulnerability assessments, and if so, how frequently it conducts those assessments.
`
`
`PJM Response to Question 1
`
`PJM recognizes that extreme weather presents challenges to the reliable operation of the PJM
`System. PJM strongly believes that action needs to be taken to ensure that the industry is able to
`prepare for, withstand and/or respond to extreme weather events and other system conditions that
`present current and future reliability- and resilience-related concerns.7 While PJM does not
`
`                                                            
`3 Order No. 897 at P 52.
`4 Id. at P 3.
`5 Id. at P 48.
`6 On August 11, 2023, at a meeting of the PJM Transmission Owners Agreement-Administrative Committee (“TOA-
`AC”) (“August 2023 Meeting”), PJM outlined an approach pursuant to which interested PJM Transmission Owners
`could work with PJM to develop a joint informational report. See https://www.pjm.com/-/media/committees-
`groups/committees/toa-ac/2023/20230811/20230811-agenda.ashx. Following
`the August 2023 Meeting,
`the
`transmission owners listed in footnote 2 elected to submit a joint report with PJM.
`7 Indeed, PJM has urged the Commission to adopt a common definition of resilience and a specific resilience planning
`driver for grid enhancements, applicable to all planning entities. See, e.g., Building for the Future Through Electric
`Regional Transmission Planning and Cost Allocation and Generator Interconnection, Initial Comments of PJM
`Interconnection, L.L.C., Docket No. RM21-17-000, at 11-25 (Aug. 17, 2022) (“PJM Initial NOPR Comments”).
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`currently perform extreme weather vulnerability assessments as defined in Order No. 897, PJM
`describes below its actions to date to improve transmission system resilience, including through
`transmission planning, market-related studies and analyses, and operations, in preparation for
`extreme weather events.
`
`
`Addressing Extreme Weather from an Operations Perspective
`
`
`Due to the exposed nature of power system infrastructure to severe weather conditions, PJM
`closely monitors both short- and long-term weather patterns. PJM has staff meteorologists who
`analyze weather conditions and terrestrial hazards and work closely with system operators to
`inform system operations decisions. PJM currently prepares for weather events by delaying
`scheduled outages, returning equipment being maintained to service and entering into conservative
`operations to increase operational awareness and market participant and transmission owner
`coordination.
`
`PJM and its member companies plan throughout the year for winter and summer conditions. For
`instance:
`
` Summer and Winter Period Studies – PJM Operations Assessment Task Force
`(“OATF”) conducts a study for the summer and winter “study period.”8 The purpose of the
`study is to analyze a representation of the PJM system with the transmission and generation
`configuration approximating the conditions expected to exist during the study period. The
`study focuses on the current PJM RTO boundary and the boundaries of any applicable
`external companies that will be integrated into PJM prior to the study period at the time the
`scope for the study was drafted by PJM.
`
` Cold Weather Advisory/Alert – In advance of the mandatory NERC Winterization
`Standard becoming effective on April 1, 2023, PJM established the Cold Weather
`Advisory. A Cold Weather Advisory provides an early notice that forecast temperatures
`may call for a Cold Weather Alert. The early notification of an advisory is intended to
`provide PJM members ample time to gather information required by NERC standards
`EOP-011-3, Emergency Preparedness and Operations, IRO-010-4 RC Data Specification
`and Collection, and TOP-003-5 Operational Reliability Data. Members are to take any
`necessary precautions to prepare generating facilities for cold weather operations. PJM
`attempts to issue the advisory as far in advance as possible, typically within three to five
`days, but given fluctuating and changing weather forecasts, advisories could be issued up
`to 24 hours in advance.
`
`
`
`
`
` Hot Weather Alert – PJM may issue a Hot Weather Alert to prepare personnel and
`facilities for extreme hot and/or humid weather conditions that may cause capacity
`requirements/unit unavailability to be substantially higher than forecasted are expected to
`persist for an extended period.
`
`                                                            
`8 See PJM, Manual 38: Operations Planning, Attachment A (rev. 16, Jan. 25, 2023), https://www.pjm.com/-
`/media/documents/manuals/m38.ashx.
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` Generating Unit Reactive Capability Verification – PJM verifies every generator’s
`reactive capability in advance of each winter season. This is used to ensure that real-time,
`day-ahead and seasonal analysis accurately reflects the capability of generators to support
`system voltage.
`
` Cold Weather Checklist – PJM has incorporated into its manuals an extensive pre-winter
`preparation checklist. This checklist, directed to generators, covers a variety of
`winterization actions to be undertaken. Generators report the results of their analysis to
`PJM through PJM’s electronic eDART reporting system. Even though the reporting is
`voluntary today, PJM has received a high level of generator compliance, particularly from
`those units that otherwise could face the most weather-related impacts.
`
` Seasonal Fuel Inventory and Emissions Survey – PJM surveys generators about their
`fuel supply and delivery details, fuel inventory and emissions limitations. This information
`is required for reliable operations planning purposes and enhances PJM’s situational
`awareness in preparation for extreme weather events.
`
` Cold Weather Exercise - PJM recommends that generators that have not run on their
`primary or alternate fuel in the preceding eight weeks leading up to December 1 should
`self-schedule a test to run during the month of December when temperatures are below 35
`degrees.
`
` Annual NERC Winter Readiness Webinar – Prior to each winter season, PJM
`participates in NERC’s Annual Winter Preparation Webinar to review and refresh on
`lessons learned, review the NERC Reliability Guideline and Generating Unit Winter
`Weather Readiness, and discuss other winter items of interest.
`
` Coordination With Neighboring Reliability Entities – PJM coordinates winter system
`readiness with its neighboring systems to include New York Independent System Operator,
`Inc. (“NYISO”), Midcontinent Independent System Operator, Inc. (“MISO”), Northeast
`Power Coordinating Council, Inc. (“NPCC”), and the Virginia-Carolinas (“VACAR”)
`region.
`
` Emergency Procedures Drill – PJM conducts a winter emergency procedures drill prior
`to winter operations to exercise emergency procedures and communications with PJM
`operations, member company operations teams and state emergency management teams.
`
`
`Through outreach to the PJM Operating Committee and System Operations Subcommittee, all
`members are also encouraged to review and implement recommendations regarding preparedness
`for extreme weather events.
`
`In addition to the above, PJM recently released its Winter Storm Elliott Report, which reviews the
`events up to and during Winter Storm Elliott,9 assesses the actions of PJM and its members during
`                                                            
`9 PJM, Winter Storm Elliott Event Analysis and Recommendation Report (July 17, 2023), 20230717-winter-storm-
`elliott-event-analysis-and-recommendation-report.ashx.
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`those times, and looks for lessons learned and associated recommendations to help improve grid
`reliability. The Winter Storm Elliott Report contains 30 recommendations that are broadly focused
`on:
`
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` 
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`
`
` Addressing winter risk with enhancements to market rules, accreditation, forecasting and
`modeling;
`
`Improving generator performance through winterization requirements, unit status reporting
`and testing/verification;
`
` Tackling gaps in gas-electric coordination, including timing mismatches between gas and
`electric markets, the liquidity of the gas market on weekends/holidays and the alignment
`of the electricity market with gas-scheduling nomination cycles;
`
` Evaluating how the Performance Assessment Interval (“PAI”) system of rewarding or
`penalizing generator performance is impacted by exports of electricity to other regions,
`whether excusal rules can be simplified, whether PAI triggers need to be refined, and if the
`contributions of Demand Response and Energy Efficiency are accurately valued; and
`
` Pursuing opportunities with generation owners, other members and states to improve
`education, drilling and communication regarding PJM’s emergency procedures, Call for
`Conservation and PAIs.
`
`Many of these recommendations are currently pending before the Commission10 or are being
`addressed through other forums.
`
`
`
`In order to ensure reliable transmission service, PJM prepares an annual Regional Transmission
`Expansion Plan (“RTEP”) to identify system reinforcements that are required to meet North
`American Electric Reliability Corporation (“NERC”) Reliability Standards, PJM reliability
`planning criteria, and Transmission Owner reliability criteria. PJM does not currently perform
`extreme weather scenario analyses as part of the RTEP analyses, per se. However, PJM currently
`plans to address extreme weather events to the extent such events are considered as one of a set of
`drivers of High Impact, Low Frequency (“HILF”) events. In particular, the following NERC
`Reliability Standards assess HILF events to some extent:
`
`
`Addressing Extreme Weather from a Planning Perspective
`
` NERC Standard TPL-001-5.1: Transmission System Planning Performance Requirements,
`in particular, Table 1;
`
`                                                            
`10 See PJM Interconnection, L.L.C., Proposed Enhancements to PJM’s Capacity Market Rules - Market Seller Offer
`Cap, Performance Payment Eligibility, and Forward Energy and Ancillary Service Revenues, Docket No. ER24-98-
`000 (Oct. 13, 2023); PJM Interconnection, L.L.C., Capacity Market Reforms to Accommodate the Energy Transition
`While Maintaining Resource Adequacy, Docket No. ER24-99-000 (Oct. 13, 2023) (collectively, October 2023
`Filings). In the October 2023 Filings, PJM submitted proposed capacity market reforms designed to support reliability
`of the electric grid now and in the future amid increasingly extreme weather and a changing generation fleet.
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` NERC Standard CIP-014-3: Physical Security; OATT Attachment M-4 Planning Process;
`
` NERC Standard TPL-007-4: Transmission System Planned Performance for Geomagnetic
`Disturbance (GMD).
`
`
`In addition, PJM also adapts other existing analyses and processes, such as those described below,
`to derive conclusions about the ability of the PJM Bulk Electric System (“BES”) to withstand a
`HILF event:
`
`
` Conventional RTEP analysis deliverability studies evaluate 90/10 weather/temperature-
`driven load levels that emulate stressed system test conditions.
`
`
`
` Fuel Assurance Studies that look at the ability of PJM to withstand disruptions to power
`output caused by the availability of fuel, e.g., natural gas pipeline delivery.
`
` Cascading tree analyses which evaluate an extreme event that encompasses a risk that may,
`after some number of additional cascading events, lead to system collapse (i.e., blackout).
`Major blackouts are usually caused by low-probability, high-consequence events.
`
` Planning procedures used by the PJM Transmission Owners as set forth in Attachment M-
`4 to PJM’s Open Access Transmission Tariff (“Tariff”) to mitigate the risk associated with
`critical transmission stations and substations identified pursuant to NERC reliability
`standard CIP-014-4.
`
` A Critical Substation Planning Analysis criteria that PJM has adopted with the goal of
`avoiding the creation of new Critical Substations. Although the criteria is not specifically
`driven by extreme weather, it could mitigate the impact of extreme weather to the extent
`such weather events results in total loss of a substation and its connecting transmission
`lines.
`
`PJM is also actively engaged through the Transmission and Substation Subcommittee in the
`development of transmission system hardening practices, including design philosophy, design
`requirements, and operating practices for grid enhancements, to prepare for extreme weather
`events.11
`
`PARTICIPATING TRANSMISSION OWNERS’ RESPONSES:
`
`AES Ohio Response to Question 1
`
`AES Ohio conducts extreme weather analysis as part of its annual system analysis.
`
`
`                                                            
`11 See PJM’s Recommendations of Resilience and System Hardening Practices, https://pjm.com/-
`/media/planning/design-engineering/maac-standards/recommendations-of-resilience-and-system-hardening-
`practices.ashx.
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`AMP Transmission Response to Question 1
`
`AMP Transmission Planning does not perform extreme weather scenario analysis as part of its
`yearly studies. AMP Transmission does not own or operate any generation. In addition, AMP
`Transmission does not have any retail or wholesale load directly connected to its transmission
`system.
`
`Dominion Response to Question 1
`
`Yes, Dominion Energy Virginia - Electric Transmission (DEV-ET) has a continuous process for
`analysis and asset management focused on extreme weather. In 2015, DEV-ET’s engineering staff,
`along with industry colleagues from IEEE and CIGRE, performed a vulnerability assessment on
`natural and manufactured events as part of our effort for maintaining safety, reliability, and
`resiliency of the Bulk Electric System. There was a smaller scope assessment performed in 2021
`and as a result, DEV-ET has enhanced their construction, maintenance, and operating standards to
`harden the transmission system. In addition, the DEV-ET System Operations Center maintains,
`performs drills, and operates from the Dominion Energy-PJM Coordinated Emergency Plan which
`covers emergency procedures, communications, coordination, and other emergency activities in
`an extreme weather event.
`
`Duquesne Response to Question 1
`
`Transmission system Planning Assessments of the Bulk Electric System are federally required in
`accordance with the NERC Reliability Standards and in particular TPL-001-5.1. The purpose of
`TPL-001-5 Standard is to establish planning performance requirements to develop a BES that will
`operate reliably over a broad spectrum of System conditions and following a wide range of
`probable Contingencies. DLC is a member of the PJM Regional Transmission Organization
`(“RTO”), and PJM is the NERC registered Planning Coordinator (“PC”) and Transmission Planner
`(“TP”) for DLC. Per the Applicability section of TPL-001-5, PJM is responsible for performing
`the required Planning Assessments for the DLC transmission system as documented in PJM
`Manual 14B and PJM Manual 38.
`
`DLC does not perform Planning Assessments to specifically evaluate vulnerabilities associated
`with defined extreme weather hazards. DLC does however independently conduct annual long
`term and seasonal transmission assessments to ensure the reliability of the entire DLC transmission
`system.
`
`DLC transmission assessments consider all the contingencies identified in TPL-001-5.1 including
`the loss of various BES elements (e.g., lines, generating units, towers, etc.) that represent
`conditions which could be experienced during extreme weather events (e.g., high winds, severe
`storms, landslides, flooding, etc.). The transmission assessment also considers a sensitivity study
`where higher than average loading conditions are experienced across the DLC transmission system
`(ex: 90/10 loading forecast).
`
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`EKPC Response to Question 1
`
`EKPC performs an annual transmission-planning assessment of the performance of its
`transmission system versus its transmission-planning criteria at a 1-in-10 load level during both
`summer and winter peak-load conditions. This assessment is performed by developing power-flow
`models of expected system conditions at these load levels and reviewing the model to determine
`if any voltage and/or thermal violations exist over the 15-year planning horizon. EKPC does not
`require voltages and power flows to remain within criteria limits during contingency conditions,
`so this assessment has historically only been performed for normal (“N-0” -- all facilities in
`service) conditions. In 2023, EKPC also utilized these extreme-loads models to perform an N-1
`(single-contingency) analysis of the performance of its system at a 1-in-10 load level in order to
`obtain information regarding potential areas of concern on the system that could potentially drive
`future mitigation measures.
`
`As a transmission-owning member of PJM, EKPC participates, as opportunities are available
`and/or necessary, in extreme-weather vulnerability assessments performed by PJM. EKPC reviews
`information developed by PJM through these assessments to understand potential vulnerabilities
`on the EKPC system.
`
`EKPC does not perform other extreme-weather vulnerability assessments as contemplated in this
`questionnaire as a normal course of business activity.
`
`Exelon Response to Question 1
`
`Maintaining energy system reliability is of paramount importance to Exelon, and weather-related
`risk preparedness is always a key focus area for the company. As a transmission facilities owner,
`Exelon prepares on an ongoing basis for adverse impacts of severe weather, including extreme
`weather, through methods such as the development and performance of the seasonal readiness plan
`programs. The seasonal readiness plan is a key risk mitigation tool for severe weather events on
`the system and is designed to support reliable performance during all operating periods. Prior to
`each winter and summer season, Exelon focuses on three elements of seasonal readiness:
`1) organizational preparedness by discipline, 2) system material condition readiness, and
`3) emergency response posture.
`
`Exelon continuously reviews and accordingly updates transmission system design standards to
`improve system reliability and resiliency during extreme weather. For example, substation design
`standards have been updated to improve flood resiliency while transmission line standards have
`been updated to reduce effects of ice-bridging on jumpers, to specify the use of anti-cascade
`structures within long segments, and to replace wood structures with stronger class steel poles.
`
`Exelon also coordinates and cooperates with PJM, the RTO and transmission provider, on the
`performance of operations and long-term planning assessments and seasonal preparedness
`activities. Such coordination includes, but is not limited to, participation in the PJM OATF and
`support for the development of the PJM RTEP. Through the RTEP process, planning studies are
`performed in accordance with NERC, PJM, and Exelon planning criteria. Included in Exelon’s
`planning criteria are scenarios reflecting more severe load forecasts (driven by extreme heat or
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`extreme cold) with a 10% probability that the actual peak load will be higher than the level
`forecasted in that year. PJM performs assessments and activities in accordance with its
`responsibilities as the registered Balancing Authority, Reliability Coordinator, Transmission
`Operator, Planning Coordinator, and Transmission Planner for the Exelon utilities.
`
`
`Going forward, Exelon is expanding its adaptation planning efforts to better incorporate resilience
`considerations, including changes to the types of weather conditions that may challenge our
`systems now or in the future. Exelon is working to build its adaptation planning toolkit through
`our current involvement in the Electric Power Research Institute Climate READi program that
`builds on separate work we have done through our founding member participation12 with the DOE
`Partnership for Energy Sector Climate Resilience. The Partnership for Energy Sector Climate
`Resilience is a voluntary initiative that aims to develop a framework to identify optimal resilience
`and adaptation investments in the power system in the context of climate and extreme weather
`risk. Through Climate READi, Exelon participates in industry-led efforts to convene global
`thought leaders and researchers to develop a comprehensive, integrated approach to managing
`physical climate risk. The adaptation planning toolkit will also incorporate work conducted
`through our ongoing partnership with Argonne National Lab including the recent collaboration
`with ComEd on a Climate Risk and Adaptation Outlook report.13 This report specifically evaluated
`future climate risks to ComEd’s infrastructure and operations.
`
`In addition, some of the ways Exelon is expanding its efforts to adapt to impacts from climate
`change, including extreme weather, include:
`
`Incorporating projections of changing climatic conditions into our engineering standards
`and existing system material condition assessments to facilitate for improved infrastructure
`planning.
` Working with the communities where we operate to understand their climate change
`response plans so that we can adapt and evolve our risk mitigation approaches in
`coordination with those efforts.
` Supporting development of a common methodology for applying potential impacts to
`utility infrastructure planning, as well as improvements in the tools used to evaluate the
`benefits of alternative resilience investments.
`
`
`FirstEnergy Response to Question 1
`
`FirstEnergy does not conduct vulnerability assessments explicitly labeled “extreme weather
`vulnerability assessment.” However, within its annual reliability assessments, FirstEnergy
`sufficiently assesses risks to the transmission system, including extreme weather events.
`FirstEnergy’s annual assessment includes 14 sensitivity scenarios to assess the reliability of the
`transmission system under various system conditions. The scenarios include a high summer load
`
`                                                            
`12 There are 13 founding Climate READi members: Alliant Energy Corporation, Ameren Corporation, American
`Electric Power, Consolidated Edison Co. of New York, Exelon Corporation, National Grid PLC, New York Power
`Authority, Pacific Gas & Electric, Portland General Electric, Puget Sound Energy, Southern California Edison,
`Southern Company, and WEC Energy Group.
`13 ComEd Climate Risk and Adaptation Outlook, Phase 1: Temperature, Heat Index, and Average Wind Report
`[Argonne National Laboratory Center for Climate Resilience and Decision Science].
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`case, transfers across the FirstEnergy transmission system, and the outage of critical generators or
`transmission elements as a precondition.
`
`Furthermore, the planning events subject to NERC Reliability Standard TPL-001-5.1 are tested in
`each of the scenarios and the extreme events are tested on the 50/50 summer peak case. The
`planning and extreme events can be extrapolated as a simulation of the impact of extreme weather
`events on transmission facilities.
`
`Linden VFT Response to Question 1
`
`The Linden VFT, LLC facility is a multi-channel Variable Frequency Transformer unmanned
`station located in Linden, New Jersey (“Linden VFT”). Linden VFT provides a connection
`between the PJM and NYISO grids and sits on just 1-acre of land. Due to the nature and design of
`the plant, historically cold weather has not been a reliability issue as there are no fuel, steam, or
`water systems required to operate the plant. As a registered Transmission Owner of a Merchant
`Transmission Facility, Linden VFT is not required and does not currently perform extreme weather
`vulnerability assessments.
`
`NEET MidAtlantic Response to Question 1
`
`NEET-MidAtlantic, a subsidiary of NextEra Energy, Inc. (“NextEra”) does not perform extreme
`weather assessments for its BES transmission assets. Any extreme contingency assessment under
`TPL-001-5.1 is performed by PJM as the registered Planning Coordinator and Transmission
`Planner, while NEET-MidAtlantic provides needed modelling data to PJM pursuant to MOD-032-
`1. On a broader level, all NextEra subsidiaries that own or operate BES transmission assets are
`part of the company’s enterprise-wide emergency management plans. These plans evaluate a
`myriad of potential threats, including natural threats such as extreme weather, which may
`adversely impact any of NextEra’s BES assets, including the transmission assets owned by NEET
`MidAtlantic in the PJM region. Risk assessments for NextEra’s emergency management plans are
`updated from time to time based on lessons learned from drills and real-world incidents.
`
`ODEC Response to Question 1
`
`ODEC’s transmission system is 69kV and therefore is not covered by NERC BES standards.
`ODEC does not conduct extreme weather vulnerability assessments at this time. The transmission
`owner has a planned inspection and maintenance program for all transmission systems and rights-
`of-way, with additional selective inspections when necessary.
`
`PPL EU Response to Question 1
`
`PPL EU does not conduct its own unique extreme weather vulnerability assessment. PPL EU
`conducts the standard yearly NERC TPL-001-5.1 contingency analysis on the transmission system
`on a 90/10 case, which is a peak load extreme case.
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`PSE&G Response to Question 1
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`PSE&G provides input annually to PJM per TPL-001-5.1. PSE&G prepares event files for extreme
`events per the requirements identified in Table 1 of TPL-001-4. PJM performs analysis for extreme
`events with event files provided by PSE&G.
`
`In the aftermath of Super Storm Sandy in 2012, PSE&G took decisive action to protect its
`customers from future extreme weather events. This included modernizing and strengthening its
`systems, such as installing more advanced transformer monitoring, raising substation equipment,
`installing flood walls, and relocating out of flood zones where that presents a more cost effective
`and feasible solution than raising equipment in certain flood prone areas.
`
`In 2021, given the potential physical risks of climate change on New Jersey and PSE&G’s utility
`operations, PSE&G’s parent company conducted a company-wide physical risk screening to help
`better plan and prepare for the changes ahead. The Physical Risk Screening was performed based
`on emerging best practices for climate impact assessments, following the recommendations of the
`Task Force on Climate-related Financial Disclosures. The Physical Risk Screening provided high-
`level data to help identify and evaluate potential risks to PSEG’s infrastructure and operations. The
`study focused on 13 of the most common science-based climate indicators and considered multiple
`severity levels/scenarios, including extreme heat, water supply, extreme wind and sea-level rise.
`It mapped each of these potential climate hazards across the entire state, enabling PSEG to identify
`assets that fall in areas with elevated levels of future climate hazard exposure and to better
`understand asset vulnerabilities and risk of impact.
`
`With regard to operations, PSE&G conducts extreme weather drills annually that are managed
`through PSE&G’s disaster recovery team.
`
`Rockland Response to Question 1
`
`Rockland Electric Company (“Rockland”) is continually looking at extreme weather in its
`planning efforts. From 2012 through 2022, Rockland leveraged lessons learned from Superstorm
`Sandy and invested a total of $58 million to improve resilience of its electric system in New Jersey.
`In September 2023, Rockland’s parent company, Orange and Rockland Utilities, Inc. (“O&R”),
`released its Climate Change Vulnerability Study (“CCVS”) based on the latest climate science.
`Given the proximity and similarity of Rockland’s and O&R’s service territories, Rockland will be
`able to employ the climate data and vulnerability projections of the CCVS to inform its extreme
`weather vulnerability assessments. Rockland plans to participate in future efforts to assess climate
`change vulnerabilities, resilience, and adaptation measures.
`
`Silver Run Response to Question 1
`
`Silver Run Electric is a transmission owner in the PJM region, but is not the Transmission Provider
`under NERC TPL-001-5.1. Silver Run does not perform individual extreme weather vulnerability
`assessments. Silver Run Electric’s Transmission Facilities have only been in operation since 2020
`and were planned pursuant to PJM planning criteria, including extreme weather, as relevant at the
`time of development. Silver Run Electric will continue