UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

: Service Corporation : Docket No. EL20-58-000 :

COMMENTS OF PJM INTERCONNECTION, L.L.C.

Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”)

Notice of Petition of Declaratory Order,1 PJM Interconnection, L.L.C.2 (“PJM”) respectfully submits these limited Comments in support of American Electric Power Service Corporation’s

(“AEP”) Petition for Declaratory Order in the captioned docket.3

The narrowly-tailored Petition seeks confirmation that one project, the Middle Creek energy storage project (the “Middle Creek Project” or “Project”), is a Transmission Facility4 as defined in the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C.

(“Operating Agreement”).5 The Project addresses a local condition on the lower voltage AEP system for which “AEP does not propose that the project will participate in wholesale energy or capacity markets or provide ancillary services.”6

1 American Electric Power Service Corporation, Notice of Petition for Declaratory Order, Docket No. EL20-58-000 (July 23, 2020). 2 PJM submitted a doc-less motion to intervene in this docket on August 6, 2020. 3 American Electric Power Service Corporation, Petition for Declaratory Order, Docket No. EL20-58-000 (July 22, 2020) (“Petition”). 4 Capitalized terms that are not defined herein have the meaning specified in the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C. (“Operating Agreement”) or Open Access Transmission Tariff (“Tariff”). 5 The Petition also seeks confirmation that the Middle Creek Project is eligible for cost-of-service recovery through AEP’s transmission formula rates. PJM’s comments do not address this issue. 6 See Petition at 1, 2, 8, 11-12.

Under the project-specific facts detailed in the Petition, PJM agrees that the Middle Creek

Project will qualify as a Transmission Facility as defined in the Operating Agreement.7

Specifically, the Middle Creek Project: (i) is within the PJM Region;8 (ii) as represented by AEP,9 will be billed consistent with FERC’s uniform system of accounts; and (iii) has gone through the

Tariff, Attachment M-3 process, such that PJM issued the Project a Supplemental Project ID

(S2200.1-.3) and has included the Project in the posting10 of the Subregional RTEP Committee –

Western’s Local Plan11 for the AEP zone. PJM will integrate that Local Plan into the Regional

Transmission Expansion Plan (“RTEP”) to be approved by the PJM Board of Managers.12

Although the Petition is not seeking generic findings,13 it is noteworthy that PJM is facilitating a stakeholder process that is evaluating whether existing PJM planning rules provide sufficient clarity regarding if and how storage as a transmission asset should be evaluated and incorporated into the PJM RTEP process.14 This stakeholder effort may result in the development

7 Operating Agreement, Section 1, Definitions S-T: “Transmission Facilities” shall mean facilities that: (i) are within the PJM Region; (ii) meet the definition of transmission facilities pursuant to FERC’s Uniform System of Accounts or have been classified as transmission facilities in a ruling by FERC addressing such facilities; and (iii) have been demonstrated to the satisfaction of the Office of the Interconnection to be integrated with the PJM Region transmission system and integrated into the planning and operation of the PJM Region to serve all of the power and transmission customers within the PJM Region. 8 Petition at 3 (the Project is being proposed at the “Middle Creek Substation near Floyd, ”). 9 See Petition at 9, 12-13. 10 See https://pjm.com/-/media/committees-groups/committees/srrtep-w/postings/aep-local-plan- submission-of-the-supplemental-projects-for-2020-rtep.ashx?la=en (Slides 138-139) (note: the April 20, 2020 V6 added the Middle Creek Project); see also Petition at 5-6 & n.8. 11 Operating Agreement, Section 1, Definitions I-L. 12 See Operating Agreement, Schedule 6, sections 1.5.6(g), 1.5.6(h), and 1.6(a). 13 Petition at 10 (“AEP is not requesting Commission approval for generic tariff revisions that would apply to projects other than the Middle Creek Project.”). 14 See Storage as Transmission Asset Planning Committee Special Session, Problem/Opportunity Statement and Issue Charge, https://pjm.com/-/media/committees-groups/committees/pc/2020/20200605- special/20200605-item-02a-storage-as-a-transmission-asset-problem-statement-clean.ashx and

2

of processes that could be used in evaluating storage as a transmission asset to address elements

in the RTEP. Further, the stakeholder process is investigating opportunities to enhance clarity in

PJM’s evaluation process of storage as a transmission asset to provide more transparency for

stakeholders. Given that the Middle Creek Project satisfies the Operating Agreement’s definition

of Transmission Facilities, the Commission’s approval of the instant Petition will not disturb the

discussions in this ongoing stakeholder process. PJM looks forward to continuing to engage with its stakeholders on the important topic of storage as transmission.

For the reasons set forth in these Comments, the Commission should confirm that the

Middle Creek Project qualifies as a Transmission Facility as defined in the PJM Operating

Agreement.

Respectfully submitted,

By: /s/ Mark J. Stanisz Craig Glazer Mark J. Stanisz Vice President-Federal Government Policy Senior Counsel PJM Interconnection, L.L.C. PJM Interconnection, L.L.C. 1200 G Street, N.W., Suite 600 2750 Monroe Blvd. Washington, D.C. 20005 Audubon, PA 19403 Ph: (202) 423-4743 Ph: (610) 666-4707 Fax: (202) 393-7741 Fax: (610) 666-8211 [email protected] [email protected]

Date: August 21, 2020

https://pjm.com/-/media/committees-groups/committees/pc/2020/20200605-special/20200605-item-02b- storage-as-a-transmission-asset-issue-charge-clean.ashx.

3

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document on those parties on the official Service List compiled by the Secretary in these proceedings.

Dated at Audubon, this 21st day of August, 2020.

By: /s/ Mark J. Stanisz Mark J. Stanisz Senior Counsel PJM Interconnection, L.L.C. 2750 Monroe Blvd. Audubon, PA 19403 Ph: (610) 666-4707 [email protected]