Hospitals, 911 centers, water plants: what the federal grid emergency order left alone

RICHMOND, Va. - When the U.S. Department of Energy authorized the operator of Virginia's regional grid to order backup generators switched on during a September emergency, it drew a line around the generators that protect life and safety.

Paragraph D of Order No. 202-26-45, signed by Energy Secretary Chris Wright on Sept. 17, states that the order "is not applicable to any backup generation resource serving a critical reliability or backup need." It lists examples: generators "at defense, homeland security, first responder, air traffic control, hospital facilities, 911 call centers, water treatment or wastewater facilities, natural gas pipeline facilities, natural gas gathering facilities, or other similar facilities."

Why the carve-out matters

The order gave PJM Interconnection, which runs the grid across 13 states and D.C., two emergency tools for Sept. 17 and 18.

The first let PJM run listed power plants past limits in their environmental permits. The second, in Paragraph B, let PJM direct backup generation "as a last resort before declaring an EEA 3 (i.e., before firm load interruption) or during an EEA 3." Paragraph C states that the order "requires the operation" of those backup resources.

The point was to have large users run on their own power, freeing grid supply for everyone else. PJM's application said that could "help the RTO avoid residential load shed at EEA level 3."

The exemption keeps that requirement from reaching generators held in reserve for an outage at a hospital, an emergency dispatch center or a water plant. Those generators remain available for the facilities they protect instead of being run down during a grid emergency.

The language is broad

The list ends with "or other similar facilities," which leaves room for judgment. The order does not define the phrase or say who decides whether a facility qualifies. PJM is authorized to call on transmission owners and electric distribution companies to carry out the order. In Virginia, that includes Dominion Energy Virginia in the Dominion zone.

PJM's application framed the request around large loads. It asked for "use of backup generation by large loads notwithstanding any applicable environmental limitations." It also said that without emergency relief, "residences, hospitals, military facilities, water treatment plants, and other critical facilities may lose electric service to all or parts of their facilities."

Who did run

PJM's compliance report for Sept. 17 lists backup units that ran in reliance on the order. In Virginia, six diesel units in Ashburn, labeled VA1, VA2, VA3, VA5, VA6 and VA10, ran 8 to 10 hours. Outside Virginia, the list includes a Pennsylvania state prison listed as "PA - DOC - SCI Greene," an Ohio school district, a company listed as Gottlieb Inc. and two University of Akron entries.

The filings do not identify the owners or facility types behind the Ashburn units. A 30-megawatt diesel unit in Gainesville, labeled CH1, was on PJM's resource list but does not appear on the Sept. 17 report.

Other limits

Beyond the exemption, the order says backup units used under it "shall not be considered a capacity resource." It limits operation to the times and parameters PJM sets for reliability, and it requires monitoring, reporting and recordkeeping "to the maximum extent practicable." After the order expired, normal state, local and federal rules applied again.

PJM had to give DOE daily notice of each resource operating under the order. DOE can request more information about environmental impacts.

The backdrop

PJM told DOE it expected demand near 133,285 megawatts on Sept. 17, about 700 megawatts short of its reserve margin, with strain worst in the BGE, Pepco and Dominion zones. A plant serving those zones unexpectedly went offline that morning, PJM said in a supplemental letter that did not name the facility. PJM called emergency demand response in the three zones that afternoon.

The order was effective through Sept. 18. Virginia's State Corporation Commission was copied.

Documents

The order, PJM's application, its supplemental letter and Exhibit A are posted on the Department of Energy's 202(c) page for Order No. 202-26-45 at energy.gov. PJM's daily compliance report for Sept. 17 is posted at pjm.com.