This issue concerns several NERC CIP issues pertinent to black start owners:
Schedule 6A includes those costs incurred as a result of a NERC compliance standard similar to the CIP standards.
Schedule 6A allows black start owner to carry risk insurance for reasonable costs to cover a risk policy for those potential penalties associated with a NERC compliance issue related to maintaining black start status.
Schedule 6A allows black start owner to pass on any NERC penalties associated with black start compliance failures to the PJM membership.
Schedule 6A language for the provision for black start providers to file at the FERC for recovery of capital investment related to Black Start service within the context of the formula rate provided.
Schedule 6A language for the requirement for PJM to handling billing associated with the above arrangements with no significant issues.
Schedule 6A language for the inclusion of CONE to replace CDR with some additional clarifications on the details of CONE to be included in the tariff language.