Comment from PJM

Please consider the Energy Sector (Critical Infrastructure) ISO/RTO control centers should require strict physical boundaries, defined 24/7 closures, and the inclusion of advanced, real-time Remote ID tracking to protect the reliability of the bulk electric grid and mitigate the national security risks posed by unauthorized drone incursions. Please consider incorporating the following actionable actions in the protection of vital energy infrastructure: •Elevate the Security Profile: Independent System Operators (ISOs) and Regional Transmission Organizations (RTOs) manage the bulk electric power grid for entire multi-state regions. Unauthorized drone incursions pose severe national security and homeland security threats. ISO/RTO control centers require Special UAFRs (requiring express approval to fly) rather than just Standard UAFRs. •24/7 Permanent Designations: Flight restrictions for ISO/RTO facilities should operate 24 hours a day, 365 days a year. Grid operations cannot endure gaps in airspace security, particularly during peak demand or emergency grid events. •Strengthen Remote ID Mandates: Any permitted exceptions for authorized operations must be strictly conditioned on active Remote ID broadcasting. Facility operators need to be able to immediately trace and log drone activity in the vicinity. Expand Horizontal Boundaries: Control Centers oversee massive regional networks, the proposed restricted perimeter should account for the entire property footprint plus a necessary buffer zone to detect and prevent perimeter breaches before damage occurs.