Under NERC Critical Infrastructure Protection (CIP) Reliability Standards, the Reliability Coordinator (RC), Planning Coordinator (PC), or Transmission Planner (TP) are responsible for identifying critical facilities and their associated contingencies for the planning area. In the event that PJM, functioning as the RC/PC/TP identifies generation facilities during its annual CIP (CIP-002-5.1) critical facilities derivation of Interconnection Reliability Operating Limits (IROLs) and their associated contingencies, Generator Owners (GO) may face significant incremental compliance costs with no existing means to recover the costs.