PJM’s Board of Managers on June 9 initiated a critical issue fast path (CIFP) process to determine how to compensate Constellation Energy for continuing to run two gas-fired units at the utility’s Eddystone plant under a Department of Energy emergency order.

While PJM and MISO both have provisions to compensate generation that must remain online to maintain transmission reliability, they lack mechanisms for retaining and paying resources whose deactivation is delayed for resource adequacy purposes.

The announcement initiating the CIFP process said the purpose is to “engage with stakeholders and to receive feedback on the specific issue of the appropriate cost allocation methodology associated with the recovery of the DACC [deactivation avoidable cost credit] payments to Constellation for the Eddystone Units.”

The board communication says Constellation agreed to use the DACC to determine compensation for keeping units 3 and 4 at the 760-MW Eddystone plant online. However, PJM’s tariff contemplates applying the credit only for units serving under reliability-must-run agreements for transmission purposes. (See DOE Orders PJM, Constellation to Keep 760-MW Eddystone Generators Online.)

“This discussion may also include the potential establishment of a generic cost allocation structure that could be utilized in the event that additional [Federal Power Act Section] 202(c) orders are issued in the future for resource adequacy purposes, and the generator owners subject to those orders elect to utilize the DACC as their form of compensation,” the communication says.

Since the emergency order requires the Eddystone units to be operational on June 1, the CIFP process will proceed on a shortened timeline beginning with a problem statement, issue charge and solution proposed on June 10 and stakeholder feedback and alternatives solicited on June 12. A meeting for package development will be held on June 16, and a June 18 meeting will review the final proposed solution and allow “members and invited non-members” to provide feedback to the board.

Consumers Energy has filed a complaint against MISO asking FERC to require the RTO to file tariff revisions detailing how it will compensate generators required to defer their deactivations under Section 202(c) emergency orders. Consumers’ 1,560-MW J.H. Campbell generator in Michigan only has also been required to remain operational under a separate DOE emergency order (EL25-90).

“To be clear, the specific costs, if any, to be recovered by Consumers Energy are not at issue in this complaint. Rather, Consumers Energy plans to make a Section 202(c) filing after the conclusion of the extended service required by the DOE order in which it will present, explain and support what it believes are its just and reasonable costs associated with running the Campbell plant from the date of the DOE order, netting out applicable market revenues,” the complaint states.

‘False Narrative’

The Eddystone emergency order also was discussed at the June 3 PJM Operating Committee meeting, at which Senior Vice President of Operations Mike Bryson reiterated the RTO’s support for the order.

“PJM did not initiate the request for the emergency order; PJM does support the emergency order,” he said.

Bryson said the DOE reached out to PJM to inquire about generators that have requested deactivation, with a particular focus on “immediate concern generation” that would go offline by the end of May. The RTO responded by providing a spreadsheet of resources that are set to retire, highlighting those that are set to go offline in the next three years and are seeking to withdraw their deactivation request.

The emergency order was facilitated by an April 8 executive order that widens how the Section 202(c) authority may be used, which Bryson said sparked PJM’s interest due to the focus on retaining generation found to be critical to maintaining resource adequacy and preventing resources over 50 MW from deactivating or changing their fuel type if the conversion would reduce accredited capacity. (See Trump Seeks to Keep Coal Plants Open, Attacks State Climate Policies.)

Bryson said PJM has been vocal in congressional testimony about projected resource adequacy issues, load forecasts and its February 2023 “Energy Transition in PJM: Resource Retirements, Replacements & Risks” position paper. (See PJM Whitepaper to Highlight Future RA Concerns.)

In a June 2 statement, the Delaware Riverkeeper Network disputed that there is any emergency requiring Eddystone to remain online and said its continued operation harms public health and degrades water and air quality. It argued that Eddystone contributes to high ozone concentrations that exceed federal standards.

“Our nation has excess fossil fuel energy, so much so that it is being exported to countries oversees,” Maya van Rossum, head of the network, said in the statement. “The assertion of an energy emergency is a lie; a false narrative pedaled by Donald Trump as an excuse he can use to prolong continued use of aging energy operations like Eddystone, and to advance his demand that all federal agencies expedite approval of dirty fossil fuel operations in our region and nationwide.

“Proof of the lie is that while Donald Trump is perpetuating and fast tracking dirty fossil fuels, he is doing so in a way that disadvantages solar and wind projects which would provide for our region and nation’s energy needs while at the same time protect communities from air pollution and environmental degradation and help protect present and future generations from the ravages of climate crisis,” she said.