Dominion Presents Proposal to Change Dual-fuel Definition

VALLEY FORGE, Pa. — Dominion Energy presented the Markets and Reliability Committee with a quick-fix package to expand the definition of dual-fuel generation in the Reliability Assurance Agreement (RAA) to include generation capable of running on a backup fuel type with off-site storage and dedicated delivery.  

The current language restricts the dual-fuel classification to gas combustion turbines or combined cycles capable of starting and operating on an alternative fuel with on-site storage. Dominion’s James Davis said that would exclude an LNG storage facility the company is building in Virginia. Dedicated pipelines would run from storage to two CC generators, a configuration not recognized as dual-fuel under the existing rules, but which Davis said provides a comparable degree of reliability. 

The quick-fix process allows a problem statement, issue charge and proposal to be brought concurrently. The proposal would be effective for the 2028/29 Base Residual Auction (BRA), the schedule of which has fuel-type attestations due in November. 

Calpine’s David “Scarp” Scarpignato said the proposed language could loosen the definition of fuel source to allow configurations that would not deliver the reliability expected from dual-fuel units. When Calpine proposed changes to the dual-fuel definition in 2024, the Independent Market Monitor recommended changes to the proposed language to ensure the backup fuel actually could be used. Scarp gave the example of a generation owner seeking dual-fuel status for a resource with a small on-site storage tank intended to be resupplied by truck as needed. (See “Quick Fix for Dual-fuel Classification Endorsed,” PJM MRC Briefs: April 25, 2024.) 

Stakeholders Bring Alternative SATA Issue Charges, Endorsement Delayed

The committee deferred voting on an issue charge seeking to establish a ruleset for battery storage to be installed and operated as a transmission asset (SATA) to allow more time to consider two alternatives brought by Constellation and Exelon. 

The PJM issue charge has been discussed at several meetings in recent months, with voting delayed to hold education on how SATA would operate and its implementation in other RTOs.  

Building off PJM’s issue charge, Constellation added several key work activities (KWAs) to identify the use case for SATA, when the batteries would run and more thoroughly consider the market effects storage might have. Stakeholders seeking more consideration of the topic before voting on an issue charge have argued inadequate rules could allow batteries on a regulated rate to displace market-based resources. 

Independent Market Monitor Joe Bowring has said in past meetings there is not a way to meaningfully distinguish between a resource injecting energy for transmission support or market participation. 

Exelon proposed edits to the Constellation language focused on ensuring SATA would be treated and used the same as other transmission solutions. It replaced a Constellation KWA to “identify what the market impacts could be and a commitment to address them” with “ensure a storage device identified as transmission only and not a market resource is treated no differently than any other transmission asset, including with respect to market impacts.” 

1st Read on 3rd Phase of Hybrid Resource Rules

PJM presented revisions to several manuals to conform with FERC’s approval of the third phase of PJM’s hybrid resource rules (ER25-1095). Elements of the manual changes were endorsed by the Planning, Operating and Market Implementation Committees earlier in June. (See “3rd Phase of Hybrid Resource Rules Endorsed,” PJM MIC Briefs: June 2, 2025.)  

Phase 3 expands the hybrid model to include pairings of co-located non-inverter-based generation and battery storage as one market unit. Hybrids with a capacity commitment would fulfill their obligation to offer into the energy market by submitting their forecast output, capped at the inverter capability, while a hybrid with a storage component should offer the “anticipated intermittent and battery output.” 

Revisions to the formula for lost opportunity cost (LOC) credits would make eligible storage and hybrid resources instructed to increase charging to mitigate transmission constraints or reliability issues. Resources instructed to reduce charging would not be eligible. 

The definition of closed- and open-loop batteries also would be revised to allow resource owners to determine how a storage unit should be classified. For instances where storage is capable of charging from the grid, the resource owner would be permitted to choose whether to offer it as open- or closed-loop, allowing for situations where a battery is physically capable of charging but the owner has determined not to operate it in that fashion. 

PJM Presents Capacity Market Manual Revisions

PJM presented a first read on proposed revisions to Manual 18: PJM Capacity Market to conform with several filings the RTO has made in recent months reworking elements of the market (ER25-682, ER25-785, ER24-2995 and ER25-1357). 

The changes include modeling the expected output of some resources operating on reliability-must-run agreements as capacity; implementing a minimum capacity market clearing price and lowering the price maximum; removing the addback for energy efficiency resources; codifying the BRA schedule; maintaining a CT as the reference resource; and setting an RTO-wide capacity performance penalty rate. The revisions also would remove an exemption from the requirement that resources offer into the capacity market for intermittent, storage and hybrid resources. (See FERC OKs Changes to PJM Capacity Market to Cushion Consumer Impacts.) 

Members Committee

Board to Hold Dialogue with Stakeholders at MC Meetings

PJM Board of Managers Chair David Mills told the Members Committee that attending board members will remain at the Conference and Training Center (CTC) for the full meeting to facilitate a dialogue with stakeholders. That includes a commitment to remain in the region overnight to allow discussions to continue after the MC concludes. Mills was joined by board members Paula Conboy and Vickie VanZandt at the CTC, with other members attending virtually. 

“This is an opportunity for us to hear out one another. And all this is against the backdrop of our responsibility as board members …. to hear what you have to say,” Mills said, adding that listening to stakeholders does not mean the board will take sides on issues or compromise its independence. 

At the Annual Meeting on May 12, Mills broached the idea of adding a standing MC agenda item for the board and stakeholders to bring issues they wish to discuss. Several stakeholders cited lacking transparency and access to the board as their reason for voting against re-electing two board members during the meeting. (See PJM Stakeholders Vote Out 2 Board Members.) 

Much of the discussion during the June 18 meeting centered on the format future discussions should take, with the aim to have them begin in earnest at the July 23 MC meeting. Mills said his vision is for the format to be more informal than that of the Liaison Committee (LC), with conversations rather than prepared speeches. That could take the form of moving to group conversations in the lobby or remaining in the conference room. 

PJM Proposes Revisions to Antitrust Language

PJM Assistant General Counsel Eric Scherling presented updated antitrust guidance for stakeholder meetings intended to bolster the RTO’s recommendations for avoiding conduct that could run afoul of antitrust law. He characterized the guidance as a clarification, rather than a change, in the language. 

The changes affect the antitrust language included in meeting agendas, which are referenced by committee and stakeholder group chairs before meetings begin, as well as guidance on the PJM website. Scherling said the change in guidance is not in response to any particular stakeholder behavior, but rather making improvements that PJM has identified. 

While stakeholders can discuss how trends and forecasts may affect market pricing or costs, disclosure of non-public information, such as bidding practices, could violate federal antitrust statutes. The guidance states that “informal, hypothetical or joking references to these topics should be avoided.” 

Scherling said there are a pair of protected areas where market practices or non-public information could be discussed without violating federal law. The Noerr-Pennington doctrine allows for good-faith advocacy for federal agencies to adopt proposals that may reduce the competitiveness, while Parker immunity allows uncompetitive activity so long as it is authorized by state policy. 

Changes to Liaison Committee Registration Discussed

PJM plans to close registration for future LC meetings a few days in advance to ensure staff have time to validate the credentials of attendees ahead of time, Manager of Stakeholder Process and Engagement Michele Greening said. 

For the July 28 meeting, that means registration will close at 5 p.m. July 24, with no late registrations accepted. 

Constellation Vice President of Wholesale Market Development Adrien Ford said prior to the COVID-19 pandemic, the LC meeting was a great opportunity for members to speak with the PJM Board of Managers about pressing matters and network with other attendees afterward. In-person attendance has not returned to pre-pandemic levels, however, and there have been fewer meetings recently, making the committee a less rich experience. 

PJM CEO Manu Asthana said part of why there have been fewer LC meetings is the board has been meeting more regularly to address pressing issues as they arise.