Constellation deferred on asking the Market Implementation Committee to vote on a quick-fix proposal to account for any downtime dual-fuel gas generators may require when switching fuels. The process allows for a problem statement, issue charge and solution to be considered concurrently.
Director of Wholesale Market Development Erik Heinle said the company is working to incorporate amendments offered by PJM to ensure the reliability value of dual-fuel units is not compromised if they switch to their alternative fuel when gas prices are high. Resources still would be required to be capable of operating for at least 16 hours on alternate fuels.
The proposal would revise the dual-fuel definition in PJM Manual 11: Energy & Ancillary Services Market Operations to reflect “limitations or restrictions resulting from fuel switching time modeling within PJM’s software platforms.” The current definition requires dual-fuel units offer schedules for both their primary and alternate fuels, while respecting limits stemming from “energy or environmental limitations imposed on the generating unit by applicable laws and regulations.”
While Heinle said PJM’s amendment can be included without significantly disrupting the company’s goal of having the changes implemented before the 2026/27 winter, Constellation is wary of expanding the scope to address other issues.
Manual Revisions Sought to Clarify VOM and Opportunity Costs
PJM presented revisions to Manual 15: Cost Development Guidelines drafted through the document’s biennial review that center on clarifying the variable operating and maintenance (VOM) adder and opportunity cost calculator. Endorsement will be sought at the April 8 MIC meeting.
Language would be added to specify that the format of operating costs can be changed only at the time of submission and once every calendar year thereafter.
The opportunity cost calculator section would be expanded to state that the dispatch will be between resources’ economic minimum and maximum parameters. A paragraph would be added to detail how the opportunity cost adder interacts with environmental and operational limits.
