PJM’s rules for pseudo-tied resources lack “sufficient notice and transparency” regarding how the RTO conducts its market-to-market (M2M) flowgate test and applies its electrical distance requirement, FERC ruled last week.
Acting on complaints by Brookfield Energy Marketing and Cube Yadkin Generation, the commission ordered PJM to amend its Tariff within 45 days to address the shortcomings.
Brookfield contended that PJM’s deliverability requirements and M2M flowgate test were interfering with the ability of the company’s Calderwood and Cheoah hydroelectric generation facilities in the Tennessee Valley Authority and Duke Energy balancing authority areas to provide capacity in the RTO. The commission ruled that Brookfield had not proven that PJM’s pseudo-tie requirements are unjust and unreasonable (EL19-34).
The commission also rejected Cube’s allegation that PJM applied the electrical distance requirement in an unjust and unreasonable manner to the company’s four hydroelectric resources. But the commission required the RTO to amend its Tariff to spell out the procedure in more detail (EL19-51). The Tariff defines “electrical distance” as “the measure of distance, based on impedance and in accordance with the PJM manuals, from the generation capacity resource to the PJM region.”
FERC ordered PJM to revise its Tariff to provide pseudo-tie applicants with results of their tests and related work papers and to post on its website the assumptions used in the tests. It also required the RTO to meet with applicants if requested to discuss assumptions, modeling and test results.
In a third order, FERC rejected a complaint by Tilton Energy alleging that PJM wrongly determined that Tilton’s pseudo-tie from the MISO BAA into PJM did not pass the M2M flowgate test (EL18-145).
The company filed a complaint after its 176-MW natural gas-fired generation facility in the MISO BAA was rejected by PJM because 44 of the tested flowgates failed the test. PJM uses the test to determine whether it can use a dispatchable internal resource to alleviate the impact on congestion caused by the external pseudo-tied resource.
The failed test prevented Tilton from participating in capacity auctions after the 2021/22 delivery year, despite having served as a capacity resource in two prior years.
The commission sided with PJM’s interpretation of its Tariff regarding the testing. “We find that PJM’s interpretation reasonably permits PJM to reject pseudo-ties that could create new coordination and congestion costs,” it said.
It said the fact that Tilton had previously been accepted as a capacity resource was irrelevant. “Tilton has not previously been subject to the flowgate test, given the five-year transition period for existing pseudo-tied resources,” it said.
