PJM stakeholders last week endorsed a “quick-fix” manual revision to correct a date reference in Manual 18 following a discussion in which some members objected to the process and suggested further talks on lingering pseudo-tie issues.
Jeff Bastian of PJM reviewed the problem statement and issue charge to correct Manual 18’s reference to the effective date for notifying pseudo-tied resource owners of their assigned locational deliverability area (LDA) prior to each delivery year. The Market Implementation Committee endorsed the measure with 78% support (149 votes) at its Oct. 7 meeting.
Bastian said under initial Capacity Performance provisions, a performance shortfall was calculated for external generation capacity resources only during performance assessment hours for when the emergency action was declared for the entire PJM region.
However, in November 2017, FERC accepted changes to be effective with the 2020/21 delivery year that would calculate a performance shortfall for external generation capacity resources for any performance assessment interval for which performance by such external resources would have helped resolve the emergency (ER17-1138). (See FERC OKs Change to MISO, PJM Pseudo-Tie Rules.)
PJM Manual 18 changes made to conform with the accepted provisions incorrectly specified the provisions as being effective with the 2021/22 delivery year, Bastian said.
Carl Johnson of the PJM Public Power Coalition said he recognizes what PJM was trying to accomplish with the change and why it would be done in the quick-fix process. Johnson said he represents some members who were involved in the FERC docket on the issue who still have concerns they feel are unresolved and would like to see PJM address them in a new problem statement and issue charge.
Johnson said the PPC would like to address some of the issues that FERC said were out of scope for the proceeding but should be raised in the stakeholder process. He cited questions about pseudo-tied resources’ obligations, how they receive pricing and penalties that may be imposed on an external resource. (See FERC Sets Hearings in PJM Hydro Pseudo-Tie Spat.)
Steve Lieberman, assistant vice president of transmission and PJM affairs for American Municipal Power (AMP), said he agreed with Johnson about opening a stakeholder process to examine unresolved issues. AMP was one of the entities that challenged PJM’s requirements for pseudo-tied generators. (See FERC Sides With PJM on Pseudo-Tie Challenges.)
Lieberman said he was concerned by PJM’s use of the quick-fix process to make the change because it affects a specified delivery year that has already started.
“It just strikes me as a little unsettling that we would be making a change after the start of a delivery year,” Lieberman said. “I just don’t like seeing us go down the path of making changes that specify a specific start time that’s already passed.”
Bastian said the Tariff correctly lists the 2020/21 delivery year as the effective date, superseding the manual language. Bastian said the idea was to make the two documents consistent and eliminate the discrepancy.
Sharon Midgley of Exelon said her company is supportive of PJM’s quick-fix and didn’t think it was appropriate to hold up a conforming change to a manual to discuss other issues. Midgley said Exelon would support stakeholders continuing a discussion and bringing forward a new problem statement and issue charge.
Behind-the-meter Generation
Members unanimously endorsed clarifications to the behind-the-meter generation (BTMG) business rules for units changing status from netting against load to participating in PJM markets.
Terri Esterly of PJM reviewed the problem statement and issue charge addressing the clarifications, saying a BTMG unit can be designated as a capacity resource or energy resource in the wholesale markets or be designated as BTMG netting against load on a unit-specific or partial-unit basis. Any BTMG unit seeking to be designated in whole or in part as a wholesale resource must submit an interconnection request.
BTMG rules were developed beginning in 2003 within the Behind-the-Meter Generation Working Group, Esterly said, and there has been limited review of the rules governing them since their development. Esterly said the OC in 2019 endorsed clarifying updates to BTMG business rules focused solely on the reporting, netting and operational requirements of non-retail BTMG.
Esterly said the Tariff and Manual 14D updates are needed because of the increased development of distributed energy resources and load-serving entity requests for adjustments to network service peak load and obligation peak load to reflect new BTMG.
The key work activities include providing education on existing BTMG business rules on status changes in the Tariff and Manual 14D. Work also will include reviewing and identifying business rules related to status changes that would benefit from clarification or additional detail or that may conflict with existing rules.
Stakeholders are expected to work on the issue for four months.
Midgley asked how the BTMG effort lines up with PJM’s compliance activities associated with FERC Order 2222 and what steps the RTO will take to make sure there are no conflicts between what stakeholders develop in the BTMG effort versus what is developed for Order 2222. (See FERC Opens RTO Markets to DER Aggregation.)
Esterly said the BTMG effort is to clarify existing rules but additional changes may be needed because of Order 2222.
Real-time Values Market Rules
Laura Walter, senior lead economist, provided an update on the work completed during the MIC special sessions on real-time values market rules and reviewed the proposed packages from the solutions matrix.
The special sessions have been taking place since January, after stakeholders endorsed an issue charge at the December Markets and Reliability Committee meeting. (See “Real-time Values,” PJM MRC Briefs: Dec. 19, 2019.) The problem statement said observations indicated real-time values were being used to consistently override unit-specific parameter limits or approved parameter limited exceptions.
The original intent of RTVs was to provide a way for generation operators to communicate current operating capability to PJM if their resources couldn’t meet their unit-specific parameter limits or approved exceptions, Walter said. Generators opting to use RTVs forfeit operating reserve credits and make-whole payments.
In a nonbinding poll conducted in August, 55% of stakeholders said they supported the PJM package, and 10% gave support for the IMM package, while 71% said they were happy with the status quo.
Walter said market participants that repeatedly fail to reflect actual operating conditions in their submitted operating parameters could be referred to FERC for enforcement. The package also calls for adding real-time values to the Tariff. Currently, real-time values are mentioned only in the manual, Walter said.
The IMM proposal includes removing minimum run time from the list of eligible parameters with RTV submissions. It also said units that choose to run longer can self-schedule beyond the minimum run time, with PJM operator notification.
The proposal also prevents withholding by using longer minimum run time, Walter said. Any penalties collected are to be allocated to daily real-time load.
The MIC will vote on the PJM and IMM packages at the November meeting with a first read scheduled for the December MRC meeting.
Manual 15 Review
Stakeholders unanimously endorsed revisions to Manual 15 as part of the biennial review. Gabrielle Genuario of PJM reviewed updates to Manual 15, including reformatting and rewording in sections 2.6.1 and 2.6.8 to provide more clarity.
The revisions will be voted on at the Oct. 29 MRC meeting and the Nov. 19 MC meeting.
Manual 11 Revisions
Vijay Shah of PJM reviewed proposed updates to Manual 11: Energy & Ancillary Services Market Operations. Shah said the changes involve increasing transparency and conforming to current PJM process as part of the five–minute dispatch and pricing problem statement.
The changes include an added reference to the day-ahead and real-time sections in Section 2.2: Definition of Locational Marginal Price and updated “LMP verification” to “price verification” throughout Section 2.10: Verification Procedure as verification includes review of real-time and ancillary service prices.
Stakeholders will vote on the proposed updates at the November MIC meeting.