By Christen Smith

FERC ordered paper hearings Monday in disputes over the criteria PJM used to reject several hydroelectric resources from pseudo-tying into the RTO’s grid.

Both Brookfield Energy Marketing and Cube Yadkin Generation said PJM erred when it determined some of their generating resources didn’t meet the RTO’s pseudo-tie requirements, preventing the companies from offering capacity.

Brookfield Complaint

In January, Brookfield challenged PJM’s assertion its Calderwood and Cheoah generating facilities did not pass the market-to-market flowgate test or meet its extraterritorial deliverability requirements, despite maintaining a firm point-to-point service from the Tennessee Valley Authority into Duke Energy’s balancing authority area at an annual cost of $5 million. The company says it has held capacity obligations in PJM since 2014.

PJM told Brookfield in March 2018 its tests determined the facilities failed for 38 flowgates. A follow-up test three months later found the facilities failed “19 transmission elements.” PJM rejected as insufficient a report prepared by Quanta Technology that affirmed Brookfield’s point-to-point service complies with the RTO’s requirements.

PJM’s current pseudo-tie rules were approved by the commission in November 2017. The order included a five-year transition period for resources that had an existing pseudo-tie and had cleared in a capacity auction before May 2017 (ER17-1138). As a result of the failed tests, PJM said the Brookfield generators would be ineligible to participate in its capacity auction for the 2022/23 delivery year, after the transition period expired.

FERC ruled Aug. 26 that Brookfield’s complaint raised legitimate concerns about how PJM applied its requirements (EL19–34). The commission noted PJM’s Tariff and Manuals do not specify the “deliverability criteria” the RTO uses for its evaluations.

“The record is not clear as to what deliverability criteria PJM uses to determine whether pseudo-tied resources can participate in the auctions, whether it uses those deliverability criteria consistently for all projects or how PJM evaluated the Brookfield facilities,” the commission said. ” … PJM has not sufficiently explained why the Brookfield facilities failed the M2M flowgate test while other external generators affecting the same flowgate (Flowgate No. 93209) did not.”

However, the commission denied Brookfield’s request to extend the five-year transition period. PJM said doing so would be inappropriate because the transition period is memorialized in the Tariff and would require a showing that the original transition was unjust and unreasonable. “Brookfield has presented neither a basis on which the commission could grant its requested interim relief nor a demonstration such relief would be appropriate in these circumstances,” FERC said.

Cube Yadkin Complaint

Cube Yadkin Generation filed its complaint after PJM informed it in June 2018 that its 220-MW Yadkin Project — the Tuckertown, High Rock, Falls and Narrows hydroelectric sites on the Yadkin River about 75 miles from Charlotte, N.C. — did not meet the “electrical distance” requirement under its pseudo-tie rules.

FERC approved the electrical distance test in its 2017 order, saying it struck an appropriate balance between allowing external resources to participate in PJM’s capacity market while providing the RTO with reliability assurance. The commission said it accepted PJM’s representation that the further its state estimator model extends beyond its own borders, the less resilient the PJM system becomes to data losses and inaccuracies.

In its Aug. 26, order, the commission said Yadkin had raised factual questions about how PJM conducted the electrical distance test (EL19-51). Cube Yadkin said PJM’s identification of three electrically closest buses for the project is electrically impossible because the series arrangement of the resources — with grid connections to only High Rock and Badin — means there can only be two closest buses.

FERC said PJM did not directly dispute Cube Yadkin’s arguments but responded each site’s location has a “unique set of paths through and out of the Yadkin area to the PJM border and, given these unique paths, finding differences between each location is not unexpected.”

The commission said that raised questions as to how PJM’s algorithm selects the buses and paths used in the electrical distance test and whether the selection of the wrong bus could cause a generator to fail when it would have otherwise passed.

FERC gave PJM 30 days to respond to its questions about its methodology, with responses by Brookfield and Yadkin due within 15 days of the RTO’s filings. “After receipt of these filings, commission staff is authorized to establish additional procedures, including a staff technical conference,” FERC said.