By Suzanne Herel
The Illinois Commerce Commission and PJM’s Independent Market Monitor said last week they oppose the Illinois Municipal Electric Agency’s request for a waiver from the rules for May’s Base Residual Auction.
IMEA asked the Federal Energy Regulatory Commission last month for a waiver that would allow it to use capacity resources outside of the Commonwealth Edison Locational Deliverability Area to meet its internal resource requirement in serving its Naperville, Ill., load (ER15-834).
Last May, FERC granted IMEA such a waiver for the 2017/18 delivery year (ER14-1681). Neither the ICC nor the IMM weighed in on last year’s waiver request.
Others Impacted
The ICC’s criticism echoed FERC’s in its Jan. 22 order denying IMEA’s request to extend last year’s waiver (ER14-1681-001). (See FERC Denies IMEA Request for Extended Waiver on Capacity Obligation.)
“Despite the small size of IMEA’s [fixed resource requirement] load relative to total load in the ComEd LDA, the financial impact of granting IMEA’s requested waiver could be significant for the other [load-serving entities] if PJM models the ComEd LDA separately in the May 2015 Base Residual Auction and the ComEd LDA subsequently binds on the [Capacity Emergency Transfer Limit],” the ICC said.
“Moreover, as the commission noted in its Jan. 22 Order, IMEA has had sufficient time to address any consequence of its decision to take the FRR option for the 2018/2019 delivery year.”
The ICC offered two alternatives.
The first — also suggested in the Jan. 22 order — was for IMEA to request to be excused from the five-year stay-in provision for FRR participants so that it could participate in the capacity auction.
Alternatively, the ICC said, FERC could order PJM not to model the ComEd LDA separately.
“If the commission does choose to grant the waiver requested by IMEA, then the ICC requests that the commission also direct PJM to adjust the LDA reliability requirements upon which a separately stated [variable resource requirement] curve for the ComEd LDA would be calculated downward by the amount of internal reliability requirements that IMEA is excused from providing,” it said.
The Market Monitor also said IMEA’s waiver request could have adverse effects on other entities.
“IMEA made certain investments in external units to meet its capacity needs. IMEA made a voluntary election to submit an FRR plan,” the Monitor said. “IMEA made these decisions based on expectations that were not realized. IMEA’s unrealized expectations do not justify waiving the rules.”
PJM Not Opposed
PJM filed comments last week saying it does not oppose IMEA’s current waiver request. It noted that stakeholders have begun a review of the underlying issue regarding historical transfer rights. (See PJM MIC OKs Capacity Transfer Rights Query.)
“PJM cannot predict with certainty if and when a resolution will be reached through the stakeholder process,” the RTO said. “However, PJM anticipates that the stakeholder process will not have run its course in time to culminate in a filing with the commission to resolve the identified issue prior to the 2015 BRA.”