IMEA Reaps Limited Relief from Capacity Rule Change
IMEA has been working with PJM staff all year to find a way to continue using external capacity to fulfill its internal resource requirements.

By Suzanne Herel

WILMINGTON, Del. — The Illinois Municipal Electric Agency, which had been working with PJM staff all year to find a way to continue using external capacity to fulfill its internal resource requirements, finally received the approval it had been seeking last week.

Its relief was short-lived, however.

Because the clearing price for the ComEd locational deliverability area separated from out of the RTO’s footprint in the Base Residual Auction last month, the new rules approved by the Markets and Reliability Committee on Thursday only exempt IMEA until the next auction.

“IMEA will be considering how best to manage its resources and its loads over the next several months,” Troy Fodor, vice president and general counsel, told RTO Insider.

“The [reliability assurance agreement] provisions approved by the MRC … solve a problem with the [fixed resource requirement] alternative that IMEA believes needed to be fixed,” he said. “The fact that the auction prices for the ComEd LDA have now separated for the first time does affect IMEA’s ability to fully benefit from the revised RAA provisions, but they are still a positive improvement.

“Moving forward, IMEA will continue to watch for opportunities to have a voice on future decisions regarding self-supply and the proper treatment of external resources.”

The rule change allows load-serving entities to meet their internal capacity requirements using historic resources under certain conditions: The percentage internal resource requirement is enforced only if the LDA has been separately modeled due to certain triggers; an FRR entity is permitted to terminate its FRR alternative election prior to meeting the minimum five-year commitment period requirement under certain conditions; and first-time elections of the FRR alternative are due four months prior to a Base Residual Auction instead of the current two-month deadline. (See “Members OK Rule Change on External Capacity Transfer Rights” in PJM Market Implementation Committee Briefs.)

Stu Bresler, PJM senior vice president for markets, said that while ComEd did bind as a constrained LDA in the auction, “Making these changes puts FRR entities on equal footing if this happens anywhere else. It still has applicability in the near term.”

FERC in January rejected IMEA’s request for an extended waiver that would allow it to use generation resources outside the ComEd LDA to meet its internal resource requirement in serving its Naperville, Ill., load. (See FERC Denies IMEA Request for Extended Waiver on Capacity Obligation.)

That waiver had been granted in May 2014 for the 2017/18 delivery year after the ComEd LDA was modeled for the first time with a separate variable resource requirement curve.

Capacity MarketIllinoisPJM Markets and Reliability Committee (MRC)Reliability

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