By Rich Heidorn Jr.

A study released last week by the American Public Power Association estimates that PJM’s Capacity Performance rules will increase costs to consumers by $7.3 billion over the 2016-2019 delivery years — a tally in line with PJM’s own estimates.

But while PJM says the increased capacity costs will pay off in improved reliability and reduced energy market prices, APPA says the spending is not justified.

“PJM’s recent changes are an over-reaction to the ‘polar vortex’ and address a problem that was largely already addressed by PJM and market participants through various other measures,” said Joe Nipper, APPA’s senior vice president of regulatory affairs and communications. “As a result, bill-paying consumers will pay a lot more for the same product.”

The report was prepared by James Wilson, who also consults for state consumer advocates in PJM. Wilson said that the transition auctions recently held for the 2016/17 and 2017/18 delivery years resulted in $4 billion in additional costs to upgrade 60% and 70% of “base” capacity to Capacity Performance, respectively.

In addition Wilson estimates that the Base Residual Auction for 2018/19, which cleared at $164.77/MW-day, would have cleared at $124.23/MW-day if not for the requirement that 80% of the resources acquired be CP. That, Wilson said, increased the total BRA cost to $10.9 billion, an increase of $3.3 billion. Wilson’s quantitative findings are in line with PJM’s own calculations.

PJM said the incremental cost of the 2016/17 transition auction was $2.3 billion, slightly below the estimate of $2.5 billion to $3.6 billion PJM and the Independent Market Monitor had predicted in a joint analysis. The increase for 2017/18 was $1.7 billion, PJM said (versus an estimate of $3.1 billion to $4.2 billion).

The RTO said the 2018/19 BRA represented a $3.4 billion increase over the previous year’s auction, an amount that is within the $2 billion to $5 billion range PJM and the Monitor had expected. (See PJM Transition Auction Means Reprieve for Exelon Nukes.)

Different Conclusions

But while Wilson’s math generally agrees with PJM’s, he does not agree with the RTO over what ratepayers are getting for their money.

“Improved generator performance certainly would have resulted in much lower energy costs during the ‘polar vortex’ period of extreme cold in early 2014, when very high forced outage rates caused price spikes in the PJM energy markets,” Wilson wrote. “However, that very extreme period followed 19 winters during which such extreme cold did not occur, capacity was never scarce during winter and winter energy prices remained low in PJM.

“The polar vortex period revealed accumulated fuel and winterization issues at many plants. Apparently, many of these issues were resolved by the winter of 2015, when performance was much improved. The improved performance in winter 2015 reflects numerous steps taken by market participants and PJM following the polar vortex events, and well before Capacity Performance was approved or implemented.

“So it is unclear that CP is likely to have a substantial incremental impact on future energy prices. The expected value of the incremental impact of CP on future annual energy prices is likely an order of magnitude lower than the estimated impact on capacity cost developed in this report.”

“The combination of the changes to the [variable resource requirement] curve and the CP rule changes caused capacity prices in the 2018/2019 BRA to be higher than they otherwise would have been,” PJM said in a statement. “However, PJM is confident that the implementation of Capacity Performance has been the right approach to making the grid more reliable and benefiting consumers, and that consumers will, in fact, enjoy substantial benefits in the form of lower energy prices should extreme weather conditions materialize again as they have in the recent past. The results of the annual and transitional auctions demonstrate the market was ready and prices were competitive.”

While supply stakeholders are upset over CP’s costs, some generators are pushing to relax what they say are unduly harsh non-performance penalties. (See Generators Seek to Reopen PJM Capacity Performance Rules.)