October 5, 2024
PJM Market Implementation Committee Briefs
Members OK Clarifications to Preserve ‘Physicality’ of Auction-specific Bilateral Transactions
The PJM Market Implementation Committee endorsed changes to Manual 18 clarifying rights and responsibilities under auction-specific bilateral transactions.

VALLEY FORGE, Pa. — The Market Implementation Committee last week endorsed changes to Manual 18 clarifying rights and responsibilities under auction-specific bilateral transactions.

The trades — which are intended to be physical, not merely financial — are expected to become more popular under the tougher Capacity Performance rules, PJM said.

Members had asked for clarification on issues such as which party is entitled to bonus payments, which is responsible for performance and whether members would be indemnified if a party to a bilateral deal defaults. (See “PJM Proposes Clarifications to Bilateral Transactions,” PJM Market Implementation Committee Briefs.)

To ensure the physicality of such deals, PJM offered the following clarifications: The rights and title to cleared capacity go to the buyer; the seller remains obligated to perform and to pay for any deficiencies; and the buyer will indemnify PJM Settlement if the seller defaults on its performance obligations. There were four abstentions.

Members to Study Ways to Prevent Black Start Billing Delays

The committee also approved a problem statement and issue charge to study annual revenue requirements for black start units.

The issue arose after a large number of such units entered service before their billing requirements were approved, leading to billing delays and large retroactive charges. Many were replacing retiring units. (See “Retroactive Black Start Billing Charges Focus of Proposed Study,” PJM Market Implementation Committee Briefs.)

pjm market implementation committee

Current Tariff language does not clearly define the review process for the costs of new units entering black start service outside of the annual revenue recalculation period.

“Basically, what we’re looking for is to put language in the Tariff and minimize the potential of billing delays,” PJM’s Tom Hauske said. “We’ve also added transparency for billing to the issue charge.”

The issue will be worked by the full MIC and is expected to take six months.

Members Debate Ways to Release Excess Capacity into Incremental Auction

The MIC heard three proposals for how to release excess capacity into the third incremental auction for the 2017/18 delivery year, to be held in February.

PJM must file its plans with FERC by November. The RTO’s proposal mirrors its approach for the 2016/17 third incremental auction. In that auction, PJM released 4,556 MW of capacity at an average price of $4.79/MW-day, netting $21,827/day. That reduced the RTO’s total reliability charge by 0.103%.

At the time that PJM received permission from its members and FERC for a Tariff change to release the capacity for the 2016/17 incremental auction, it did not address the subsequent auction because the Supreme Court had not yet ruled on whether demand response resources would remain in the wholesale energy markets. (See Supreme Court Upholds FERC Jurisdiction over DR.)

Last week, stakeholders who said they felt the released capacity was worth much more presented alternate proposals.

One came from Direct Energy, which proposed a sloped offer curve for the sale of an estimated 10,000 MW. This price floor would help prevent supply resources from being able to cheaply buy out of their obligation at load’s expense. (See “Price Floor for Incremental Auctions?”, PJM Market Implementation Committee Briefs.)

“We’re reducing reliability for everyone with little financial benefit in exchange,” Direct Energy’s Jeff Whitehead said. “In the 2016/17 third incremental auction, PJM sold excess capacity for nearly $5 [per MW-day] when the price in the rest of the RTO was $60.”

With a similar premise, Michael Borgatti of Gabel Associates presented a proposal on behalf of NextEra Energy that would make PJM’s sell offer into the existing third incremental auction equal to the transitional incremental auction adder that the RTO currently charges to load.

He provided an example showing that selling all 10,017 MW of excess capacity would produce $284,698/day in incremental revenue using the current charge of $28.42/MW-day. Selling the same capacity at $5.02/MW-day would bring in $50,285/day.

Even selling just half of that capacity at the higher price would bring in more money — $142,349 — than PJM could reap selling 10,017 MW at the $5.02/MW-day price.

Dave Mabry, of the PJM Industrial Customer Coalition, likened the release of excess capacity at $4.79/MW-day to a “fire sale,” suggesting that PJM consider keeping the capacity.

Added Steve Lieberman of Old Dominion Electric Cooperative: “I do believe there is a break-even point where we’d rather have the megawatts than the money.”

Independent Market Monitor Joe Bowring, who had to leave the meeting before the presentations, weighed in on the issue, saying simply, “You should not buy more capacity than you need. You should not sell it back for less than the price paid for it. It’s bad for customers.”

While the proposals addressed only the upcoming auction, Whitehead said he would be drafting a problem statement to study the issue on a long-term basis.

Special Session Planned on Fuel-cost Policy Development

The MIC will hold a special session July 27 to further detail PJM’s requirements for developing fuel-cost policies.

In June, FERC ruled that PJM “lacks provisions for sufficient review of cost-based offers and could permit a resource to submit inaccurate cost-based offers.”

It ordered PJM to add to its Tariff and Operating Agreement a requirement that generators submit fuel-cost policies that are approved by the RTO prior to submission of cost-based offers, including a penalty structure for those that file inaccurate information (ER16-372).

PJM is required to make a compliance filing in the docket by Aug. 16. (See “Members Delay Endorsement of Manual 15 Changes Regarding Definitions, Fuel Cost Policy,” PJM Market Implementation Committee Briefs.)

“We want to improve the process so that from a compliance perspective, PJM does not feel as exposed as we do today, given the way the process currently operates,” said Stu Bresler, senior vice president of market operations.

Participants prodded PJM to move more quickly and be more definitive with its rulemaking process.

Lieberman expressed concern over being forced to draft policies in compliance with manual changes that are only in draft form and not yet approved.

He explained after the meeting that, with approval targeted for mid-October and implementation likely in December, the timeline creates a “narrow” window to make and get approval for any necessary policy-submission changes prior to the compliance deadline. FERC’s order for a PJM compliance filing on the issue further complicates the situation, he said, because the commission’s ruling on that could come as late as mid-October and may require further filings from PJM.

“A member faces a lot of uncertainty prior to the start of winter and not a lot of time for resolution,” he said.

Bresler acknowledged that the timeframe is “compressed.”

Carl Johnson, who represents the PJM Public Power Coalition, pressed for adding clarity on the process to the Tariff, including expected review periods and potential remedies for unapproved submissions. He said his members want to know “what it is they need to supply to PJM and be sure that once they’ve done that, they’re going to get an approved policy.”

Bresler acknowledged the comments and reminded participants that they need to retain enough documentation to validate the input to the cost-based offer they submit. He confirmed that once a policy is approved and a cost-based offer submitted, if additional market-power issues arise, they will go before FERC.

Bowring said his staff has developed a policy template for every fuel type. He said his interest is market-power mitigation. PJM ultimately approves or rejects the policies, and the Monitor reviews them beforehand to determine if they are consistent with not exercising market power, he noted.

— Suzanne Herel and Rory D. Sweeney

PJM Market Implementation Committee (MIC)

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