By Rory D. Sweeney

FERC has issued a deficiency notice requesting more information from PJM on its proposal to incorporate more seasonal resources under Capacity Performance (ER17-367).

PJM has until Jan. 22 to respond to the Dec. 23 notice, which asks for more detail and specific examples about its plan to integrate seasonal resources into capacity auctions and incorporate them into operational protocols. The proposal would relax the current prohibition on seasonal resources aggregating across locational deliverability areas. In October, the RTO angered some stakeholders when staff announced at the annual meeting of the Organization of PJM States Inc. that it was filing its proposal despite a lack of stakeholder consensus. (See PJM to Seek FERC OK for Seasonal Capacity Proposal.)

“The proposed [Open Access Transmission Tariff] revisions appear unclear as to how PJM will determine which Seasonal Capacity Performance Resource offers clear an auction and which do not, and how PJM will ensure least-cost capacity procurement,” the commission wrote.

It asked if offers will be put in auctions individually or paired with a resource from the opposite season with an aggregated offer price. FERC also asked how PJM’s optimization algorithm will compare seasonal and annual resources, at what price the algorithm would stop clearing seasonal resources and how it will break ties if multiple seasonal resources submit identical offer prices.

The RTO’s proposal would allow resources to aggregate beyond LDA borders, with unmatched resources moving up to the next LDA level until a match is found.

FERC wanted more detail on how PJM’s cross-LDA aggregation concept would affect operational procedures, noting that the current proposal allows a seasonal resource to clear an auction, be counted toward the reliability requirement of an LDA other than the lowest level one in which it’s located and receive a clearing price less than that of the lowest-level LDA.

The commission also asked how a resource could be subject to a performance assessment hour in the LDA where it’s located, but receive the clearing price and help with the reliability requirement for the LDA in which it cleared the auction. It wanted to know how PJM plans to apply performance-related charges and credits and what rates will apply.

FERC also asked if the RTO intends for fixed resource requirement capacity plans that include seasonal resources to have equal quantity of summer and winter resources.

The commission wondered why PJM created a way for summer demand response to offer into auctions, but not for winter resources. “Why does PJM propose to exclude a winter-period demand resource from participating as a seasonal Capacity Performance resource?” it asked.

FERC also showed interest the differences between seasonal resources, asking PJM to opine on whether resources from one season or the other make a bigger difference on system reliability. It asked about any documentation PJM has on the topic.