By Rory D. Sweeney

VALLEY FORGE, Pa. — PJM expects to implement its new fuel-cost policy rules on May 15, PJM’s Jeff Schmitt told the Market Implementation Committee last week. That would require generators to file any policy changes by March 15 to guarantee approval before the transition date.

Despite its looming implementation, the new rules continue to raise substantial questioning from stakeholders, which PJM is attempting to address with a FAQ document.

On Feb. 3, FERC largely accepted PJM’s proposed rule changes, siding with the RTO in requiring that policies be verifiable and systematic but not algorithmic, as Monitoring Analytics, the Independent Market Monitor, had proposed. (See FERC Seeks More Details on PJM Fuel-Cost Policy Proposal.)

The Monitor said the policies should be based on a simple average of broker quotes, bilateral offers or a weighted average index price posted on the Intercontinental Exchange (ICE) trading platform. The commission said the Monitor’s insistence that policies be “algorithmic under all circumstances” ignores how natural gas markets operate during stressed conditions that may make them illiquid, potentially understating generators’ real costs.

The Monitor contends the term “algorithmic” is misunderstood by PJM and by FERC. Algorithmic simply means a step-by-step process to get from a defined input to an output; it is therefore virtually impossible to have a verifiable policy that is not also algorithmic, it says.

Schmitt, the manager of market analysis, said PJM’s verification documents the steps taken daily to develop cost-based offers that do not change based on variables. He walked through the documents necessary for an approved policy, including filing a numerical example for each cost-based offer, likely on a spreadsheet, in the Monitor’s Member Information Reporting Application. While generators’ decisions won’t be challenged during the policy review, it’s critical for them to note whether they include emissions and variable operations and maintenance in their offers, he said. The Monitor has required a numerical example for all approved fuel-cost policies for more than two years.

Stakeholders expressed concern that the rules for dual-fuel generators appeared to not allow the flexibility to switch between fuels as desired, essentially requiring a forced outage. PJM and the Monitor said that the preferred resolution would be to create a cost-based offer for each fuel type.

FERC made “a pretty strong statement” on the separate fuel-type offers, and that “flies in the face of only needing one cost-based offer for dual-fuel units,” said Catherine Tyler Mooney of Monitoring Analytics.

“If we commit you on a gas schedule, and you run on oil, that risk exposure is 100% yours,” said Adam Keech, PJM executive director of market operations. “Our intention is not to put you on a forced outage when you have fuel.”

As long as a generator has an approved cost-based offer, “we think [it] should be able to switch as needed based on physical requirements,” Monitor Joe Bowring said.

PJM and the Monitor also addressed ongoing questions about their relationship in approving policies. The sides appeared to have settled their differences, as the tone of their comments were markedly less confrontational than they had been at recent meetings. (See Stakeholders Caught in PJM-IMM Dispute over Fuel-Cost Policy.)

“Once we’ve been through reviewing the policies, it makes it easier for PJM,” Bowring said. “I can’t think of one we’ve approved that PJM hasn’t approved. … It’s proven efficient to go through us first.”

“It’s been helpful for PJM folks to be in listening mode during the IMM negotiations,” said Stu Bresler, PJM senior vice president of operations and markets.

However, the Monitor’s late submittal of proposed revisions in Manual 15 regarding its role in the policy-review process created some heartburn among stakeholders. Before the agenda had even been discussed at the beginning of the meeting, Gary Greiner, director of PJM market policy at Public Service Enterprise Group, questioned why the Monitor had been allowed to file such a late addition. Bowring responded that when his group must respond to late filings, it becomes impossible to avoid filing them late himself.

Mooney explained that the Monitor’s proposed changes would enunciate the separation between it and PJM in the approval process.

“Working together is happening, but it should be clear that the reviews are separate,” she said.

Bob O’Connell of Panda Power Funds questioned why the Monitor elected to propose that it “may” provide its recommendation regarding policy approval to PJM in writing. He requested that it be changed to “shall.”

“Not having that recommendation in writing is troublesome,” he said.

Bowring responded that the Monitor plans to provide its recommendations in writing and that it is always very clear with market participants about issues with fuel-cost policies.