In a unique joint vote, the PJM Operating and Market Implementation committees overwhelmingly endorsed an RTO package of revisions of its fuel requirements for black start resources.
The changes center around the creation of a new “fuel assured” classification of black start service providers that can demonstrate a higher level of reliability by reducing fuel availability concerns.
The PJM package, which was drafted with Brookfield Renewable and the D.C. Office of the People’s Counsel, received 76% of the 206 votes cast, while a proposal from the Independent Market Monitor received 9% support over the status quo, the RTO revealed during a special joint meeting of the committees Friday. The revisions will now go before the Markets and Reliability Committee during its meeting this Wednesday.
In addition to meeting existing black start requirements, the PJM proposal would require that a fuel-assured unit must either have adequate fuel storage for 16 hours of full run time, the ability to operate independently on two or more interstate pipelines, be directly connected to a natural gas gathering system, or be capable of providing 16 hours of full load operation with 90% confidence, as determined by the RTO.
The new fuel assured category would also come with a higher black start incentive, but it would come with a penalty of lost monthly revenue for generators that fail to meet the requirements. The increased incentives would cost an estimated $436,000 across all sites, PJM said during the Friday meeting.
The penalty remained a source of concern for some stakeholders who believe the risk isn’t matched with the payoff for becoming a fuel-assured unit.
The mitigation of eight high-impact black start sites in five transmission zones is also estimated to increase PJM’s annual revenue requirement for the service by $28 million per year, according to the RTO.
PJM staff said they will continue to tweak the revisions in the days leading up to the MRC vote to provide further clarifications and to add that gas generators submitting a fuel-assured application can demonstrate their ability to use two pipelines with actual usage in the past year, rather than needing to test each pipeline independently.
Voting on the IMM and PJM proposals opened after the OC meeting closed on Sept. 8 and closed Sept. 13. Stakeholders of both the OC and MIC could vote on the packages, though individual entities were limited to one vote overall and any duplicates were removed.
The Monitor’s package largely differed around the treatment of intermittent resources; while the PJM proposal would allow for their inclusion as fuel-assured units if they were determined to be able to meet the requirements with 90% confidence, the IMM language excluded them outright because the technology is not currently ready for them to provide power at the reliability needed for black start. (See PJM, Monitor Debate Black Start Fuel Requirements Proposals.)
The IMM also expressed concerns that the PJM package could result in overpayment for units that meet the fuel-assured requirements but don’t enter into the black start procurement process as such, allowing them to receive the benefits of being fuel assured without the risk associated with the penalties.