FERC has approved a nearly one-week extension of the comment period on PJM’s two filings to rework several areas of its capacity market following the conclusion of the Critical Issue Fast Path (CIFP) process in October (ER24-98, ER24-99).
The extension, issued Oct. 27, allows comments to be submitted through the end of Nov. 9, rather than the Nov. 3 deadline PJM sought. PJM Chief Communications Officer Susan Buehler said the extension does not impact the Dec. 12 effective date PJM requested in its filing and therefore would not impact its target to have changes in place for the 2025/26 Base Residual Auction, scheduled to be run in June 2024. (See PJM Files Capacity Market Revamp with FERC.)
The commission did not go as far as the Independent Market Monitor asked when it filed a request for comments to be permitted until Nov. 17, arguing that the intricacy of the filing warrants additional time. The request was supported by American Electric Power, American Municipal Power (AMP), Old Dominion Electric Cooperative, the PJM Industrial Customer Coalition and the Office of the Ohio Consumers’ Counsel.
“The Market Monitor requests an extension of time of 14 days because the filings in these dockets raise important, complex and intricate issues about the design of the PJM capacity markets. More time is required for preparation of an adequate response than the current deadline affords,” the Monitor wrote.
PJM responded that the Monitor and stakeholders should be aware of the changes being proposed in the filing through the months of discussion throughout the CIFP process. Extending the comment period would reduce the amount of time for the commission to evaluate the filing and comments to make a reasoned decision by Dec. 12.
“Specifically, PJM thoroughly discussed the proposed enhancements with all stakeholders, including the Market Monitor, through the Critical Issue Fast Path stakeholder process over a six-month period before the actual filing. Further, the PJM board issued a public letter to all stakeholders detailing the very proposals contained within the underlying dockets nearly one month ago on Sept. 27, 2023,” PJM wrote.
In its comments supporting the Monitor’s request, AMP wrote that the changes being considered could have substantial impacts on the capacity market that should be fully thought out. If full consideration of the proposals leads to the commission not issuing an order prior to the commencement of pre-auction activities, AMP recommended that the commission delay the auction schedule or order it to be run it under the status quo rules.
“If a delay becomes necessary, PJM should seek a revised date for that auction or run it under the existing rules, which have not been found to be unjust, unreasonable or unduly discriminatory. Neither the stakeholders’ nor the commission’s review of PJM’s complex filings should be cramped by PJM’s assertions that allowing two more weeks for comments will materially affect the auction schedule,” AMP said.
