PJM’s Electric Gas Coordination Senior Task Force has opened a poll on a proposal aimed at aligning components of the RTO’s energy market with gas pipeline operations. 

The joint package sponsored by PJM, Dominion Energy and Gabel Associates would add intraday real-time commitment runs to the day-ahead market ahead of the three gas nomination cycle deadlines and notify gas-fired generators that they are being committed with adequate time for them to nominate for fuel in the subsequent cycle. In turn, generators would be asked to notify PJM if they have procured fuel or expect to do so in time to be scheduled. 

Speaking during a Jan. 30 task force meeting, PJM’s Brian Fitzpatrick said the proposal is focused on improving situational awareness over the status of gas generators and reducing the need for operators to check in with the approximately 300 such resources during emergency conditions. 

“Really it’s about reducing the unknowns and identifying where there are risks,” he said. 

Having multiple commitment periods throughout the day corresponding to the gas nomination cycles would give PJM insights into when resources are likely to be available, such as whether they have obtained fuel for evening peaks. 

Voting on the proposal will be open for around two weeks, and results are expected to be discussed at the task force’s Feb. 29 meeting. This is the second poll the task force has held, following a round in which six packages failed to receive majority support in October. 

The highest vote-getter was a joint proposal sponsored by PJM and Dominion, which would have required gas generators to confirm to PJM that they had procured adequate fuel to meet their day-ahead commitment. It would have also required that resources that had not procured fuel during a PJM cold weather alert verify gas availability with pipeline operators twice a day and reflect any shortages as a forced outage. 

Michael Borgatti, Gabel senior vice president of RTO services and regulatory affairs, said he’s hopeful that the joint proposal can be a compromise between all those previously brought to the task force. 

The revised package now under consideration states that generators should confirm the availability of their fuel supply and reflect that in their parameters, but Fitzpatrick said it would not carry any enforcement or penalties. 

Brock Ondayko, director of RTO operations for AEP Energy, said that even without any specified penalties at PJM, generators that report incorrect information — such as stating that a unit has purchased fuel and then experiencing an interruption in supply — could run into compliance issues with FERC. 

Independent Market Monitor Joe Bowring said the fuel reporting component is vague and would be ineffective at providing true situational awareness without stronger requirements. In particular, he said allowing generators to state that they expect to have fuel available would add too much ambiguity to the process. 

“It is creating false confidence, so I really don’t see the point of this,” he said. “In my view this is potentially worse than not having it. … The straightforward approach is to have a mandatory requirement to report whether a unit has procured gas. Combining the voluntary reporting in the proposal with reporting about what generators expect makes that part meaningless or worse than meaningless. A rule based on a generator’s expectation is an unenforceable rule.” 

Vistra Director of PJM Market Policy Erik Heinle said the deadlines for reporting information to the RTO could distort the gas market if a large number of generators are trying to get contracts in place at the same time. 

Bowring also said that the proposal would be a significant change to PJM’s day-ahead markets that has not included a careful review of how the interaction with markets would work and the likely consequences. 

“Issues including whether the commitment process prior to the day-ahead market would use the same software and have the same objective function have not been addressed. Issues about how market payments and uplift payments would be defined and the treatment of commitments prior to the day-ahead market that carry forward into the next day have not been carefully thought through. The Market Monitor supports increased situational awareness and supports inclusion of offer parameters that are consistent with pipeline rules, but this proposal is being rushed to a vote before important questions have been asked, let alone answered,” Bowring said.