By Rory D. Sweeney

WILMINGTON, Del. — PJM again deferred a vote on the grid operator’s proposed pseudo-tie pro forma agreement last week after stakeholders complained that revisions were not made public until the night before the Markets and Reliability Committee meeting.

“While I agree you’ve read the documents [during presentations at previous meetings], I don’t agree that you’ve read the same documents … so, in a sense, they’re multiple first reads,” American Municipal Power’s Steve Lieberman said. “People are trying to keep up with the speed at which you’re making changes, but it’s difficult.”

CFO Suzanne Daugherty, who chairs the MRC, agreed to the delay. She said the late changes reflected language PJM and MISO had agreed to just two days prior to the meeting.

PJM had postponed a vote on the agreement at the May MRC meeting, citing ongoing negotiations with MISO, which had been reluctant to sign PJM’s proposal. (See “Pseudo-Tie Discussion Postponed to Continue Negotiations with MISO,” PJM Markets and Reliability Committee Briefs.)

PJM’s Jacqui Hugee said the RTO resolved its issues with MISO by incorporating language into their Joint Operating Agreement obviating the need for the grid operators to agree to each other’s pseudo-tie rules. MISO has filed its own agreement at FERC and isn’t requesting approval from other grid operators or balancing authorities, she said. Other balancing authorities, including Duke Energy, the Tennessee Valley Authority and SPP, have been willing to sign PJM’s agreement.

“Whether [the unit is being tied] into PJM or into MISO, the same rules are going to apply,” she said.

Some stakeholders, including Independent Market Monitor Joe Bowring, remained concerned about language that suggested that the native balancing authority (BA) would control redispatch of pseudo-tied resources in certain situations, including non-emergencies.

Hugee said the language complied with NERC standards. Mike Bryson, PJM’s vice president of operations, explained that the RTO would maintain control during performance assessment hours and resources would be rewarded or penalized like any other resource under Capacity Performance requirements. In other situations, the native BA would set certain operating limits, scenarios that are also addressed in PJM’s existing market-to-market flowgate procedures, he said.

“If PJM is experiencing an emergency and MISO is experiencing an emergency at the same time, MISO — according to NERC standards — has the authority to dispatch that resource because it’s in their balancing authority. So what will happen is that resource will probably be penalized because they’re not available to PJM during that performance assessment hour, assuming PJM would have called on them,” Hugee said. “Everybody knows that’s a risk they take before they pseudo-tie.”

“That means that a pseudo-tied unit is not really equivalent to an internal unit, which is what the issue has been all along,” Bowring responded. “I could certainly imagine someone arguing that they shouldn’t have to pay a penalty because they were following NERC procedures and following dispatch instructions.”

“They can argue it, but we have a provision that says if you are a Capacity Performance resource and you’re not there when we call on you, you’re going to get a penalty,” Hugee said. “The same Capacity Performance rules apply to everybody, whether you’re physically internal or you’re tying into PJM from another balancing authority.”

PJM also incorporated in the agreement a provision allowing it to suspend a resource. If the RTO intends to cancel an agreement, it likely won’t want the tied unit operating during the 60-day notice period for cancellation, Hugee said. She also introduced an accompanying agreement for dynamic scheduling but said that will be brought for vote at a later meeting.

AMP’s Lisa McAlister asked how the agreement will affect collecting congestion charges from the resource to the RTO border and if it resolves the double-charge issue. Hugee said that topic isn’t being addressed in the current agreement and that it will be filed in concert with MISO as JOA revisions in a separate docket at FERC. PJM believes the congestion charge filing is likely to be challenged as there are already five pending complaints on the issue, Hugee said. The RTO hopes the filing on agreements will not be challenged and may win commission approval even without a quorum.

Hugee said that, while the Tariff and JOA revisions for the agreement will require separate dockets, PJM wants to file all of them contemporaneously and have them reference each other.

“The plan is to file one big packet because I’d like to resolve everything at once, and it makes sense to do it that way,” she said. “We [would] … explain to FERC that it’s very important that all of these things get approved [together] … so that we can alleviate that concern about getting out of sync of one getting approved and the other not getting approved.”

Hugee said that if the agreement needs to be “tweaked” for individual units, she would ensure it remains in accordance with the JOA.

Carl Johnson, representing the PJM Public Power Coalition, was the first to suggest deferring the vote. He said he couldn’t vote in favor of the package at the meeting because some of his members hadn’t yet reviewed the current version of some of the documents, but that he “probably could get to a point where we could support it” by the MRC’s July meeting. Lieberman said AMP also couldn’t vote in favor of the changes at the meeting. He said it is still attempting to figure out how PJM handled the revisions it had recommended, which it couldn’t find in the current versions.

Hugee said PJM and MISO have committed to filing the agreement with FERC by July 27, the same day as the next MRC meeting.

“Maybe we’ll have to ask them for a couple of days,” Daugherty said, then announced that PJM would be deferring the vote until the July MRC and Members Committee meetings.