By Suzanne Herel

PJM and its Independent Market Monitor asked FERC Thursday to revise Capacity Performance rules to address concerns that generators might ignore dispatch instructions to avoid penalties.

FERC’s June 2015 order approving PJM’s tougher capacity requirements directed the RTO to eliminate language that would allow generator parameter limitations to be used as an excuse for nonperformance (ER15-623, EL15-29). The order argued that if resources were held only to parameter limits based on their physical characteristics, those that were less flexible would be able to avoid nonperformance charges more readily than more flexible units. (See What is Changing in PJM’s Proposal?)

However, PJM said in a Dec. 22 informational filing that eliminating any consideration of parameter limits from penalty calculations might lead some generators to self-schedule at maximum output in anticipation of a performance assessment hour, ignoring economic dispatch.

In a joint statement last week, PJM and the Monitor asked the commission to allow consideration of parameter limits but incorporate the Monitor’s recommendation that the limits be based on original equipment manufacturer (OEM) specifications rather than on historical performance data. This, they said, would ensure that resources not escape penalties “as a result of economic decisions about maintenance and investment.”

Under the proposal, resources would not face nonperformance charges if their operating parameters complied with the OEM limits and they followed dispatch orders. Resources that offered parameters less flexible than the OEM specifications would be ineligible for uplift and could be vulnerable to penalties.

They also asked FERC to approve the Monitor’s proposal that parameter limits be defined for ramp rate and boiler temperature retention times.