By Suzanne Herel
The Federal Energy Regulatory Commission should reject Public Service Electric and Gas’ claim that PJM erred in its solicitation of a stability fix for Artificial Island, the RTO said in a March 11 filing (EL15-40).
Barring that, the commission should wait to rule on the matter until PJM has chosen a bidder for the project, which it expects to do “in a matter of months,” it said.
If FERC does find merit in the complaint, PJM asked that it not adopt PSE&G’s “draconian remedy” of reposting the project, which would require the RTO to “throw out two years of PJM work.”
Artificial Island, home to the Salem and Hope Creek nuclear reactors, is the second largest nuclear complex in the country. Historically, special operating procedures have been employed to maintain stability in the area. However, according to PJM, those procedures have become increasingly difficult to implement while respecting the system’s other operational limits.
PJM issued a solicitation for a stability fix — its first competitive transmission project under FERC Order 1000 — in April 2013.
PJM staff initially selected PSE&G as the winning bidder but reopened the process after being widely criticized for its choice by losing applicants and environmentalists.
PSE&G is one of four finalists for the job, along with Transource Energy, Dominion Resources and LS Power. In January, it lodged a complaint with FERC accusing PJM of breaking its own rules in refereeing the competition by allowing contenders to modify their proposals. (See PSE&G: PJM Broke the Rules in Artificial Island Solicitation.)
In its response last week, PJM said the Artificial Island solicitation process began months before the Order 1000 procedures were finalized.
“Because the Artificial Island solicitation commenced prior to the effective date of the Operating Agreement and Tariff provisions that establish PJM’s new competitive solicitation Tariff, PJM was not bound to those provisions in conducting the solicitation,” it said.
“Instead, PJM has been conducting the Artificial Island solicitation consistently with its commission-approved transition for implementing its Order No. 1000 process.”
Even if the Order 1000 provisions were deemed to apply, PJM said, PSE&G “has not shown that PJM has acted inconsistently with its Order No. 1000 process and, similarly, has provided no basis for the drastic and self-serving remedy it seeks.”
PJM also defended its right to combine aspects of various proposals, saying that if PSE&G’s “interpretation of the Tariff were accepted, anytime that PJM cannot conclude that a picture-perfect project has been proposed that is the ‘more efficient or cost-effective’ solution, PJM must repost the violation and accept rebids or, if there is no time to repost and rebid, give a PJM-specified project to an incumbent.”