Members last week agreed to create a senior task force to fix the underfunding of Financial Transmission Rights (FTRs) following a debate over the role of Auction Revenue Rights.
The Markets and Reliability Committee approved a problem statement and issue charge to tackle the issue.
PJM says over-allocation of Stage 1A ARRs have become the biggest cause of the problem, responsible for $420 million of underfunding for planning year 2013/14, 73% of the total. That was up sharply from 2012/13, when ARRs caused only 26% of underfunding, or $75 million. (See chart below.)
PJM agreed to modify the task force’s initiating documents to include an evaluation of the causes of underfunding after several stakeholders raised concerns that ARRs were being unfairly singled out. ARRs are allocated annually to firm transmission service customers and entitle them to receive a share of the revenues from the annual auction of FTRs.
Ed Tatum of Old Dominion Electric Cooperative objected to the original problem statement, which he said improperly included a solution that targeted ARRs.
ARRs are “a touchstone issue for the load-serving entities,” Tatum said. “We don’t believe the numbers [cited by PJM] reflect the actual impact of the problem … We think it’s a much lower number and we’d like to understand how PJM calculated it. It’s more than likely there are other, more significant causes of the underfunding.”
Andy Ott, executive vice president for markets, said PJM wanted to keep the issue scope narrow to avoid the “food fights” of the past.
PJM says more than 15% of Stage 1 historical generation (25,544 MW) has retired or submitted deactivation notices since the ARR allocation process was designed. “This is the biggest reason for underfunding,” said Harry Singh of Goldman Sachs. “You’re allocating things that don’t exist.”
Singh said a failure to address FTR over-allocation could jeopardize the Commodity Futures Trading Commission’s order exempting FTRs from the agency’s jurisdiction. The order said FTRs must “be limited by the physical capability of the … transmission system.”
The problem statement also identified other underfunding causes, including external loop flows, maintenance- and construction-related transmission outages and the creation of temporary interfaces to capture operating procedures — such as the dispatch of demand response — in locational marginal prices.
The RTO introduced FTRs in 1999, intending them to provide a financial hedge against the costs of day-ahead transmission congestion.
Singh said that load-serving entities “should also care about having good hedges.” Those who oppose solutions to the problem “are not doing a favor for the people they work for,” he said. Over-allocation to a handful of load-serving entities amounts to a subsidy by other LSEs, he said.
Ott said the task force, which will report to the MRC, should complete its work by Oct. 31, before the next annual FTR auction. “If we don’t deal with it by October, then we miss a whole year,” he said.