Two-thirds of PJM’s transmission owners have failed to file FERC-approved tariffs disclosing the methodology they use to calculate customer rates, PJM industrial customers told the Markets and Reliability Committee Thursday.
“There’s a vacuum in the tariff,” said Robert Weishaar, an attorney with McNees Wallace & Nurick LLC who represents several industrial energy users. “There’s a lack of transparency and a lack of accountability… Utilities sometimes change methodologies without notice.”
Weishaar will ask MRC June 27 to approve a problem statement that could result in requirements that transmission owners make tariff filings disclosing their calculation of total hourly energy obligations, peak load contributions, and network service peak loads. The calculations are used to allocate energy, capacity, and transmission cost responsibility among load serving entities.
Weishaar said the disclosures are required by the Federal Energy Regulatory Commission’s “rule of reason” as provisions that affect rates, terms, and conditions.
Weishaar’s proposal is intended to require Baltimore Gas & Electric, PECO Energy, PPL Electric Utilities, Dominion, Dayton, PEPCO, AEP, Duquesne Light Company, Rockland Electric, and Duke to file Attachments M-1 or M-2 to the PJM OATT disclosing their methodologies.
Weishaar said FirstEnergy, Commonwealth Edison, Public Service Electric & Gas, Atlantic City Electric and Delmarva Power & Light have already filed such disclosures.
Weishaar said the descriptions need to be detailed enough to allow LSEs to verify the accuracy of the calculations. Attachments “that merely reference methodologies contained in manuals posted on the transmission owner’s website do not adequately address the problem,” the problem statement says. “Because the necessary level of detail is not included in a FERC tariff, transmission owners may change methodologies, or inconsistently apply methodologies, with little recourse to LSEs and their customers.”
The problem statement also calls for PJM to establish default methodologies that would apply for zones without tariff attachments. It seeks a FERC filing within three months after assignment by the MRC.
