Stakeholders Endorse Issue Charge on Dual-fuel Switching Downtime
PJM’s Market Implementation Committee endorsed an issue charge to explore how dual-fuel gas generators should reflect the downtime needed to switch fuels in their requirement to offer into the energy market.
Constellation’s Erik Heinle said the proposal would enhance reliability by ensuring resource limits are recognized by PJM. The issue charge was jointly sponsored by Constellation and PJM.
PJM’s Brian Chmielewski said, from a markets perspective, staff is interested in talking through the apparent inconsistencies between the parameters resources may submit and their limits. On the operations side, there’s interest in having more flexibility to preserve stored oil fuel.
Language was added to the problem statement ahead of the meeting to reflect stakeholder concerns about oil fuel inventories being depleted during winter events when gas prices are high. Since PJM’s scheduling software prioritizes cheaper offers, a dual-fuel unit might be asked to switch from gas to oil even when dispatchers would prefer to preserve stored fuel for later in the event.
Asked why the issue should be considered separate from ongoing work to consider how resources are committed, Heinle said Constellation is seeking to have the change in place ahead of next winter. He said because the issue charge is focused on a narrow issue and is likely to require only manual revisions, it could be advanced more quickly as a standalone item.
The issue charge was revised during the meeting to address stakeholder concerns that it was overly prescriptive around the possible solution and to reflect PJM’s desire to have more flexibility around when oil is burned.
PJM’s Kevin Hatch said resources going offline while switching fuels would be able to use the transition time as an exception from the must-offer requirement. The requirement is applicable to resources with a capacity commitment.
PJM Seeks Changes to LOC Eligibility for Flexible Resources
PJM presented proposed revisions to make flexible resources ineligible for lost opportunity credits (LOC) if they submit inflexible offers in the real-time (RT) energy market.
The changes would update the tariff’s definition of a flexible resource, inserting the phrase “all available schedules separately specify” ahead of “a combined start-up time and notification time of less than or equal to two hours; and a minimum run time of less than or equal to two hours.” A resource would be disqualified from receiving a LOC payment if it commits on a flexible schedule in the day-ahead (DA) energy market by submits inflexible offers in the RT market.
The issue stems from how PJM’s intermediate term SCED (IT SCED) software would evaluate an inflexible offer from a flexible resource. If the unit was committed in the DA market on a flexible cost-based offer because it would fail the market power mitigation test under a modeled transmission constraint, the start-up and notification parameters of an inflexible offer could be longer than the lookahead IT SCED uses. If the constraint does not manifest, IT SCED would be unable to schedule the unit.
PJM Presents Quick-fix Manual Changes for Fuel Cost Policies
PJM presented a quick-fix proposal to rework how it calculates penalties when a resource submits a cost-based offer that violates its fuel cost policy. The quick fix process allows a problem statement, issue charge and proposed solution to be considered concurrently.
Because LMP is a component of the penalty formula, the penalty could be negative if prices are negative when the violation is identified — effectively becoming a credit.
The proposed changes to Operating Agreement Schedule 2 would set the penalty at the greater of the existing rate or zero.
Monitor Investigating Fractional Clearing Contributing to High Regulation Prices
The Independent Market Monitor is looking into situations when a marginal resource being assigned a regulation commitment below 1 MW leads to high regulation clearing prices.
Chief Economist Howard Haas said costs can “explode” when partial or fractional commitments (between 0.1 and 1 MW) are the marginal resource in the regulation market — depending on offer parameters and realized differences between market clearing LMP forecasts and realized LMP lost opportunity.
The Monitor is working with PJM to optimize how resources’ parameters interact with the regulation market design. Differences between the economic dispatch range and the regulation range and between bid in ramp and actual ramp may make regulation prices highly sensitive to differences between forecast and actual LMPs.
One of the Monitor’s initial recommendations is for a resource’s Reg Max parameter to be tied to its energy market Eco Max parameter. LOC would be determined on the basis of Reg Max falling below Eco Max.
PJM’s Michael Olaleye said the regulation redesign implemented in October 2025 has made price formation and procurement more efficient and positioned the market for increased renewable penetration. Uplift has fallen from 14% to 2% and the market now more accurately captures the cost for a resource to reduce its output for energy or regulation purposes.
He stressed there are no errors in how PJM clears or prices regulation resources and staff is monitoring the optimization engine results for improvements.
Manual 15 Biennial Review Changes Endorsed
Stakeholders endorsed revisions to Manual 15: Cost Development Guidelines intended to clarify how to update the format of the variable operating and maintenance (VOM) adder and the functioning of the opportunity cost calculator.
Under the changes, resource owners may change the VOM format only once per calendar year at the time of submission. Subsequent changes would not be permitted until the start of the following calendar year.
The changes state that, when simulating the hours of operation with the greatest energy market revenue excluding short run marginal costs, the opportunity cost calculator will model a unit as being dispatched between its economic minimum and maximum.
An additional paragraph states the adders the calculator produces are normally a dollar per megawatt-hour value, except when environmental or operational limits limit how often a unit can be started or operated during a compliance period. In cases when the resource is limited by starts per period, the adder is a dollar per start value and can only be applied to start-up costs. If the limit is run hours per period, the adder is dollars per hour and can only be included in no-load costs.
1st Read on Manual 11 Changes to Advance Commitment Offer Selection
PJM presented revisions to Manual 11: Energy & Ancillary Services Market Operations to distinguish between offer selection for advance commitments and resources scheduled in the day-ahead market.
Resources with start-up or notification times exceeding a day — those with advance commitments — would be scheduled on their cheapest cost-based offer available at the time they are committed, with updates not permitted. Resources with shorter start-up or notification times would be scheduled on their cheapest cost-based offer at the close of the day-ahead market.

