By Christen Smith
In a ruling issued Feb. 19, FERC rejected the stakeholder-approved mechanism submitted for inclusion in PJM’s Operating Agreement and Tariff that would have implemented a process for market sellers seeking cost recovery for certain gas contingencies associated with fuel-switching instructions from the RTO (ER19-664.)
PJM’s filing would have become effective Dec. 21 and allowed generators to request cost recovery from FERC across nine different categories: park-and-loan service charges; overrun charges; exceeding maximum daily quantity; exceeding minimum/maximum storage balance; imbalance cash-out charges; disposal of gas and related products costs; other gas balancing costs; start-up costs; and alternate fuel costs.
FERC described PJM’s definition of “penalty” — costs that are designated as such in the pipeline or local distribution gas company tariff and imposed by the applicable pipeline or company — as “unreasonably narrow and unsupported.” The commission said pipeline tariffs delineate between penalties and the RTO’s proposed categories in different ways, meaning what appears to be relevant fuel-switching costs for one pipeline could be considered a penalty for another. The commission also faulted PJM for not including events that might trigger fuel-switching directives in its Tariff and for lacking established procedures for dealing with such contingencies through existing market design.
“Continuous communication and coordination between the RTO, the gas pipeline operator and the relevant generation owners can be critical to ensure the reliable operation of both systems,” FERC concluded in its ruling. “Given this lack of clarity, PJM’s proposal does not reasonably ensure that coordination occurs prior to a generator’s switching to an alternate pipeline.”
The D.C. Office of the People’s Counsel crafted the rules and compensation plan detailed in the filing after earning a majority of stakeholder support at the December meeting of the Markets and Reliability Committee. (See “Gas Pipeline Contingencies,” PJM MRC/MC Briefs: Dec. 6, 2018.)
The supermajority vote signaled a major victory for load interests who were opposed to the Calpine-authored plan endorsed at the Market Implementation Committee in November. That proposal would have developed a formula for cost recovery to be filed with FERC that did not include pipeline penalties. (See “Gas Pipeline Contingencies,” PJM Market Implementation Committee Briefs: Nov. 7, 2018.)
Jeff Shields, a PJM spokesperson, said Friday that staff are still considering next steps.
“We continue to believe that this is an important issue to resolve and is another step in improving gas-electric coordination,” he said. “We are evaluating the order and our options for working with stakeholders to rectify the issues FERC found with our filing.”