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June 2, 2024

Manual Changes Approved by the Market Implementation Committee on June 5, 2013

The Market Implementation Committee Wednesday approved changes to Manual 11 affecting regulation rules, hydropower generators, station manning and shortage pricing. The changes go next to the Markets and Reliability Committee.

Reason for changes: Clarifications, error corrections and changes to conform with other manuals.

Impact:

The changes:

  • Clarify and add conforming language for regulation rules:
    • Resources cannot clear for both RegA and RegD within an operating hour (Section 3.2.9)
    • Changes language to conform with M12: Regulation resources must return to their regulation range within 10 minutes of the end of a synchronized reserve event (Section 4.2.12). The current language calls for a return within two minutes.
  • Clarify hydropower units’ opportunity cost when providing synchronized reserve:
    • Hydro units providing Tier 2 synchronized reserve receive lost opportunity cost payments only when they are held to condense mode rather than off-line. (Section 4.2.7)
  • Corrects and clarifies Attachment C regarding cost offers and station manning:
    • Removes language stating that a resource can submit only five cost offers for energy. The actual limit is “in the 60s,” said Rus Ogborn, of PJM.
    • Clarifies the compensation rules that apply when PJM requests resources to be manned in order to start units more quickly. Units required to provide staffing will be compensated even if the resource is not called on because system conditions change.
  • Clarifies and cleans up revisions for Shortage Pricing rules. Changes were made to clarify existing rules and remove errors in the current text.

PJM contact:  Rus Ogborn

Industrials Call for Transparency in Transmission Owner Calculations

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.

Manual Changes Approved on May 30 at the PJM MRC

The Markets and Reliability Committee gave final approvals to the following manual revisions at their meeting this past Thursday.

  • Electronic Notifications for Curtailment Service Providers: Changes to Man­u­als 1 and 18 will imple­ment an auto­mated process that will allow Cur­tail­ment Service Providers to pro­vide oper­a­tional data to — and receive dis­patch instruc­tions from — PJM. The new Load Response System (eLRS) process replaces the current manual methods, which rely on email and spreadsheets.

See “Manual Changes to Implement Electronic Notification System.”

  • Resid­ual Zone Pric­ing: Resid­ual Zone Pric­ing will replace phys­i­cal zone LMPs for real-time load effec­tive June 1, 2015. A Resid­ual Zone is an aggre­gate of all load buses in the phys­i­cal zone, exclud­ing load priced at nodal locations. The change was endorsed by the Mem­bers Com­mit­tee in Feb­ru­ary 2012 and approved by FERC in Docket ER13-347.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • East Ken­tucky Power Coop­er­a­tive: PJM needs to add the East Ken­tucky Power Coop­er­ative zone into PJM mar­kets man­u­als to accommodate the coop’s inte­gra­tion into PJM, effec­tive June 1.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • NERC Reliability Standards: PJM needs to amend M-36: System Restoration to reflect NERC Standards EOP-005-2 (System Restoration Plans) and EOP-006-2 (Reliability Coordination – System Restoration).  Updates for consistency with other RTOs; updates underfrequency load shed tables; incorporates recommendations from RFC/SERC audit, and adds specific references to transmission operator restoration plans.
  • Manual 03A:  Energy Management System (EMS) Model Updates and Quality Assurance: The changes include numerous edits for updates and clarity.

See “Manual 03: Transmission Operations.”

  • Regulation Market Cost-Based Offers:  New rules imple­mented in Octo­ber require reg­u­la­tion offers to include capa­bil­ity (cost, in $/MWh to reserve a resource for reg­u­la­tion) and per­for­mance (costs of track­ing the reg­u­la­tion sig­nal in miles/MW).  Pre­vi­ous rules, as defined in Man­ual 15, did not include per­for­mance costs.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • Manual 35: Definitions and Acronyms: Adds language to Economic Maximum and Economic Minimum definitions; changed Operations Analysis Working Group to Operations Assessment Working Group; Replaced TTV4TF (TO/TOP Version 4 Task Force) with TTMS (TO/TOP Matrix Subcommittee).
  • NERC standard PRC-023-2: Updates to Manual 14B: PJM Region Transmission Planning Process are required to implement standard PRC-023-2 (Transmission Relay Loadability). PJM annually develops a transmission facility list to comply with NERC criteria.
  • Manual 03: Transmission Operations: Semi-annual update to incorporate procedural changes.

Capacity Auction Fallout: EnerNOC, Utility Stocks Hit; NJ Subsidy Strategy in Question

By Rich Heidorn Jr.

With its market-leading status in demand response, blue chip clients and international expansion plans, EnerNOC Inc. may be a good long-term investment play on the Smart Grid. But as the last week demonstrated, it’s not for the faint of heart.

EnerNOC’s stock is down 25% — a loss of nearly $134 million in market capitalization — since PJM announced the results of its 2016/17 capacity market auction May 24. The auction saw a 56% drop in RTO-wide capacity prices and a 16% drop in the volume of DR clearing as new natural gas-fired plants and imports increased their market shares.

Stocks of PJM-based utilities also have fallen since the auction, with Exelon Corp. and FirstEnergy Corp. each down 9%.

The auction also may scramble New Jersey’s efforts to subsidize new capacity after a 660-MW natural gas generator planned by NRG Energy failed to clear the auction for the second time despite the state incentives.

No one felt the impact of the auction results more than EnerNOC. Demand response was responsible for 88% of the company’s $278 million in 2012 revenues, with PJM representing 40% of sales for the year (see PJM, FERC Rules Buffet EnerNOC).

Analyst Reaction

EnerNOC’s stock dropped Tuesday after Credit Suisse, one of the underwriters of its 2007 initial public offering, downgraded it from outperform to neutral. Needham & Company cut its price target on EnerNOC shares to $18 two days later while maintaining its buy rating.

Raymond James saw it differently, upgrading the company Wednesday from an outperform rating to a strong-buy rating with a $20.00 price target. And Pacific Crest, which had raised its price target from $22 to $24 on May 8, reversed course Wednesday, dropping the company’s rating from outperform to sector perform.

EnerNOCs-growing-pains-revenues-net-incomeMotley Fool columnist Travis Hoium wrote Tuesday that the market had overreacted. “Is the company really worth nearly $100 million less today than it was yesterday? Not to a long-term investor, so I don’t think today’s move changes the investment thesis, and if you’re bullish (which I’m not) this should be viewed as a discount more than a reason to panic today.”

EnerNOC did not respond to a request for comment yesterday.

In a press release last week, the company said it cleared 4,400 MW of capacity, a small drop from the 2015/2016 auction, and increased its DR market share in PJM to more than 35%.

“Although we are obviously disappointed with the clearing prices in this auction, it is important to put Friday’s outcome into a broader perspective,” Chairman and CEO Tim Healy said in the statement. “Our results are reflective of our ongoing strategy to strike the right balance between growth and profitability and to not simply be a price-taker where we would be managing demand response resources at a loss.”

The company said it will continue its efforts to increase its revenues from non-DR products and from regions outside PJM.

History

Founded in 2001, EnerNOC has grown by focusing on seven categories of commercial and industrial customers: technology, education, food sales and storage, government, healthcare, manufacturing/industrial and commercial real estate. Its customers include AT&T, General Electric, Pfizer, Sears, Shop Rite and Whole Foods Markets.

EnerNOCs-bumpy-rideThe company went public in 2007, with shares ending its first trading day at $31. Those who bought at that price had lost about half of their investment through yesterday. The company has had only one year of profitability (2010) as it has acquired five companies and expanded to Australia, New Zealand and the United Kingdom.

Competition

The company said in its 2012 10-K that it was seeing “increasingly aggressive pricing” on DR from its competitors, and that it might be forced to increase the amount it pays to C&I customers to participate.

Those competitors include privately held Comverge, Inc., whose revenues are about half that of EnerNOC, and Energy Curtailment Specialists. ECS, which operates only in North America, has about 2,000 MW of DR under contract, less than a quarter of that claimed by EnerNOC.

The company also cites competition from natural gas peaking plants, which have benefited from the increased supplies and low price of shale gas.

Nearing the Import Limit

PJM said increases in new gas-fired generation and imports were the biggest contributors to the drop in capacity prices. Most of the nearly 90% increase in imports clearing came from west of PJM.

At the Markets and Reliability Committee meeting Thursday, Andy Ott, PJM’s senior vice president for markets, said the almost 7,500 MW of capacity that cleared from outside the RTO “is pretty close to the limit” on PJM’s import capability.

Ott said almost two-thirds of the imports has firm transmission into PJM and another 20% has firm transmission on part of its path. “It [imports] does have some risk, but we don’t view it as a large risk,” Ott said.

Impact on Utility Stocks

Transmission constraints caused prices to separate within the RTO: Prices in the MAAC region cleared at $119/MW-day, double the RTO’s $59, while the Public Service zone in New Jersey cleared at $219, more than three times as high.

There also was a separation in the response to utility stocks following the auction.

Prices dropped 68% in ATSI, home to FirstEnergy in northern Ohio and PennPower in western Pennsylvania. FirstEnergy’s stock is down 9% through yesterday.Share-Price-Pct-Change-May-23-June-3

Prices in MAAC dropped 29% and utilities in the region (Pepco Holdings, including Atlantic City Electric and Delmarva Power; Exelon’s PECO and Baltimore Gas and Electric, PPL, ConEdison’s Rockland Electric Co.) fell from 3% to 9%.

New Jersey Impact

Prices in the Public Service region increased 31% while PSE&G’s stock dropped 3%.

New Jersey has agreed to provide almost $3 billion in subsidies to three proposed natural gas plants in the state, but one of them, NRG Energy’s proposed plant in Old Bridge, N.J. failed to clear the capacity auction for the second year in a row.

NRG spokesman David Gaier declined to say yesterday whether the company would proceed with the project. “We’re gong to look at our options over the next several weeks,” he said.

PJM Seeks OK to Suspend Day-Ahead Market After Internet Outage

PJM will seek stakeholder approval this month for contingency plans to respond to an Internet outage that forces the RTO to suspend the day-ahead market.

PJM has no procedures for dealing with an Internet outage that could prevent the RTO from receiving participant data needed to solve the day-ahead market. Under the proposed tariff changes outlined to the Markets and Reliability Committee Thursday, all mar­ket set­tle­ments would be done in real time.

The pro­ce­dure requires changes to sec­tions 1.10.8 and 1.10.9 of the Open Access Trans­mis­sion Tar­iff, includ­ing clar­i­fi­ca­tion that the rebid period will be from 4 p.m. to 6 p.m. but may be revised by PJM if the clear­ing of the day-ahead energy mar­ket is sig­nif­i­cantly delayed.

The MRC will vote on the changes June 27.  (See “PJM Work­ing on Con­tin­gency Plan for Loss of Inter­net.”)

MRC Approvals 5/30/13: PMU Costs, CFTC Order, UTC Credit

Below is a summary of problem statements and manual, Operating Agreement and Tariff changes approved by the Markets and Reliability Committee Thursday, May 30, 2013.

PMU Deployment

The committee endorsed manual revisions requiring new gen­er­a­tors to pay for the instal­la­tion of pha­sor mea­sure­ment units (PMUs). There were four no votes and three abstentions. The Planning Committee approved the changes March 7, reject­ing an alter­nate pro­posal to have PJM cover the cost.

Rea­son for change: PMU data can enhance grid reli­a­bil­ity for both real-time oper­a­tions and plan­ning appli­ca­tions (e.g., gen­er­a­tion dynamic model cal­i­bra­tion and val­i­da­tion, pri­mary fre­quency response, oscil­la­tion mon­i­tor­ing and detec­tion). PJM expects to receive PMU data from 82 sub­sta­tions by the end of 2013 but has none located at gen­er­a­tion stations.

Impact: The Inter­con­nec­tion Ser­vice Agree­ment will be changed to require instal­la­tion of PMUs at new inter­con­nec­tions for gen­er­a­tors with name­plate rat­ings of 100MVA or larger.  Data col­lected by the PMU must be trans­mit­ted to PJM con­tin­u­ously and stored locally for 30 days.

Commodity Futures Trading Commission Exemption Order

MRC and the Members Committee approved changes to the Operating Agreement and Tariff to comply with conditions in the Com­mod­ity Futures Trad­ing Com­mis­sion order exempt­ing most PJM mar­ket par­tic­i­pants from CFTC jurisdiction.

Rea­son for Change: The CFTC agreed March 28 to largely exempt from its reg­u­la­tions Finan­cial Trans­mis­sion Rights, day ahead and real time energy trans­ac­tions, for­ward capac­ity trans­ac­tions and reserve reg­u­la­tion trans­ac­tions, sales that are already reg­u­lated by the Fed­eral Energy Reg­u­la­tory Com­mis­sion.

How­ever, the CFTC said the exemp­tion did not apply to finan­cial mar­ket par­tic­i­pants that can­not qual­ify as “appro­pri­ate per­sons” under the Com­mod­ity Exchange Act (CEA). PJM responded April 7 by announc­ing it may deny trad­ing priv­i­leges to small mar­ket par­tic­i­pants if they are unable to qual­ify for the exemp­tion.

Impact: The changes approved Thursday expand finan­cial mar­keters’ offi­cer cer­ti­fi­ca­tion requirements. Although the changes require FERC approval, PJM CFO Suzanne Daugherty said her staff will immediately begin contacting about 100 market participants for whom the RTO does not have sufficient financial information.

The MRC was asked to choose between two options regarding the financial qualifications of an unlimited guarantor.

Stephanie Staska, of Twin Cities Power LLC, proposed language requiring “an issuer that has at least $1 million of total net worth or $5 million of total assets per Participant for which the issuer has issued an unlimited Corporate Guaranty.”

PJM proposed that the guarantor be “an issuer that would qualify for an Unsecured Credit Allowance of at least $1 million.”

Daugherty said the Twin Cities language complied with the CFTC order but was “just a little less thorough” than PJM’s proposal.

Staska said her proposal was identical to that used by MISO for compliance with FERC order 741. “It “does just as much to protect the market,” she said.

The changes were approved with the Twin Cities language with no objections and three abstentions.

See, “CFTC Approves Dodd-Frank Exemption for RTOs,” “PJM May Bar Some Financial Players from Trading.”

Up-To Congestion (UTC) Transaction Credit Requirements

MRC and the Members Committee endorsed credit requirements for up-to-congestion (UTC) trades, a fast-growing virtual transaction that previously had no credit requirements.

Rea­son for Change: UTC trad­ing vol­umes have grown dra­mat­i­cally since 2010 but there are no credit require­ments to pro­tect mar­ket par­tic­i­pants against defaults.

Impact: Bid screen and cleared port­fo­lio credit require­ments are based on a per­centile of the dif­fer­ence between each member’s bid or cleared price and the two-month rolling aver­age of real-time value per path.

Traders who fail the credit screen based on their initial bids will be able to rebid within their limits.

See “MIC OKs UTC Credit Requirement.”

FTR Forfeiture Rule Changes

MRC approved a man­ual change doc­u­ment­ing the Market Monitor’s cur­rent appli­ca­tion of the FTR forfeiture rule on incre­ment and decre­ment transactions and a prob­lem state­ment to deter­mine how the rule should be inter­preted in the future.

Reason for Change: PJM dis­cov­ered only recently that it dis­agreed with the cri­te­ria by which the mon­i­tor has been deter­min­ing whether a company’s vir­tual bid is “at or near” the deliv­ery or receipt buses of its FTR.

Impact: The manual change documents the monitor’s interpretation of the rule. The inquiry may result in changes to the application of the rule.

The mon­i­tor has been apply­ing the penalty based on the net impact of vir­tual bids, trig­ger­ing its appli­ca­tion in less than one-tenth of 1% of trades. PJM pro­posed a dif­fer­ent cal­cu­la­tion under which com­pa­nies would lose any profit for an FTR if 75% or more of the energy injected or with­drawn by a vir­tual bid is reflected in a con­strained path between FTR source and sink.

“We believe this is about as clear as we can make it,” Stu Bresler, PJM vice president of market operations, said of the manual change.

The problem statement was approved over the objections of 15 members of the PJM Public Power Coalition.

“There are at least five new problem statements on this week’s agenda,” said Bill Schofield, of Customized Energy Solutions, which represents the coalition. “This is not the time to be adding this to our plate.”

But representatives of financial marketers said revising the rule was important to them.

“Because of the heightened risk in terms of FERC enforcement action … I think it’s important that we get some clarity on how we analyze these power flows,” said Greg Pakela of DTE Energy Trading. “This kind of acts as a safe harbor.”

FTRs are “a fundamental building block to the forward price curve,” said Bruce Bleiweis, of DC Energy, LLC. “Many people would like some additional clarity here.”

Market Monitor Joseph Bowring also supported the review, noting that the rule has been unchanged since 2001. “Are we getting false positives or false negatives?” he asked. “We need to make sure everyone understands the rule. I think there’s a lot of misunderstanding.”

See “Back to the Drawing Board on FTR Forfeitures For Incs, Decs.”

Energy Market Uplift Costs

MRC approved a prob­lem state­ment cre­ating a senior task force to take a broad review of its method of pro­vid­ing Oper­at­ing Reserve pay­ments.

Reason for Change: PJM said changes are needed to reduce grow­ing uplift costs. Oper­at­ing Reserves are “make whole” pay­ments that ensure gen­er­a­tors dis­patched out of merit for sys­tem reli­a­bil­ity don’t oper­ate at a loss. Because they are col­lected through uplift charges and not reflected in day-ahead or real-time loca­tional mar­ginal prices, they can­not be hedged.

Impact: The task force will consider revising the sources of Operating Reserve charges and the methodology used to allocate them. The goal will be to minimize uplift costs while ensuring market prices are consistent with operational reliability, decrease charge rates, and reduce transaction risk due to variable fees.

See “PJM Proposes Operating Reserve Changes to Cut Uplift.”

PJM, FERC Rules Buffet EnerNOC

With its reliance on demand response and heavy concentration in PJM, EnerNOC has seen its fortunes wax and wane based on decisions made in Valley Forge and Washington. The company cited the following examples in its 10-K disclosures to shareholders:

  • The company saw its DR revenues fall in 2011 versus 2010 due in part to lower prices in the PJM, New York and New England markets and fewer demand response events in PJM during the year, which cut energy payments.
  • The Federal Energy Regulatory Commission’s February 2012 order accepting a PJM proposal on measuring and verifying DR capacity hurt the company’s revenues and profit margins.
  • PJM’s elimination of its Interruptible Load for Reliability (ILR) program last June “reduced the flexibility that we had to manage our portfolio of demand response capacity in the PJM market and impacted our revenues and profit margins.”
  • Declining PJM capacity market prices hurt revenues, gross profits and profit margins in 2012. “To the extent we are subject to other similar price reductions in the future, our revenues, gross profits and profit margins could be further negatively impacted.”

East Kentucky Power Cooperative System Joins PJM

PJM system operators took over management of the East Kentucky Power Cooperative system at midnight Saturday, adding almost 3,100 MW of generation and 2,800 miles of transmission to the RTO.

While PJM is a summer-peaking system, EKPC’s demand peaks in the winter. “The diversity of demand between EKPC and other PJM members and the resources they bring will strengthen reliability and have economic benefits not only for EKPC but throughout the region we serve,” said PJM President and CEO Terry Boston.

EKPC-map-chartEast Ken­tucky, which joined PJM as an Other Sup­plier in 2005, esti­mates it will save almost $132 mil­lion over the next decade by tak­ing advan­tage of PJM’s economies of scale and gen­er­a­tion diversity.

“Our organizations have put a lot of hard work into this integration,” EKPC CEO Anthony “Tony” Campbell said in a statement. “This move will help EKPC to operate more efficiently and economically.”

The biggest sav­ings will come from reduced reserve require­ments. East Ken­tucky main­tains a 12% reserve mar­gin. By join­ing the summer-peaking PJM, it will be able to reduce its reserve to 2.8%, allow­ing it to sell the dif­fer­ence in the capac­ity market. The inte­gra­tion also will result in more eco­nom­i­cal gen­er­a­tion dis­patch, as the coop replaces its higher cost gen­er­a­tion with cheaper PJM power.

East Ken­tucky said its move was prompted by increas­ing trans­mis­sion con­straints with poten­tial coun­ter­par­ties and fed­eral envi­ron­men­tal reg­u­la­tions, which made it expen­sive to con­tinue oper­at­ing as an inde­pen­dent con­trol area and bal­anc­ing author­ity. The coop has inter­con­nec­tions with TVA, Duke Energy, Amer­i­can Elec­tric Power and Louisville Gas and Elec­tric Co./Kentucky Util­i­ties Co.

EKPC is owned by 16 distribution cooperatives that serve 1.1 million people in 87 counties across Kentucky.

PJM, Monitor Push New MOPR Changes

Andy Ott and Joseph Bowring often disagree.

But last week, PJM’s Senior Vice President for markets and the Independent Market Monitor said there’s at least one thing on which they agree: the MOPR unit-specific review process is “flawed, non-transparent and provide[s] too much discretion to PJM and the IMM.”

The Markets and Reliability Committee approved a problem statement Thursday to standardize and improve the transparency of the unit-specific review process used in applying the Minimum Offer Price Rule (MOPR).

PJM and the monitor wanted to do away with the unit-specific MOPR exemptions in favor of blanket exemptions for win­ners of com­pet­i­tive solicitations and self-supply resources.

But the Federal Energy Regulatory Commission ruled May 2 (ER13-535) that elim­i­nat­ing the review for gen­er­a­tors that don’t meet the exemp­tions was not just and reasonable. Instead, FERC suggested that PJM conduct a stakeholder process to consider revisions to the process. (See “Split Decision on MOPR.”)

MOPR was added to PJM’s capac­ity mar­ket rules in 2006 to pre­vent buyer-side mar­ket power.

The problem statement and issue charge approved by MRC seeks to develop new financial modeling assumptions, with a goal of standardizing them and making them more consistent with those used to establish Net CONE (cost of new entry). Among the issues to be considered are asset life and calculations of net revenue and cost of capital.

The project, to be assigned to the Capacity Senior Task Force, is scheduled for completion in time for a December 1 FERC filing and implementation in the 2014/15 delivery year.

Compliance Filing

Ott also briefed the MRC on a compliance filing the RTO must make in response to the FERC order.

PJM’s response, filed yesterday:

  • allows MOPR exemp­tions for qualifying facilities under con­tract to capac­ity mar­ket sellers;
  • pledges to review the net short and net long thresholds for the self-supply exemption every four years; and
  • defines “repow­er­ing” to clar­ify that it includes both projects that increase capac­ity and those that don’t. PJM had pro­posed that repow­ered gas gen­er­a­tors be treated as a new resource under MOPR.

Also yesterday, Calpine Corp., FirstEnergy Corp. and NRG Energy Inc. filed requests asking FERC to reconsider its ruling, joining a rehearing request filed last week by the Illinois Commerce Commission.

The Illinois filing alleges FERC erred in allowing PJM to subject integrated gasification combined cycle (IGCC) generators to MOPR.

Calpine Corp said FERC was mistaken in requiring PJM to retain the unit-specific review. The commission “neglected to address the fact that the MOPR modifications set forth in the December 7 Filing were proposed as a package that was overwhelmingly approved by stakeholders and that reflected significant compromises on the part of Calpine and other parties,” Calpine said.

FirstEnergy said the self-supply exemption is based on PJM’s analysis of the 2015/2016 auction, which it said is not representative of current market conditions. The company said FERC should address the potential that the exemption could be gamed.

NRG said the commission had abandoned its long-standing “regulatory compact” with investors. “The MOPR Order cuts the legs out from under the buyer-side power mitigation rules by selectively approving the elements of the PJM proposal that would weaken the MOPR, while rejecting those elements that would strengthen the buyer-side market power protections,” the company said.

MRC Meeting Preview: PMU Costs, CFTC Order, UTC Credit

erators to pay for the installation of phasor measurement units (PMUs).

The Planning Committee approved the changes March 7, rejecting an alternate proposal to have PJM cover the cost. PMU data can enhance grid reliability for both real-time operations and planning applications.

Planning Committee Votes to Bill Generators for PMUs
3. Commodity Futures Trading Commission (CFTC) Exemption Order (9:25-9:55)
The committee will be asked to endorse the changes to the Operating Agreement and Tariff to comply with conditions in the Commodity Futures Trading Commission order exempting most PJM market participants from CFTC jurisdiction.

The CFTC agreed March 28 to largely exempt from its regulations Financial Transmission Rights, day ahead and real time energy transactions, forward capacity transactions and reserve regulation transactions, sales that are already regulated by the Federal Energy Regulatory Commission. However, the CFTC said the exemption did not apply to financial market participants that cannot qualify as “appropriate persons” under the Commodity Exchange Act (CEA). PJM responded April 7 by announcing it may deny trading privileges to as many as 55 small market participants if they are unable to qualify for the exemption. PJM said the change was necessary for the RTO to avoid being deemed a swap dealer and becoming subject to CFTC reporting requirements.

The changes being considered expand financial marketers’ officer certification requirements.

PJM Delays Action on CFTC Order

CFTC Approves Dodd-Frank Exemption for RTOs

PJM May Bar Some Financial Players from Trading
4. Up-To Congestion (UTC) Transaction Credit Requirements (9:55-10:10)
The committee will be asked to endorse credit requirements for up-to-congestion (UTC) transactions.

UTC trading volumes have grown dramatically since 2010 but there are no credit requirements to protect market participants against defaults. Bid screen and cleared portfolio credit requirements are based on a percentile of the difference between each member’s bid or cleared price and the two-month rolling average of real-time value per path.

MIC OKs UTC Credit Requirement
5. PJM Manuals (10:10-10:30)
The committee will be asked to approve the following manual revisions:

A. Electronic Notifications for Curtailment Service Providers: Changes to Manuals 1 and 18 will implement an automated process that will allow Curtailment Service Providers to provide operational data to — and receive dispatch instructions from — PJM. The new Load Response System (eLRS) process replaces the current manual methods, which rely on email and spreadsheets.

Manual Changes to Implement Electronic Notification System

B. Residual Zone Pricing: Residual Zone Pricing will replace physical zone LMPs for real-time load effective June 1, 2015. A Residual Zone is an aggregate of all load buses in the physical zone, excluding load priced at nodal locations. The change was endorsed by the Members Committee in February 2012 and approved by FERC in Docket ER13-347.

Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market

C. East Kentucky Power Cooperative: PJM needs to add the East Kentucky Power Cooperative zone into PJM markets manuals to accommodate the coop’s integration into PJM effective June 1.

Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market

D. NERC Reliability Standards: PJM needs to amend M-36: System Restoration to reflect NERC Standards EOP-005-2 (System Restoration Plans) and EOP-006-2 (Reliability Coordination – System Restoration).  Updates for consistency with other RTOs; updates underfrequency load shed tables; incorporates recommendations from RFC/SERC audit, and adds specific references to transmission operator restoration plans.

E. Manual 03A:  Energy Management System (EMS) Model Updates and Quality Assurance:
The changes include numerous edits for updates and clarity.

Manual 03: Transmission Operations

F. Regulation Market Cost-Based Offers:  New rules implemented in October require regulation offers to include capability (cost, in $/MWh to reserve a resource for regulation) and performance (costs of tracking the regulation signal in miles/MW).  Previous rules, as defined in Manual 15, did not include performance costs.

Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market

G. Manual 35: Definitions and Acronyms: Adds language to Economic Maximum and Economic Minimum definitions; changed Operations Analysis Working Group to Operations Assessment Working Group; Replaced TTV4TF (TO/TOP Version 4 Task Force) with TTMS (TO/TOP Matrix Subcommittee).

H. NERC standard PRC-023-2: Updates to Manual 14B: PJM Region Transmission Planning Process are required to implement standard PRC-023-2 (Transmission Relay Loadability). PJM annually develops transmission facility list to comply with NERC criteria.

I. Manual 03: Transmission Operations: Semi-annual update to incorporate procedural changes.
Recess (10:30-11:15)
The MRC will recess for a brief Members Committee meeting to finalize revisions to the OA and Tariff regarding the CFTC Exemption Order and the UTC credit requirements (#s 3 and 4 above).
6. FTR Forfeiture Rule Changes (11:15-11:30)
MRC will be asked to approve a manual change documenting the Market Monitor’s current application of the FTR forfeiture rule on increment and decrement transactions and a problem statement to determine how the rule should be interpreted in the future.

PJM discovered only recently that it disagreed with the criteria by which the monitor has been determining whether a company’s virtual bid is “at or near” the delivery or receipt buses of its FTR.

The monitor has been applying the penalty based on the net impact of virtual bids, triggering its application in less than one-tenth of 1% of trades. PJM proposed a different calculation under which companies would lose any profit for an FTR if 75% or more of the energy injected or withdrawn by a virtual bid is reflected in a constrained path between FTR source and sink.

Back to the Drawing Board on FTR Forfeitures For Incs, Decs
7. Energy Market Uplift Costs (11:30-11:45)
MRC will be asked to vote on a proposed problem statement that would create a senior task force to take a broad review of its method of providing Operating Reserve payments. PJM said changes are needed to reduce growing uplift costs.

Operating Reserves are “make whole” payments that ensure generators dispatched out of merit for system reliability don’t operate at a loss. Because they are collected through uplift charges and not reflected in day-ahead or real-time locational marginal prices, they cannot be hedged.

PJM Proposes Operating Reserve Changes to Cut Uplift
8. Minimum Offer Price Rule (MOPR) Compliance Filing (11:45-12:00)
PJM will provide a summary of PJM’s compliance filing in response to FERC’s May 2 order on the Minimum Offer Price Rule (ER13-535). FERC allowed PJM to exempt two categories of resources from MOPR but denied its request to eliminate its current unit-specific review.

Split Decision on MOPR
First Readings:
9. MOPR Unit Specific Exemption (12:45-1:00)

10. FTR Modeling Proposals (1:00-1:30)

11. Suspension of Day-Ahead Market for Loss of Internet (1:30-1:45)

12. Regional Planning Process Task Force (RPPTF) (1:45-2:15)

13. Demand Response Problem Statement (2:15-2:30)

14. Gas Electric Senior Task Force (GESTF) (2:30-2:45)

15. Tariff and OA Errata (2:45-3:00)

16. Replacement Capacity (3:00-3:15)

17. Transparency of TO Calculations (3:15-3:30)

18. PJM Manuals (3:30-3:45)
Future Agenda Items (3:45)]>