By Rory D. Sweeney
VALLEY FORGE, Pa. — After a year under new fuel-cost policy (FCP) rules, PJM stakeholders want to make some tweaks.
Discussions on the revisions commenced Tuesday at a special session of the Market Implementation Committee. The special sessions are the result of a problem statement and issue charge approved by the MIC in September. (See “Review of Fuel Cost Policy Rules,” PJM Market Implementation Committee Briefs: Sept. 12, 2018.)
PJM staff and stakeholders alike agreed the process could use some revisions to reduce its administrative burden. The rules went into effect in May 2017 after months of debate. In June 2017, the Independent Market Monitor announced that it had rejected fewer than 5% of FCPs during its annual review, but that those rejections accounted for roughly 11% of the units requiring FCPs. (See PJM Monitor Rejects Fuel-Cost Policies for 11% of Units.)
John Rohrbach of ACES highlighted a specific concern that “innocuous” operator errors representing less than half a penny can create tens of thousands of dollars in penalties.
“It seems reasonable to ask whether that is a reasonable system to have” such potential for penalties, he said.
The Monitor’s Joel Romero Luna clarified that PJM’s online information-submission portal rounds to the penny and that no penalty would be assessed if the error does not make it to the portal.
Rohrbach, however, pointed out that the Tariff and Operating Agreement give staff no leeway in assessing penalties for such FCP violations.
PJM attorney Chenchao Lu agreed that the current OA language doesn’t provide the RTO any discretion in assigning penalties for violations, though it does have some discretion in determining whether the FCP was violated in the first place.
Calpine’s David “Scarp” Scarpignato said the lenience should be expanded to include additional types of errors, including those “not intentional.”
“It’s very difficult to be able to determine intent just by looking at the data,” PJM’s Glen Boyle said. “If I move a decimal place on a number, is it intentional? How do I prove that?”
PJM staff provided education on how the current FCP procedures work for developing cost-based offers. Stakeholders then listed a dozen areas of interest for revising the rules, including removing the administrative burdens for both the RTO and unit owners and adjusting potential penalties to be proportional to violations.
PJM’s Bhavana Keshavamurthy, secretary of the MIC, said she would add the topic to the agenda for the MIC’s Dec. 12 meeting for further discussion.