Supporters of the PJM PIOs’ RMR Complaint fail to establish that current Reliability Must Run treatment is unjust and unreasonable.
Date filed: October 31, 2024
Venue: Federal Energy Regulatory Commission (FERC)
Docket No.: EL24-148
Summary:
On October 31, 2024, the Electric Power Supply Association (EPSA) filed an answer at the Federal Energy Regulatory Commission (Commission) to the PJM Independent Market Monitor (IMM) and other parties’ comments supporting the PJM Public Interest Organizations (PIOs)’ Complaint regarding treatment of reliability-must-run (RMR) units in the PJM capacity market.
“PJM’s longstanding rule allowing owners of RMR units to determine for themselves whether to offer into RPM Auctions makes perfect sense,” writes EPSA.
The higher prices seen in the Base Residual Auction for the 2025/2026 Delivery Year are consistent with “supply-demand fundamentals in a region where existing resources are exiting faster than replacement resources are entering,” and not a result of RMR treatment.
The answer was accompanied by an expert affidavit of Dr. Paul Sotkiewicz. The answer emphasizes that none of the parties’ comments filed in support cures the fatal legal and market flaws in the PIOs Complaint or otherwise establishes that the longstanding rule that RMR units are not required to offer into PJM capacity market auctions is unjust and unreasonable.
In particular, the answer and affidavit respond to the PJM IMM comments, which includes an alternative to the PIOs’ requested treatment of RMRs.
The EPSA answer follows EPSA’s protest, with an affidavit from Dr. Sotkiewicz, filed last week urging the Commission to deny the PIOs’ Complaint.
Key Term: Reliability Must Run
“Reliability Must Run” or “RMR” refers to a power generating unit that is slated to be retired by its owners but is needed to be available for reasons of reliability. Typically, it is requested to remain operational beyond its proposed retirement date until transmission upgrades are completed (PJM Interconnection Glossary).
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