EPSA Comments on PJM Capacity Market Adjustments Filing Underscore Importance of FERC Adhering to NRG Doctrine in Assessing Proposed Changes
Date filed: January 6, 2025
Venue: Federal Energy Regulatory Commission
Docket No.: ER25-682-000
Summary: On January 6, 2025, the Electric Power Supply Association (EPSA) submitted comments at the Federal Energy Regulatory Commission on the December 9, 2024 filing by PJM Interconnection proposing revisions to the Reliability Pricing Model (“RPM”) rules.
EPSA strongly supports PJM’s proposal to retain a combustion turbine (“CT”) as the reference unit through the 2027/2028 Delivery Year and also supports its proposed penalty reforms, which will appropriately ensure that there are sufficient resource performance incentives in all Local Deliverability Areas (“LDAs”).
Troublingly, however, PJM insists that these sound reforms be treated as part of an un-severable package with other problematic proposals, including a proposal to counterfactually assume for purposes of clearing the RPM Auctions that reliability must-run (“RMR”) units without Capacity commitments are providing Capacity.
Ideally, PJM would agree that these proposals are severable and allow them to float or sink on their own merits. Nonetheless, if PJM will not relent and the Commission must consider what are, in PJM’s words, “discrete” elements as an indivisible package, EPSA reluctantly agrees that the package should be approved, if only to avoid running the upcoming RPM Auctions for the 2026/2027 and 2027/2028 Delivery Years with the near-vertical demand curves that would apply but for the retention of the CT as the reference unit and without adequate performance incentives in some LDAs.
