OMAHA, Neb. — When SPP CEO Nick Brown welcomed Walmart as one of the organization’s newest members last month, he made a point of noting the company was the first in the RTO’s large retail customer sector, which has been vacant since 2003.
A big deal for SPP, maybe, but old hat for Walmart. The retail giant is a member of every U.S. grid operator except CAISO, though that could eventually change.
“It depends on the regulatory environment there,” Chris Hendrix, Walmart’s director of markets and compliance, told RTO Insider.
As it is, Walmart is involved in most states that are open to retail competition, along with markets in Canada and the U.K., the latter through its Asda affiliate. Other markets, national and international, could follow “depending on how they’re structured,” Hendrix said.
“It’ll be easier for me to tell you what markets we aren’t in,” he said, ticking off Delaware, Michigan, Rhode Island and D.C.
Walmart’s foray into electricity markets began simply enough in 2003, when it joined ERCOT as a retail electric provider (REP) through its Texas Retail Energy entity. The wholly owned company has a customer of one, procuring power for Walmart, Sam’s Club and other subsidiaries and their many stores and distribution centers.
“Initially, it was all about lowering our costs,” Hendrix said. “We’re like other REPs [in Texas], only we don’t have sales people or customer service reps.”
Hendrix, who brought 15 years of energy experience in both the gas and electricity sectors when he joined Walmart in 2003, is part of a team of 15 former energy insiders and company associates “doing all types of things.”
Everything, that is, except sales. There’s no need to market outside the Walmart family of companies.
“We can be in control of our own destiny,” Hendrix said. “We can buy power how and when we want to, as opposed to being beholden to somebody else’s buying schedule at the utility, or the market products they can come up with. We access the wholesale market when and how we see fit.”
No Middleman
Hendrix said Walmart benefits from its membership in SPP and other grid operators by gaining access to hourly pricing and managing it for the company’s needs.
“We cut out the middleman, and we leverage our credit as Walmart,” he said. “The cost savings come from leveraging our credit, as well as operational efficiencies from having less people and services that we have to offer.”
Asked to quantify Walmart’s energy savings, Hendrix demurred.
“Cutting out the middleman’s margin is basically the savings,” he said. “Our goal is everyday low prices, and along with that, everyday low costs. Anything we can do to lower the cost helps the business opportunities of Walmart.”
At the same time, Walmart’s involvement with RTOs and ISOs has been instrumental in the company’s sustainability program. The retailer has been working toward a goal of operating with 100% renewable energy since 2005.
Walmart has been the eighth largest corporate purchaser of wind and solar power globally since 2008 with 781 MW, according to Bloomberg New Energy Finance, and it gets about 28% of its electricity from renewables. Just before the presidential election in 2016, the company announced it intended to get half its power from wind and solar energy by 2025, passing Google as the world’s top buyer of renewable power.
Nothing has changed, despite the Trump administration’s lack of support for renewables.
“Our goals and objectives have not changed at all since they were first introduced … and more specifically, in November before the election,” Hendrix said. “By the time it’s all finished, 35% of our load in Texas will come from wind. That’s a significant number, but it’s still not a 50% number. We’re looking to do a lot more, because we can’t get there with on-site solar. It has to be large-scale solar and large-scale wind.”
Hendrix said one of the side benefits of participating in energy markets is purchasing renewables on a wholesale basis. To participate in most of the markets it’s in, Walmart had to become a member of the grid operators. SPP doesn’t have that same requirement, but its 18 GW of installed wind capacity was too enticing to pass up.
“As we do a lot more renewables, a lot of that … is in the SPP territory,” he said.
Walmart’s annual $6,000 membership fee is a small price to pay. As the executive responsible for regulatory and legislative matters for the company’s retail and wholesale energy businesses, Hendrix also gets to have a vote in SPP’s stakeholder process.
“We decided, as we have been in all those other markets and we have seen the benefits of being on those committees, it made sense to join SPP,” he said. “We try to understand what’s happening with the ISO’s policies and try to steer them in the direction that we think is best. We’ll always advocate for competition and free markets.”
SPP’s hefty exit fee — about $673,000 for non-transmission owners, the RTO estimates — has scared away some potential members, but not Walmart.
“We don’t intend to go anywhere,” Hendrix said. “It works out to $6,000 a year. We think we get the benefit of being involved in the market.”
PJM may soon have to choose between continuing to greenlight its “largest-ever” congestion-reducing transmission project or risking a public relations war with opponents of the project who live in its proposed pathway and have gained influential allies in their fight to have it shelved.
The $340.6 million project proposed by Transource Energy would consist of two separate 230-kV double-circuit lines, totaling about 42 miles, across the Maryland-Pennsylvania border — one between the Ringgold substation in Washington County, Md., and a new Rice substation in Franklin County, Pa.; and another between the Conastone substation in Harford County, Md., and a new Furnace Run substation in York County, Pa.
PJM and regulatory filings refer to the project as “9a,” while Transource has dubbed it the Independence Energy Connection.
Once referred to as the AP South Congestion Improvement Project, Transource’s Independence Energy Connection project would consist of two lines. The western portion would run from the Ringgold substation in Maryland to the Rice substation in Pennsylvania. The eastern line would run from the Conastone station in Maryland to the Furnace Run station in Pennsylvania. | Transource
“Until now, landowners have considered Transource to be their opponent, but unless PJM soon exercises its right to withdraw the project, we will hold PJM responsible,” wrote the opponents — consisting of three landowner groups in Harford, York and Franklin counties — in a June 30 letter to the RTO’s Board of Managers.
“PJM will become the target of our media outreach, our legislative efforts and, potentially, our legal efforts as we hold PJM responsible for the tremendous costs incurred by landowners who will ultimately emerge victorious,” the letter warned. “Further PJM support of this project will be viewed as an abuse of process.”
Project 9a
PJM selected Transource’s market efficiency proposal in August 2016 to reduce congestion along the RTO’s AP South interface. As part of PJM’s implementation of FERC Order 1000, the congested interface was included in its inaugural window for proposing such projects and received the most attention, attracting seven of the 17 total proposals submitted. (See AP South, Cleveland Draw Congestion Relief Proposals.)
At the time, PJM CEO Andy Ott called it “PJM’s largest-ever market efficiency project,” projecting it would save ratepayers $622 million in congestion costs over 15 years. The eastern portion would relieve the Graceton-Conastone 230-kV line, which was the most congested line in PJM’s 2016 long-term analysis. Its congestion costs in 2017 were $51.8 million and were expected to rise over the next 10 years to $68.88 million in 2027.
Another line leading into Graceton, the 230-kV Bagley-Graceton, was third on the list with $23.59 million in 2017 congestion costs and estimates of $59.57 million in 2027. A third line in the area, the 500-kV Peach Bottom-Conastone, was second on the current list with $32.78 million in congestion costs, which are expected to drop precipitously to $1.9 million in 2027.
FERC approved a formula rate for the project in January 2017 and a settlement this January on Transource’s return on equity, but it refused to reconsider whether the company should be allowed to make single-issue rate filings or recover all costs if the project is canceled through no fault of the company.
Transource received permission, starting on Jan. 31, 2017, to recover all “prudently incurred costs” if it must abandon the project for reasons “beyond Transource’s control.” All costs prior to that are subject to a cost-sharing policy FERC ordered in Opinion 295, through which Transource could recover 50% (ER17-419).
‘Do the Right Thing’
But opposition has developed among residents who live around the proposed paths, and they have orchestrated an awareness campaign that netted support from high-level elected officials on both sides of the state border. U.S. Rep. Scott Perry (R-Pa.) wrote a letter to FERC in March, calling on the commission to reconsider whether Order 1000 “puts impacted private citizens at a distinct disadvantage” in opposing projects. FERC Chairman Kevin McIntyre responded in April, outlining how projects are selected through Order 1000’s competitive solicitation process and assuring Perry that PJM re-evaluates its decisions annually.
Maryland Gov. Larry Hogan wrote to PJM’s Board of Managers on July 10 to “express concerns” that “the project will take prime agricultural land out of production, including land that is in permanent agricultural easements.” He sympathized with “the need to reduce power congestion in Maryland” but requested that the project be halted pending a re-evaluation or rerouting using existing rights of way, along with greater engagement with residents and state agricultural and energy agencies.
PJM says it never received Hogan’s letter.
“We have no record of receiving it,” PJM spokesperson Susan Buehler told RTO Insider in an email.
But the PJM board did receive the letter from opponents, who mentioned McIntyre’s “favorable response” and called for the project to be removed from the Regional Transmission Expansion Plan because the benefits have dropped substantially since the RTO last analyzed it.
“While we understand that PJM feels a responsibility to Transource to allow them to fail gracefully at the state level after a protracted review, the facts demand that PJM cancel this project immediately,” they wrote.
The opponents argued that near-universal local opposition and unknown environmental impacts should induce staff “to use your professional and moral judgment to do the right thing.”
Citing testimony from PJM’s Paul McGlynn to the Maryland Office of People’s Counsel (OPC), they argued system changes since last year’s annual analysis have reduced the potential benefits while costs have likely risen. The reference was to a data request from the OPC to PJM as part of the Maryland Public Service Commission’s review of Transource’s application for a certificate of public convenience and necessity for the project. In a portion of the data request provided to RTO Insider by the opposition, McGlynn appears to indicate that the congestion savings have fallen from the $620 million expected when the project was approved to $245.75 million in the most recent analysis.
However, that number is not a direct input in PJM’s analysis of such projects. That analysis, which was performed last September and posted in January, still produced a benefit-to-cost ratio of 1.32, exceeding PJM’s 1.25 threshold for considering a proposal. PJM was unable to independently verify the document cited by the opposition but confirmed that the information McGlynn would have used came from the analysis that resulted in the 1.32 benefit-cost ratio. Any changes in the variables will be included in the next analysis coming in September.
“PJM is currently conducting a third evaluation of the project, and we are using up-to-date data in doing so,” PJM spokesperson Jeff Shields said in an emailed statement. “In the past, the PJM board has canceled several major transmission projects in the region — including the [Mid-Atlantic Power Pathway] and [Potomac-Appalachian Transmission Highline] projects in 2012 — as a result of such re-evaluations.”
Impact on the Ground
The opposition argues that PJM does not give enough consideration to utilizing existing infrastructure. They point out that PPL’s existing Conastone-Otter Creek 230-kV line, which largely mirrors the proposal’s eastern path, has capacity to run another line.
PJM confirmed that PPL offered a proposal among the 41 submitted to address the AP South interface congestion, but its benefit-cost ratio did not meet the 1.25 threshold. A PPL representative said the company’s proposal “involved adding equipment to an existing substation.”
[Editor’s Note: An earlier version of this article incorrectly reported, based on information provided by PJM, that PPL had not submitted a proposal.]
Because it’s PJM’s largest market-efficiency project, “they want it to go through at any cost to land owners and local communities,” said Patti Hankins of Harford County, who joined the opposition in 2017 after learning property belonging to her husband’s cousin would be impacted.
Opponents are also concerned about the safety of high-voltage lines and the potential impact on destination agriculture, such as Shaw’s Orchard Farm Market in White Hall, Md., and other farm-to-table operations. New construction should be the last resort, they argue.
“The impact on the ground is so significant that there should be no new construction until it’s absolutely necessary,” said Aimee O’Neill, a Maryland resident and president of grassroots group Stop Transource Powerlines MD, a signatory to the opposition letter.
Political Action
O’Neill has been lobbying state legislators to pass five bills that would require developers to use existing transmission infrastructure where possible before building new. Opponents of the bills, which O’Neill hopes will be reintroduced in the legislature’s 2019 session following mid-term elections, argue that state regulatory oversight is satisfactory and that such laws would significantly upset plans to replace much of the regional grid that is nearing the end of its usable life.
“Maryland is not prepared to protect the interests of the people in the face of a changing energy environment,” O’Neill said. “There’s really nothing wrong with requiring those upgrades to be completed in existing easements with existing equipment, and what we’ve learned is that unless there is legislation requiring that … people [opposing new projects] are doomed to go through this time and again.”
Every property owner along the proposed routes has objected to the project, so Transource will need eminent domain authority to take them, O’Neill said. The company is currently working through permitting and eminent domain proceedings with regulators in both states.
A Transource representative said the company would not a comment on the opponents’ letter because it is directed to PJM.
FERC on Wednesday accepted MISO’s compliance filing spelling out rules for its new energy storage category, rejecting a protest and rehearing request by Indianapolis Power & Light (ER17-1376-002, ER17-1376-003).
MISO was responding to FERC’s March 23 ruling approving the creation of a Stored Energy Resource Type II that ordered the RTO to flesh out the concept further. MISO proposed the new storage category last year following IPL’s complaint against the RTO’s existing storage participation rules. (See FERC OKs MISO Plan to Expand Storage.)
IPL Harding Street Station battery interior | IPL
In its compliance filing, MISO revised the definition of SER-Type II resources to clarify that they are eligible for up/down ramp capability if technically capable.
It also said that SER-Type II resources will be subject to the same must-offer obligation that applies to other capacity resources. MISO said it would be expensive and time-consuming to redesign its day-ahead market software to exclude such resources from the must-offer obligation. However, MISO also revised its Tariff to allow the storage facilities to derate their capacity to limit their supply to four hours.
The filing also revised the definition of station power to exclude the energy used to charge an SER-Type II resource.
In Wednesday’s ruling, FERC said MISO’s filing was largely responsive to the March order, although it agreed with IPL that Tariff changes regarding up/down ramp capability are incomplete and ordered the RTO to add additional Tariff language.
The commission rejected IPL’s protest of MISO’s proposal to apply the must-offer rules to SER–Type II resources that provide capacity. But it noted that Order 841 required each RTO/ISO to demonstrate that its existing market rules allow storage resources to provide capacity in a way that acknowledges their limitations.
“Therefore, while we accept MISO’s clarification that its must-offer rules apply to SER–Type II resources, we note that MISO still has a compliance obligation under Order No. 841 to demonstrate how its capacity market acknowledges the energy limitations of electric storage resources,” the commission said.
The commission also rejected IPL’s request for rehearing, saying it had addressed the company’s arguments in both the March 2018 order and a February 2017 ruling. “Indianapolis Power does not raise any issues in its rehearing request challenging the commission’s conditional acceptance of MISO’s compliance filing that are new to this proceeding or that Indianapolis Power had not raised earlier,” FERC said.
The New England Power Pool filed a proposal with FERC on Monday to codify its unwritten ban on press attendance at stakeholder meetings (ER18-2208).
The proposed amendments to the NEPOOL Agreement add a definition of “press” and bar anyone working as a journalist from becoming a NEPOOL member or alternate for a participant.
NEPOOL’s 2017 Annual Report included a photo of a stakeholder meeting. Of the seven RTOs and ISOs in the U.S., only New England’s bars the press and public from attending. | NEPOOL
New England is the only one of the seven U.S. regions served by RTOs or ISOs that prevents press coverage of stakeholder meetings.
NEPOOL’s Participants Committee approved the press ban June 26 with 79% in favor in a sector-weighted vote. An alternative proposal that would have made the press eligible for a non-voting membership failed with only 27% in support, with only the end-user sector strongly in support. (See NEPOOL Votes for Press Ban, Discusses Fuel Security.)
RTO Insider prompted the vote by having reporter Michael Kuser, who lives in Vermont, apply for committee membership as an end-user customer in March. NEPOOL has not acted on the application.
NEPOOL’s filing says that permitting press to become a participant or to represent a participant “would adversely impact NEPOOL’s ability to continue to foster candid discussions and negotiations in its stakeholder meetings. Without such discussions and negotiations among its members, ISO New England Inc. and state officials, NEPOOL would be limited in its ability to narrow or resolve complex issues within the NEPOOL stakeholder process. This could have the effect of increasing the issues and scope of litigation at the commission on ISO-NE Tariff changes and related matters before it.”
It cited concerns that press attendance at meetings “could encourage public posturing, pre-scripted statements and reduced willingness or ability by members to freely explore ideas or solutions.”
The filing notes that FERC ruled in a 2001 order that the NEPOOL Agreement is not a FERC tariff but “a supporting document … [and the] equivalent of a utility’s Articles of Incorporation.”
While it relieved NEPOOL of filing the agreement in tariff form, the commission said the organization must continue to file proposed changes to the agreement with the commission. “The commission will continue to review the proposed changes that fall within its authority under the [Federal Power Act],” the commission said.
NEPOOL said the commission is in “‘an essentially passive and reactive’ role’” and can only reject the filing if it finds the changes not “just and reasonable.”
“Thus, if the commission determines that a provision that precludes press from becoming a NEPOOL participant or participant representative falls within its authority, it can only reject that provision if it concludes that the changes are unlawful,” it said. “The commission’s review does not extend to the question of whether there are other reasonable approaches to the press membership issue.”
NEPOOL requested the change take effect Nov. 1.
RTO Insider began covering PJM stakeholder meetings in early 2013 and expanded coverage to stakeholder meetings of MISO and NYISO in late 2014, SPP in early 2015, and ERCOT and CAISO in 2016. RTO Insider also began covering ISO-NE in late 2014 but has been barred from all stakeholder meetings except for the Planning Advisory Committee, which is run by the RTO.
RENSSELAER, N.Y. — NYISO’s Business Issues Committee voted Monday to approve a revised charter for the state’s Integrating Public Policy Task Force (IPPTF), the group exploring how to incorporate the cost of CO2 emissions into the ISO’s markets.
Michael DeSocio, NYISO senior manager for market design, highlighted a single sentence added to clarify the task force’s mission: “Incorporating the cost of carbon dioxide into the wholesale energy markets is intended to provide the most efficient means to incentivize carbon abatement from a broad set of electric suppliers, supporting the state’s clean energy policies to reduce electric sector carbon dioxide emissions while continuing to leverage market forces to provide affordable, reliable electricity.”
The IPPTF is being run by NYISO after initially being set up in collaboration with the state’s Department of Public Service. The group next meets at ISO headquarters Aug. 20.
Broader Regional Markets Report
Staff continue work on clarifying the minimum deliverability requirements for external capacity from PJM into NYISO’s Installed Capacity (ICAP) market, Nicole Bouchez, ISO principal economist, highlighted from the monthly Broader Regional Markets report.
At the July 31 Installed Capacity/Market Issues Working Group meeting, the ISO presented its proposed market design to improve the supplemental resource evaluation process for external capacity resources. It will communicate next steps after evaluating stakeholder feedback.
In related matters, Bouchez highlighted that the Independent Power Producers of New York last month filed a complaint asking FERC to direct the ISO to disallow PJM resources from selling ICAP into New York City (Zone J) using certain unforced capacity deliverability rights (UDR) facilities.
Public Service Electric and Gas in May had filed a complaint against Consolidated Edison concerning two transmission lines, B3402 Hudson-to-Farragut (B line) and C3403 Marion-to-Farragut (C line). PSE&G alleged that underwater portions of the lines may have been permanently damaged and should be removed.
On June 6, the ISO filed a protest with FERC indicating that removal of the B and C lines would undermine resilience in both New Jersey and New York and requested that PSE&G’s complaint be denied.
Sub-20-MW Constraint Reliability Margin Values
The BIC approved the ISO’s proposal to apply a sub-20-MW constraint reliability margin (CRM) value to certain facilities where warranted. A CRM is a portion of a transmission facility’s capacity kept in reserve to help meet NERC and other reliability standards. A few facilities use the normal 20-MW CRM under most conditions but also use a larger CRM during periods of higher load, such as the Gowanus Substation in Brooklyn.
David Edelson, manager for operations performance and analysis, said the ISO would base its determination to use a sub-20-MW CRM mainly on the desire to keep CRM values at a level representing no more than 10% of a facility’s rating.
NYISO’s Tariff currently requires use of a minimum value of at least 20 MW for any non-zero CRM value employed in the day-ahead and real-time markets. As the ISO continues to consider inclusion of certain 115-kV facilities with lower thermal ratings (relative to 230-kV and higher facilities) into its dispatch, a 20-MW CRM can often represent a significant percentage of the facility limits.
For instance, many 115-kV facilities have post-contingency limits of 150 MW or lower. A 20-MW CRM represents 13% of the rating for a 150-MW facility.
In megawatt terms, a facility with a 150-MW rating and a 20-MW CRM would be secured in the dispatch using a 130-MW limit. By comparison, a typical 345-kV circuit has a 1,550-MW post-contingency rating with a 20-MW CRM representing only about 1% of the rating.
The ISO will seek Management Committee approval at its next meeting Aug. 29, and by the ISO’s Board of Directors during a special call on the issue in early September, with a FERC filing targeted for the middle of next month.
T&D Manual Revisions
The BIC voted to approve incorporating into the ISO’s Transmission and Dispatching Operations Manual (T&D Manual) an existing technical bulletin on the procedures transmission owners must use to secure their facilities into the Business Management System (BMS) day-ahead and real-time market models.
The information would be located in a new section in the manual and would not substantively differ from the existing guidelines, said Ethan D. Avallone, senior market design specialist.
The committee also approved proposed revisions to Section 3.1.3 of the T&D Manual, specifying that the New York Control Area reserve is monitored through the use of the Reserve Monitor Program; and to Section 4.2.11, regarding procedures when a transmission owner or the Northeast Power Coordinating Council observes or reports significant geomagnetically induced currents.
Distillate Prices Up 40% Y-o-Y
NYISO locational based marginal prices (LBMP) averaged $39.58/MWh in July, up nearly 18% from June and 10% higher than the same month a year ago, Bouchez told the BIC.
Year-to-date monthly energy prices averaged $46.64/MWh in July, a 28% increase a year ago. July’s average sendout was 529 GWh/day, higher than 445 GWh/day in May and 454 GWh/day a year earlier.
Transco Z6 hub natural gas prices averaged $2.87/MMBtu, up about 17% from both June and a year earlier. Distillate prices dropped slightly compared to the previous month but were up 40% year-over-year. Jet Kerosene Gulf Coast and Ultra Low Sulfur No. 2 Diesel NY Harbor averaged $15.05/MMBtu and $14.81/MMBtu, respectively.
Total uplift costs and uplift per megawatt-hour dropped from June, but the ISO’s 44-cent/MWh local reliability share in June came in higher than the previous month’s 18 cents/MWh, while the statewide share dropped from 12cents /MWh to -57 cents/MWh. Thunderstorm alerts (TSAs) accounted for 21 cents/MWh for the month, down from 39 cents/MWh in June. TSAs occur when actual or anticipated severe weather conditions lead the ISO to reduce transmission transfer limits on the UPNY-SENY interface, which often leads to severe congestion.
PJM last week asked FERC to delay next year’s Base Residual Auction to Aug. 14 to provide the RTO more time to respond to the commission’s June 29 order requiring changes to capacity market rules.
The commission ordered PJM to expand its minimum offer price rule (MOPR), which now covers only new gas-fired units, to all new and existing capacity receiving out-of-market payments. The commission’s ruling, which rejected PJM’s April “jump ball” capacity filing (ER18-1314) and partially granted a 2016 complaint led by Calpine (EL16-49), initiated a Section 206 proceeding in a new docket (EL18-178). (See FERC Orders PJM Capacity Market Revamp.)
| 123RF
PJM requested the delay in an Aug. 9 filing supporting the Organization of PJM States Inc.’s (OPSI) motion to extend to Oct. 11 the deadline for filing testimony, evidence or arguments in response to the FERC order (EL16-49, et al.).
The RTO asked the commission to issue an initial order directing a compliance filing by Jan. 15 and a final order on compliance by March 15. “This proposed schedule will provide PJM and capacity market sellers with approximately five months to undertake the Tariff imposed obligations in advance of the delayed BRA,” PJM said.
PJM, OPSI and more than a dozen other parties also have requested rehearing of the commission’s ruling, including industrial customers, the American Public Power Association, Exelon, Old Dominion Electric Cooperative, Dominion Energy, FirstEnergy Services, and regulators from Illinois, New Jersey and Maryland.
VALLEY FORGE, Pa. — PJM staff are still working on how to respond to GreenHat Energy’s default in the financial transmission rights market, CFO Suzanne Daugherty told stakeholders at last week’s Market Implementation Committee meeting.
Daugherty announced at the June meeting of the Markets and Reliability Committee that GreenHat was likely to default on payments for a sizable FTR portfolio that was proving unprofitable. After the company defaulted, PJM staff realized that their current rules for attempting to mitigate the financial burden to members might instead exacerbate the situation and requested a waiver from FERC to find a more effective solution (ER18-2068).
PJM analysis shows the continuing downward trajectory of GreenHat’s FTR portfolio. | PJM
The Tariff requires PJM to liquidate the FTRs of a defaulted member by offering for sale “all” current planning period FTR positions in the next monthly balance of planning period FTR auction “at an offer price designed to maximize the likelihood of liquidation of those positions.”
PJM said a waiver is required “given the market impact by the liquidation of GreenHat’s large FTR portfolio and observed low levels of market liquidity more than one month forward (i.e., non-prompt months).” Staff found that the bids offered to take the portfolio’s positions would have been approximately four times the pre-default auction clearing prices on the affected paths. Instead of being forced to liquidate the entire portfolio at once and potentially suppress the holdings’ return in an illiquid market, PJM asked FERC on July 26 to allow it to not liquidate each FTR position until the month it becomes due in the market. FERC has not yet responded. (See “ Default Details,” PJM MRC/MC Briefs: July 26, 2018.)
At the same time, PJM also requested a waiver of its requirement to return collateral posted by Orange Avenue, another FTR market participant that is affiliated with GreenHat (ER18-1972). Orange has challenged that request, but PJM argued that it may become necessary to sue Andrew Kittell, who oversees both firms, and that Orange’s collateral would be included among Kittell’s assets.
When GreenHat acquired most of its positions starting in 2015 long-term FTR auctions, both historical congestion and the FTR auction clearing prices indicated that the portfolio would be profitable, so it had a low credit requirement. However, by April 2017, PJM staff realized the portfolio, consisting primarily of prevailing-flow FTRs, were on paths where transmission upgrades were expected to reduce future congestion.
According to PJM, GreenHat’s portfolio was estimated at $57 million based on the auction clearing prices when the positions were taken. In the 2015-16 planning year, the same portfolio would have netted $548 million. It dropped slightly in the next planning year to $481 million. However, the following year the value dropped precipitously to $126 million and continued falling in subsequent auctions. By June 2018’s auction, the portfolio would have lost $110 million.
After realizing GreenHat’s exposure, staff approached Kittell, who offered to mitigate some of the potential risk by signing over what he told PJM were the rights to receive $62 million in proceeds from several bilateral FTR contracts. PJM accepted the agreement in June 2017 and opened a bank account for the expected proceeds, but the other company in the contract, whose name was redacted from the public filings in the docket, says it paid what it owed to GreenHat well before Kittell signed the agreement with PJM. The RTO wants FERC to allow it to keep the collateral from Orange while it investigates “whether Mr. Kittell and GreenHat fraudulently induced PJM to enter into the pledge agreement.” FERC hasn’t responded to that request yet either. Kittell did not respond to a request for comment.
His attorney, David Gerger, also declined to comment but pointed to Orange’s July 27 protest, in which it told PJM it “was not making any representations or warranties about the value of the additional collateral … and that PJM must make its own valuation.”
Orange said “PJM was uniquely poised to [establish the value of the collateral] because the [$62 million] number came from applying the PJM Tariff to amounts entered into PJM’s FTRCenter System.”
In the wake of the GreenHat default, PJM received stakeholder endorsement to enhance its credit policy for FTR traders. The new rules, to be implemented on Sept. 3, will institute a 10-cent/MWh minimum monthly credit requirement for FTR bids submitted in auctions and cleared positions held in FTR portfolios. (See “Credit Requirements,” PJM Market Implementation Committee Briefs: July 11, 2018.)
However, Daugherty confirmed at the MIC meeting that GreenHat remained compliant with the credit requirements existing at the time until it failed to post a collateral call in April. Stakeholders grilled her on why PJM hadn’t previously attempted any regulatory action or policy changes if it knew about the concern nearly a year and a half ago.
“There was nothing specific in the credit policy that would have allowed PJM to make a collateral call” sooner, she said, noting that the agreement with Kittell was signed in June 2017.
Additionally, staff said that FERC lacked a quorum of commissioners at the time and that stakeholders had not yet agreed on revisions on how to analyze predicted congestion. Daugherty said staff made a “good faith effort” to bring GreenHat and Kittell to heel.
Several stakeholders pushed PJM to provide even a rough estimate of the expected losses. One, Vitol’s Joe Wadsworth, said he used recent market results to determine that it could be upward of $145 million.
“It is getting worse,” he said.
If accurate, the result would be almost triple the $52 million credit default by Tower Research Capital’s Power Edge hedge fund in 2007, which also triggered credit policy revisions. (See PJM Credit Adder Fails upon Heightened Review.)
Daugherty resisted the requests, saying that it would be impossible to accurately predict.
“We will not know the dollars until they play out or they are liquidated because we may have to pay to liquidate them,” Daugherty said.
“There’s urgency here. We can’t just let this ride on the market,” Wadsworth said. He said engaging with GreenHat once the risk was identified was “clearly the right thing to do,” but he asked why the company was allowed to continue participating in the auctions.
“These numbers are kind of scary. We’re trying to find out … how big this is going to be,” Old Dominion Electric Cooperative’s Adrien Ford said. “I’d appreciate some sort of take on it so I can go back to the home office and say ‘roughly we think it’s about this size.’”
“I don’t think you should expect that PJM’s going to project a number,” Daugherty said.
Stakeholders also debated the best strategy for how to liquidate the portfolio if FERC approves PJM’s waiver request. Some, including Wadsworth, called for immediate action, as auction results have shown a continuing downward trend. Others, including Direct Energy’s Marji Philips, argued it might be better to wait to see if something materializes that’s better than the current guaranteed loss.
“Do you liquidate today and have a fixed number, or do you want to not liquidate today, and the number might come in lower,” she said.
PJM is working with its members to agree upon a strategy at the August MRC meeting and targeting a final approval vote at the September MRC meeting.
According to PJM’s rules, all members will be on the hook for at least some of the losses. Of the final amount, 10% will be allocated on a per capita basis to the 992 members, including affiliates, as of June 21. The per capita assessments are capped at $10,000 per year, though Daugherty confirmed the rule’s intention was for the cap to count per default event and that the language may need to be clarified.
The remaining losses will be allocated according to each member’s gross PJM activity over the three months preceding the default. The RTO said the total activity for the period was $24 billion.
So far, PJM has sent, or plans to send, bills for $42.5 million, about 18% of GreenHat’s portfolio.
Daugherty confirmed “there is no other situation like [GreenHat’s exposure] related to credit requirements.” She said PJM is working with external consultants from trading exchanges, clearing houses, other consultants and its Independent Market Monitor “to review factors that can affect future congestion levels and [perform a] gap analysis against how FTR credit requirements would address those factors.” The talks are excluding members to avoid potential conflicts of interest.
DC Energy’s Bruce Bleiweis said the incident was not a failure of the FTR market or structure but “clearly a significant failure of the credit policy.”
However, he expressed concern that PJM’s presentation indicated staff might agree with the IMM’s position that the benefits of long-term FTRs are outweighed by their risks.
In June, stakeholders endorsed changes to the long-term FTR auction construct to prohibit participants from obtaining the rights to congestion on transmission paths before the owners of the underlying auction revenue rights. The Monitor has said the revisions are improvements but don’t go far enough. (See “Long-term FTRs Undercut Annual FTRs,” PJM Market Implementation Committee Briefs: June 6, 2018.)
Kittell worked as an energy trader for JPMorgan Venture Energy Corp. when FERC fined the company $285 million and ordered it to disgorge $125 million for “manipulative bidding strategies” from September 2010 through November 2012. Kittell and two other employees named by the commission were not charged.
VALLEY FORGE, Pa. — Stakeholders at last week’s Market Implementation Committee meeting overwhelmingly endorsed PJM’s proposal for revising how it calculates balancing ratios while also rejecting several competing proposals.
PJM’s proposal received 0.88 in favor, surpassing a 0.5 threshold in the sector-weighted vote. Stakeholders also preferred it to the status quo, voting 0.69 in favor of the new proposal.
The proposal, known as Package A, would calculate the balancing ratio used in the default market seller offer cap (MSOC) and nonperformance charge rate (PPR) formulas by averaging the balancing ratios from the three delivery years that immediately preceded the capacity auction. For years that don’t have at least 30 hours of performance assessment intervals (PAIs), the actual number of PAIs would be supplemented with estimated balancing ratios calculated during the intervals of the highest RTO peak loads that do not overlap a PAI. PAIs are five minutes apiece.
Some stakeholders like the proposal because it is straightforward and maintains the same number of PAIs used in either the MSOC or the PPR. However, others argue the calculation overestimates the likely number of PAIs, which leads to an artificially high MSOC. Such conditions led Independent Market Monitor Joe Bowring to conclude last week that the clearing prices in May’s Base Residual Auction were higher than they should have been. (See related story, IMM: PJM 2018 Capacity Auction was ‘Not Competitive’.)
“This all turns on your belief that 30 hours is a reasonable number [for PAIs]. I don’t believe that. … I would say it’s pretty clearly not a reasonable number,” Bowring said.
“We don’t have any technology that can solve that problem [of accurately predicting the number of PAIs], so we’re left with what is a reasonable number to put in there,” PJM’s Adam Keech said.
“The 30 hours is definitely an issue for the consumer advocate offices I’ve talked to,” said Greg Poulos, executive director of the Consumer Advocates of the PJM States.
PJM’s Pat Bruno announced that staff planned to abandon a second proposal, Package B, unless a stakeholder offered to sponsor it. Dave Mabry, representing the PJM Industrial Customer Coalition, agreed to do so. The proposal would calculate the balancing ratio in the same manner as Package A but would also estimate an expected number of PAIs for the delivery year using data from the prior three years. That estimate would be inserted into the MSOC and PPR formulas.
Each formula would include a floor of PAIs, but they would differ: five hours for the MSOC and 15 hours for the PPR. That difference concerns stakeholders, who argue the numbers need to be the same for the formulas to maintain their mathematical relationship.
“We don’t share PJM’s thoughts that they have some problems at FERC with the” formulas, Mabry said in sponsoring the proposal. American Municipal Power’s Steve Lieberman seconded it, and it received 0.09 in favor.
Additional proposals from Exelon and Calpine differed with PJM on the PAI calculations for the formulas. Calpine’s would floor both at 10 hours and calculate a number based on the past 10 years of data. Exelon’s would use a probabilistic model to look forward. Both would keep constant the number of PAIs used in the two formulas.
“We think it’s illogical to have different assumptions for those calculations,” Exelon’s Jason Barker said.
“The heart of our proposal was to get the expected amount of performance assessment [intervals] to match. It didn’t make sense to us [to have them not match], and I don’t think it would make sense to FERC,” Calpine’s David “Scarp” Scarpignato said.
Scarp withdrew his proposal in favor of PJM’s Package A. Exelon’s received 0.36 in favor.
“I am more in favor of fixing the immediate problem of the” balancing ratio, Scarp said.
“You can’t fix [the balancing ratio] without addressing the problem on a consistent basis,” Bowring said.
A proposal from the Monitor, which mirrored Package B except that it had floors of just five hours for either formula, received 0.02 in favor.
Quadrennial Review of VRR Curve
Stakeholders endorsed a proposal from Scarp on revisions for PJM’s quadrennial review of the variable resource requirement (VRR) curve in its Reliability Pricing Model capacity market construct. Several other proposals, including one endorsed by PJM, were rejected by stakeholders.
Despite the result, all four proposals will be up for consideration at the August meeting of the Markets and Reliability Committee meeting. Stakeholders had made that request long before the vote in an attempt to overcome the influence of companies with multiple affiliates, which can each vote separately at lower committees.
Scarp’s proposal largely mirrored PJM’s, except that it maintains the current combustion turbine configuration as the curve’s reference technology; the RTO had planned to change it to a newer model. It also maintained the curve’s current calculation, while PJM and the other two proposals would have shifted it 1% left. The shift was part of revisions recommended by the Brattle Group, who were hired by PJM to analyze the curve. (See “VRR Curve Update,” PJM Market Implementation Committee Briefs: July 11, 2018.)
PJM’s proposal received 0.39 in favor.
A proposal from the Monitor agreed with PJM on updating the reference technology, but it differed on several other factors. That proposal received 0.1 in favor.
A proposal from the D.C. Office of the People’s Counsel sought to use a combined cycle unit for the reference technology and otherwise largely mirrored the Monitor’s proposal. It received 0.1 in favor, as well.
Fuel Cost Policy
John Rohrbach of ACES, representing the Southern Maryland Electric Cooperative, presented a proposed problem statement and issue charge to review the first year’s performance of the new fuel-cost policy rules and determine if any improvements can be made.
The proposal was also endorsed by Old Dominion Electric Cooperative and Panda Power Funds. The group hopes to have any potential revisions to the current policy identified by April 19 to target a June filing at FERC. Any potential alternatives to the current policy that are identified would need to be ready for consideration by the fall to target a FERC filing in the fourth quarter.
Transmission Constraint Penalty Factor
PJM and its Monitor have developed a joint proposal to revise how the transmission constraint penalty factor is utilized. PJM’s Angelo Marcino explained that the current process uses “constraint relaxation” so that the penalty factor doesn’t set shadow prices. This “masks” transmission shortages in the market. The proposal would remove constraint relaxation and allow the $2,000/MWh penalty factor to set prices as appropriate.
The proposal received so little reaction that PJM suggested canceling the next meeting of the group overseeing the issue, which stakeholders approved.
After the meeting, PJM posted online an analysis from the Monitor on the potential impact of the proposed revisions. The Monitor found that in 2017 the revisions would have increased the balancing market in the aggregate by $10 million.
Texas regulators last week issued requests for comments on real-time co-optimization (RTC) and incorporating marginal losses into dispatch decisions, proposals that have varying levels of stakeholder support.
On June 29, ERCOT’s Independent Market Monitor filed a report at the Public Utility Commission indicating RTC could have saved as much as $257 million in reduced congestion costs and $155 million in reduced ancillary service costs during the 2017 test year.
IMM Director Beth Garza told ERCOT’s Board of Directors on Aug. 7 that a significant cost of providing operating reserves is the lost opportunity cost of providing energy.
“The cost of containing those reserves, setting them aside, is the lost opportunity of selling that energy,” Garza said. “When initially selected in the day-ahead market, the costs of providing both energy and reserves are minimized. That is, co-optimized.”
During their Aug. 9 open meeting, the commissioners approved a set of questions as part of its review of RTC (Project No. 48540). They also approved a second group of questions related to incorporating marginal losses’ costs into dispatch (Project No. 48539).
Commissioners (left to right) Shelly Botkin, DeAnn Walker and Arthur D’Andrea discuss market improvements during the PUCT open meeting. | Admin Monitor
A second report, filed by ERCOT, found the grid operator would benefit from RTC through its more efficient procurement of ancillary services and congestion management, and reduced reliability unit commitments.
The IMM and ERCOT will host a technical workshop on the two filed reports Sept. 6.
The PUC held a pair of workshops last year following a report coauthored by Harvard University’s William Hogan and FTI Consulting’s Susan Pope that recommended rule changes to address intermittent renewables and add incentives for generators. (See ERCOT, Regulators Discuss Need for Pricing Rule Changes.)
The PUC also published a list of questions on the review and approval of substations. It has scheduled an Oct. 4 workshop on the subject (Project No. 48251).
Commissioners Approve Tweaks to Retail Website
The commissioners approved staff’s suggested recommended changes to the PUC’s Power to Choose website, where consumers in Texas’ competitive areas can shop for electricity providers. The website has drawn the commission’s attention following consumer complaints of pricing gimmicks that result in unexpectedly high costs.
“We’ve been here before,” Commissioner Arthur D’Andrea said. “The commission thought we fixed this website, and now here we are again. I don’t want to be back here in two years doing the same thing.”
“Unfortunately, I think we may be because REPs [retail electric providers] adjust,” Chair DeAnn Walker said. She had reason to be pessimistic, saying she had recently met with a retail representative.
“People are already trying to figure out how to get around these” rule changes, Walker said.
Staff’s proposal adds a filter to weed out plans that offer low average prices at the 1,000-kWh usage level, when they cost significantly more for customers who average more than 1,000 kWh/month. The recommendations will also limit the number of offers a REP can list on the website to prevent them from “flooding” a page.
“Doing so will encourage REPs to use [their] available postings wisely, rather than repeating very similar offers to strategically dominate search results,” staff said.
PUC to Intervene in FERC Entergy Dockets
Following an executive session, the commissioners agreed to intervene in five dockets at FERC involving Entergy Services and cost-reimbursement agreements with its five operating companies (ER18-2079, et al.).
Entergy proposed last year to recover $5.9 million from Texas retail rates for Entergy Texas’ portion of construction costs for a pair of transmission control centers it built in Arkansas and Mississippi.
FERC set the agreements for settlement proceedings in February, but the company said the negotiations between Entergy Service its operating companies, commission staff and other parties were not “fruitful” and further discussions “would not resolve the issues in these proceedings.” The company filed cancellation notices for the reimbursement agreements with the commission in July. Entergy said no payments were made and no benefits received under the agreements.
VALLEY FORGE, Pa. — Opponents and advocates of new rules to increase the importance of cost containment in transmission project proposals found themselves in uncommon agreement at last week’s PJM Planning Committee meeting.
Both shared concerns over the RTO’s plan to delay inserting some language for the new rules into Manual 14F.
Staff explained that it was a last-second decision meant to avoid confusion for those reading the manuals, and while stakeholders didn’t fully support the explanation, they eventually agreed to endorse some of the modified manual revisions but defer voting on the cost-containment language.
The wide-ranging changes include revisions to PJM’s processes for selecting “market efficiency“ transmission projects and prequalification for submitting proposals. But stakeholders were focused on how PJM plans to implement the cost containment rules, which were endorsed earlier this year following a controversial stakeholder process. (See Cost Containment Clears MC Vote Despite PJM Plea.)
While some of the changes could be implemented immediately, two frameworks for comparing projects are being developed by PJM and its Independent Market Monitor. The first framework on construction costs is expected to be ready for use in December, while the second comparing return on equity and capital structures is expected by May. Because they aren’t ready for use, staff decided to keep language revisions related to frameworks out of the public version of the manual. They are being maintained in an internal version that will be brought for stakeholder endorsement once the frameworks are finalized.
“The manual is a reflection of what’s in effect today, and the comparative process is not a part of that today,” PJM’s Jason Shoemaker explained.
LS Power’s Sharon Segner, who led the campaign to get the cost containment language endorsed, said PJM would be “picking and choosing” which parts of the approved revisions it’s implementing.
“This is kind of different than what was communicated to me just a few days ago as far as the approach, so I’m just concerned,” she said.
Alex Stern of Public Service Electric and Gas, who largely opposed Segner throughout the cost containment battle, joined her in expressing concern because staff was not being clear with exactly what changes it was proposing from what was presented at the first reading last month and its meeting materials did not reflect the changes or represent the statements being made. His concern stemmed particularly from PJM’s representation that it was removing language from the manual that had received stakeholder endorsement. Withholding the language related to the frameworks from the revisions up for endorsement wasn’t clearly spelled out in the issue presentation PJM posted online prior to the meeting, and Stern questioned whether an endorsement should move forward when significant changes were being unclearly communicated immediately before the requested endorsement vote.
“This is a change also from my point of view,” he said. “I’m not clear as to why you’re carving it out.”
PJM’s Sue Glatz assured stakeholders that the withholding was limited to one section in the manual and a note would be included explaining that the material will be added later “so it’s not being lost.” She pointed out it would also be captured in the meeting’s minutes.
PJM’s Steve Herling said it wasn’t the first time staff had used this tactic, so he didn’t understand the “nervousness.” Including it now wouldn’t impact whether — or how quickly — the frameworks are completed, he said, and “it’s highly likely“ that additional manual language beyond what has already been approved will be needed to comprehensively detail the process.
“We can’t post language … [that] will cause confusion if it’s not ready to be implemented. People will be reading the manuals,” he said. “When it is ready to be implemented, it will be posted.”
“I think taking out the note causes more confusion than it helps,” Stern said. “I’m actually confused the other direction how it helps to carve this out when there is the confusion. … I’m really not sure what people are concerned about.”
Once the situation was explained, Tonja Wicks of Duquesne Light said she was supportive of PJM’s plan. American Municipal Power’s Steve Lieberman said he was “sensitive” to Herling’s points.
PJM eventually offered to remove the cost-containment language from the endorsement vote proceeding, with the Manual 14F changes focused on market efficiency procedures.
Following additional debate, Segner eventually decided to trust the process.
“I’m still a little confused, but I think we’re on the right path, and I’m going to support this today,” she said.
PJM’s Mark Sims reviewed staff’s planned timeline for implementing the cost containment measures. He explained that the comparative frameworks will help staff put proposals into a fuller context that includes constructability and financial data, along with risk evaluations.
DER Ride-through
Staff are asking stakeholders for the opportunity to investigate whether certain operating parameters for inverter-based generators create a reliability risk for the grid.
A PJM analysis shows how DERs not using ride through worsens system reliability, while using it improves reliability. | PJM
PJM’s Andrew Levitt presented a proposed problem statement and issue charge to determine whether the “ride-through” settings for distributed energy resources like residential wind and solar might create low-voltage risks. For safety and other reasons, DERs are configured to trip off within two seconds if they experience under- or over-voltage. As the amount of DERs grows, all of them tripping during such an event could exacerbate the situation. A new industry standard would address that issue by requiring DER to ride through certain system fluctuations.
Levitt had previously approached the Operating Committee in March about transmission owners taking the lead in implementing the new Institute of Electrical and Electronics Engineers standard. (See “Implementing DER Ride Through,” PJM Operating Committee Briefs: March 6, 2018.)
Normal conditions wouldn’t cause an issue, Levitt said, but “our relay clearing logic doesn’t always work correctly” and could exceed the two-second threshold.
“Really, we would need to change our planning criteria under that kind of a scenario,” he said. “Ride-through is good; lack of ride-through is bad.”
Stakeholders noted several challenges that would have to be addressed, including the safety of utility workers working on lines, engineering and regulatory differences between the transmission and distribution systems, and the appropriateness of focusing on one technology type.
PJM will be hosting a technical workshop on the issue Oct. 1-2, Levitt said.
CIRs
Staff announced that stakeholders impacted by planned revisions to how PJM calculates the output of generating units will have more than six years to prepare for the changes.
Changes planned for Manual 21 would revise and add detail to how PJM would test a generator’s output and determine its net capability each year. Among the changes, the capacity factors for wind and solar units would be calculated using the median factors instead of the average. Throughout the year, PJM’s Jerry Bell has been presenting analysis showing that the median more closely predicts actual performance than the average. (See “Skepticism of Gen Capability Changes Continues,” PJM Operating Committee Briefs: June 5, 2018.)
However, the changes would mean that affected wind and solar units would have their capacity injection rights (CIRs) reduced. The potential reductions have concerned stakeholders because they have to pay for the CIRs. Bell has said the CIRs could be reallocated to other projects, but they would be constrained to projects on the same transmission line.
In an attempt to placate the concerns, Bell announced that the changes won’t go into effect until the 2025 delivery year. Stakeholders will be alerted to CIR reductions by Aug. 1, 2024, and have to identify where they plan to move the CIRs by Jan. 1, 2025. They will then have until the end of that year to utilize them elsewhere. Any unused CIRs won’t technically be lost until June 1, 2026.
“When it comes to incorporating intermittent resources … this has always been a work in progress,” PJM’s Tom Falin said. “This is just a further refinement in that area as we have accumulated more data.”
The longer lead time seemed to have its intended effect.
“These changes are certainly much improved from the initial proposal,” Dayton Power and Light’s John Horstmann said.
TO Supplementals Discussion
PPL’s Frank “Chip” Richardson announced that TOs will be hosting an online conference on Aug. 28 to discuss additional details of their plan to implement FERC’s order from earlier this year requiring TOs to increase stakeholder engagement in the development of supplemental projects.
Supplemental projects are transmission construction initiated by TOs to address their own planning criteria and aren’t in response to any wider planning criteria. FERC determined that PJM TOs’ processes for developing those projects weren’t in compliance with Order 890, sending reverberations through several stakeholder initiatives that most recently culminated in the termination at July’s Markets and Reliability Committee meeting of a task force focused on end-of-life supplemental projects. (See PJM Stakeholders End Tx Replacement Task Force.)
ARR Analysis Finds Infeasible Facilities
PJM’s Xu Xu announced at last week’s Transmission Expansion Advisory Committee meeting that the annual analysis of stage 1A auction revenue rights found one violation within PJM’s territory and eight across flowgates to MISO. The analysis assesses the simultaneous feasibility of the ARRs’ paths for a 10-year period.
The internal violation is expected to be addressed through a project that should be in service in 2020. Proposals to address the others are being considered in interregional planning with MISO.
Cost of Dominion’s Haymarket Line Triples with Undergrounding
A decision by Virginia regulators to settle a controversy over a transmission line planned through a historical community through partial undergrounding will triple the cost of the line, staff confirmed.
A 6-mile 230-kV line planned for the area of Haymarket, Va., to feed new data centers received national attention after protesters raised concerns about Dominion Energy’s plan to site it through a historically African-American community inhabited by descendants of emancipated slaves. The Virginia State Corporation Commission stepped in to approve project revisions under a newly enacted underground transmission pilot program as part of the Grid Transformation and Security Act of 2018, which went into effect July 1.
Dominion’s supplemental project around Haymarket, Va. | PJM
The revisions will underground roughly half the project, increasing costs from an initial estimate of between $45 million and $57 million to the new estimate of $174 million.
Because the proposal was a supplemental project initiated by Dominion, PJM confirmed that the entirety of the cost will be billed back to customers in Dominion’s zone. However, that might change after the D.C. Circuit Court of Appeals rejected earlier this month PJM’s cost allocation rules for supplemental projects that involve high-voltage lines. The rule, which had prohibited cost sharing for all supplementals, was remanded back to FERC for revision. (See DC Circuit Rejects PJM Tx Cost Allocation Rule.)
