Stakeholders Narrowly Endorse Uplift Changes
VALLEY FORGE, Pa. — The Market Implementation Committee endorsed a joint PJM and Independent Market Monitor proposal to rework how uplift and deviation charges are calculated for market sellers depending on how they respond to market signals and dispatch instructions. It passed with 53.3% support and is set to go for a first read at the Markets and Reliability Committee on May 21. (See “First Read on Proposal to Overhaul Uplift,” PJM MIC Briefs: March 5, 2025.)
The changes would establish a new tracking ramp-limited MW desired (TRLD) metric to replace the three existing MW desired metrics used in calculating balancing operating reserve (BOR) credits and deviation charges. The TRLD would follow how a unit responds to instructions over time, rather than focusing on individual five-minute intervals as the ramp-limited desired, dispatch and locational marginal pricing-desired metrics do.
PJM’s Lisa Morelli said that would address scenarios where a unit ignoring dispatch and keeping its output steady can avoid deviation charges.
The TRLD would account for any dispatch instructions arising from ancillary services a market seller is responding to as well, such as regulation or sync reserve, allowing corresponding automatic exemptions from deviation to be eliminated.
In past meetings, Morelli gave the example of a unit operating at 100 MW being dispatched down to 95 MW in accordance with its ramp rate. If that unit ignored the signal and stayed at 100 MW, it would not exceed the 10% margin that defines when a unit is deviating from dispatch under the status quo. Additionally, because dispatch is limited by ramp rates in the next interval, PJM could bring it down only to 95 MW in the following interval.
The proposal also would rework the BOR credit formula by taking the lesser of real-time output or the TRLD and adjusting for ramp parameters for each interval, which Morelli said would simplify the equation. The start and end points for uplift eligibility would be revised to align with when a market seller’s commitment began and to run through either the end of that commitment or the unit’s minimum run time.
Morelli said PJM’s goal is not to reduce uplift and the changes are likely to be a net benefit for many participants, as they also address scenarios where generators are undercompensated in some scenarios.
If endorsed by the Members Committee in July, Morelli said PJM would aim to file tariff revisions at FERC in September. The changes would be implemented in two phases, starting with simulated results in market settlements reporting system (MSRS) reports before affecting actual settlements in late 2026 or early 2027.
Responding to stakeholders questioning how PJM could respond to any gaps or unintended consequences identified during the soft launch, Morelli said the intention is to have enough detail in the tariff language to give direction to how the TRLD would function, with finer detail spelled out in the manuals. Any edge cases stakeholders are concerned about could be addressed by adjusting the manuals without needing to make additional FERC filings. The governing document language likely would empower PJM to adjust the TRLD if there are instances where SCED would dispatch a unit inconsistent with locational marginal pricing or the unit’s offers.
Committee Endorses Manual 11 Periodic Review
Stakeholders endorsed revisions to Manual 11: Energy & Ancillary Services Market Operations drafted through the document’s periodic review. The changes were deferred during the committee’s March 5 meeting after concerns were raised with the language designating data centers as plug load. (See “Periodic Review of Manual 11 Deferred,” PJM MIC Briefs: March 5, 2025.)
PJM’s Joseph Tutino said the proposal was changed since the first read to include data centers and crypto mining as “business segment” load following feedback that plus load typically includes smaller devices, such as household appliances. He said the remaining changes are mainly typographical.
PJM’s Maria Belenky told the committee in March that data centers are considered plug load for the purpose of curtailment service providers (CSPs) reporting load enrolled in demand response.
First Reads on Manual Revisions
PJM presented a first read on revisions to Manuals 6, 11, 28 and 29 to conform with FERC’s May 2023 order accepting a PJM proposal on how it proceeds with settlement under a market suspension. PJM’s transmittal letter states that a market suspension never has occurred but could result from “extraordinary circumstances such as a failure of computer systems.” (See “Market Suspension,” PJM Market Implementation Committee Briefs: June 8, 2022.)
The filing stated that the tariff has no way of determining energy and ancillary service prices when zonal dispatch rates cannot be calculated by software. Three different sets of rules are included for determining real-time prices when suspensions last less than six hours, between six and 24, or for longer. Shorter suspensions would use the average real-time prices for each hour prior to and following the outage; for moderate duration events, day-ahead prices would be used if available, otherwise real-time prices would be used; and for suspensions exceeding a day, an aggregate supply curve would be developed (ER23-1431).
The proposed Manual 28 language would use actual output for calculating energy offers during real-time energy market suspensions. Lost opportunity costs (LOC) would not be included for suspensions longer than one day, and BOR charges would be allocated to real-time load plus exports if a suspension exceeds one hour.
PJM also gave a first read on revisions to Manual 18 to conform with FERC orders granting several changes PJM sought to make to its capacity market in recent months (ER25-682, ER25-785, ER24-2995).
The bulk of the changes arise from FERC’s Feb. 14 order granting a host of capacity market changes meant to address tightening supply and demand. The corresponding manual revisions would codify delayed Base Residual Auction (BRA) dates; model resources operating on reliability-must-run (RMR) agreements as capacity; continue the use of a combustion turbine generator as the reference resource; and clarify that market sellers do not hold “safe harbor” from claims of market power exercise by holding a categorical exemption from the requirement that all resources holding capacity interconnection rights (CIRs) must offer into the capacity market. (See FERC OKs Changes to PJM Capacity Market to Cushion Consumer Impacts.)
It also includes the elimination of must-offer exemptions for intermittent, storage and hybrid resources, requiring market sellers to offer those units into capacity auctions starting with the 2026/27 BRA scheduled to be conducted in July. Stakeholders and intervenors argued the exemption artificially increased auction clearing prices, while many generation owners argued the existing and proposed market rules do not allow them to reflect the risk exempt resources would take on with a capacity obligation.
The final change would be to memorialize the removal of the energy efficiency addback and eliminate the resource class outright following the 2025/26 delivery year. PJM argued to the commission that the addback was a holdover from a prior set of rules and no longer was needed, as EE was captured in its load forecast. Removing capacity status for EE was sought as the RTO argued that it could not be demonstrated that capacity market revenues were used to reduce load. (See PJM Asks FERC to Eliminate Energy Efficiency from Capacity Market.)
Stakeholders Discuss Pseudo-tied Resources
The committee continued its discussions on how pseudo-tied generators are assigned to locational deliverability areas for the purpose of determining clearing prices and the amount of local capacity PJM models as available within a zone. The subject was brought up by the North Carolina Electric Membership Corp. (NCEMC) to explore whether a load-serving entity seeking to self-supply with pseudo-tied generation should receive the clearing price for an LDA or the RTO-wide clearing price, with the latter being the status quo.
PJM’s Nebiat Tesfa said pseudo-tied resources are those that have an indirect connection to PJM, hold firm transmission service and are studied to ensure deliverability akin to internal resources. Those studies do not, however, determine whether any particular resource is deliverable to a specific LDA; to ensure the right to inject to an LDA, either incremental capacity transfer rights (ICTRs) or investment in qualifying transmission upgrades (QTUs) must be obtained. In some cases, modeling the flow from a pseudo-tied resource can use the reliability requirement for an LDA to increase, she said.
PJM’s Tim Horger said the RTO’s priority going into the topic is ensuring there are no inconsistencies between internal and pseudo-tied resources when modeling congestion or transmission.
In its own presentation, NCEMC said there were circumstances in the 2025/26 BRA where LSEs were exposed to price separation within their LDAs and were prevented from using their own resources adjacent to that zone and which they believe are electrically serving that load. It said analysis of dispatch data shows that those units are providing congestion management in Mid-Atlantic Dominion.
Horger said PJM and stakeholders have to be careful when considering changes down the path of using distribution factor (DFAX) analysis to determine whether a given resource is helping a specific LDA.
Carl Johnson, representing the PJM Public Power Coalition, said if resources are tied to an LDA, especially when it’s the same organization trying to serve load with its own resources, there should be a way of recognizing that the cost shouldn’t be different just because an LDA separates.
PJM’s Jonathan Kern said the CETL study is agnostic about which capacity resource is supplying an LDA, so there’s going to be some association with the CETL and generation outside the LDA but not associated with any particular resource.