FERC Filings
MOTION FOR LEAVE TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-PJM Interconnection, L.L.C.-Docket No. ER01-1936-000
II. COMMENTS
Following the Commission’s order issued on March 14, 2001 and input from market participants, PJM proposes to change its station power rules to reflect that: (1) energy used for pumped storage, synchronous condensing, and restoration and black start is expressly excluded from the definition of “station power;” (2) the period for netting a generator’s usage of energy against its generation output is changed from one hour to one month; (3) the provision of station power among affiliates within a corporate family is permitted; and (4) transmission of station power from one generating unit to another will be subject to non-firm transmission charges, but not ancillary charges.
In particular, EPSA supports PJM’s proposal to change the netting period for a generator’s usage of energy against its generation output from one hour to one month, maintaining that “monthly netting coincides with PJM’s billing cycle, making implementation of a monthly netting process simple, quick, and efficient.” Similarly, monthly netting is supported in the Commission’s March 14th Order where it is stated that reasonable time periods over which station power may be netted included a day or week, but also that “[the Commission] would look favorably upon the use of a longer time period over which to measure.”
Monthly netting is also supported by the Independent Power Producers of New York (IPPNY) in their Request for Rehearing and/or Clarification filed on April 12, 2001 (IPPNY Filing), where they state that “a month or a comparable billing cycle of a control area administered by an independent system operator would be such a reasonable [netting] period.” Allowing monthly netting would coincide with already existing billing procedures in PJM and the New York ISO, and more importantly, support the formation of a seamless regional market.
EPSA also supports PJM’s proposal to allow the provision of station power among affiliates within a corporate family, noting that the divestiture of generation has defined different corporate ownership structures of generation facilities. Furthermore, the PJM Filing states that “to consider remote supply of station power among subsidiaries of one parent corporation as not being self-supply, while considering remote supply of station power among generators owned by a traditional vertically integrated utility as self-supply, could be considered discriminatory.”