FERC Filings
EPSA Comments On The PJM Amendments and Market Monitor's Report
COMMENTS
Without specifically defined criteria and adequate support information, the PJM compliance filing is difficult to evaluate by market participants. The competitive analysis does not appear to be based on a specific objective parameter for determination of the constrained transmission facilities. For example, when selecting facilities that are representative of a constrained transmission facility, the facilities chosen are those that appear “several times” in the top 15 occurrences for TLRs. The focus on the word “several” suggests there was discretion, rather than specific criteria, used to screen the facilities. If there are elements of discretion employed in performing the competitive analysis, market participants should be allowed to comment specifically on the appropriateness of such discretion.
The supply curves constructed for each constraint using GE MAPS software also need more documentation to allow verification of the analysis results. The load duration analysis is complex and difficult to comprehend without the benefit of the support data. The report describes that system load and price were used for discrete analysis of each constraint; however, the system load and price data and their source are not included in the report. While, the analysis includes the delivered price test results, there is insufficient evidence about how this result was reached. The delivered price test results are critical to the conclusions reached in the competitive analysis, and understanding those results is imperative to assessing the market power test results.
The PJM market monitor identifies generating units that affect the constraint analysis as those “with significant impact on the respective constraints…” It is not clear from the report how the significant impact is measured. Since a generating unit can be offer capped, it is important to understand what a significant impact is and specifically what units are being singled out by the competitive analysis, and how the existing offer capping affects the competitive analysis. All stakeholders, including generators need more information to understand how existing generation is being included in the report and evaluated with respect to their impact on the PJM transmission system.
EPSA understands that the data used by the PJM Market Monitor to conduct the competitive analysis may be data that are confidential pursuant to the PJM tariff and market rules. Should this be the case, EPSA’s members are willing to sign the necessary confidentiality agreements in order to facilitate receipt of the information. The Commission can best answer stakeholder questions about the competitive analysis conclusions by convening a technical conference. The conference should focus on the criteria and methodologies used in the analysis to give generators, as well as other stakeholders, a greater understanding of the PJM Market Monitor’s competitive analysis conclusions.