FERC Filings
EPSA Comments On The PJM Amendments and Market Monitor's Report
PREFACE
The Electric Power Supply Association (EPSA) hereby files comments on the October 26, 2004 PJM filing of the PJM Market Monitor Report (October 26 Filing) regarding Offer Capping of Major Transmission Constraints and Amendments to the PJM Open Access Transmission Tariff and the Amended and Restated PJM Operating Agreement.
On August 10, the Commission issued an order requiring PJM to justify its offer capping exemption provision and perform a competitive analysis of transmission constraints associated with interfaces with American Electric Power, Dayton Power and Light, and the Virginia Electric and Power Company. Additionally, the Commission required PJM to address whether offer capping should be limited to those generators that fail the market power test. PJM’s October 26 Filing responds to the Commission’s August 10, Order.
In the October 26 Filing, the PJM Market Monitor indicates that a competitive analysis was conducted to underpin specific conclusions. Unfortunately, the assumptions and the data supporting those conclusions are not included in sufficient detail in the market monitor report. Moreover, the specific screening criteria used gives rise to more questions than answers about the report’s conclusions. To adequately assess the PJM Market Monitor’s conclusions, stakeholders need the competitive analysis background and support information to understand the screening criteria. Therefore, EPSA requests that the Commission require PJM’s Market Monitor to make available the source material and methodology used for the competitive analysis. Should the Market Monitor have relied on information that it must keep confidential pursuant to its tariff and market rules, EPSA members are willing to sign the necessary protective agreements. The Commission should also hold a technical conference where the PJM Market Monitor can explain how the conclusions in the competitive analysis were reached.