FERC Filings
EPSA Comments on the Feb. 4 Reposne of the PJM Interconnection to the FERC Deficiency Notice
Background
On January 5, 2005, the Director of the Division of Tariffs and Market Development – East issued a deficiency letter to PJM in Docket No. ER04-539-006 and requested additional information in relation to the PJM Market Monitor's reports regarding offer capping of major transmission constraints made in compliance with PJM Interconnection, L.L.C., 108 FERC 61,187 (2004) (August 10 Order). In response to the deficiency letter, on February 4, 2005, PJM provided information on the competitive analysis used to determine whether an exemption from mitigation is needed on the major transmission interfaces into and/or out of the control areas of Allegheny Power, ComEd, AEP, DP&L and VEPCO. PJM's filing included a discussion of the Market Monitor's use of the no-three pivotal suppliers test to determine whether each constraint could be exempt from offer capping. The Commission later issued a notice requesting comments on the February 4 Filing.
In another PJM proceeding, on January 25, 2005 (Docket Nos. EL03-236-001, et al.), the Commission addressed a PJM proposal to add a new provision to the PJM market rules allowing the suspension of offer caps when competitive conditions exist in a load pocket. PJM's proposed revisions to its market rules retained the no-three pivotal suppliers test (e.g., four or more jointly pivotal suppliers are considered competitive as are zero pivotal suppliers) as the trigger for the suspension of offer caps. The Commission accepted the use of the no-three pivotal suppliers test, but also ordered a Section 206 investigation in Docket Nos. EL03-236-001, et al. to determine whether the no-three pivotal suppliers test is just and reasonable and whether it needs to be revised.