Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Credit and exit · Reliability and curtailment
Procurement · PDF pp. 8–26
PJM described the backstop and its forthcoming curtailment proposal as independent. It asked FERC to consider procurement even if the other tariff needed more review.
the two filings are independent of each other PDF p. 12Filed comments: Reliability and curtailment
New capacity · PDF pp. 27–52
The July proposal allowed newly contracted or self-supplied capacity to reduce the quantity PJM would buy. The customer had to report the capacity during the procurement window and provide evidence.
if reported to PJM within the RBP procurement window and supported by sufficient evidence PDF p. 38
Delivery risk · PDF pp. 53–80
A project could retain its commitment through delays, but failing to supply any backstop capacity for three consecutive delivery years would cancel the balance of its 15-year commitment.
If the RBP Resource fails to provide any RBP UCAP MW after three consecutive Delivery Years PDF p. 68
Revenue settlement · PDF pp. 81–100
PJM proposed paying suppliers the shortfall after capacity-market revenue, subject to actual availability and clearing. Customers would fund the measured shortfall rather than a forecast.
Loads will fund the actual revenue shortfall, measured ex post PDF p. 88
Cost allocation · PDF pp. 101–120
PJM distinguished the wholesale allocation it proposed from the decision retail regulators make about passing those charges on to individual customers.
allocation to retail customers, including data centers, is within the states’ and/or RERRAs’ purview PDF p. 111
Public Service Commission of West Virginia · Direct response
The West Virginia commission warned that complex rules could discourage participants from reporting qualifying capacity. That would make the final purchase larger than necessary.
PDF pp. 2–4, bilateral matching and offsetsOrganization of PJM States · Direct response
OPSI asked PJM to remove withdrawn large projects when setting the procurement target. Otherwise existing customers could pay for generation to meet demand that no longer exists.
PDF pp. 3–4, original August 21 commentsNew Jersey Board of Public Utilities · Direct response
The New Jersey board sought more flexible terms for demand resources and distributed resource aggregations in the original procurement. This concerned auction eligibility; it did not endorse the later peak-shaving formula.
PDF p. 15, footnote 54Illinois Commerce Commission and Joint Consumer Advocates · Direct response
Illinois regulators and the consumer advocates warned that a single end date for contracts could amplify forecast errors. FERC recorded that concern as it considered freezing load shares at one point in time.
PDF p. 40, footnote 144Amazon and Northern Virginia Electric Cooperative · Direct response
Amazon argued that immutable shares would diverge from actual demand as projects changed. NOVEC asked why PJM considered a single snapshot appropriate.
PDF p. 40, responsive pleadingsIndependent Market Monitor for PJM · Direct response
The monitor objected to eligibility rules that could let an existing resource reclassify its capacity. Its test was whether an award actually paid for additional physical supply.
PDF p. 15, responsive pleadingsIllinois Commerce Commission · Direct response
The ICC supported a one-time supplemental purchase but wanted protection against forecast error, data for state regulators and no new obligations on states. It warned that a modest percentage error in a larger forecast could mean paying for substantial unneeded capacity.
PDF pp. 1–2, 4, 6–7Public Service Commission of West Virginia · Direct response
The commission opposed the original filing in its proposed form and on its proposed timetable. It wanted PJM to learn how much demand would be covered by bilateral contracts before setting a central procurement target.
PDF pp. 1–4Pennsylvania Office of Consumer Advocate · Direct response
The office argued that PJM was asking states to determine the shares suppliers would owe under a wholesale rate. It asked FERC to reject that design or explain how the new allocation would respect the line between state and federal authority.
PDF pp. 3–5Data Center Coalition · Direct response
The coalition supported offsetting a new load’s own capacity purchases and procurement through bilateral deals. It also wanted backstop costs charged to loads driving the need rather than customers elsewhere.
PDF pp. 3–4Organization of PJM States, recorded member positions · Direct response
OPSI backed a supplemental purchase. Its filing names support from Delaware, D.C., Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee and Virginia commissions. The West Virginia commission did not support the comments. OPSI also wanted to recalculate the target when projects withdrew.
PDF pp. 1–4, footnote 2 and commentsNew Jersey Board of Public Utilities · Direct response
FERC records the board’s comparison of one distributor counting projects from 50 MW and another reporting expansions from 20 MW. The board wanted a consistent threshold so that equally sized projects would not pay differently just because of where they connected.
PDF pp. 43–44, NJBPU comments summarized by FERCOffice of the Federal Energy Advocate, Public Utilities Commission of Ohio · Direct response
FERC records support from the PUCO office for allowing states to determine the allocation to large loads. This is a different office and a different issue from the Ohio Consumers’ Counsel request for confidential registry access.
PDF p. 47, responsive pleadings, citing Ohio FEA comments p. 4Google, Equinix and Data Center Coalition · Direct response
FERC cites all three commenters as seeking to share the underlying allocation data with states. Those data would let a retail regulator see which wholesale obligations had been assigned before setting the customer’s retail rate.
PDF p. 49, footnote 191, citing Google comments p. 8Printed headings where available; page ranges otherwise. Open a heading to read the original passage.