On April 7, 2015, PJM Interconnection, L.L.C. (“PJM”) requested a one-time waiver of its tariff so that PJM may delay its upcoming Base Residual Auction (“BRA”) until after FERC has ruled on its December 2014 capacity performance tariff revision filing. PJM requested to delay the BRA from the week of May 11-15, 2015 to a week that is 30 to 75 days after FERC’s ruling on the merits of its capacity performance proposal, but no later than the week of August 10-14, 2015. PJM stated that the delay until after FERC acts on its capacity performance filing would allow for market participant certainty on the status, schedule, and rules for the BRA.
On December 12, 2014, PJM submitted a series of capacity performance tariff revisions. In its filing, PJM stated that the tariff revisions would provide greater assurance that resources committed as capacity will meet PJM’s reliability needs during emergencies. PJM stated that these tariff revisions were to apply to the May 11-15 BRA. However, on March 31, 2015, FERC issued a deficiency letter requesting additional information on PJM’s capacity performance tariff revisions.
In light of the deficiency letter, PJM requested the delay of the 2015 BRA to a later date so that PJM may apply to the 2015 BRA any Commission decision on the merits of PJM’s proposed revisions issued in the next two months. PJM stated that it did not make the requested delay lightly, and under almost any other circumstances, PJM would not seek to delay the BRA. However, PJM argued that the present situation was unique and warranted a delay because its proposed capacity performance revisions were necessary to maintaining reliability within PJM, and its current tariff provisions do not provide sufficient incentives to ensure that committed resources deliver during emergencies.
PJM stated that the waiver is consistent with FERC standards as it is: (1) of limited scope; (2) addresses a concrete problem; and (3) does not have undesirable consequences.