AEMA filed additional comments to the original complaint at FERC regarding seasonal resource participation in PJM Interconnection’s Reliability Pricing Model (“RPM”) capacity construct. In the comments, AEMA states that a perfect capacity market would precisely account for every resource’s ability to serve load at all times and find the least-cost mix of those resources that meet reliability standards. While a perfect market may not be achievable in practice, but how close market designs come to this ideal should guide the Commission. AEMA’s complaint identifies specific areas where the inefficiencies and discrimination resulting from PJM’s RPM rules require action by the Commission under FPA section 206.
See full comments here: Seasonal Capacity Post Technical Conference Comments (429 downloads )