Federal Energy Regulatory Commission

October 17, 2019

Open Commission Meeting

Staff Presentation

Items E-1, E-2

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www.FERC.gov

Good morning Mr. Chairman and Commissioners.

Today the Commission is acting on items E-1 and E-2, draft orders addressing 

Southwest Power Pool’s and PJM Interconnection’s filings in compliance with Order 

No. 841, the Commission’s Final Rule on Electric Storage Resource Participation in 

Markets Operated by Regional Transmission Organizations, or RTOs, and Independent 

System Operators, or ISOs. 

Order No. 841 addresses the participation of electric storage resources in the 

capacity, energy, and ancillary service markets operated by RTOs and ISOs. The 

reforms adopted in Order No. 841 more effectively integrate electric storage 

resources into RTO and ISO markets, enhance competition, and help ensure that those 

markets produce just and reasonable rates. 

To remove barriers to the participation of electric storage resources in the RTO and 

ISO markets, Order No. 841 requires each RTO and ISO to revise its tariff to establish a 

participation model consisting of market rules that, recognizing the physical and 

operational characteristics of electric storage resources, facilitate their participation 

in the RTO and ISO markets. 

Today’s draft orders find that, consistent with Order No. 841, SPP’s and PJM’s 

participation models for electric storage resources generally enable electric storage 

resources to provide all services those resources are capable of providing in their 

wholesale electric markets, and allow those resources to be compensated for the 

wholesale services that they provide in the same manner as other resources that 

provide these services. The draft orders find that both SPP and PJM have proposed 

market rules that appropriately recognize the unique physical and operational 

characteristics of electric storage resources and facilitate their participation in the 

RTO/ISO markets. The draft orders also direct SPP and PJM to submit further 

compliance filings, within 60 days of the date of issuance of these orders.
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www.FERC.gov

The draft orders also find that SPP’s and PJM’s tariffs generally satisfy Order No. 

841’s directive with respect to allowing electric storage resources to de-rate their 

capacity to meet minimum run-time requirements. However, they note that SPP’s 

and PJM’s tariffs do not include minimum run-time requirements for resource 

adequacy and capacity, respectively. The draft orders explain that, even though the 

Commission did not require RTOs/ISOs to make specific changes to their minimum 

run-time requirements in Order No. 841, such requirements affect rates, terms, and

conditions of service. Therefore, pursuant to section 206 of the Federal Power Act, 

the draft orders direct both SPP and PJM to submit tariff provisions reflecting their 

rules and practices regarding minimum run-time requirements. The draft orders 

direct SPP and PJM to submit these tariff provisions no later than 45 days after the 

publication of notice in the Federal Register of the Commission’s initiation of these 

separate section 206 proceedings. 

In initiating the separate PJM 206 proceeding, the draft order addressing PJM’s 

compliance filing also establishes a paper hearing procedure to investigate whether 

PJM’s minimum run-time rules and procedures are unjust, unreasonable, unduly 

discriminatory or preferential as applied to Capacity Storage Resources, outside of its 

compliance with Order No. 841.

Thank you. And thank you to the large inter-office team of Commission staff who 

contributed to the preparation of these orders. This concludes our presentation. We 

would be happy to address any questions that you may have.