November 20, 2020

ESA and Clean Energy Associations Urge FERC’s Expeditious Approval of PJM Capacity Accreditation Reforms

ESA jointly submitted comments today with AWEA, SEIA, and AEE (“the Clean Energy Associations”) to express support for PJM’s proposed capacity accreditation reforms in Docket No. ER21-278, submitted on 10/30, and to urge that FERC expeditiously accept this filing to avoid delays in implementing the reforms in time for the 2023/2024 Delivery Year.  In these comments, the Clean Energy Associations note that PJM’s ELCC proposal will greatly improve how PJM calculates the capacity capabilities of a wide range of energy storage durations, as well as hybrid storage resources. Additionally, the Clean Energy Associations underscored support for PJM’s proposed transition mechanism to reduce excessive volatility for storage and other resources.

PJM’s capacity accreditation reforms would implement an Effective Load Carrying Capability (ELCC) method to calculate the contribution of storage and renewables to resource adequacy. In addition to calculating ELCC values for storage of 4, 6, 8, and 10-hours duration, the proposal includes a transition mechanism that would also codify minimum guaranteed ELCC values to bound uncertainty over value in future years. PJM’s ELCC Proposal arose out of the RTO’s compliance with Order No. 841, and FERC’s findings in its October 2019 Order that:

  1. PJM’s Open Access Transmission Tariff should include minimum run-time rules and procedures currently specified in its Manual for every resource type; and
  2. that PJM’s application of its minimum run-time rules and procedures to Capacity Storage Resources such as the 10-hour rule may be unjust and unreasonable.

PJM’s 10/30 filing is in part a response to the FERC’s April 2020 Order, which held in abeyance an ongoing Federal Power Act section 206 paper hearing (initiated in Docket No. EL19-100-000) regarding the 10-hour performance rule for storage resources.


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