As if PJM's electric market rules aren't already complicated enough, now PJM is insisting that RPM participants follow rules that aren't even rules yet.
Well, yeah, we all know that PJM answers to no one. No, really, a certain PJM employee actually told a reporter once, "PJM answers to no one," when he was trying to sell the PATH project to West Virginia citizens.
And PJM's market monitor told a newspaper once, "following the rules does not mean you are not manipulating the market."
So, it appears that PJM gets to make up its own rules, often before or after the fact, and nobody can protect you, because PJM is omnipotent and all. Following the tariff doesn't appear to offer any protection against being accused of manipulation. And, now it seems that PJM members have obligations to abide by proposed rules that aren't even in the tariff...
Recently, PJM filed changes to the capacity market portion of its tariff which, if approved, will establish a deadline for data submittal. The new deadline will occur in early January each year. In its filing, PJM has asked FERC to approve the tariff revisions by April 1st.
But, PJM and Monitoring Analytics seem to think the proposed portion of the tariff is already in effect and are requiring capacity suppliers to submit certain data now. FERC has yet to approve these new rules! But, what could happen if the new data is not submitted by the proposed deadline in January, even though the tariff revisions are proposed to be effective in April and are NOT YET IN EFFECT? Could the market participant be referred to FERC under a tariff violation claim?
So, not only is it possible to be guilty of something without actually violating PJM's rules, it is now also unacceptable to violate new rules that are not yet in effect!
I think the bloated bureaucracy that is PJM needs to be slimmed down and cleaned up, because free M&Ms only have so much charm.
Well, yeah, we all know that PJM answers to no one. No, really, a certain PJM employee actually told a reporter once, "PJM answers to no one," when he was trying to sell the PATH project to West Virginia citizens.
And PJM's market monitor told a newspaper once, "following the rules does not mean you are not manipulating the market."
So, it appears that PJM gets to make up its own rules, often before or after the fact, and nobody can protect you, because PJM is omnipotent and all. Following the tariff doesn't appear to offer any protection against being accused of manipulation. And, now it seems that PJM members have obligations to abide by proposed rules that aren't even in the tariff...
Recently, PJM filed changes to the capacity market portion of its tariff which, if approved, will establish a deadline for data submittal. The new deadline will occur in early January each year. In its filing, PJM has asked FERC to approve the tariff revisions by April 1st.
But, PJM and Monitoring Analytics seem to think the proposed portion of the tariff is already in effect and are requiring capacity suppliers to submit certain data now. FERC has yet to approve these new rules! But, what could happen if the new data is not submitted by the proposed deadline in January, even though the tariff revisions are proposed to be effective in April and are NOT YET IN EFFECT? Could the market participant be referred to FERC under a tariff violation claim?
So, not only is it possible to be guilty of something without actually violating PJM's rules, it is now also unacceptable to violate new rules that are not yet in effect!
I think the bloated bureaucracy that is PJM needs to be slimmed down and cleaned up, because free M&Ms only have so much charm.
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