COMMISSION REQUEST FOR ADDITIONAL INFORMATION

Transcription

1 PJM Interconnection, L.L.C Monroe Blvd Audubon, PA James M. Burlew Senior Counsel T: (610) ǀ F: (610) VIA ELECTRONIC FILING The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC Re: Proposed Revisions to Joint Operating Agreement Midcontinent Independent System Operator, Inc. and PJM Interconnection, L.L.C. FERC Docket Nos. ER ; ER ; ER ; ER Response to Deficiency Letter Dear Secretary Bose: The Midcontinent Independent System Operator, Inc. ( MISO ) and PJM Interconnection, L.L.C. ( PJM ) (together, the RTOs ) respond to the December 28, 2017 letter ( December 28 Letter ) of the Federal Energy Regulatory Commission s ( Commission ) Office of Energy Market Regulation ( OEMR ) seeking additional information concerning revisions to the Joint Operating Agreement ( JOA ) between the RTOs, filed on October 23, 2017, and amended on October 24, 2017 and October 25, 2017 to address overlapping congestion charges on pseudo-tied generation resources. The RTOs appreciate the opportunity to further clarify the proposed revisions. I. THE OCTOBER AMENDMENTS The October JOA amendments propose the first of two phases of JOA and Tariff changes to address growing concerns over the potential for overlapping congestion charges between the RTOs markets. This first phase solution focuses on treating pseudo-tie transactions as similar as practically possible to dynamically scheduled interchange transactions while ensuring the congestion and market-to-market ( M2M ) process accurately reflects the transfer of the pseudotie from the Native Balancing Authority to the Attaining Balancing Authority. II. COMMISSION REQUEST FOR ADDITIONAL INFORMATION In the December 28 Letter, OEMR stated that MISO s and PJM s submissions were deficient and that additional information would be required by the Commission in order to evaluate the proposed amendments. Specifically, OEMR directed MISO to address three sets of questions enumerated below. The RTOs joint responses to OEMR s questions follow.

2 Page 2 Nature of Congestion Charge Overlap Issues 1. As part of the proposal, PJM and MISO explain in their filings that [a] congestion overlap issue occurs on the pseudo-tie transaction path between the source generation resource and sink interface for congestion associated with [Reciprocally Coordinated Flowgates (RCF)] that are coordinated under the [Market-to-Market (M2M)] process. The congestion overlap only occurs when an associated M2M constraint binds in both markets (i.e., both markets are binding on the same constraint). a. How many hours per year do market-to-market constraints bind simultaneously in both PJM and MISO? In Real-Time between MISO and PJM, in 2016, there were 7,421 constraint-hours in which shadow prices were non-zero, resulting in settlements between the RTOs and 140 unique constraints. 1 In Real-Time between MISO and PJM, in 2017, there were 7,866 constraint-hours in which shadow prices were non-zero, resulting in settlements between the RTOs and 135 unique constraints. b. Under what conditions do constraints typically bind simultaneously in both PJM and MISO? Section 3.1, Real-Time Energy Market Coordination Procedures, describes how the RTOs manage M2M flowgates. In the Real-Time Market, the Monitoring RTO monitors flows on facilities and will bind total flow if a flowgate is approaching its limit 2. By binding total flow, the Monitoring RTO ensures reliability of the flowgate. The Monitoring RTO binds a flowgate in its dispatch software; it informs the non- Monitoring RTO of the condition 3. The non-monitoring RTO also redispatches for that flowgate to the extent it can do so more cost-effectively than the first. Both RTOs will then continue to redispatch their systems respecting the constrained flowgate. The result of this coordination will be the most economic redispatch solution for the combined footprint. When the constraint is no longer binding in the Monitoring 1 This data is derived from publicly available Hourly Market-to-Market Settlements reports on MISO s Website. to Market 2 See JOA Attachment 3 (Interregional Coordination Process), Section When any of the M2M flowgates under a Monitoring RTO s control is identified as a transmission constraint violation, the Monitoring RTO will enter the M2M flowgate into its security-constrained dispatch software, setting the flow limit equal to the appropriate facility rating. 3 See JOA Attachment 3 (Interregional Coordination Process), Section The Monitoring RTO will then notify the Non-Monitoring RTO of the transmission constraint violation and will identify the appropriate M2M flowgate that requires mitigation.

3 Page 3 RTO s system, both RTOs will remove the constraint from their systems and redispatch will end. Do these market-to-market constraints bind in both PJM and MISO more often during a particular time of day or year? MISO and PJM reviewed M2M results from 2016 and 2017 and found that, in general, M2M constraints bound more during peak hours of the day (hour ending 7 through 22). In general, M2M constraints bound more in shoulder seasons, fall and spring, than in peak seasons, summer and winter. See figures below. 450 Binding Hours by Hour of the Day M2M Constraints Binding Hours Hour of Day

4 Page 4 Binding Hours Binding Hours by Month of the Year M2M Constraints Month of the Year c. How many market-to-market constraints are affected by congestion overlap? Overlapping congestion charges only occur when associated market-to-market constraints were binding in both markets (i.e., both markets are binding on same constraint resulting in market-to-market coordination on the market-to-market flowgates). Currently, there are 366 flowgates designated as market-to-market constraints, also known as market-to-market flowgates, on which market-to-market coordination can occur under the JOA. Binding and settlements between the RTOs occurred on 140 market-to-market flowgates in Therefore, 140 market-tomarket flowgates were potentially affected by overlapping congestion in In 2017, binding and settlements between the RTOs occurred on 135 market-to-market flowgates. Therefore, 135 market-to-market flowgates were potentially affected by overlapping congestion in What is the percentage of market-to-market constraints affected by congestion overlap?

5 Page 5 Theoretically, all M2M constraints could be affected by congestion overlap, to the extent that M2M constraints bound in both markets, pseudo-tie generators were sourcing transactions in both markets, and the generators and/or interfaces had nonzero sensitivities to the binding M2M constraints in both markets. Are the market-to-market constraints affected by congestion overlap concentrated in specific locations along the PJM/MISO seam? The M2M constraints most affected by congestion overlap are those with sensitivities, or non-zero shift factors, to pseudo-ties. The M2M constraints with the higher shift factors relative to the pseudo-ties are impacted most by the congestion overlap. How often are each PJM and MISO the monitoring RTO for the market-tomarket constraints affected by congestion overlap, both by number of constraints and number of hours? In 2016, of the 140 constraints, MISO was the Monitoring RTO on 98 constraints (70.0%), PJM was the Monitoring RTO on 42 constraints (30.0%). Of the 7,421 constraint-hours when the M2M constraints bound, MISO was the Monitoring RTO for 5,285 hours (71.2%), PJM was the Monitoring RTO for 2,136 hours (28.8%). In 2017, of the 135 constraints, MISO was the Monitoring RTO on 95 constraints (70.4%), PJM was the Monitoring RTO on 40 constraints (29.6%). Of the 7,866 constraint-hours when the M2M constraints bound, MISO was the Monitoring RTO for 6,096 hours (77.5%), PJM was the Monitoring RTO for 1,770 hours (22.5%). Of the currently-effective 366 active M2M flowgates, PJM is the monitoring entity for 40% of them and MISO is the monitoring entity for 60%. Generator Pseudo-Tie Market Flow Adjustment Calculation 2. PJM and MISO propose to revise section 3.2 and add section 11 to the Interregional Coordination Process in Attachment 3 of the JOA to provide procedures for: (1) reflecting a new Generator Pseudo-Tie Market Flow Adjustment in the Real-Time Energy Market Settlements (Real-Time Energy Market Settlements); and (2) calculating the Market Flow Adjustment for generation pseudo-ties used to reduce the Real-Time Market Flows (Market Flow Adjustment for Generator Pseudo-Ties). a. PJM and MISO state that the equation in section 11.1 will be used to calculate the transfer distribution factor for each generator pseudo-tie and market-tomarket flowgate pairing, which includes a weighted shift factor. How will PJM

6 Page 6 and MISO determine the weighted shift factor from the MISO-PJM common interface and each market-to-market flowgate pairing? PJM and MISO will employ a shift factor calculation to determine the weighted shift factor. This calculation will determine the weighted shift factor for the MISO/PJM Common Interface, which represents the portion of the path from the physical unit location to the MISO/PJM border. The current interface is composed of a collection of Price Nodes ( Pnode ), shown in Table 1 below. PNODE_ID PNODE_NAME WEIGHTING_FACTOR WAUKE 138 KV WA WILL 20 KV WC POWERT24 KV PO CAYUGA2 345 KV CAY MICHIGA2345 KV MC SCHAHFER345 KV SH BVR CH 620 KV RCH52GUN ROCKPOR226 KV RP MONROE 26 KV MON EBEND 20 KV EB Table 1 PJM/MISO Common Interface Pnodes, as implemented on June 1, 2016 Each Pnode within the interface has its own shift factor. To calculate the weighted shift factor, first the weighting factor must be calculated, which describes the total pnode participation in the interface. Ideally, this sum should equal 1, but if an individual Pnode shift factor was not available, the other Pnodes will become a larger representation of the interface or an equivalent Pnode may be used. WWFF IIIIIIIIIIIIIIIIII = WWFF PPPPPPPPPP, IIIIIIIIIIIIIIIIII PPPPPPPPPP Interface Once the weighting factor (WF) is calculated, the weighted shift factor (WSF) can be calculated by multiplying the weighting factor of each individual Pnode by the shift factor of the individual Pnode and dividing by the total weighting factor of the interface. WWWWFF IIIIIIIIIIIIIIIIII,FFFF = SSFF PPPPPPPPPP,FFFF WWFF PPPPPPPPPP, IIIIIIIIIIIIIIIIII WWFF IIIIIIIIIIIIIIIIee PPPPPPPPPP Interface Will these calculations be shared with the pseudo-tied resource?

7 Page 7 MISO and PJM are using the same interface modeling methodology in determining the market flow credit and the real-time commercial models. MISO posts the PJM interface definition on the MISO Extranet as part of its Commercial Model. The approach is outlined in MISO s Network and Commercial Model Business Practices Manual ( BPM ). 4 Neither MISO nor PJM publicly posts such market related calculations. Please provide an example calculation and explain any assumptions made in the example. The weighted shift factor of the MISO-PJM common interface for each M2M flowgate pairing is calculated by using the shift factor (SF) matrix for each flowgate/interface unit pair. In below example SF values (SF_FGx) for one flowgate for each of the interface units are used to calculate the WWWWFF IIIIIIIIIIIIIIIIII,FFFF(xx). WWWWFF IIIIIIIIIIIIIIIIII,FFFF for each flowgate is calculated by calculating the average of the individual SF values under SF_FGx (for the interface units that are online), which will be same as sum of Weighting_Factor * SF_FGx (sum of last column). The following image demonstrates the calculation of weighted shift factor using sample data: 4 See Section of BPM-010, currently available at

8 Page 8 In the above example, it is assumed that all interface units are online. If any unit is offline, the weighting factor will be different. For example, if eight units are online, weighting factor will be 1/8, which equals 0.125). 3. PJM and MISO state that the equation in section 11.2 will be used to calculate the Pseudo-Tie Market Flow Adjustment, defined as the transfer distribution factor for each pseudo-tied resource and M2M flowgate pairing multiplied by the output of the pseudotied resource. For modeling purposes, PJM and MISO will determine the amount of impact on M2M flowgates based on resource offers in the day-ahead market. This adjustment will then be included as part of the Real Time Energy Market Settlements calculation in section 3.2, which includes two equations for payments between PJM and MISO.

9 Page 9 a. Please provide an example in which the Real-Time Market Flow minus the Generator Pseudo-Tie Market Flow Adjustment is greater than the flow entitlement plus the Approved MW adjustment from day-ahead coordination. The following equation and example solution describes the calculation for payment demonstrating the requested outcome. Payment = ((Firm Flow Entitlement MW 5 + Approved MW 6 ) (Real- Time Market FlowMW 7 - Generator Pseudo-Tie Market Flow Adjustment 8 )) * Transmission Constraint Shadow Price in Non- Monitoring RTOs Dispatch Solution Real-Time Market Flow MW = 50 MW Generator Pseudo-Tie Market Flow Adjustment = 20 MW Firm Flow Entitlement MW = 40 MW Approved MW = 0 MW Trans. Constraint Shadow Price in Non-Monitoring RTOs Dispatch Solution = $100 Payment = ((40 + 0) - (50-20)) * $100 Payment = $1,000 b. Please also provide an example in which the Real-Time Market Flow minus the Generator Pseudo-Tie Market Flow Adjustment is less than the flow entitlement plus the Approved MW adjustment from day-ahead coordination. The following equation and example solution describes the calculation for payment demonstrating the requested outcome. Payment = ((Firm Flow Entitlement MW + Approved MW) (Real- Time Market FlowMW - Generator Pseudo-Tie Market Flow Adjustment)) * Transmission Constraint Shadow Price in Non- Monitoring RTOs Dispatch Solution Real-Time Market Flow MW = 50 MW Generator Pseudo-Tie Market Flow Adjustment = 20 MW Firm Flow Entitlement MW = 40 MW Approved MW = 0 MW 5 This value represents the Non-Monitoring RTO s Firm Flow Entitlement. 6 This value represents the Approved MW that resulted from the Day Ahead Coordination. 7 This value represents the Non-Monitoring RTO s Real Time Market Flow. 8 This value represents the Generator Pseudo-Tie Market Flow Adjustment as described in Section 11 of the Interregional Coordination Process, which is Attachment 3 to the JOA.

10 Page 10 Trans. Constraint Shadow Price in Non-Monitoring RTOs Dispatch Solution = $100 Payment = ((40 + 0) - (50-20)) * $100 Payment = $1,000 c. In your examples to parts (a) and (b) above, please also include what the payments between PJM and MISO would be in the absence of the Generator Pseudo-Tie Market Flow Adjustment (i.e., what the payments would be under the currently effective JOA). If the Real-Time Market Flow is greater than the flow entitlement plus the Approved MW adjustment from Day Ahead Coordination, then the Non-Monitoring RTO will pay the Monitoring RTO for congestion relief provided to sustain the higher level of Real-Time Market Flow. This payment will be calculated based on the following equation: Payment = (Real-Time Market Flow MW - (Firm Flow Entitlement MW 3 + Approved MW)) * Transmission Constraint Shadow Price in Monitoring RTOs Dispatch Solution Real-Time Market Flow MW = 80 MW Firm Flow Entitlement MW = 40 MW Approved MW = 0 MW Trans. Constraint Shadow Price in Monitoring RTOs Dispatch Solution = $100 Payment = (80 - (40 + 0)) * $100 Payment = $4,000 If the Real-Time Market Flow is less than the flow entitlement plus the Approved MW adjustment from Day Ahead Coordination, then the Monitoring RTO will pay the Non-Monitoring RTO for congestion relief provided at a level below the flow entitlement. This payment will be calculated based on the following equation: Payment = ((Firm Flow Entitlement MW + Approved MW) Real- Time Market FlowMW) * Transmission Constraint Shadow Price in Non-Monitoring RTOs Dispatch Solution Real-Time Market Flow MW = 50 MW Firm Flow Entitlement MW = 40 MW Approved MW = 0 MW Trans. Constraint Shadow Price in Non-Monitoring RTOs Dispatch Solution = $100 Payment = ((40 + 0) - 50) * $100

11 Page 11 Payment = - $1,000 (The negative value implies that the Non-Monitoring RTO will pay the Monitoring RTO $1,000) d. Please explain whether and how the proposed Pseudo-Tie Market Flow Adjustment might address any congestion overlap for pseudo-tied loads between MISO and PJM. To the extent that these calculations do not address pseudo-tied loads between MISO and PJM, please indicate the section of the JOA which does, or, in absence of such provisions, how PJM and MISO address this type of congestion overlap. There are currently no pseudo-tied loads between MISO and PJM that are impacted by the congestion overlap issue. The current JOA and the proposed changes do not explicitly address pseudo-tied loads. MISO and PJM have not proposed changes to address pseudo-tied loads as part of the Phase 1 and Phase 2 solution due to the lack of applicability. Neither the MISO Tariff nor the PJM Tariff contain provisions requiring loads to pseudo-tie. 4. Please provide an example of how PJM and MISO will determine the impact on market-to-market flowgates according to the proposed language to section 4.1 (Day Ahead Energy Market Coordination Procedures) of the Interregional Coordination Process. PJM Response: PJM and MISO have proposed a revision to section 4.1 of the Interregional Coordination Process ( ICP ). 9 PJM proposes utilizing a forward looking impact analysis that calculates a Day Ahead Limit (FFE) adjustment on every monitored M2M flowgate. This adjustment will include the impact of every PJM Pseudo-Tie (i.e., Pseudo-Tied into PJM) using anticipated Day Ahead topology from the PJM AFC MMWG based PSSE cases effective for the operating day. On an hourly basis, PJM will calculate the relative impact of an injection at each Pseudo-Tie that is Pseudo-Tied in to PJM and corresponding withdraws at the PJM- MISO common interface on every M2M flowgate. PJM will assume the full Pseudo- Tie RPM commitment as the injection amount of each Pseudo-Tie. The following expressions would describe the impact of a single Pseudo-Tie on a single flowgate: GGGGFF PPPP,FFFF GGSSFF CCCC,FFFF = TTTTFF PPPPPPh,FFFF (1) PPPPPPPPPPPPPPtt PPPP,FFFF = TTTTFF PPPPPPh,FFFF MMWW PPPP (2) 9 Attachment 3 of the JOA.

12 Page 12 The following expression then describes the aggregate Pseudo-Tie adjustment for each M2M flowgate where n is the total number of Pseudo-Ties Pseudo-Tied into PJM: PPPPPPPPPPPPPPtt FFFF = ii PPPPPPPPPPPPPPPPtt ii,ffff = ii nn GGGGFF ii,ffff GGGGFF CCCC,FFFF MMWW ii (3) nn Example Three Pseudo-Ties are Pseudo-Tied into PJM and one is Pseudo-Tied out of PJM and into MISO, as illustrated below. FFGG MM1 A D B C I FFGG PP1 C Pseudo-Tied in to PJM Pseudo-Tied out of PJM Table 1 below shows each Pseudo-Tie impact on each flowgate. Table 1 - Day Ahead Pseudo-Tie Flowgate Adjustments Generator FFFFFFFFFFFFFFFF GGGGFF PPPP GGGGFF CCCC TTTTFF PPPPPPPP MMMM IIIIIIIIIIII A M B M C M D M A P B P C P

13 Page 13 D P Table 2 below provides a flowgate level summary of the adjustments that PJM will make in its Day Ahead Market software. Table 2 - Day Ahead Flowgate Adjustment Summary FFFFFFFFFFFFFFFF Owner IIIIIIIIIIII M1 MISO -29 P1 PJM -0.5 MISO Response: The RTOs are aligning their respective day-ahead constraint limits with expected real-time settlement volumes. As a result, PJM requires a more robust solution to address a larger number of constraints. MISO will rely on existing tariff provisions in its day-ahead solution. MISO uses historical information to develop expectations in administering Day-Ahead Constraint Limits, including those under M2M Coordination. In the example above, MISO would take into account the impact of Pseudo-Tie D on the flowgates M1 and P1 in determining Day-Ahead Constraint limits to account for the impact of real-time Market Flow Adjustment on M2M settlements. Proposed Phase 1 Solution 5. PJM and MISO state that As implemented through this filing, the Phase 1 changes will ensure adequate funding for congestion rights or rebates that may be developed by MISO and PJM in their Phase 2 filings for circumstances in which Phase 1 does not sufficiently mitigate the congestion overlap. a. Please explain in detail the circumstances in which Phase 1 does not sufficiently mitigate the congestion overlap. The congestion overlap exists for individual transactions, i.e. injections and withdrawals in each market as a result of the market they are scheduled in and the congestion on binding M2M constraints in those markets. Phase 1 seeks to mitigate the impact of the congestion overlap through day-ahead market coordination improvements such that day-ahead congestion prices better align with real-time congestion prices on M2M constraints. This will better align

14 Page 14 Day-Ahead congestion and associated charges with Real-Time binding and congestion in both Attaining and Native markets. Additionally, the Generator Pseudo-Tie Market Flow Adjustment ensures that one RTO does not receive M2M Congestion payments from the counterparty RTO for congestion it has been compensated for, or been compensated by a pseudo-tie transmission customer. As a result, each RTO will retain congestion revenues assessed to transactions in its market in order to provide appropriate congestion rebates as part of existing, or to be proposed Phase 2, mechanisms. Phase 1 will provide congestion rebates indirectly via proper Day-Ahead LMPs to the extent that market participants hold FTRs in the Attaining Balancing Authority, but will not provide full congestion rebates to transactions assessed overlapping congestion charges in the Attaining Balancing Authority because of the potential Real-Time deviations from the Day-Ahead market. In Phase 2, rebates will be available for the deviations from the Day-Ahead commitments and these rebates remove the remainder of the congestion overlap not accounted for with the Phase 1 Day- Ahead market adjustments. Therefore, a rebate mechanism has been established for the future Phase 2 filing. This Phase 2 rebate mechanism requires Tariff changes to the PJM and MISO respective tariffs. b. In situations where Phase 1 does not fully mitigate the congestion overlap, please explain how the proposed Phase 1 solution will ensure adequate funding for congestion rights and rebates that may be developed in the Phase 2 filings. The Generator Pseudo-Tie Market Flow Adjustment removes the congestion impacts from RCFs in the Attaining Balancing Authority preventing the Attaining BA from passing along congestion revenues collected from the Pseudo-Tie to the Native BA through M2M Settlements. This will provide revenue to fund congestion refunds to the appropriate Market Participants in the Attaining Balancing Authority s market. Since the Native BA assesses a Transmission Usage Charge to the pseudo-tie for congestion impacts, including those associated with RCFs, the Native BA does not require payment from the Attaining BA in order to fund congestion rights. 6. PJM and MISO state that Phase 1 ensures that neither [Regional Transmission Operator (RTO)] is compensated for congestion on RCFs by both their pseudo-tied transmission customer and the coordinating RTO via compensation for Market Flows in excess of Firm Flow Entitlements. Please explain whether removing the congestion impacts from RCFs in the Attaining Balancing Authority s Market Flow calculations results in resolution of the overlapping congestion charges affecting pseudo-ties in PJM and MISO? Removing the congestion impacts from RCFs in the Attaining Balancing Authority prevents the Attaining BA from passing along congestion collected from the Pseudo-Tie to the Native BA through M2M Settlements. This will

15 Page 15 provide revenue to fund congestion rights/refunds to the appropriate Market Participants in the Attaining Balancing Authority s market. 7. In their joint answer (Joint Answer), PJM and MISO state that the Phase 1 solution properly accounts for the market-to-market congestion caused by and paid for by the pseudo-tied resources in computing market-to-market settlements. The Joint Answer further states that the overlapping congestion charges are not eliminated in the real-time market, but are administered and rebated in the appropriate markets. To the extent possible, please provide further detail explaining how the Phase 1 solution properly models and accounts for this overlapping congestion when a resource does not receive a day-ahead commitment but is dispatched in the realtime market. Please explain how congestion charges are administered under the proposed Phase 1 solution. Please see PJM and MISO s response to question no. 5 (a) above. In question no. 5(a), the Commission directed the RTOs explain the circumstances in which Phase 1 does not mitigate the congestion overlap. The RTOs response explains: (1) the overlapping congestion that occurs under the currently-effective version of the JOA; (2) the overlapping congestion that will be addressed by Phase 1; and (3) the overlapping congestion not addressed by Phase 1 that will be addressed by Phase 2. III. REVISED EFFECTIVE DATE In their October filings, the RTOs each requested an effective date of March 1, 2018 and requested a substantive order from the Commission by no later than December 22, 2017, explaining that time was needed to implement the software changes associated with the proposed JOA revisions. Accordingly, the RTOs respectfully request that the Commission allow the RTOs to inform the Commission of a revised effective date to allow sufficient time for the RTOs to develop, test, and implement the software associated with the Phase 1 solution. 10 The RTOs commit to making a subsequent Section 205 filing with the Commission to update the Tariff sheets to reflect the most up-to-date versions of the then-current Tariff provisions. The update filing will be submitted at least 60 days prior to the proposed effective date of the Tariff provisions. 10 In the October filings, the RTOs described their intent to file Phase 2 revisions by no later than March 1, 2018 and implement them by June 1, The submission and implementation of Phase 2 revisions may also be affected by delays in the effective date of Phase 1.

16 Page 16 IV. NOTICE AND SERVICE MISO has served a copy of this filing electronically, including attachments, upon each person designated on the official service list compiled by the Secretary in this proceeding as well as all Tariff Customers, MISO Members, Member representatives of Transmission Owners and Non-Transmission Owners, as well as all state commissions within the region. For other parties interested in this matter, the filing has been posted electronically on MISO s website at PJM has served a copy of this filing on all PJM members and on all state utility regulatory commissions in the PJM region by posting this filing electronically. In accordance with the Commission s regulations, 11 PJM will post a copy of this filing to the FERC filings section of its internet site, at the following link: with a specific link to the newly-filed document, and will send an on the same date as this filing to all PJM members and all state utility regulatory commissions in the PJM region 12 alerting them this filing has been made by PJM and is available by following such link. If the document is not immediately available by using the referenced link, the document will be available through the referenced link within twenty-four hours of the filing. A copy of this filing will be available on the Commission s elibrary website at the following link: in accordance with the Commission s regulations and Order No V. CORRESPONDENCE AND COMMUNICATIONS Correspondence and communications with respect to this submission should be sent to, and pursuant to Rule 2010 of the Commission s Rules of Practice and Procedure, 18 C.F.R (2016), MISO requests the Secretary to include on the official service: Erin M. Murphy Managing Assistant General Counsel Midcontinent Independent System Operator, Inc. 720 City Center Drive Carmel, IN Tel: emurphy@misoenergy.org Kristina C. Pacovsky Senior Corporate Counsel Midcontinent Independent System Operator, Inc. 720 City Center Drive Carmel, IN Tel: kpacovsky@misoenergy.org 11 See 18 C.F.R 35.2(e) and (f)(3). 12 PJM already maintains, updates, and regularly uses lists for all PJM Members and affected state commissions.

17 Page 17 Craig Glazer Vice President Federal Gov t Policy PJM Interconnection, L.L.C G Street, N.W. Suite 600 Washington, D.C Tel: craig.glazer@pjm.com James M. Burlew Senior Counsel PJM Interconnection, L.L.C Monroe Boulevard Valley Forge Corporate Center Audubon, PA Tel: james.burlew@pjm.com VI. CONCLUSION PJM requests that the Commission accept this response to the December 28 Letter. Respectfully submitted, Craig Glazer Vice President Federal Government Policy PJM Interconnection, L.L.C G Street, N.W. Suite 600 Washington, D.C (202) craig.glazer@pjm.com James M. Burlew Senior Counsel PJM Interconnection, L.L.C Monroe Boulevard Audubon, PA (610) james.burlew@pjm.com cc: Mr. Mark Armamentos (Mark.Armamentos@ferc.gov) Mr. Eric Icart (Eric.Icart@ferc.gov)