Commissioner Richard Glick Statement
May 29, 2020
Docket No. ER20-1451-000
Joint Concurrence of Commissioner Richard Glick and Commissioner James Danly Regarding PJM Interconnection, LLC
We support the Commission’s approval of PJM’s revisions to the creditworthiness provisions of its tariff. Although we are made somewhat uneasy by the breadth of the discretion afforded to the RTO in making creditworthiness decisions, on the whole, PJM’s proposal is at least as exacting as others we have approved[1] and is otherwise just and reasonable.
These revisions represent an important first step in enhancing PJM’s credit risk evaluation process, but they are just that: a first step. Further changes should be considered, not only in PJM, but in all the organized markets. In this regard, we note that the Commission has pending before it Docket No. AD20-6-000, a petition to convene a technical conference and initiate a rulemaking addressing credit and risk management procedures across the markets.[2] Docket No. AD20-6-000 represents a timely vehicle for the Commission to engage in a much-needed discussion on these important issues, and we urge the Commission to take advantage of the opportunity afforded by this petition.
For these reasons, we respectfully concur.
[1] See, e.g., Midcontinent Indep. Sys. Operator, Inc., 170 FERC ¶ 61,257 (2020); N.Y. Indep. Sys. Operator, Inc., 170 FERC ¶ 61,054 (2020).
[2] See Energy Trading Institute, Request for Technical Conference and Petition for Rulemaking to Update Credit and Risk Management Rules and Procedures in the Organized Markets of Energy Trading Institute, Docket No. AD20-6-000 (Dec. 16, 2019).