Exelon asks FERC for a prompt PJM capacity auction; PJM pushes back
PJM answered a day later, opposing fast-track review and seeking until December 21 to reply; Invenergy filed its own complaint seeking MISO capacity accreditation for merchant HVDC lines.
Exelon asked the Federal Energy Regulatory Commission on November 3, 2026 to find PJM Interconnection's three-year-forward capacity auction schedule unjust and unreasonable and to replace it with a "prompt" auction held two months before each delivery year, starting with 2030/2031. The complaint, docket EL27-11, would move the 2030/2031 Base Residual Auction, now scheduled for May 2027, to approximately March 2030. Exelon asks for fast-track processing and an order by January 31, 2027, the last day before PJM was scheduled to post that auction's planning parameters, with a refund effective date of January 1, 2027.
The complaint comes from the buying side. Exelon's six utilities serve more than 10.7 million customers in PJM, and the auction has been expensive. The 2027/2028 and 2028/2029 auctions both cleared at the FERC-approved price cap ($325.00 per MW-day in PJM's Rest of RTO zone for 2028/2029) and fell short of PJM's reliability requirement by 6,517 MW and 6,831 MW. The 2029/2030 auction, scheduled for December 2026, runs under a $337.83 per MW-day cap, and Exelon leaves it out of the request because its planning parameters are already posted. Later auctions are slated to run without a cap, Exelon says, and moving the 2030/2031 auction would keep customers from what it calls the uncapped surge in capacity prices expected in spring 2027.
Why three years, and why not now
The forward auction had a reason. The 2006 settlement FERC approved set the gap at three years, leaning on testimony that a new plant typically took 33 months from study agreement to commercial operation, and FERC accepted that customers might bear the risk of an inaccurate forward estimate as reasonable against the risk that enough capacity would not be built.
Exelon argues both halves of that bargain have gone. On forecasting, it says load adjustments in PJM's 2026 forecast equal 18.4% and 21.7% of summer peak four to five years out, where adjustments in the 2017 through 2021 forecasts were no more than 2%. On building, it cites manufacturers' backlogs, including 116 GW at GE Vernova and Mitsubishi gas turbine lead times of five years or more, with deliveries booked as far out as 2031 to 2034. It also counts about 24 GW of planned generation that terminated signed interconnection agreements since 2020 before reaching commercial operation, 13.5 GW of it gas. Its most useful witness is PJM: Exelon quotes PJM's own May 2026 white paper saying the three-year timeline's "foundational assumption of the RPM design has been physically broken."
A prompt auction, Exelon says, would price capacity on better load forecasts and accreditation data, and would let only resources that have reached, or are on the imminent path to, commercial operation participate. Exelon says FERC has already found prompt schedules just and reasonable for ISO New England, New York's NYISO and MISO, and that the change would align PJM with every other grid operator running a centralized capacity market. The company concedes the fix is partial. "A move to a prompt auction schedule alone will not solve the affordability challenges facing the region," its November 4 release says.
The prompt auction is Exelon's near-term fix. Its longer-term idea gives the auction a smaller part: the company's October 30 investor deck called for state-directed planning and procurement of generation, with the capacity market "providing residual support," as The Duck Curve reported when its utilities pitched owning batteries.
PJM: not on Exelon's clock
PJM answered the next day. Its November 4 preliminary answer opposes fast-track processing and asks FERC to push its deadline to answer on the merits back four weeks, from November 23 to December 21, 2026. PJM says changing so foundational a rule needs its stakeholders' input, and it disagrees that a prompt auction is just and reasonable on its own without a suite of complementary enhancements.
Its main argument is that Exelon's deadline is not one. Legal consequences attach when sellers submit binding offers, PJM argues, not when planning parameters are posted, and a refund effective date already preserves whatever relief FERC might grant. The date has also moved: after a FERC order on October 30 accepted tariff changes, PJM now expects to post the 2030/2031 planning parameters on or before March 1, 2027, so even an order timed to beat the posting could come as late as February 28. Exelon's deadline "no longer reflects PJM's anticipated pre-auction schedule for posting the planning parameters," PJM says.
PJM also wants room for its board, which is scheduled to consider the path forward for the 2030/2031 auction at its November 17, 2026 meeting. PJM says the board's determinations are expected to "substantially inform" its position. The grid operator Exelon wants to move faster is asking for more time, partly to hear what its own board decides about that very auction.
Next door, a line not yet built asks to be paid
A day after Exelon filed, Invenergy Transmission filed its own complaint, docket EL27-12, against MISO, one of the prompt-auction markets Exelon cites as precedent. Its argument is about who gets paid, not when. MISO counts the support that interregional merchant HVDC lines provide when it sets its Planning Reserve Margin, which lowers how much capacity it buys, but its rules do not let merchant HVDC lines be accredited as Capacity Resources or otherwise be paid for that value, Invenergy says. Merchant lines have no captive ratepayers, and Invenergy argues that as things stand "there is no product or service that can be the basis of a merchant-based transaction in MISO."
The line behind the complaint is Grain Belt Express, a planned HVDC line of approximately 800 miles and 5,000 MW whose first phase would connect MISO and SPP with 2,500 MW of transfer capacity beginning in 2031. A Synapse Energy Economics study for Invenergy estimates the line could provide more than 1,800 MW of accredited capacity under MISO's Direct Loss of Load method, and that with no firm transmission contracts it would have cut MISO system costs by $1.8 billion for the 2026-2027 planning year had it been online and able to participate. That is a counterfactual for a line whose first phase is not scheduled to carry power until 2031. Invenergy wants MISO's fix filed within six months of an order and in place no later than the 2030/2031 delivery year, the same year Exelon wants PJM's prompt auctions to start.
Outlook
If FERC applies the five-day period PJM asked for, responses to its extension request would be due November 9; the PJM board meets November 17; and answers to the complaint are due November 23 unless FERC grants the extension to December 21. If FERC grants the extension, about ten weeks would separate the last answers from PJM's expected March 1 posting, by our count, and an order after that date would test PJM's argument that posting carries no legal consequence. The December 2029/2030 auction is outside Exelon's request, its $337.83 per MW-day cap set either way. In the MISO case, comments on Invenergy's complaint are due November 24, per FERC's notice.
⚠ The Outlook extrapolates from the dates in PJM's November 4, 2026 preliminary answer (its requested November 9 response date, the November 17 board meeting, the November 23 and December 21 answer dates, and the expected March 1, 2027 posting of planning parameters, with the ten-week interval our own arithmetic) and from Exelon's November 3 complaint (the 2029/2030 auction's $337.83 per MW-day cap and its exclusion from the request). FERC has not acted on the complaint, the fast-track request or the extension motion; the November 24 comment date on Invenergy's complaint is from FERC's November 5 notice.
Sources
Primary
- Complaint Requesting Fast Track Processing of Exelon Corporation, Exelon Corporation v. PJM Interconnection, L.L.C., Docket No. EL27-11-000 · Exelon Corporation (filed with the Federal Energy Regulatory Commission)
- Complaint of Invenergy Transmission LLC v. Midcontinent Independent System Operator, Inc., Docket No. EL27-12-000 · Invenergy Transmission LLC (filed with the Federal Energy Regulatory Commission)
Supporting
- Preliminary Answer of PJM Interconnection, L.L.C. Opposing Fast-Track Processing and Motion for Extension of Time to Answer, Docket No. EL27-11-000 · PJM Interconnection (filed with the Federal Energy Regulatory Commission)
- Exelon Seeks to Protect Customers from "Unreasonable Costs" in New FERC Complaint · Exelon (via Business Wire)
- Combined Notice of Filings #1, November 5, 2026 · Federal Energy Regulatory Commission
Copies of cited sources are retained where available. If a link no longer resolves, request a copy at contact@theduckcurve.com.