Joseph Dominguez - Exelon Corp.
Analyst · Stephen Byrd with Morgan Stanley
Yes. Stephen, it's Joe, and let me just start off with an observation. It's interesting. Secretary Perry in the 403 last fall identified a resilience problem in these markets. And as you know, that proposal was widely panned with a number of parties indicating that there is no resilience issue. Yet, in the last 48 hours, we've seen a filing by the New England ISO to retain Mystic on fuel security resilience grounds, and of course, we saw this white paper from PJM on Monday indicating that it too may have a resilience problem that would require capacity market changes. From our perspective, turning to that white paper, the things that are going to be important is to understand the analytics, the inputs into the analyses that PJM runs and in particular, how they think about the unavailability of natural gas pipeline service and for what duration. What Chris mentioned at the top of the call is that in addition to those constraints or those modeling parameters, we'd like to see them model environmental impacts associated with this fuel mix. We kept the New England system running this year really on the back of oil-fired units. And while we succeeded in keeping the lights on, it was a disappointing outcome for environmentalists in New England, where we burned 2 million barrels of oil and a disastrous, frankly, outcome for the stakeholder process in New England, where they want to get to lower air pollution, carbon and conventional pollutant emissions. So, we think that needs to be incorporated as well into PJM's analysis. And until we get those environmental externalities incorporated, we're not going to have a complete market. So, we see this as a positive step forward. We're going to look very carefully at how they intend to model this situation, again, the unavailability of gas and for how long. And we think if they do that right, they're going to find that they, too, like New England, have a significant number of fuel constraints on the system that will require them to preserve fuel secure resources. Now, that could be gas plants on Marcellus Shale's storage, it could obviously be nuclear plants and it could be coal plants, but then we need to take another look at that mix and make sure we're meeting the expectations of our customers and communities in terms of environmental impacts. In 2018, emissions need to be going down. And any resolution of this issue that results in emissions going up is going to continue to create incentives for state actions and indeed, for other federal actions to correct the flaws in those market.