Summary Efficient electricity day-ahead market designs include virtual transactions. These are financial contracts awarded at day-ahead prices and settled at real-time prices. In PJM these virtual transactions include incremental offers (INCs) that are like generation offers, decremental bids (DECs) that are like demand bids, and up-to-congestion bids (UTCs) that are like transmission price spread bids. Virtual transactions offer potential benefits to improve the efficiency of electricity markets, mitigate market power, enhance price formation, hedge real-time market risks, and price those risk hedging benefits.
The role and performance of virtual transactions has been a subject of controversy. A report by PJM addresses some of these controversies, identifies possible problems in the present implementation of virtual transactions with the associated settlement rules, and makes recommendations for changes in the treatment of virtual transactions. The PJM report is generally supportive of the contribution of virtual transactions as improving overall market performance. Illustrative examples in the report highlight these contributions and add to the general understanding of the benefits and some of the problems with its current rules for treating virtual transaction.
Although these examples help in explaining the mechanics of virtual transactions, and the interactions with the underlying physical market, the examples do not provide a framework for evaluating the overall cost and benefits of virtual transactions. The PJM analysis is not alone in this regard, because the evaluation task is not easy. There is no readily available template waiting to be applied to the PJM case. The limited available analyses from other regions indicate that the benefits are material and outweigh the costs, but no available studies cover all the relevant issues. However, going beyond examples of particular outcomes to consider, the broader context is important. Looking to the broader framework can change both the diagnosis of the symptoms and the prescriptions for the cures.
Under the current PJM market rules, there is an asymmetry in the settlement treatment of different types of virtual transactions, applying residual uplift charges to INCs and DECs but not to UTCs. One of the PJM recommendations is to eliminate this asymmetry by extending the same uplift treatment to UTCs. The argument is based on allocation of uplift costs according to the deviations between real-time quantity and day-ahead schedules. This approach is particularly problematic for virtual transactions, which by design involve a 100% deviation.
There is no simple connection between deviations, uplift costs and market efficiency. Under a broader equilibrium analysis there can be conditions where there is no relationship between any of these components. Furthermore, the allocation of properly defined residual costs according to a cost causation argument can in itself be a contradiction. More importantly, the focus on uplift cost causation is misplaced. The important question is the aggregate net benefit of virtual transactions, not the residual cost. If virtual transactions increase the net benefits in the market, then there is no incentive-based reason to assign additional costs to virtual transactions. The iii criterion for assigning residual costs would then turn to doing the least damage to the performance of the market.
A better symmetric solution is to avoid any uplift allocation to virtual transactions. The residual cost allocation would then apply to real load; liquidity and entry in financial day-ahead virtual transactions would be enhanced; market power would be reduced; accurate price formation would be supported; and the efficiency of the overall PJM electricity market system should be improved. This reversal of the conventional wisdom follows from a broader framework than that applied by PJM for consideration of the costs and benefits of virtual transactions.
This broader framework builds directly on the basic principles of efficient electricity market design. Stepping back to consider first principles makes it easier to see the connections among the components of market design, in order to consider the function and benefits of virtual transactions from the perspective of aggregate market performance. PJM’s own analysis provides many examples of the contributions and effects of virtual bidding, but does not connect the examples to the broader framework of electricity market design principles. Furthermore, going beyond the uplift allocations, the PJM recommendations restricting the use of virtual transactions do not follow necessarily even from a narrower evaluation perspective. The principal problem PJM identifies with virtual transactions is a computational burden that would be only indirectly affected by uplift allocations, and could be addressed through other means with fewer negative consequences for the broader market design, such as by continuation of bidding budgets that allowed flexibility in the choice of virtual transactions.
Restricting explicit virtual bidding, as PJM proposes, creates market power for those who can make implicit virtual bids. Explicit virtual bidding mitigates or eliminates this market power, provides liquidity, improves price formation, allows hedging, connects naturally with longer term financial transmission rights, helps reveal defects in market design, and on average should improve system operations.
The PJM report appears in a context where virtual bidding is under attack. While a complete cost benefit analysis is not available, the PJM analysis can be expanded to enhance both the understanding of the role of virtual bidding and the policies that support overall electricity market efficiency.