Voltus and Mission:data pushed back on opposition to their complaint against PJM from the RTO and others on using statistical modeling for residential demand response customers, saying the current rules have residential customers providing just 0.4% of registered DR in the market (EL26-4).

“Complainants wish to make it completely clear for the record: Voltus and Mission:data’s complaint is limited to residential customers,” they said in an answer filed Nov. 18. “Voltus and Mission:data are not proposing that statistical sampling be employed for any other class of customer, or to sample across customer classes.”

PJM argued in its response that the complaint was trying to get around state rules, which have made it hard to access interval meter data for residential customers for legitimate reasons. The RTO also said it lets DR aggregators use statistical modeling when interval metering data is not available at all for residential customers. (See PJM Asks FERC to Deny Demand Response Metering Data Complaint.)

Allowing DR aggregators to use those statistical modeling techniques when interval meter data is made unobtainable by state rules would unlock residential DR in PJM, Voltus Chief Regulatory Officer and former FERC Chair Jon Wellinghoff said in an interview Nov. 19.

“I would say there’s probably several thousand megawatts of DR that could be brought into PJM if we could access those residential customers, but this is the block,” Wellinghoff said. “We are being blocked by the fact that we don’t have reasonable access to interval meter data.”

The original complaint detailed Voltus’ efforts to procure the needed data from utilities for residential customers and how that proved difficult enough to be infeasible. It did that after FERC rejected a similar complaint from CPower on the grounds it had not filed enough information to prove data access rules were a hindrance to signing up customers for wholesale DR.

Voltus has no problem going through information security regulations to access the data where they are available, but it showed in the original complaint that many utilities across PJM make it very difficult for any third parties to get access, he added.

FERC granting the complaint could lead to states making their rules more workable, Wellinghoff said.

“It will give money in the pockets of residential consumers who are hurting from utility bills,” he added. “It will provide money to them for participating in these programs.”

Two of the biggest issues facing the industry are interconnecting large loads and affordability, which can be in tension. DR can help free up space on the grid to connect additional loads, and it can save customers from paying for extra investments to the grid, while directly giving money to participants.

“All the governors in PJM should be all over this complaint, telling FERC you should approve it immediately,” Wellinghoff said.

These kinds of DR programs for residential customers get around resistance to more economically elegant price-responsive demand, which could be a grid resource given the right price signals such as time-of-use rates, Wellinghoff said. But PRD has not proved popular among consumers, even as technology has advanced.

“It’s simply because consumers would much rather have some third party provide some service to them that can control independently their devices in ways that will help the market but also preserve the comfort in their home and provide them money in their pocket,” Wellinghoff said. “But they don’t want to do anything actively, because they’ve got other things to do.”

Having a third-party aggregator handle the optimal charging for a plug-in car or when to moderate air conditioning demand makes it easier for consumers who need to focus on their family life or jobs, he added.

The utilities with interval meters for residential customers have unfettered access to the data and could set up these programs themselves, but they lack the incentives to do so, Wellinghoff argued.

“They have no interest or incentive to have consumers go on time-of-use rates,” Wellinghoff said. “They have no interest or incentive to help customers participate in wholesale markets because they don’t make any money doing that. In fact, they lose money by doing that, because what that does is it allows consumers to help the system run more efficiently.”

That means less investment in the system, and less investment means fewer returns for shareholders, he added.

In addition to opposition from the RTO and member utilities, PJM’s Independent Market Monitor opposed the complaint on the grounds that the statistical modeling methods were by nature less accurate than the real data, which would degrade the RTO’s ability to track Capacity Performance and its ability to maintain resource adequacy.

“What the IMM also does not acknowledge is that PJM, in fact, accepts this ‘uncertainty’ and lack of precision for financial settlements today, where interval meters do not exist, as outlined in Manual 19,” Voltus said in its answer. “PJM’s statistical sampling process is designed to be rigorous and requires [that] ‘samples must be designed to achieve a maximum error of 10% at 90% confidence.’ The IMM does not explain how complainants’ proposal would introduce unacceptable certainty beyond what is established practice today.”