WILMINGTON — A proposal to study potential “fatigue” among demand response resources met strong opposition Thursday, March 28, with curtailment service providers suggesting anticompetitive motives by the sponsor.
Ken Carretta, of PSEG, told the Markets and Reliability Committee that stakeholders should explore whether PJM has sufficient safeguards to ensure that Emergency Demand Response resources will perform as needed if they are increasingly called upon in the future, as PJM expects.
Carretta said the proposed problem statement, presented to the committee on first reading, is a response to a recommendation by the Brattle Group that PJM should “confirm that [DR] Resources can respond as often and as seasonably as claimed.”
Representatives of demand response companies, including Dan Griffiths of Comverge and Bruce Campbell of EnergyConnect, said new rules could increase their record-keeping costs and were unnecessary because providers already face high penalties if they fail to perform. “This appears to be an anticompetitive” move, said Aaron Breidenbaugh, of EnerNOC. “… A solution in search of a problem.”
Bob Weishaar, who represents industrial customers, also was skeptical. “We normally don’t oppose problem statements but we have no evidence that there’s been any demand response fatigue,” he said.
Carretta denied the proposal was motivated by competitive concerns. Current PJM rules, he said, don’t require CSPs to demonstrate that their portfolios are capable of meeting frequency obligations. Potential reporting requirements for DR resources would be no more onerous than those for generators, which track their outages, he said.
PJM Concerned
Michael Kormos, PJM senior vice president for operations, declined to take a position on the problem statement or any potential solutions but said the RTO “absolutely” is concerned about its increasing reliance on DR.
PJM expects the importance of demand response to increase because its Installed Generation Reserve Margin (IGRM) is projected to fall from the current 13% to 9% after 2013/14. The RTO projects DR resources will be called upon from five to nine times annually beginning in 2014/15, up from one to five calls in 2013/14.
“It’s not a problem — we’re still reliable — but we’ll probably have to call on demand response more in the future,” Kormos said.
Annual Limits
Limited DR resources can be called upon 10 times annually for up to six hours each over the summer. Annual DR resources can be called upon for up to 10 hours a day with no limit on the number of days they are called.
