Consumer Advocates to PJM: No More Changes, Please
Consumer advocates asked the PJM Board of Managers to assess the impact of recent capacity market changes before making any new ones and criticized what they called the RTO’s new “inflexibility.”

CAMBRIDGE, Md. — Consumer advocates asked the PJM Board of Managers last week to assess the impact of recent capacity market changes before making any new ones and criticized what they called the RTO’s new “inflexibility.” Environmental groups, meanwhile, asked PJM to become “proactive” in addressing climate change and to do more to capture the role of energy efficiency in its planning.

The comments came at the board’s yearly meeting with consumer advocates and public interest groups on the first day of the PJM Annual Meeting here. The tone was a bit less rancorous than 2013’s meeting, with several activists praising PJM for its work maintaining electric service during January and for its response to generator retirements.

Still, the participants weren’t going to let their one shot to talk to the board — and it was almost entirely a one-way conversation — go to waste.

“Five major proposals in the capacity market in the last 12 months is a lot to digest,” said Assistant Pennsylvania Consumer Advocate Dave Evrard, who cited four changes that were approved by FERC and one that was rejected. Evrard noted that PJM had provided cost estimates on only one of the four proposals, a restriction on how demand response clears in the auction. (See PJM Wins on DR, Loses on Arbitrage Fix in Late FERC Rulings.)

“We watch somewhat nervously to see what the results of the current base residual auction will be,” Evrard said, noting that demand response offers dropped by 27% between the 2012 and 2013 base residual auctions. The question is whether the recent DR changes “[exacerbate] the decline or if that was simply an aberration,” he said.

Wil Burns, an attorney who represents environmental groups, echoed Evrard’s concerns, saying the board should not make any additional changes until it has analyzed the impact of the recent changes.

PJM’s `Inflexibility’

Brian Lipman, litigation manager at the New Jersey Division of Rate Counsel, criticized PJM for failing to discuss with stakeholders its position on a crucial capacity market rule before filing comments with the Federal Energy Regulatory Commission. PJM sided with FirstEnergy, which petitioned FERC on April 7 to change how the RTO calculates the maximum price generators can offer into capacity auctions (EL14-36).

“We didn’t find out about PJM’s position until it was filed,” he said. “That is concerning to us that we didn’t have any input into that decision.”

PJM’s “recent inflexibility” regarding rule changes “makes stakeholders worry about the future of consensus-building,” he added.

Lipman said PJM should take more time in stakeholder discussions, such as in the current discussions on the use of the Handy-Whitman building cost index in the calculation of the Cost of New Entry (CONE). “We could have been discussing that for a year now,” he said. “Decisions are happening before we have a chance to participate.” (See related story, PJM Proposes Changes to Capacity Auction Parameters for 2015.)

Role of DR, EE

Environmentalists, meanwhile, asked the board to incorporate demand response and energy efficiency into more of its planning efforts. DR and energy efficiency are “factored into one of your eight planning estimates only,” Burns said.

Yorktown Power Station (Source: Dominion Virginia Power)
Yorktown Power Station (Source: Dominion Virginia Power)

For example, PJM should consider whether increased DR might allow Dominion Virginia Power to retire its Yorktown coal-fired generators as planned at the end of 2014 rather than continuing to operate temporarily to address reliability problems, Burns said.

Alison Clement, of the Sustainable FERC Project, said PJM could learn from ISO New England, where at least 90% of energy efficiency bids into the capacity market.

Rob Marmet, of the Piedmont Environmental Council, called on PJM to help states find the most effective ways to comply with pending EPA rules on greenhouse gas emissions for existing generators.

PJM Chairman Howard Schneider offered some brief remarks at the end of the session. “We value the issues you bring to us and the way you bring them to us,” Schneider said. “The relationship has improved vastly over the last several years.”

PJM CEO Terry Boston was the only other board member to offer feedback to advocates, saying he liked Burns’ idea of giving DR a bigger role in PJM’s winter reliability plans.

Capacity MarketDemand ResponseEnergy EfficiencyPJM Board of Managers

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