By Rory D. Sweeney

VALLEY FORGE, Pa. — Despite being out of scope for potential rule changes, representatives of state interests last week asked for education sessions on load-related analyses during the first meeting of PJM’s new Summer-Only Demand Response Senior Task Force (SODRSTF).

The task force’s issue charge specifically prohibits proposed changes to loss-of-load expectation (LOLE) studies or business rules, but stakeholders still asked if they can learn about LOLE issues.

“I don’t think the out-of-scope items precludes us from doing any education,” said Greg Carmean, the executive director of the Organization of PJM States Inc. (OPSI), which represents state utility regulators within the RTO’s footprint.

Greg Poulos, executive director of the Consumer Advocates of the PJM States (CAPS), and EnerNOC’s Katie Guerry supported the request.

PJM staff agreed to education but warned that contemplating any changes based on that education would require seeking a charter amendment from the Markets and Reliability Committee.

James Wilson of Wilson Energy Economics, who consults for several consumer advocates within the PJM footprint, asked about the RTO’s seasonal capacity filing being out of scope for discussion, calling it “the elephant that’s not invited in the room.” Foregoing stakeholder endorsement, PJM last year unilaterally filed for FERC approval of its proposal to aggregate seasonal resources so they can qualify for the year-round rules of PJM’s Capacity Performance capacity construct. The proposal was accepted under delegated authority during FERC’s eight months without a quorum, but Wilson noted that the commissioners could review and reject it at any time.

PJM has far more summer-only seasonal resources than winter, so the aggregation rules left thousands of megawatts of summer-only resources without capacity commitments. In the aggregation filing, PJM agreed to address what to do with them since, as it acknowledged in the task force’s problem statement, “these resources have made investments, and in some instances commitments to state regulators, that will result in their continued operation (primarily as peak shaving resources).”

Calpine’s David “Scarp” Scarpignato asked the group to investigate what operational flexibility DR can provide beyond simply reducing load.

The task force’s next meeting is Jan. 29, when PJM will provide an overview of how it develops its LOLE study including winter resource adequacy, load forecast and installed reserve margin.