VALLEY FORGE, Pa. — PJM Market Implementation Committee members last week expressed frustration over a proposal from the Independent Market Monitor on price-responsive demand (PRD) requirements, saying they hadn’t been given any time to review it prior to voting on the issue.
Ruth Ann Price of Delaware’s Division of the Public Advocate apologized on the Monitor’s behalf and took responsibility for requesting the late submission, but the measure failed to garner stakeholder backing. The proposal was so unexpected that it didn’t make it into the presentation PJM posted on the issue. It received 28 votes in support, or 15%, far below the 50% threshold for approval.
Two other proposals — one from PJM and the other from Calpine’s David “Scarp” Scarpignato — did receive enough support and will be presented at the Markets and Reliability Committee meeting on Dec. 7. Because of the Thanksgiving holiday, PJM moved the November MRC to the first week of December.
At issue is how PRD will be held to Capacity Performance requirements. PRD was developed before CP existed, but PRD bids cleared the annual Base Residual Auction in May for the first time since the new construct was implemented. PJM has proposed extending annual requirements developed for demand response to PRD and trigger CP penalty assessments during performance assessment intervals when the LMP is greater than the PRD price curve. Scarpignato’s “Proposal C” would make the assessment triggers any performance assessment interval. (See PJM Grilled on Price-Responsive Demand Rule Changes.)
DR provider Whisker Labs had presented another proposal but retracted it in favor of the Monitor’s proposal. The IMM argued that all PRD eligibility and performance should be measured from the participant’s peak load contribution (PLC). Both the planned PRD and the amount finally registered should be measured as the PLC minus the participant’s firm service level (FSL) and performance should be measured as PLC minus the actual load, the Monitor proposed.
“The key difference is that in our proposal, it is based on the total consumption in the summer period,” the IMM’s Skyler Marzewski said.
Carl Johnson, representing the PJM Public Power Coalition, and Dave Pratzon of GT Power Group objected to the proposal’s late inclusion because neither had had a chance to review it and make voting recommendations to their membership.
“It’s tough when totally new proposals come in at the last minute with no explanation,” Pratzon said.
Monitor Joe Bowring explained to RTO Insider in an email following the meeting that his staff provided PJM with its proposal on Oct. 29, more than a week before the MIC, and attempted to present it at a meeting of the Demand Response Subcommittee the following day. He said they were told they could not present on such short notice.
“The IMM’s proposal was included in the posted matrix on Monday prior to the Wednesday MIC meeting,” Bowring said. “The IMM agrees that there was some miscommunication among the IMM, the DRS and the MIC.”
Pratzon requested an explanation for basing all measurements off the PLC. Marzewski said the measurement should reflect how much the participant can reduce from its overall peak demand, not how much it can reduce at that moment. PJM proposed using different peak-demand calculations for summer and winter measurements.
He remained unmoved.
“As of right now, I’m not seeing the justification for the different treatment,” he said.
Gregory Carmean, the executive director of the Organization of PJM States Inc., argued the baseline should be the load that the RTO would have purchased if not for reduction.
“It’s PJM that’s trying to turn this into a seasonal product” by changing the definition of the PRD measurement between summer and winter, he said.
Delaware’s Price, Joe DeLosa of the Delaware Public Service Commission and Greg Poulos, executive director of the Consumer Advocates of the PJM States, also voiced support for the Monitor proposal.
Advocates “want residential customers to be able to respond to price,” Poulos said.
Dave Mabry, representing the PJM Industrial Customer Coalition, argued that the purpose of PRD is to get “the customer back to paying for the capacity that he needs.”
“There isn’t a payment that flows back,” he said.
Scarp argued that point, and PJM’s Pete Langbein confirmed the performance is paid as a credit.
“Call that a payment, call that a credit, but that’s effectively what will happen,” Langbein said.
Scarp said “PRD was supposed to get away from” the “hypothetical difference” between what was scheduled to be used and what was actually used.
James Wilson of Wilson Energy Economics, who consults for consumer advocates in several PJM states, disagreed that the proposal increases winter-adequacy risks. PJM’s reserve requirements study always shows zero loss-of-load expectation (LOLE) in winter, he said, and “there’s a huge margin of excess winter capacity before we get anywhere near where that changes.”
Big Support for Jurisdiction Mention in DERS Charter
Stakeholders voted overwhelmingly to include explicit deference to state and local regulatory authority in the charter for the new Distributed Energy Resources Subcommittee. (See “DER Subcommittee Charter Sent Back to MIC,” PJM MRC/MC Briefs 10-26-17.)
FirstEnergy had proposed what it hoped was an uncontroversial amendment, which stated “Market rules must respect the distribution system and state/local jurisdictional agency standards and protocols to ensure safety and reliability. Rules should adhere to all pertinent jurisdictions and respect the relevant electric retail regulatory authority (RERRA).”
DER companies saw it as a potential barrier to market entry.
“The vagueness of ‘respect the … standards and protocols’ concerns us,” said Tom Rutigliano, who represents providers of distributed resources.
“I think it’s just a matter of clarification. It’s motherhood and apple pie — we have to follow these things. I really wonder why there’s the apprehension to having it in there. … I really don’t understand all the pushback,” FirstEnergy’s Jim Benchek said.
Exelon’s Sharon Midgley agreed. “This would give us a lot of comfort moving forward if this is added,” she said.
They got their wish. The original version of the charter received 17% approval, or just 26 votes in favor, while the amended version received 92% approval, or 160 votes in favor.
Seasonal DR Aggregation Registration Rules
EnerNOC’s Steven Doremus presented a proposed revision to PJM’s DR aggregation registration rules, arguing that the current method fails to maximize use of available resources. The proposal accompanied the first read of a problem statement and issue charge.
The current method is to take as the CP capability the lesser of the registrant’s summer or winter capability. The CP capabilities of the registrants are then added together for a total capability, but this leaves a substantial amount of DR undispatchable.
“The problem we see is this is not the most efficient way to register the customers,” Doremus said.
EnerNOC proposed adding up the summer and winter capabilities of all registrants and using the lesser of the two summations at the overall CP capability “to maximize the value.”
“It wouldn’t change the value; it wouldn’t change the annual requirement,” PJM’s Langbein said of the proposal. “It’s just how do we sum up winter and summer capabilities to ensure there’s an annual capability at the [Reliability Pricing Model]-resource level.”
Meetings Reduction
Responding to a request from the Members Committee, PJM staff reviewed the status of all issues assigned the MIC and subcommittees. Of the 23 issues, seven are completed and will be closed. Three others have proposals awaiting endorsement votes.
At the October Members Committee meeting, Vice Chair Mike Borgatti of Gabel Associates announced that the MIC, MRC, Operating Committee and Planning Committee will be directed to determine if any timelines can be relaxed to “free up a little room in the schedule.” The directive came at the request of stakeholders, who have been complaining about the roughly 500 stakeholder meetings PJM conducts each year. (See “Reducing the Workload,” PJM MRC/MC Briefs.)
Adrien Ford of Old Dominion Electric Cooperative thanked PJM for developing the review and taking a “leadership role” in streamlining the issues.
Account Cleanup
PJM will be automatically terminating accounts on its website that have been locked longer than nine months. The terminations will reduce security risks, as well as improve system performance, staff explained.
PJM.com has 141,000 accounts, but 60,000 have already been terminated. Of the remaining 81,000, approximately 37,000 have been locked for more than nine months, or about 46%. Only about 20,000 accounts are actively used.
Accounts can be restored, but account managers at member companies have been notified to review employees’ accounts and delete any unneeded ones.
— Rory D. Sweeney