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Commissioner Tony Clark Statement
April 1, 2016
Docket No.
ER16-873-000 PDF

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Concurrence in Part regarding PJM Demand Resources Measurement

“In proposing corrections to Tariff and Operating Agreement language describing how PJM measures Demand Resources compliance during non-summer months, I concur with the majority that PJM’s assertion that requiring 12,000 first-time relative root mean square hourly error calculations ahead of the 2016/2017 Delivery Year presents significant feasibility and practicality issues.1

“Based on the weight of this argument alone, PJM provides adequate justification for its section 205 filing. As a matter of policy, however, I would urge PJM and PJM stakeholders, along with other regional grid operators and participants, to expand work towards developing methodologies which find better insight into Demand Response and its particular attributes.

“When it comes to how the Commission treats Demand Response resources, it is my concern that we have a continuing trend whereby when it relates to compensation, Demand Response is treated as a like-for-like equivalent to generation resources, even though it plainly has different attributes. Yet when it comes to responsibilities and obligations, the same reasoning does not apply.

“In the long run, such an asymmetrical structure is not in the best interest of competitive, functional wholesale markets nor the American consumer. The Independent Market Monitor has consistently raised a red flag for the Commission regarding these matters and does so again here in this docket.2 The Commission, regional grid operators and stakeholders would do well to address these ongoing concerns lest they degrade the proper functioning of these markets.

“For these reasons, I concur in part with the order.”


    1 PJM Filing at 7-8.
    2 Independent Market Monitor Comments at 2. Independent Market Monitor Answer at 1-2.