• PJM Moves to Rein in Demand Response “Double Counting”
  • April 14, 2011 | Authors: Paul F. Forshay; Daniel E. Frank; Catherine M. Krupka; Keith R. McCrea
  • Law Firm: Sutherland Asbill & Brennan LLP - Washington Office
  • Responding to the Federal Energy Regulatory Commission’s recent order in EnerNOC, Inc., 134 FERC ¶ 61,158 (2011), on April 7, 2011, PJM Interconnection, L.L.C. (PJM) submitted a Federal Power Act section 205 filing intended to clarify the measurement of capacity curtailment by demand response resources in PJM’s capacity market. PJM’s filing proposes changes to its tariff, Operating Agreement and Reliability Assurance Agreement to resolve the so-called “double counting” controversy discussed in EnerNOC. Consistent with its position in EnerNOC, PJM’s proposals ultimately would cap the load reduction that a demand response resource could provide during system emergencies at its Peak Load Contribution (PLC).