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AEE and AEMA Letter Regarding PJM’s Proposed Order No. 2222 Compliance Plan
If PJM files a compliance proposal at FERC on Order 2222 that excludes net metered solar from PJM's capacity market participation - PJM's proposal will be non-compliant with the Order 2222 intent.
"Net energy metered resources represent a substantial number of DERs within PJM states. PJM estimates
approximately 7,000 MW of non-wholesale DER in the region and predicts that power from rooftop solar
installations will reach nearly 12,000 MW over the next 15 years.3 This is a significant resource that can provide real
value to PJM, especially when paired with batteries and electric vehicles. AEE and AEMA are concerned that the
proposed blanket restriction on the participation of net energy metered DERs in the PJM capacity market will
exclude a broad swath of customers from the PJM market (especially residential but also many commercial and
industrial customers), leading to substantial out-of-market activity with no visibility for PJM grid operators. This
would result in the loss of the reliability and market efficiency contributions of numerous resources in existence or
under development in the PJM region in response to state policy and customer preferences, such as rooftop solar,
energy storage, bidirectional electric vehicles and charging equipment, and demand response enabled by smart
thermostats and home devices. "
AEE and AEMA Letter Regarding PJM’s Proposed Order No. 2222 Compliance Plan
Dear Mr. Takahashi and Mr. Asthana, Advanced Energy Economy (AEE), on behalf of itself and Advanced Energy Management Alliance (AEMA), writes to express concern regarding PJM’s proposed treatment of net energy metered distributed energy resources (DERs) in its upcoming Order No. 2222 compliance filing at the Federal Energy Regulatory Commission (FERC).1 AEE and AEMA appreciate that PJM Staff and stakeholders in the Distributed and Inverter-Based Resources Subcommittee have committed significant time and resources to the Order No. 2222 compliance process. While we may raise concerns regarding other aspects of PJM’s proposal to comply with the requirements of Order No. 2222 when it is filed at FERC, we are especially concerned that the current proposal will effectively exclude most residential and many commercial & industrial customer DERs from participating in the PJM capacity market, resulting in increased costs, the loss of reliability benefits for PJM customers, and the loss of visibility of DERs for PJM operators.
Source: www.pjm.com
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