AEMA sent a letter in support of PJM’s position on the FirstEnergy 202(c) petition to the U.S. Department of Energy. Text of the letter is as follows:
By Electronic Mail
April 2, 2018
The Honorable James Richard Perry
Secretary of Energy
United States Department of Energy
1000 Independence Avenue, S.W.
Washington, DC 20585
Re: FirstEnergy Request for Emergency Order Pursuant to Federal Power Act Section 202(c)
Dear Secretary Perry:
The Advanced Energy Management Alliance (“AEMA”)[1] writes in support of the PJM Interconnection position regarding the FirstEnergy 202(c) petition. AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy consumers. AEMA’s mission is to advocate for policies that empower and compensate customers appropriately in a manner that contributes to a more efficient, cost-effective, resilient, reliable, and environmentally sustainable grid and we have continually supported the inclusion of these resources into wholesale markets to achieve electricity cost savings for consumers, contribute to system reliability, and ensure balanced price formation.
The resources AEMA represents are part of the diversity that is crucial to operating the grid in a reliable manner. We believe that any attempt to increase payments to only a sub-set of power plants will simply drive up costs on the entire grid—both for consumers and for innovative technologies such as demand response, distributed energy resources, and distributed energy storage, that increasingly provide flexible and resilient services to the system. The Federal Energy Regulatory Commission (“FERC”) has cited multiple studies finding that distributed energy resources contribute to reliability and to resilience by providing “greater reliability through consumer reliance upon distributed energy resources to provide resilience from bulk power and distribution service interruptions” and “power outage mitigation or critical power support during outages (resilience) and power quality improvement (enhanced reliability).” [2]
AEMA has engaged[3] at FERC and in states throughout various resilience proceedings, making a strong case for inclusion of distributed resources for reliability and resilience as critical to maintaining a flexible, cost-effective, and reliable system. We agree with PJM that their system, because of the diversity of resources participating in their ISO, is not facing issues of reliability. AEMA remains convinced that the technologies and services that our consumers and innovators are providing in PJM are part of the reason for that reliability. Thus, we support the position of PJM in opposition to the FirstEnergy petition.
Please do not hesitate to contact me at 202-524-8832 or Katherine@aem-alliance.org should you have any questions regarding this letter. Thank you for the consideration.
Sincerely,
Katherine Hamilton
Executive Director
Advanced Energy Management Alliance
[1] For more information, see AEMA website: https://aem-alliance.org
[2] FERC citing Responses in a High Distributed Energy Resources Future, at 26-28 (Report 1, Nov. 2015), https://emp.lbl.gov/sites/all/files/lbnl-1003823_0.pdf (Berkeley Lab Report); DNV-GL, A Review of Distributed Energy Resources: New York Independent System Operator, at 18 (Sept. 2014) (DNV-GL Report), http://www.nyiso.com/public/webdocs/media_room/publications_presentations/Other_Reports/Other_Reports/A_Review_of_Distributed_Energy_Resources_September_2014; U.S. Department of Energy, The Potential Benefits of Distributed Generation and Rate-related Issues that May Impede Their Expansion: A Study Pursuant to Section1817 of the Energy Policy Act of 2005 (Feb. 2007), https://www.ferc.gov/legal/fed-sta/exp-study.pdf.; IEA, Repowering Markets: market design and regulation during the transition to low-carbon power systems, at 33 (2016)
[3] AEMA filed Comments (https://aem-alliance.org/aema-files-comments-doe-nopr-ferc/) and Reply Comments to the DOE NOPR (https://aem-alliance.org/aema-files-reply-comments-doe-nopr/) as well as comments in Puerto Rico regarding resilience (https://aem-alliance.org/aema-makes-resilience-recommendations-puerto-rico-commission/).