Read KEEA & EEA-NJ’s Sign-On Letter on EE Resources in the PJM Marketplace

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Urgent Request to PJM Regarding Energy Efficiency and Markets and Reliability

March 20, 2024 — KEEA and EEA-NJ sent the letter below to PJM leadership on March 19th. 36 organizations joined us in asking PJM to take a deliberative and open approach regarding any changes to how the PJM capacity market handles energy efficiency resources.

March 19, 2024

Mr. Manu Asthana, President & CEO
Mr. Mark Takahashi, Chair, PJM Board of Managers on behalf of the entire Board of Managers
PJM Interconnection
PO Box 1525
Southeastern, PA 19399-1525

Dear PJM Leadership Team:

As energy efficiency businesses and supporters, we are writing to express deep concern about the pace and nature of the prospective changes to energy efficiency resources that are accepted into the PJM capacity market.

Our industry and our country are at a critical juncture in planning and coordinating grid reliability, decarbonization and state-level programs. We believe a deliberative process rather than a process that is both closed and needlessly swift since its start in early February of this year could cause more disruption and harm than good. 

Because the impact will be significant and could potentially be deleterious to utilities and ratepayers (including impacting even the use of Technical Resources Manuals of PJM states), we urge a more thoughtful, open, and deliberative and slowed-down process.

We ask that any scheduled vote for proposed manual 18(b) changes be taken off the Markets and Reliability Committee agenda for March 20, and further that it be delayed until PJM provides an appropriate forum for all energy efficiency stakeholders – including ratepayers, utilities, state utility commissions, and the energy efficiency industry to understand the complex issues being considered and be given the opportunity to provide comments.

The Federal Energy Regulatory Commission (FERC) has, on several occasions, concluded that energy efficiency should be treated on par with other resources serving FERC-jurisdictional markets. More specifically, FERC has determined that energy efficiency plays an important, positive role in PJM’s markets.

Given the recent FERC Order No. 2222, which requires PJM to remove barriers to DER participation in its wholesale electricity markets through allowing DERs to aggregate output, forming DER Aggregations (“DERAs”), we think a deliberative process is particularly salient and needed at this time.

Lastly, we welcome an open, full dialogue to appropriately examine how energy efficiency resources are considered as part of the load forecast, and we appreciate your consideration and voice in this matter.


Jeaneen A. Zappa
Executive Director, Keystone Energy Efficiency Alliance

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