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The PJM Industrial Customer Coalition filed a complaint against PJM Interconnection LLC on Nov. 20, asking FERC to find that it would be unjust and unreasonable to allow the Dec. 31 expiration of locational marginal pricing payments for customer curtailments when LMP exceeds a particular threshold, currently set at $75/MWh.
Citing adverse financial implications of the Dec. 31 sunset provision and the fact that the PJM stakeholder process did not reach a final decision until Nov. 14, the industrial customers argued that FERC should fast-track their complaint.
The self-described "ad hoc" coalition is made up of 31 companies with large facilities in the PJM region. Coalition members generally support the goals of demand-side response and curtailment operations "when the economics of the credit mechanism justify the cessation of energy consumption," the filing said.
Energy costs are a major factor in the ability of industrial customers to compete in the global marketplace, the coalition noted. For this reason, compensation "commensurate with the benefits that the demand response participant delivers to other, non-participating customers and to the efficient operation of the PJM energy markets" is critical to the success of demand response in wholesale markets, the coalition said.
Allowing PJM's demand-side response tariff provisions to expire "is unjust and unreasonable and, therefore, a violation of the Federal Power Act because the tariff provisions are necessary, in some form, to...