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FERC Won't Require Disclosure Of Demand Response Provider's Customer Names As Part Of PJM Uplift Reporting

March 22, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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FERC issued an order on a compliance filing from PJM in which PJM had submitted various revisions to its operating agreement to comply with a prior FERC order concerning the reporting of uplift to market participants

As previously reported, in Order No. 844, the Commission directed each RTO/ISO to establish in its tariff the following three requirements related to uplift and operator-initiated commitment reporting and one requirement related to transmission constraint penalty factors. First, each RTO/ISO must post a monthly Zonal Uplift Report of all uplift, paid in dollars, and categorized by transmission zone, day, and uplift category. Second, each RTO/ISO must post a monthly Resource-Specific Uplift Report containing the resource name and total amount of uplift paid in dollars, aggregated across the month, to each resource that received uplift payments. Third, each RTO/ISO must post a monthly Operator-Initiated Commitment Report listing the commitment size, transmission zone, commitment reason, and commitment start time of each operator-initiated commitment. Further, each RTO/ISO must follow the transmission constraint penalty factor requirements to include, in its tariff, its transmission constraint penalty factor values; the circumstances, if any, under which the transmission constraint penalty factors can set locational marginal prices (LMP); and the procedures, if any, for temporarily changing the transmission constraint penalty factor values. Any procedures for temporarily changing transmission constraint penalty factor values must provide for notice of the change to market participants as soon as practicable.

Of note is that, concerning the Resource-Specific Uplift Report, PJM in its compliance filing proposed to report the applicable resource name or identification number and the amount of uplift paid to each resource that received uplift payments within 90 calendar days after the end of each applicable month. Though not required by Order No. 844, PJM also proposes to report resources' uplift payments by category

Specifically, to address concerns from curtailment service providers about disclosing commercially-sensitive and confidential customer information for demand resources and economic load response participants, PJM proposed to post: (1) the individual resource identification number associated with the demand resource or economic load response participant's relevant dispatch group or registration; (2) the name of the associated curtailment service provider; (3) the associated Zone and energy pricing point used to settle the energy transaction; and (4) the corresponding amount of uplift credits by applicable uplift charge codes for the dispatch group or resource that received uplift credits. PJM had said that this information will allow market participants to ascertain the geographical information for any uplift payments made to demand response and economic load response participants, while concealing commercially-sensitive customer information.

However, the IMM argued that PJM's proposal to identify demand resources and economic load response participants by number, not name, does not comply with Order No. 844. The IMM argued that the names of these resources are not confidential because they are publicly available through the United States Energy Information Administration. The IMM argued that demand resources should not be able to mask their identity when participating in markets that require other participants to provide transparency.

The Advanced Energy Management Alliance (AEMA) supported PJM's proposal. AEMA had said that the IMM's recommendation would compromise competitive information and customer confidentiality. AEMA stated that Order No. 844's 90-day lag in posting the Resource-Specific Uplift Report does not satisfy confidentiality concerns regarding sensitive customer information because the key commercially-sensitive information for curtailment service providers is customer names, not bids. AEMA stated that curtailment service providers invest considerable resources in identifying and recruiting customers who can participate in demand response programs, and customer names are considered highly proprietary. AEMA said that identifying customer names will not offer additional information regarding location that the individual resource identification number does not also reveal.

FERC denied the IMM's protest on this issue and adopted PJM's proposal to identify in the report only the individual resource identification number associated with the demand resource or economic load response participant, rather than the participant's name.

"We disagree with the IMM and find that PJM's proposal to report the identification number associated with the demand resource or economic load response participant and the location information provides the same level of geographical granularity as there would be if PJM used specific resource names. Accordingly, the proposal meets Order No. 844's requirements," FERC said

Docket ER18-2401

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