The combination of the growing amount of committed capacity resources being DR and the increase in Generation retirements has resulted in a decrease in the installed generation reserve margin. As a result PJM expects more regular deployment of DR in system ops. Under current rules and procedures, deployment of large amounts of DR creates potential operational discontinuities which must be addressed to support ongoing reliable system operations. Additionally, the current rules permit Limited DR to cover the entire amount of excess supply under the downward sloping demand curve which has limited the effectiveness of this mechanism as a forward investment signal for long term resources. PJM expects that it will need to dispatch capacity DR on a much more operational basis going forward. Currently large blocks of DR have exactly the same notification time which is based on minimum standard rather than physical capability. Large amounts of DR are emergency-only which creates large discontinuity in dispatch when moving into emergency ops. PJM recognizes the potential impact to reliability based on the existing capacity DR construct that requires administrative procedures under Emergency ops to deploy capacity DR. Areas to be addressed: Consider enhancements to DR obligations that will address PJM’s operational concerns. • Consider changes to notification time requirements for DR to provide greater operational flexibility. • Consider enhancements to DR rules to allow for demand-side resources to operate with a dispatchable range. Consider ways to prevent the volume of Limited DR clearing in RPM auctions from impacting the long-term investment signals needed to ensure reliability. Assess the potential for changes to assumptions and modeling practices regarding DR in PJM planning studies as a result of this investigation.