Weave Grid told the commission that, where feasible, expanded utility programs using distributed energy resources (DERs) could meet PJM's peak‑shaving requirements at lower cost and with local distribution benefits.
"Where a utility program can provide peak shaving benefits at a lower cost than the RBP alternative, we believe this PJM opt‑out opportunity is worth a serious look," Deborah Irwin, head of policy at Weave Grid, said. Weave Grid described a distribution‑aware orchestration platform that coordinates customer‑sited EV chargers, batteries and flexible loads and argued these resources can deliver bulk‑system peak reductions while avoiding distribution harms if managed with distribution‑level visibility and controls.
Irwin said such a path would require incremental funding, clear cost‑recovery, and program design that values distribution benefits. She urged the commission to consider targeted funding to expand near‑term enrollment in utility programs so more customer‑sited devices can be counted for a peak‑shaving adjustment rather than relying wholly on RBP procurements.