M&V tutorial · maximum base load

Maximum base load: paying a site to drop to a firm level

Most wholesale capacity demand response, including commercial and industrial sites in virtual power plants (VPPs), is measured without a baseline. The site promises a level, and the grid checks that it got there. Here is how “drop to” works, why it dominates capacity markets, and why PJM’s market monitor disputes the results.

VPP Economics has no affiliation with, sponsorship from, or endorsement by any utility, aggregator, platform, or device maker named here.

The short answer

  • Drop to, not drop by. The resource commits to cut its load to a set level, whatever it would otherwise have used. NAESB calls it maximum base load; PJM and MISO call the level a firm service level (NAESB; ERCOT).
  • It is the backbone of wholesale capacity demand response. Firm service level covered 99.9% of PJM’s committed load management in 2023/24 (PJM).
  • No baseline, so no baseline error, and no baseline to estimate what the site actually did. PJM credits the reference peak minus metered load. A store that is closed on Sundays is an overperformer in a Sunday event (Monitoring Analytics).
  • The gap is live. For PJM’s winter 2026 events, PJM scored demand response at about 100%; its market monitor, measuring against a baseline, at about 50% (Monitoring Analytics).

From reference peak to firm level

Two numbers set before the season

A worked example for one commercial site in a PJM-style capacity program.

Swipe to see the full chart →

FROM REFERENCE PEAK TO FIRM LEVELREFERENCE PEAK5.0 MWPJM: peak load contribution, fromlast year’s five system peak hours−FIRM SERVICE LEVEL1.5 MWLoad the site always keeps on,declared in advance=CAPACITY SOLD5.0 − 1.5 = 3.5 MWWhat the site is paidto deliver when calledNo history of the event day is needed. Both levels are set before the season starts.
Illustrative numbers. PJM sets the summer nominated value as peak load contribution minus firm service level, adjusted for losses; winter uses a winter peak load (PJM Reliability Assurance Agreement).

Event day

The site drops below its firm service level within the lead time and holds it.

Swipe to see the full chart →

0 MW1 MW2 MW3 MW4 MW5 MW6 MW10 a.m.noon2 p.m.4 p.m.6 p.m.8 p.m.EVENT 2–6 P.M.Reference peak 5.0 MWFirm service level 1.5 MWCredited: 5.0 − 1.4 = 3.6 MW103% of the 3.5 MW soldMetered load
Illustrative numbers. PJM computes summer compliance as peak load contribution minus metered load times the loss factor, floors each hour at zero and gives no credit for exports (PJM Manual 18). Most load must reduce within 30 minutes (PJM).

Compare this with the other methods. There is no lookback window, no weather, no adjustment. The site sold 3.5 MW because its reference peak is 5.0 MW and it can always get down to 1.5 MW. On event day it metered 1.4 MW, so it is credited 3.6 MW: slightly more than it sold. A test simply checks that the site can reach the firm level.

Drop to versus drop by

What the credit measures

The same site meters 1.4 MW in both events. Only what it would have used differs.

Swipe to see the full chart →

01234Hot peak day: drop toreference peak 5.0 − metered 1.43.6MW creditedHot peak day: drop bybaseline 5.2 − metered 1.43.8MW actually reducedMild or quiet day: drop toreference peak 5.0 − metered 1.43.6MW creditedMild or quiet day: drop bybaseline 2.0 − metered 1.40.6MW actually reduced
Illustrative numbers. “Drop by” uses a baseline of what the site would have used, as in the interval-meter tutorial; on a mild day the site would have used only 2.0 MW.

On a hot peak day the two measures agree closely: 3.6 MW credited against 3.8 MW actually cut. On a mild or quiet day they split: still 3.6 MW credited, but only 0.6 MW of real reduction. That is the method’s core trade-off.

For drop to

It measures what the grid planned for

Capacity is bought against peak load. A site that is below its firm level is not adding to the peak, whatever the reason. MISO stakeholders argue it delivers the same system benefit regardless of why load is reduced (MISO stakeholder feedback).

Against

It pays for load that was already off

A site that is closed, slow or idle gets full credit without acting, and negative performers are zeroed out. The market monitor prefers measuring against a baseline (Monitoring Analytics).

Where the debate stands

Two ways to score the same events

PJM pre-emergency and emergency load management, winter 2026.

Swipe to see the full chart →

0%25%50%75%100%PJM metric(peak load contribution − load) ÷ capacity sold100%approximateMarket monitor metric(baseline − load) ÷ (baseline − firm level)50%approximate
Source: Monitoring Analytics, which puts the January 25, 2026, event group at 58% on its metric. Rounded as published.

The market monitor’s example makes the mechanics plain. Two sites each sold 15 MW. One cuts 5 MW; the other runs 10 MW above its reference peak. PJM’s metric zeroes the second site and scores the pair at +17%; a baseline metric nets them to −17% (Monitoring Analytics). The monitor also reports that many resources could not perform in extreme cold, exactly when they are called. FERC approved a new PJM penalty for underperformance outside emergency intervals in June 2026, at half the emergency penalty rate (Monitoring Analytics).

Who uses it

PJM

Firm service level

Capacity sold = peak load contribution − firm service level. Compliance = peak load contribution − metered load, floored at zero, no export credit (PJM Manual 18).

MISO

Firm service level for load modifying resources

Must reach the firm level within the lesser of 1 MW or 10%; reduction below it is not counted. Only load modifying resources may use it (MISO).

NYISO

Average coincident load

The reference is the average of a site’s 20 highest loads in the top 40 zone peak hours of the prior like season (NYISO ICAP Manual). A proposal to measure by a baseline instead stalled with stakeholders (industry summary).

ERCOT

Emergency Response Service, “drop to”

Assigned when an accurate default baseline cannot be built. Availability = average 15-minute load in the committed period − declared maximum base load (ERCOT).

NAESB does not allow it for reserves, where the grid needs a measured change, not a level (NAESB). It also fits poorly with home fleets: a household has no meaningful firm level, so residential virtual power plants use device data, sampling or baselines instead. The device tutorial and sampling tutorial cover those.

Where it fits and where it does not

Fits

Large, steady commercial and industrial loads

Plants and buildings that can always get down to a known level, such as process lines or chillers that can be shut off.

Fits

Loads with no good baseline

Irregular schedules defeat typical-day baselines. ERCOT assigns “drop to” for exactly this reason (ERCOT).

Does not fit

Loads that are often already low

Weekend, seasonal or idle sites get credit without acting.

Does not fit

Reserves and fast products

They need a measured response, so NAESB points to meter before / meter after or device metering (NAESB).

How it shows up in the VPP Program Designer

The VPP Program Designer does not offer maximum base load in Step 5. It is built around residential and mixed fleets, where a firm level per site is rarely meaningful. A C&I fleet settled this way would see credited capacity at or above the true reduction, depending on how often sites are already below their firm level when called.

All six ways performance is measured

Method and caveats

A tutorial for program designers, utilities, aggregators and other readers. It is not a substitute for a tariff, manual or settlement rules. The worked example uses illustrative numbers. Loss factors and winter adjustments are omitted. Checked October 23, 2026.

Performance figures for winter 2026 are the market monitor’s published summary; PJM’s own reporting may differ in scope and rounding.

Keep going