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Wide Range of Comments Filed in PUC’s DER Rulemaking
Parties filed comments on the Pennsylvania PUC proposed rulemaking regarding the implementation of the Federal Energy Regulatory Commission (FERC)’s Order No. 2222, requiring ISOs/RTOs to allow Distributed Energy Resources (DERs) to participate in wholesale markets through aggregations.
EAP urged the Commission to implement Order 2222 flexibly, expand interconnection rules to accommodate DER aggregations, allow full recovery of application costs, preserve EDC operational discretion, license DER aggregators to protect consumers, prevent double counting of DER services, avoid prescriptive data-exchange requirements, and refrain from requiring EDCs to oversee DER aggregators’ contractual relationships with participating resources.
CAUSE-PA urged the PAPUC to ensure that DERA programs do not shift costs to non-participating customers, establish strong consumer protections for DERA participants, and require EDCs to incorporate DERAs into distribution system planning.
OCA generally supports the PAPUC’s proposals but urges two modifications. First, the PAPUC should ensure that customer-generators do not receive duplicative compensation under both net metering rules and the wholesale ancillary services market for providing the same distribution system benefit. Second, the PAPUC should promote efficient data exchange among EDCs, DERA interconnection applicants, and PJM.
Duquesne Light “reiterates its strong encouragement to the PUC to exercise its authority over implementation of Order 2222 in Pennsylvania.” PPL filed in-depth comments in support of implementation of Order 2222 but argues that the PAPUC should place greater emphasis on affordability, reliability, and consumer protection.
PPL contends that net-metered customers should be prohibited from participating in DER aggregations because they already receive compensation through net metering and additional wholesale market revenues would constitute inequitable double compensation and shift costs to non-participating customers. PPL also urges the PAPUC to assert broader authority over DER aggregators through licensing and consumer protection requirements, citing examples of fraud and abuse in other aggregation programs. It recommends requiring each participating DER to execute a new “component DER agreement” with the EDC to address interconnection, operations, billing, data sharing, cybersecurity, and override protocols. In addition, PPL supports the development of standardized data exchange protocols between EDCs and DER aggregators, maintaining EDC authority to override DER operations when necessary for safety and reliability, and ensuring that the costs of implementing DER aggregation are borne by participating DERs and aggregators rather than socialized among all customers.
PECO commented in support of the proposed Order 2222 regulations but urges changes to prevent cost shifting. It recommends prohibiting net-metered resources from participating in ancillary services markets, limiting switching between net metering and DERA participation to once annually, and aligning application procedures with PJM requirements. PECO also supports EDC authority to override DER dispatch, cost recovery mechanisms, and a separate proceeding to establish DERA licensing, and cybersecurity standards.
Read all comments filed at docket link.
