News Stories

Independent Regulatory Review Commission (IRRC) – “Many of the public comments received on this proceeding acknowledge the need for the proposed rulemaking and agree that DERs should not receive compensation from both the retail and wholesale energy markets (double counting). Many of the comments reiterate issues and perspectives raised during the development of this rulemaking. To address the issues, the PUC would need to make substantive amendments to the rulemaking, and in some instances, add new language that would broaden the scope of what has been proposed in the Armex. Examples of issues raised by commentators include:

• Stronger consumer protections should be included in the rulemaking, including the potential registration of DERAs and a Code of Conduct for DERAs;
• The rulemaking is missing opportunities to reduce costs for consumers;
• Provisions related to double counting need to be strengthened and clarified;
• The participation of EDCs with less than 100,000 customers in DER programs should be reconsidered:
• The role assigned to EDCs in the review, approval, and administration of DER programs should be reduced or expanded;
• Whether the imposition of a fee by EDCs for the review of DER applications is a sufficient and fair mechanism for cost recovery or if cost recovery should include more traditional PUC ratemaking proceedings;
• Whether the rules for data exchange between EDCs, DERs, and DERAs should be included in the final rulemaking or referred to the PUC’s Electronic Date Exchange Working Group (EDEWG) for further discussion and another rulemaking on the issue; and
• Whether the authority of EDCs should be expanded as it relates to DER component dispatch override procedures.

Office of Gov Josh Shapiro – “The Office of Governor Josh Shapiro (“Shapiro Administration” or “Administration”) respectfully submits these comments concerning the regulation proposed by the Public Utility Commission (“Commission”) in this docket concerning the participation of distributed energy resources (“DERs”) in the wholesale electricity markets administered by the PJM Interconnection, LLC (“PJM”).

The aggregation and deployment of DERs represents one of the most important near-term levers to bring additional grid resources online to address reliability and affordability challenges in the Commonwealth. The Commission’s proposed regulation on DER participation in wholesale markets takes important steps toward unlocking key revenue sources for these technologies but does not provide strong enough directives to electric distribution companies (“EDCs”) to meaningfully accommodate and support DER participation. The Administration urges the Commission to make three critical changes to the regulation, described below, to more fully enable the integration of these important resources.”

Highlighted Recommendations Include:

• The Commission’s final regulation should require EDCs to meet workable statewide data-sharing standards.
• The Commission should narrow its proposed restriction on net-energy metering eligibility for wholesale market participation.
• The Commission should standardize EDC review procedures for DER aggregations.