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In Nonunanimous PUC Order Approves Electric Utility’s Proposal To Conduct RFP For Grid Services From 3rd Party Aggregators Stands In Stark Contrast To ALJ’s Recommendation To Reject The Utility’s Proposal
The Pennsylvania PUC, in a 4-1 vote, approved with modifications PPL Electric Utilities’ second distributed energy resources (DER) management plan.
Specifically, the PUC in a final order adopts the utility’s second DER management plan that requires PPL Electric to conduct an RFP for the procurement of grid services from third-party aggregators of DERs. A copy of the final order was not available at the time of publication.
The Commission’s final order stands in stark contrast to a June 30, 2025 administrative law judge’s (ALJ’s) ALJ’s recommended decision whereby the ALJ recommended that the Commission deny PPL’s petition on the grounds that “PPL failed to carry its burden of proof in demonstrating: (1) why the scope of its proposed active monitoring and control of DER devices for all customer-owned and third-party-owned inverter-based DER installations is reasonable or necessary; (2) how the proposed standards of PPL’s proposal will not result in harms to participants in the DER program; and (3) that its proposal is supported by a reliable and positive cost-benefit analyses.”
In Chairman Defrank & Commissioner Yanora’s Joint Motion they support PPL’s Exception No. 1 stating that agree that the DER management plan will help address resource adequacy by increasing the hosting capacity on distribution circuits thereby permitting more customers to connect DERs and larger DERs to be connected without requiring system upgrades. In their joint statement they say, “we believe that all tools to help manage resource adequacy must be duly considered.”
On the other hand, Vice Chair’s Barrow Statement says “I believe the record before us does not support approval of the plan. Nor do I believe I can join in the approval of a substantially modified plan as suggested in PPL’s Fourth Exception.”
“With respect to the record evidence for and against the plan, I found especially persuasive the Joint Solar Parties’ witness Mr. Graham, Exhibit 4-SR. Therein the witness provides numerous examples of other methods that could be used to accomplish PPL’s goals without mandating installation of PPL owned devices on every DER in its service territory. Namely, the use of autonomous functions of which many inverters are already capable could provide many services.”
In PPL’s Fourth Exception the company suggests approval with modification, instead of denying the proposal outright. While I believe modification of utility filings by the Commission is acceptable, I also believe that the record must support the Commission’s replacement of the utility filing. Given the complexity of the issue and the degree of deviation from the original proposal, I cannot support granting PPL’s Fourth Exception.
P-2024-3049223
(Petition of PPL Electric Utilities Corp for Approval of Its Second Distributed Energy Resources Management Plan.)
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