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Parties Filed Reply Comments in PUC’s Proposed DER Rulemaking
State Representative Ben Waxman urged the Pennsylvania PUC to adopt stronger final rules for distributed energy resource aggregations, arguing they can increase customer participation in wholesale markets.
OCA opposes proposals that would allow non-net-metered DERs or alternative net metering tariffs if they create risks of double compensation and increased administrative costs. The OCA also supports addressing EDC cost recovery and standardized DER/DERA interconnection requirements through generic rulemaking with uniform tariff provisions rather than on a case-by-case basis.
PECO urged the PAPUC to adopt distributed energy resource aggregation rules that prioritize affordability. PECO supports a collaborative stakeholder process to develop cost-effective data exchange standards and recommends aligning state review timelines with PJM’s existing process. PECO also opposes shifting DERA performance risks or penalties to utilities and their customers and urges the PAPUC to limit the rulemaking to issues required under FERC Order 2222 while developing appropriate customer protections for DER aggregators.
PPL urged the PAPUC to implement FERC Order 2222 in a way that protects grid reliability. PPL opposes allowing net-metered resources to participate in DER aggregations due to the risk of double compensation and recommends limiting the PAPUC’s rules to its jurisdiction while preserving utilities’ authority to ensure safe system operations.
The PAPUC opened this proceeding to consider 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.
As reported previously, the PUC is planning to consider changes to distributed generation interconnection rules, metering requirements, cost allocation for expanding the distribution grid to allow DER interconnection, dispute resolution, utility management of reliability issues, protection of DER owners from “unfair trade practices or excessive risk in the wholesale markets,” issues surrounding double-counting (DER participating in both the retail and wholesale markets or switching between them), and EDI changes.
