After holding its two-day Technical Conference on DERs, FERC issued two Requests for Comments on April 27, 2019 in existing Docket No. RM18-9 and new Docket No. AD18-10. FERC divided the existing rulemaking docket into two parts, separating the topic of DER Aggregation in ISOs and RTOs from the topic of DER Technical Considerations for the Bulk Power System. Also, FERC added “new” questions to the seven existing sets of questions asked before the conference. The docket split and new questions provide some new insights that should be considered in drafting comments, which are due June 26, 2018. Specifically:
- We can discern from the opening of an AD docket that is not limited to ISOs/RTOs that FERC is interested in ensuring DERs are taken into account by all Transmission Providers in modeling, planning, supporting, and operating the bulk power system.
- We can discern from new questions on planning and models that FERC may be seeking to assert some sort jurisdiction over distribution system planning on the grounds that DERs impact bulk power systems and that transmission planning must be (somewhat) integrated with distribution planning.
- We can discern from new questions about the need for DER data that more information about the importance of 1) individual DER size and 2) overall DER penetration levels should be provided to FERC.
- We can discern from the new questions about aggregating behind single versus multiple nodes that pricing issues may be difficult to resolve and may need to vary by ISO/RTO.
- We can discern from the new questions about utility distribution companies (UDC) that the myriad issues they face as relates to DERs, including ensuring distribution system safety and reliability, ensuring retail ratepayers are not adversely financially impacted, and dealing with state retail customer privacy laws, need to be identified and addressed in an appropriate fashion. The UDCs will need to identify those issues of concern, given their own particular situations.
- We can discern from the new question about participation in the CAISO DER program, that FERC needs more information on the relationship between each UDC/state retail net metering program and the impacts of such programs on the likelihood and type of DER participation in wholesale markets.