Some of the more salient points raised by DER commenters that do not fall neatly into the categories of comments already summarized by this blog are identified below. Many such commenters are quite supportive of DER aggregations and thus their comments reflect similar views of the DERs/DER Aggregator comments. (E.g., Advanced Energy Buyers Group; Microsoft; Lorenzo Kristov; Public Interest Organizations). Others, however, such as the Energy Power Supply Association (EPSA) have some concerns, such as that DERs’ contributions must be valued correctly.

  • EPRI: EPRI’s comments focus heavily on the multi-nodal issue, which it thinks can be addressed with the appropriate use of distribution factors. It believes that Distribution Owners (DOs) may require greater capability to limit DER injections. EPRI supports the concept of a DER Management System, which will provide greater grid visibility. More generally, EPRI supports more research and development efforts to find operational solutions.


  • EPSA: EPSA supports FERC starting with single node aggregation because this approach is consistent with existing security constrained economic dispatch models. Market signals could become highly distorted without such a limitation in its view. Adequate metering of DERs is another EPSA concern both for reliability and accountability reasons. To the extent DERs participate in wholesale capacity markets, accountability is crucial. EPSA also is concerned with market power and subsidization issues that could arise if DOs own and operate DERs.


  • Lorenzo Kristov: Dr. Kristov’s primary focus is on Transmission to Distribution (T-D) coordination, but he is concerned that it may be premature to develop a set of best practices. He sees a need to modernize rate design and many other aspects of DO planning and operations to address DERs. His comments stress the need for distribution system operators (i.e., DOs in the U.S. structure) to educate other stakeholders on their distribution systems. He agrees with the DO community that DOs need to assess the impacts of aggregations in a process other than the interconnection process. The comments note that liability issues will need to be worked out as there is tension between participation in wholesale markets and the need to maintain distribution reliability.


  • Public Interest Organizations: The Public Interest Organizations insist that only the Commission should be able to grant a waiver from allowing DER participation in an aggregation after notice and comment. The Public Interest Organizations support FERC providing general guidance in a final rule with details to be worked out by RTO/ISO processes.

Commentary: The comments of the identified stakeholders largely lead to the conclusion that the devil is in the details. The comments recognize that there are many details that must be addressed, but generally support forward movement by the Commission in the form of a final rule. Technology is a particular focus of these comments, as the need for new and improved technology is widely acknowledged.