Back in March of 2023, FERC issued a seemingly logical compliance order regarding one aspect of PJM’s Order No. 2222 compliance filing. This blog noted that “FERC acknowledged that DER owners in full retail NEM programs actually are compensated for ancillary services that they do not even provide and that paying them for ancillary services, assuming they could provide them, would be double counting. … Although further clarity will result on compliance, the decision reflects a breakthrough of sorts …. The fact that the Pennsylvania PUC expressed concern over double counting as to ancillary services in particular perhaps swayed FERC into recognizing the level of compensation offered by some NEM programs.” Perhaps this reading, that FERC might prohibit double compensation for the same service, was too optimistic.
That March 1, 2023 order also stated that:
PJM’s proposed tariff requires an assessment of whether the “same product is not also credited” rather than whether, as the Commission discussed in Order No. 2222, the same service is being provided by the Component DER. Being credited for a product may not be the same as providing a service. This difference may be relevant because a Component DER participating in a net energy metering retail program, for example, may be credited for a product or service that it does not actually provide.Continue Reading Double-Provision Versus Double-Compensation of Ancillary Services Under PJM’s Order No. 2222 Compliance Filing