How we're mixing things up in America's largest wholesale electricity market

Last week, the DER Task Force filed comments in a Pennsylvania rulemaking implementing FERC Order 2222. You can read the comments here, and check out the full docket here.

Here’s the TL; DR, and why this matters:

1. We offered foundational principles to best serve DERs. We tried to be comprehensive, covering the major issues that relate to DER integration, and incorporated a lot of the existing literature. We didn’t just offer pet projects to serve certain business models. This is especially clear in that we didn’t oppose utilities acting as aggregators. Instead, we said that if utilities do act as aggregators, they need to have fair, low-friction processes for data access, registration, review of aggregations, etc. We can do this advocacy because we are independently funded.

2. We proposed ways to improve the policy making process. We proposed that the PJM states could engage in coordinated DER policy development, led by the Energy Policy Design Institute. With this process, the PJM states could have one meeting about data access, rather than 14 different meetings in each jurisdiction. On Friday 5/31, we discussed this idea with the PJM states, and those discussions are ongoing.

3. We moved equity to the front. Equity needs to be baked into the policy development process (highly recommend Revolutionary Power on this point). So instead of leaving Equity as consideration 15 out of 15, we moved it to our first section——on overarching principles for policy design——and gave specific recommendations to incorporate equity.

4. We pointed out that this isn’t really about 2222. DERs are coming regardless of 2222. A lot of the work that needs to be done is to simply incorporate DERs. And we if we want a cost-effective, reliable grid, one of the best ways to do that is by unlocking the latent capacity of the DERs that are rapidly coming onto the system. So, we need better data access policies, better distribution system visibility and management, and distribution services tariffs that complement 2222’s path to wholesale market participation.

Finally I’ll note that just as DERs unlock the latent potential in the grid, these comments unlocked the latent potential in the DER community: this filing was a group project that incorporated the expertise of over a dozen members of our DER community.

The goal is that these principles can serve as a framework to develop scalable DER solutions across PJM. That doesn’t mean all the states would do the same thing. But if several states had interchangeable VDER-style tariffs while several vertically integrated states had similar BYOD programs, that scale would represent progress.

Happy to hear your thoughts, allison@dertaskforce.com or on Slack.