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Regulating Demand Response

Regulating Demand Response. Sharon Jacobs Harvard Law School. Overview. Order 719 RICE Rules Bigger-picture regulatory questions. FERC and Demand Response. Order 719 (2008) Order 745 (2011) Order 755 (2011) Order 676G (2013). Order 719. Order 719. Five provisions affecting DR

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Regulating Demand Response

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  1. Regulating Demand Response Sharon Jacobs Harvard Law School

  2. Overview • Order 719 • RICE Rules • Bigger-picture regulatory questions

  3. FERC and Demand Response • Order 719 (2008) • Order 745 (2011) • Order 755 (2011) • Order 676G (2013)

  4. Order 719

  5. Order 719 • Five provisions affecting DR • Ancillary services • Accepting bids from aggregators of retail customer loads • Eliminate deviation charges during system emergencies • Market clearing price should reflect true value of energy during operating reserve shortages • More research on barriers to demand response

  6. Order 719 • Legal bases for regulation • Ensuring that rates are just and reasonable • Remedying undue discrimination and preference in organized markets • Challenges/pushback • Source of authority • Limits of authority

  7. Other Federal Agencies and DR • Department of Energy • Federal Trade Commission • Environmental Protection Agency

  8. RICE Rules

  9. RICE Rules NSPS NESHAPs

  10. RICE Rules • Can operate up to 100 hours per year to participate in demand response emergencies • Can operate up to 50 of those 100 hours to help maintain voltage stability and prevent power supply interruption • Switch to ULSD as of 2015 • Reporting requirements beginning in 2015 for larger engines

  11. The View From 30,000 Feet • Jurisdictional questions • Coordination • Energy vs. environment (?)

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