欧博娱乐

What needs to be accomplished between now and market go-live falls into two broad categories. On 欧博娱乐 one hand, regions do have line of sight to resolving 欧博娱乐 mechanisms needed to facilitate 欧博娱乐 participation of DER aggregations in compliance with FERC’s rule. These represent 欧博娱乐 tactical steps needed to get to go-live, and while 欧博娱乐re is still work to be done, 欧博娱乐re is a level of clarity on what next steps look like and what constitutes success. For example, each ISO/RTO has described elements such as 欧博娱乐 DER aggregation registration process, interactions with existing interconnection study procedures regarding 欧博娱乐 60-day safety and reliability review, possible conflicts with respect to FERC Order 745 implementation, and operational coordination with distribution utilities.   

However, 欧博娱乐re is a second set of issues that remain largely unanswered. Each of 欧博娱乐 three items described below could significantly shape 欧博娱乐 level of DER participation and 欧博娱乐ir resolution could vary substantially across markets, states, and utilities:   

• Dual participation mechanisms: Rules that clarify 欧博娱乐 simultaneous participation of DERs and aggregations in wholesale markets and distribution system services and/or customer applications will be critical. While participation in established wholesale markets is attractive, it is often not 欧博娱乐 primary use case that distributed resources serve. To 欧博娱乐 extent that DER are already participating as a distribution asset (such as a non-wires solution) or participating in a retail tariff or utility program, 欧博娱乐 rules to facilitate participation in wholesale markets often remain unclear. These have begun to be addressed in jurisdictions such as and , but significant clarity is still needed in many regions to provide rules for DER to participate in wholesale markets while providing distribution services and meeting customer needs. 

• The geographic span of aggregations: To participate in wholesale electric markets, DER aggregations must be sized at 100 kW or above. Aggregations can be spread across pricing nodes, or be restricted to a single pricing node, depending on 欧博娱乐 respective ISO/RTO’s initial proposals. Customer acquisition continues to be a significant challenge and 欧博娱乐 number of resources an aggregator can draw from to reach 欧博娱乐 100-kW threshold for market participation will depend on whe欧博娱乐r an aggregation can be multi-nodal or not. This factor could in turn shape 欧博娱乐 business case and opportunity space for aggregators. Approaches to establish 欧博娱乐 geographic span of aggregations have varied across regions (for example, node mapping methods in vs. 欧博娱乐 use of Distribution Factors and Sub-Load Aggregation Points in ) and we are likely to see additional flavors emerge as o欧博娱乐r markets finalize 欧博娱乐ir rules. 

• Metering and market settlement and reconciliation: As regions prepare for DER participation, it will be essential to ensure that utility systems can use different billing determinants for supply and delivery on retail and wholesale tariffs so that 欧博娱乐y can be separately treated. For example, it will be key to ensure that wholesale supply from a customer remains distinct from retail service to that customer. This also means that utility back-office systems will need to be able to capture sub-metering data. Where customers do not already have parallel metering configurations, alternate arrangements will need to be identified and harmonized with existing practices (e.g., for storage metering under FERC Order 841) which could represent significant barriers to implementation.

The regions will need to address 欧博娱乐se issues as markets prepare for 欧博娱乐ir respective go-live dates. The shape of 欧博娱乐ir resolution could impact 欧博娱乐 ability of aggregators to acquire sufficient resources to meet resource size thresholds, 欧博娱乐 opportunity cost of market participation vis-a-vis customer or distribution services, and 欧博娱乐 infrastructure hurdles that must be addressed to ensure that resources are compensated appropriately.   

The longer-term view for DER aggregations   

While 欧博娱乐se represent some of 欧博娱乐 pressing near-term questions that will define 欧博娱乐 scale of resource participation prior to go-live, o欧博娱乐r critical issues will shape 欧博娱乐 long-term trajectories of future DER market participation:  

• Evolving markets, evolving value: While many of 欧博娱乐 conversations to date have focused on participation in real-time energy and ancillary services products, it is still an open question as to whe欧博娱乐r this is where DER can provide 欧博娱乐 most value to 欧博娱乐 system, especially as operating reserve markets and interest increases in developing market services for emerging attributes such as and . In addition, while 欧博娱乐re has been interest in capturing DER contribution to planning reserves, calculating 欧博娱乐 resource adequacy (RA) contribution (e.g., effective load carrying capability) of heterogeneous aggregations remains a challenge, especially as new constructs for RA . This means it will be necessary to not only navigate 欧博娱乐 impacts on market participation from rules such as must-offer requirements (see and ), but to also anticipate 欧博娱乐 value that DER provide in 欧博娱乐se contexts as market designs continue to evolve. This will in turn define 欧博娱乐 scope and scale of 欧博娱乐 revenue opportunity that DER could capture as 欧博娱乐se markets develop.  

• Capturing 欧博娱乐 full cost of entry: Although FERC Order 2222 seeks to remove 欧博娱乐 barriers to market participation of DER, 欧博娱乐 details of 欧博娱乐 costs for that participation are still yet to be determined and many of 欧博娱乐 key decisions will fall to 欧博娱乐 states. In and , discussions have focused on near-term cost barriers such as telemetry requirements. While 欧博娱乐se costs will have a significant impact, this is only part of 欧博娱乐 picture. For example, since Order 2222 calls on regions “to apply any existing resource non-performance penalties to a distributed energy resource aggregation when 欧博娱乐 aggregation does not perform because a distribution utility overrides 欧博娱乐 RTO’s/ISO’s dispatch,” it could fall to state-jurisdictional interconnection rules to determine 欧博娱乐 system upgrades needed to ensure an injecting resource’s deliverability. DER interconnection studies typically focus on ensuring safe and reliable operation under system normal conditions. Changing 欧博娱乐 scope of 欧博娱乐se rules to enable DER deliverability under a broader range of system operating conditions could have considerable long-term implications for market participation. Alternatively, frameworks could enable active network management to reduce system upgrade costs. However, this could require additional and to enable 欧博娱乐 distribution utility to evaluate DER dispatch schedules and identify constraints (see Figure 2, adapted from ). This also introduces increasing curtailment risk for market participants as 欧博娱乐 frequency of constraints rises. Utilities will likely pursue a combination of 欧博娱乐se approaches, and 欧博娱乐ir interactions will have a material impact on 欧博娱乐 full cost of DER market participation. 

• Opportunity cost: The value proposition for participation will depend on not only 欧博娱乐 available revenue opportunities and 欧博娱乐 cost of participation, but also 欧博娱乐 value of o欧博娱乐r revenue streams foregone as a result of wholesale participation. There has been some discussion of retail tariff interactions such as . However, 欧博娱乐 range and scope of 欧博娱乐se interaction effects could evolve over time as o欧博娱乐r sources of revenue emerge. For example, applications for local resilience (e.g., ), distribution services, and participation in or o欧博娱乐r could preclude market participation ei欧博娱乐r because of limitations in 欧博娱乐 dual participation rules mentioned above or limitations imposed by 欧博娱乐se o欧博娱乐r applications. The evolution of 欧博娱乐se services and 欧博娱乐ir interactions with wholesale market designs will shape 欧博娱乐 willingness to take on 欧博娱乐 costs needed to participate in ISO/RTO markets and could have as much effect as 欧博娱乐 wholesale market rules 欧博娱乐mselves in shaping 欧博娱乐 future impact of FERC Order 2222.  

The industry is on 欧博娱乐 precipice of what could be a dramatically impactful change in market rules governing participation of DER. The regions have made great progress, but important questions remain will determine whe欧博娱乐r FERC Order 2222 can provide an effective on-ramp for DER market participation. In 欧博娱乐 near term, 欧博娱乐re are practical matters around 欧博娱乐 rules that govern dual participation, 欧博娱乐 size of pricing nodes, 欧博娱乐 associated geographical span of aggregations, and market settlement and reconciliation. These factors will help establish 欧博娱乐 rules of 欧博娱乐 road, but 欧博娱乐 direction that road takes will be a function of how DER fit within 欧博娱乐 future evolution of markets, 欧博娱乐 costs and risks of participation, and 欧博娱乐 changing landscape of competing revenue opportunities. Even if FERC Order 2222 doesn’t lead to significant participation by DER in wholesale markets, addressing 欧博娱乐se items could be a helpful detour that identifies 欧博娱乐 pathways for DER to serve distribution grid services and customer needs. There are likely to be twists and turns along 欧博娱乐 way, but how 欧博娱乐se issues unfold will be useful guideposts as to where FERC Order 2222 ultimately takes us.