Texas PUC Issues Questions For Stakeholders On TDUs' Use Of Storage, Non-Traditional Tech. For Delivery Service
October 3, 2018 Email This Story Copyright 2010-17 EnergyChoiceMatters.com
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The Public Utility Commission of Texas has issued a list of questions for stakeholder comment in Project No. 48023: Rulemaking to Address the Use of Non-Traditional Technologies in Electric Delivery Service
Among other things, the questions, listed below, ask about the impact on wholesale price formation and the accounting for any storage-related energy in the wholesale market, without using UFE
The questions are:
1. Apart from energy storage, what non-traditional technologies could provide a potential cost-effective solution to reliability issues on a utility's transmission or distribution system?
2. Can a transmission and distribution utility (TDU) legally own a non-traditional technology device, including energy storage equipment and facilities, to support reliability on its system, without a specific exemption in the Public Utility Regulatory Act? If so, under what legal authority could a TDU own such a device?
3. How should any energy necessary for TDU implementation of a non-traditional
technology device be measured and accounted for within the ERCOT market,
without using Unaccounted for Energy (UFE)?
4. In which situations and scenarios would it be appropriate for a TDU to deploy a
non-traditional technology device for the purpose of supporting reliability on its
transmission or distribution system?
5. Should a Certificate of Convenience and Necessity (CCN) or other commission
pre-approval process be required before the construction or procurement of utility-owned
devices that use non-traditional technologies to support reliability on the
transmission or distribution system? If so, what criteria would be appropriate for
pre-approval of such devices and why? Should such a pre-approval process only
apply for a limited time?
6. Should the commission's rules permit or require a TDU to contract with a non-utility
service provider for the provision of a non-traditional technology device to
support reliability on the TDU's transmission or distribution system? If so, what
parameters should the commission stipulate for this arrangement?
7. If the commission were to adopt a policy of permitting a TDU to procure a nontraditional
technology device for the purposes of supporting reliability on the
TDU's transmission or distribution system, what potential effects would such a
policy have on ERCOT wholesale market outcomes, and especially price formation, in the ERCOT market? What potential effects might such a policy have
on the competitive retail market, if any?
8. What market-based alternatives exist, if any, to address reliability issues on a
TDU's transmission or distribution system?
9. How could a vertically integrated investor-owned utility maximize the value of an
energy storage device without adversely affecting wholesale market outcomes and
price formation in its respective market?
10. What impediments exist to using non-traditional technology devices on utility
transmission or distribution systems?
11. Could the commission specify conditions under which a TDU could employ nontraditional
technologies to support reliability? If so, what conditions would be
12. If you are a utility, please provide a detailed overview of any batteries or other
energy storage technologies on your transmission and distribution system in the
state of Texas that are either currently operational or planned to be operational.
Please explain the purpose, use, metering, and deployment of these technologies.
13. Are there any other issues that the commission should consider addressing in this