Final D.C. Grid Modernization Report Recommends Enhancement Of Competitive Energy Supplier Information For Customers

Recommends Online Retail Supplier Rate Board

Recommends Dynamic Pricing Working Group

Report Makes No Formal Recommendations On Utility Ownership Of Distributed Generation, Storage

Addresses Access To Customer Data, Security Requirements For Such Access

May 31, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The Modernizing the Energy Delivery System for Increased Sustainability (MEDSIS) work group process established by the District of Columbia PSC has released a final report and recommendations

Among other things, the report recommends, "The DCPSC should create a new stand-alone website or enhance their existing website to house up-to-date competitive energy supplier offers as well as energy education material that would aid customers in evaluating offers. The new site should be easily identifiable and accessible from the DCPSC home page. A marketing campaign should accompany the availability of this new website to increase customer awareness of the site"

The report notes that only about 15% of residential electric customers take competitive supply

"While many factors likely contribute to the lack of switching among residential customers, the group felt significant factors included the difficulty many District customers face in evaluating competitive offers and the shortage of trusted energy educational material that would help them evaluate offers. This lack of streamlined, readily available information in the District has likely contributed to residential customers adopting a 'do nothing' approach," the report says

Dynamic Pricing

The report recommends that, "By October, 2019, the DCPSC should reconvene the Dynamic Pricing working group that previously existed in the District and direct them to formulate the details of a new residential dynamic pricing program(s). The working group should be convened for a defined time frame – ideally with the goal of developing a program(s) that can be submitted for approval by the DCSPS [sic] in time for the 2020 cooling season. The DCPSC should conduct ongoing monitoring of the dynamic pricing program, once implemented, to ensure program elements are evolved, as needed, to address PJM market changes, increasing penetration of DERs, program role as a NWA to system build out, and customer feedback"

While various stakeholder proposals for dynamic pricing were discussed, the report does not endorse a specific design, or even specify that dynamic pricing shall include the generation side of the bill. The recommendation does not address SOS versus Third-Party Supplier Applicability of any program

Third Party Access To Customer Data

The report recommends that, "The DCPSC should direct Pepco to proceed with investigating the implementation of the Green Button Connect My Data (CMD) functionality in accordance with standards established by the Green Button Alliance. The DCPSC should review Pepco’s existing data security standards for adequacy against the CMD standard. Further, the DCPSC should ensure third parties seeking access to customer data via an electronic interface with Pepco adhere to Pepco’s cybersecurity standards for protection of this data. The DCPSC should have the authority to audit third parties’ systems and processes to ensure compliance with these standards. Finally, the DCPSC should ensure utilities and energy service providers develop policies and practices to address the integrity and confidentiality of customer data and should ensure the information security of all interfaces, devices and operations involving customer data sharing includes but is not limited to the following: 1. An opt-out data sharing policy for aggregated data to protect customer privacy and personally identifiable information (PII); 2. An opt-in customer data sharing agreement for PII data"

"If the DCPSC does make changes, they should instruct Pepco to build a portal that replicates the ability for a customer to grant access to their online account to any third party," the report says

Microgrids & Customer Choice

The report recommends that, "DCPSC should define and establish a new regulated entity of 'microgrid operator'. A 'microgrid operator' is any entity that operates a microgrid serving multiple customers."

"DCPSC should decide what types of regulations need to be applied to microgrid operators," the report recommends

"For single customer microgrids and third party campus single customer microgrids, current DCPSC rules and regulations are sufficient and there is no need to make new rules and regulations for single customer microgrids. Private contracts with a single customer are an appropriate mechanism to address customer right and responsibilities, customer protection and electricity quality of service," the report says

"For all Multi-Customer Microgrids, DCPSC should apply Consumer Rights and Responsibilities and Customer Protection standards parallel to the standards applicable to Electricity Suppliers and Electric Companies as outlined in Title 15 of DCMR," the report says

Regarding microgrids and customer choice, the report says, "For all Multi-Customer Microgrids, several stakeholders believe a private contract with microgrid-specific disclosure provisions is sufficient for retail choice and should be subject to compliance review regarding such provisions by DCPSC. If the DCPSC decides that private contract is sufficient, DCPSC should ensure appropriate use of microgrid-specific private contract disclosure provisions can allow for safe harboring of such private contracts from advanced DCPSC review. Safe harbor provisions regulated by the DCPSC could include but are not limiting to full disclosure of long term retail choice, restrictions on the ability for individual customers to exercise customer choice for imported electricity separately from the microgrid operator’s decision, appropriate customer disclosure of the microgrid itself and the associated long-term commitment."

"If the microgrid imports electricity from a supplier, it should be subject to electricity quality of service standards parallel to the standards applicable to Electricity Suppliers as outlined in Title 15 of DCMR," the report says

The report recommends that DCPSC should direct the utility to establish a customer microgrid schedule or tariffs. The tariff would be between a microgrid customer and the utility and may include: fixed charges, time-of-use charges, volumetric charges, payments and/or credits for export, and demand charges

The report recommends that the DCPSC should determine how utilities recover costs of microgrid assets, with the following recommendations:

     A. Distribution assets within the microgrid that are owned by the utility should be considered regulated assets subject to cost recovery through the utility’s ratebase

     B. Distribution assets built solely for the purposes of adding a resiliency benefit to a potential microgrid that benefits all ratepayers is subject to cost recovery through the utility’s ratebase.

     C. Distributed generation assets within the microgrid that are owned by a third-party or customer should be allowed to provide grid reliability services to the utility via a NWA contract.

Utility Ownership Of DERs, Storage, Microgrids

As exclusively first reported by EnergyChoiceMatters.com, a draft report had recommended utility ownership of distributed generation, storage, and microgrids under various situations

No such recommendations are in the final report.

Instead, a "learning" included in the report summarized stakeholder views on these issues, including what the report termed a "general agreement" on some items, but no formal recommendations were made

The report says, "The stakeholder input and working group discussions led to a general agreement amongst stakeholders that utilities should not at this time be allowed to own storage assets behind-the-meter at this time."

The report says, "The stakeholder input and working group discussions led to a general agreement amongst stakeholders that utilities should be allowed to own front-of-the-meter energy storage assets for the primary purpose of providing grid reliability services."

The report says, "The stakeholder input and working group discussions led to a general agreement amongst stakeholders to allow utilities to operate energy storage assets in wholesale markets to the benefit of rate payers."

The report says, "The stakeholder input and working group discussions led to a general agreement amongst stakeholders that utilities should continue to be allowed to own solar PV assets as long as it is not for the purposes of selling retail electricity to customers."

The report says, "The stakeholder input and working group discussions led to a general agreement amongst stakeholders that utilities should be allowed to own wind, biomass, waste-to-energy, cogeneration and/or micro turbine assets as long as it is not for the purposes of selling retail electricity to customers."

Customer Protection Under MEDSIS Pilot Projects

The report outlines a process to consider pilot projects under the MEDSIS process, and ratepayer funding of such projects (which may be undertaken by third parties)

The report recommends that DCPSC should evaluate the Customer Bill of Rights (CBOR) and update it to address the MEDSIS vision for a modern grid in time to support the Pilot Projects phase. The following specific considerations should be addressed when making updates

Formal Case No. 1130

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