|
|
|
|
|
Study Prepared For ERCOT Claims Texas Law "Mandates" That "Each" Retail Provider Must Develop Residential Demand Response Program
The following story is brought free of charge to readers by VertexOne, the exclusive EDI provider of EnergyChoiceMatters.com
A study prepared for ERCOT by a third party states that Texas law "mandates" that "each" retail electric provider shall develop a residential demand response program
The study, addressing the potential impacts of demand response and energy efficiency on ERCOT's peaks, was prepared by the Department of Electrical
and Computer Engineering at the Texas A&M Energy Institute
The study says, "Senate Bill 1699 mandates that each REP in the ERCOT
power region develop a residential demand response program aimed at
decreasing the average total residential load."
While, as first reported by EnergyChoiceMatters.com, certain parties (including Octopus Energy) have said that PURA 39.919, as created by SB 1699, should be interpreted as requiring that every REP serving residential customers must be required to offer DR programs, such is an interpretation distinct from requiring "each" REP (not only residential REPs) in ERCOT offer residential DR
Some REPs, certified to serve all customer types, choose to limit their service to non-residential customers. Moreover, some REPs -- such as Option 2 REPs -- are by rule and certification prohibited from serving residential customers. Some Option 2 REPs serve only affiliated large loads and do not offer service generally to the public. The study's quoted statement and broad interpretation of SB 1699 ostensibly would require these REPs to offer demand repose to residential customers
Although the study's alleged mandate that each REP in ERCOT shall offer residential DR was asserted in connection with the law's average total residential load reduction goal, nothing in the quote itself or the de minimis surrounding context suggests that the study's author(s) believe that the mandate is limited only to residential REPs.
Moreover, since DR is not a retail electric service, any alleged mandate specifically stating that "each" REP in ERCOT shall offer residential DR should not be read as automatically excluding non-residential REPs, since REP certification, and its limits, is not linked to DR, but rather to retail electric service. Indeed, retail electric service is defined by PURA as the "sell[ing]" of "electric energy" to "retail" customers [emphasis added]. DR does not fit such a definition. Thus, DR is not a REP service, and thus DR is not governed by REP certification limits. In other words, if PURA is being interpreted as requiring that all REPs must offer residential DR, nothing else in PURA would limit this requirement to being only applicable to residential REPs, because eligibility to offer residential DR is not constrained by a REP's certification type
The study asserts the above-quoted REP DR mandate without any discussion, but the quote itself does limit the mandatory residential DR which REPs must offer to being required in furtherance of, "decreasing the average total residential load." (e.g. SB 1699's average total residential load reduction goal).
Under SB 1699, the program to reduce average total residential load is to provide demand response participation to residential customers, "where reasonably available."
The study chooses to express this idea as SB 1699, "ensuring that demand response
participation is reasonably available to residential customers," [emphasis added] rather than residential DR programs being required where reasonably available -- a much different scenario
The study does not discuss SB 1699's limit that the residential DR participation is only required, "where reasonably available", nor does the study discuss what conditions constitute the reasonable availability of residential DR.
Notably, another section of SB1699, not cited by the study in regards to the alleged mandate, provides, in modifying PURA 39.101(b), that a "customer" is entitled to, "participation in demand response programs through retail electric providers [i]that offer demand
response programs[/i][.]" [emphasis added]
The study was filed by ERCOT in Texas PUC Projects 38578 and 55999, and is linked here
ADVERTISEMENT ADVERTISEMENT Copyright 2024 EnergyChoiceMatters.com. Unauthorized copying, retransmission, or republication
prohibited. You are not permitted to copy any work or text of EnergyChoiceMatters.com without the separate and express written consent of EnergyChoiceMatters.com
October 1, 2024
Email This Story
Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
NEW Jobs on RetailEnergyJobs.com:
• NEW! -- Director of Policy and Research, Retail Energy
• NEW! -- Director, Load Forecasting
-- Retail Supplier
• NEW! -- Wholesale Markets Analyst -- Retail Supplier
• NEW! -- Origination Analyst
-- Retail Supplier
• NEW! -- Settlements Analyst
-- Retail Supplier
• NEW! -- Billing Supervisor
|
|
|
|
|