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Texas REP Urges PUC To Allow Use Of Demand Response, DERs For Proposed Generation Firming Requirements
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In comments on a proposed Texas PUC rule concerning firming requirements for generation, Octopus Energy urged the PUC to allow demand response and DERs to serve as eligible resources to meet firming obligations
In the proposal for publication, the Commission’s draft rule would allow the
firming requirements to be met by another electric generating facility or a battery energy storage resource
that is either on-site or off-site
Octopus represented that, at a recent workshop, Commission Staff
expressed willingness to include demand response and DERs as eligible to meet the firming requirements, although Octopus said that questions remain regarding how best to
implement the requirements.
Octopus said, "We respectfully suggest that the ERCOT stakeholder process is the
appropriate place to determine these implementation details, and we urge the Commission to set
policy that is inclusive of facilities that can provide demand response and aggregate distributed
energy resources (ADERs)."
Octopus specifically proposed that, "output from facilities that can provide demand response or an aggregate
distributed energy resource (ADER), as determined by ERCOT," should be allowed as a means of meeting the firming requirements
Project 58198
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September 2, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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