Texas Staff Proposes Questions For Stakeholders On TDUs' Use Of Storage, Non-Traditional Tech. For Delivery Service

Staff of the Public Utility Commission of Texas have presented for Commission consideration a list of questions for stakeholder comment in Project No. 48023: Rulemaking to Address the Use of Non-Traditional Technologies in Electric Delivery Service

Staff's proposed questions include:

• If the commission were to adopt a policy of permitting a TDU to procure a non-traditional 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?

• 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)?

• 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?

• 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?

• 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?

• 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?

• 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?

• What market-based alternatives exist, if any, to address reliability issues on a TDU's transmission or distribution system?