Transcript Regulating Demand Response



Sharon Jacobs
Harvard Law School
1)
Order 719
2)
RICE Rules
3)
Bigger-picture regulatory questions

Order 719 (2008)

Order 745 (2011)

Order 755 (2011)

Order 676G (2013)

Five provisions affecting DR
o Ancillary services
o Accepting bids from aggregators of retail customer loads
o Eliminate deviation charges during system emergencies
o Market clearing price should reflect true value of energy during
operating reserve shortages
o More research on barriers to demand response

Legal bases for regulation
o Ensuring that rates are just and reasonable
o Remedying undue discrimination and preference in organized
markets

Challenges/pushback
o Source of authority
o Limits of authority
 Department
 Federal
of Energy
Trade Commission
 Environmental
Protection Agency
NESHAPs
NSPS

Can operate up to 100 hours per year to participate in
demand response emergencies

Can operate up to 50 of those 100 hours to help maintain
voltage stability and prevent power supply interruption

Switch to ULSD as of 2015

Reporting requirements beginning in 2015 for larger
engines
 Jurisdictional
questions
 Coordination
 Energy
vs. environment (?)