Docket No. ER22-983-004
I concur with the Commission’s order, but write separately to convey my disappointment with ISO New England’s chosen approach to complying with the Commission’s directive to either modify its metering proposal, or to explain why its proposal is just and reasonable and does not pose an unnecessary and undue barrier to individual DERs joining an aggregation.[1]
While Order No. 2222 did not require ISO New England to modify its Order No. 745-compliant method for establishing demand response baselines, as the Commission’s First Compliance Order explained, ISO New England also was not precluded from considering alternative baseline methodology approaches in assessing whether and how to modify its metering and telemetry proposal.[2] Protestors contend that, in contrast to ISO New England, “other markets . . . have made available demand response baseline methodologies and/or metering options that facilitate increased participation by behind-the-meter DERs as demand response.”[3] Yet, rather than examining the full suite of options that may facilitate participation of DERs in its markets, ISO New England focused its further compliance filing solely on non-demand response resources.[4]
In essence, ISO New England chose to do the minimum required by law to meet the Commission’s directive on this issue. I am disappointed that ISO New England declined to take a more rigorous approach, as it was clearly permitted to do. As I previously stated, every possible supply and demand resource type must be on the table,[5] especially in light of reliability concerns that have repeatedly been raised in the region.[6] It is lamentable that ISO New England has failed to examine this path for facilitating more robust resource participation, which could potentially enhance the system’s reliability in an affordable manner.
For these reasons, I respectfully concur.
[1] Referring to ISO New England’s proposal to require measurement of behind-the-meter DERs not participating solely as demand response at the Retail Delivery Point, unless the Assigned Meter Reader can accommodate submetering or parallel metering of the DER. See First Compliance Order, 182 FERC ¶ 61,137, at P 168 (2023).
[2] First Compliance Order at P 93. Indeed, the Commission provided specific examples of other baseline methodologies it has approved. Id. n.191.
[3] Protest at 12.
[4] See Transmittal at 23; Protest at 12 (“ISO-NE failed to consider opportunities to expand participation via demand response, continuing to insist that demand response is out of scope rather than thinking more holistically about ways to reduce barriers to participation for behind-the-meter DERs.”)
[5] First Compliance Order (Clements, Comm’r, concurring, P 7).
[6] Id. (Clements, Comm’r, concurring, P 2 n.3) (collecting comments describing the reliability threat facing New England in the Commission’s New England Winter-Gas Electric Forum docket).