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The Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) on April 19 to amend its regulations “to incorporate by reference the business practice standards adopted by the Wholesale Electric Quadrant of the North American Energy Standards Board (NAESB) that pertain to the measurement and verification of demand response and energy efficiency resources participating in organized wholesale electricity markets.” The NOPR is timely, coming on the heels of several contentious disputes, including FERC enforcement actions, questioning how to measure the performance of vendors of demand response and efficiency resources. To be considered, comments on the NOPR must be submitted to FERC 60 days after publication of the NOPR in the Federal Register.
Adoption of the NAESB standards, in FERC’s view, could improve demand response and energy efficiency resource performance, measuring methods and procedures. FERC also expressed its hope that the NAESB standards could assist Independent System Operators (ISO) and Regional Transmission Organizations (RTO) with accounting for and crediting demand response and energy efficiency resources.
NAESB describes the proposed standards as a “framework” to develop methodologies. The proposed demand response standards include the following changes:
- Adding a meter data reporting deadline;
- Specifying advance notification guidelines;
- Establishing a telemetry interval; and
- Tightening requirement for meter accuracy.
Through this NOPR, FERC seeks comment about whether these methodologies need to be more detailed to be useful. FERC also seeks comment on whether ISOs and RTOs need further specific development of measurement and verification standards and if so, whether NAESB or FERC should lead this process.
© 2013 McDermott Will & Emery
