With FERC Order 2222 requiring RTOs to allow distributed energy resources to participate in wholesale markets, I'm curious what folks are seeing in terms of impact on retail rates. Here in upstate New York, NYISO has been working on their compliance filing and there's talk about how this might affect the capacity market. Any of you dealing with clients who are looking at aggregating their resources? The regulatory uncertainty is making it hard to advise clients on long-term energy strategies.
FERC Order 2222 implementation - what are you seeing?
Tom, we're seeing some interest here in Tennessee with TVA's Green Invest program, though that's more of a voluntary program than a direct result of Order 2222. The bigger impact I'm tracking is how this might change standby rates for customers with significant behind-the-meter generation. MLGW hasn't made any announcements yet, but I suspect we'll see modifications to Schedule E-3 once the wholesale market participation rules get clarified. Are you seeing any movement on standby rate modifications in New York?
We're dealing with this in Oklahoma where SPP is still working through their compliance timeline. The challenge I'm seeing is that Order 2222 creates opportunities for customers with solar-plus-storage to potentially participate in wholesale markets, but the retail rate structures haven't caught up. OG&E's net metering provisions don't really account for the possibility that the customer might be participating in wholesale markets with the same resource. It's creating some interesting rate interpretation questions.
Susan, that's exactly the kind of complexity I'm worried about. We have a client with a 2MW solar array and Tesla Megapack storage system who's interested in participating in NYISO's wholesale markets, but they're also on National Grid's Schedule SC-3A standby service. The tariff language doesn't clearly address how wholesale market participation affects the standby charges. I've got a call scheduled with National Grid's rate department next week but I'm not optimistic they'll have clear answers yet.
This is creating headaches for us too here in Memphis. We have several industrial clients asking about battery storage options and whether they can participate in MISO markets, but the retail rate implications are murky. TVA's Large General Power schedule has backup provisions that could get triggered if they participate in wholesale markets, potentially costing them their favorable primary service rates. The regulatory framework just hasn't caught up to the technology possibilities yet.