front of the utility meter, and cautions that metering alone may not be sufficient for resources located behindthemeter that also have onsite retail load, and states that the Commission must develop protocols for delineating retail and wholesale charging. In reply comments, PG&E modifies its position somewhat to state that it supports two meters as a default measurement for retail and wholesale loads, but that the estimation schemes already in station power retail tariffs are sufficient as an alternative measurement in instances where loads are not separable. IEP states that “(s)eparate meters are essential to ensure comparable treatment of all resources participating in wholesale markets and to maintain a clear jurisdictional divide between retail and wholesale. Estimation or sampling does not provide the precision required for clear jurisdictional boundaries and does not maintain the comparable treatment that should be the hallmark of a competitive wholesale market.” NRG does not explicitly support either approach, but offers three cautions. The first is that the cost of the twometer approach could be prohibitive for smaller projects. Second, similar to PG&E’s position, it is unclear whether wholesale and retail transactions are distinguishable from each other, even using two meters. Third, it is imperative that behindthemeter resources not be allowed to charge at wholesale and discharge at retail. NRG recommends that if a storage resource chooses to use only a single meter for the storage device and retail load, that all energy – charging or otherwise – transacted through that meter be at retail. SCE, CESA, and LS Power support the CAISO staff’s proposal. SCE bases its support for the CAISO staff proposal on the nascence of the storage market, and supports flexibility in metering storage devices as long as wholesale and
front of the utility meter, and cautions that metering alone may not be sufficient for resources located behindthemeter that also have onsite retail load, and states that the Commission must develop protocols for delineating retail and wholesale charging. In reply comments, PG&E modifies its position somewhat to state that it supports two meters as a default measurement for retail and wholesale loads, but that the estimation schemes already in station power retail tariffs are sufficient as an alternative measurement in instances where loads are not separable. IEP states that “(s)eparate meters are essential to ensure comparable treatment of all resources participating in wholesale markets and to maintain a clear jurisdictional divide between retail and wholesale. Estimation or sampling does not provide the precision required for clear jurisdictional boundaries and does not maintain the comparable treatment that should be the hallmark of a competitive wholesale market.” NRG does not explicitly support either approach, but offers three cautions. The first is that the cost of the twometer approach could be prohibitive for smaller projects. Second, similar to PG&E’s position, it is unclear whether wholesale and retail transactions are distinguishable from each other, even using two meters. Third, it is imperative that behindthemeter resources not be allowed to charge at wholesale and discharge at retail. NRG recommends that if a storage resource chooses to use only a single meter for the storage device and retail load, that all energy – charging or otherwise – transacted through that meter be at retail. SCE, CESA, and LS Power support the CAISO staff’s proposal. SCE bases its support for the CAISO staff proposal on the nascence of the storage market, and supports flexibility in metering storage devices as long as wholesale and
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