July 1, 2009 Plan filing. However, the Commission stated that each filed plan was expected to include at least one contract with a CSP. The Implementation Order established the criteria that the Commission will use in approving request for proposals (RFP) procedures and standard form contracts for CSPs. 1. Multiple CSPs for Demand Response Program a. Positions of the Parties As originally presented in its EE&C Plan, PPL’s proposed Load Curtailment Program contemplated using a single CSP to manage and administer the program. PPL Exh. 1 Amended at 149. However, in response to a request by ClearChoice that multiple demand response CSPs be used, PPL states that it will not limit this program to a single CSP, but will solicit bids from multiple demand response CSPs to provide blocks of firm curtailable load and/or direct load control. PPL MB at 33-34. PPL states that the size of these blocks is expected to be between 5 MW and 25 MW, and asserts that it will select the most cost-effective combination of these firm load reduction blocks. PPL MB at 34. PPL further states that it not intend to favor any demand “does response CSP over another, and it would be difficult to do so because of the turnkey nature of the related programs.” PPL MB at 34. EnerNOC strongly opposes PPL’s proposal to require the bidding of load blocks to multiple CSPs, contending that separating participants into 25 MW blocks will make them too small to aggregate effectively. EnerNOC RB at 4. EnerNOC argues that such a block approach would make it less economical for a CSP to run a program, and would be extremely challenging to operate and manage. EnerNOC RB at 4-5. EnerNOC asserts that there are a number of market influences that will not be controllable under this approach, and those could easily create confusion and program failure. EnerNOC RB at 5. In this regard, EnerNOC elaborates as follows:
July 1, 2009 Plan filing. However, the Commission stated that each filed plan was expected to include at least one contract with a CSP. The Implementation Order established the criteria that the Commission will use in approving request for proposals (RFP) procedures and standard form contracts for CSPs. 1. Multiple CSPs for Demand Response Program a. Positions of the Parties As originally presented in its EE&C Plan, PPL’s proposed Load Curtailment Program contemplated using a single CSP to manage and administer the program. PPL Exh. 1 Amended at 149. However, in response to a request by ClearChoice that multiple demand response CSPs be used, PPL states that it will not limit this program to a single CSP, but will solicit bids from multiple demand response CSPs to provide blocks of firm curtailable load and/or direct load control. PPL MB at 33-34. PPL states that the size of these blocks is expected to be between 5 MW and 25 MW, and asserts that it will select the most cost-effective combination of these firm load reduction blocks. PPL MB at 34. PPL further states that it “does not intend to favor any demand response CSP over another, and it would be difficult to do so because of the turnkey nature of the related programs.” PPL MB at 34. EnerNOC strongly opposes PPL’s proposal to require the bidding of load blocks to multiple CSPs, contending that separating participants into 25 MW blocks will make them too small to aggregate effectively. EnerNOC RB at 4. EnerNOC argues that such a block approach would make it less economical for a CSP to run a program, and would be extremely challenging to operate and manage. EnerNOC RB at 4-5. EnerNOC asserts that there are a number of market influences that will not be controllable under this approach, and those could easily create confusion and program failure. EnerNOC RB at 5. In this regard, EnerNOC elaborates as follows:
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