Development of compliance rules and penalties. The assumptions underlying the calculation of flexible capacity need. The assigned Commissioner and ALJ should issue a Ruling as soon as possible to begin the formal aspect of this process. Distributed Generation In the January 23, 2013 workshop, Energy Division presented a proposed “Resource Adequacy Deliverability for Distributed Generation” initiative which offered a new pathway for distributed generation to qualify for RA value. This presentation was summarized in the transcript for that workshop at 46 – 48, and the presentation was attached to the transcript. The Energy Division proposal was developed in response to an Order of FERC in Docket ER122643000, where the FERC approved an ISO tariff filing related to deliverability for distributed generation, with certain modifications. Since the workshop, events appear to have overtaken the record. The ISO circulated a compliance proposal regarding the FERC Order on March 25 and proposed tariff language on April 2. After conducting stakeholder calls, receiving comments, and making appropriate modifications, the ISO has now filed tariffs with the FERC to respond to the FERC’s modifications. Montauk Energy states that it appears that the ISO’s revised approach to allocation of distributed generation deliverability could be implemented without requiring any specific activity on the part of the Commission. IEP also believes that events appear to have overtaken the Commission’s consideration of deliverability for distributed generation. IEP has reviewed the ISO compliance proposal and finds that the ISO has developed a reasonable response to the FERC orders on deliverability for distributed generation.
Development of compliance rules and penalties. The assumptions underlying the calculation of flexible capacity need. The assigned Commissioner and ALJ should issue a Ruling as soon as possible to begin the formal aspect of this process. Distributed Generation In the January 23, 2013 workshop, Energy Division presented a proposed “Resource Adequacy Deliverability for Distributed Generation” initiative which offered a new pathway for distributed generation to qualify for RA value. This presentation was summarized in the transcript for that workshop at 46 – 48, and the presentation was attached to the transcript. The Energy Division proposal was developed in response to an Order of FERC in Docket ER122643000, where the FERC approved an ISO tariff filing related to deliverability for distributed generation, with certain modifications. Since the workshop, events appear to have overtaken the record. The ISO circulated a compliance proposal regarding the FERC Order on March 25 and proposed tariff language on April 2. After conducting stakeholder calls, receiving comments, and making appropriate modifications, the ISO has now filed tariffs with the FERC to respond to the FERC’s modifications. Montauk Energy states that it appears that the ISO’s revised approach to allocation of distributed generation deliverability could be implemented without requiring any specific activity on the part of the Commission. IEP also believes that events appear to have overtaken the Commission’s consideration of deliverability for distributed generation. IEP has reviewed the ISO compliance proposal and finds that the ISO has developed a reasonable response to the FERC orders on deliverability for distributed generation.
70423172.docx