On October 24, 2022, the PUC Staff requested comments from the public regarding potential uplift of capital, operations, and maintenance costs to Transmission Cost of Service to support Distributed Energy Resources (DERs). A number of comments have been provided to the PUC Staff, including those of ERCOT, Oncor, CenterPoint, Calpine, LCRA, CPS Energy and the City of Houston.
ERCOT’s commentary was focused on the current situation with respect to distributed resources:
· Distribution-connected Resources can relieve transmission congestion and help ensure system reliability
· Distribution-connected Resources may be unavailable at times due to distribution system interruptions that do not impact transmission-level resources
· Distribution-connected Resources do not provide Voltage Support Service and therefore do not provide the same level of voltage reliability benefits as transmission-level resources
· Unlike a Settlement-Only Distributed Generator (SODG) and Settlement-Only Distribution Energy Storage System (SODESS), Distributed Generation Resources (DGR) and Distributed Energy Storage Resources (DESR) can be dispatched by SCED and may provide ancillary services
· DGRs and DESRs receive the same price for providing ancillary services that transmission-connected resources do
· DGRs and DESRs providing Responsive Reserves and Regulation Up present some risk that ERCOT’ s ability to address under-frequency conditions could be compromised if these resources are connected to feeders that are disconnected during a load shed event
ERCOT did not offer commentary on DESRs related to appropriate costs of distribution charges or interconnection costs.
CenterPoint’s commentary, consistent with their recent positions, suggests that all DER and DESR costs be socialized across the entire rate base:
· DER Interconnection Costs should be included with a TDU’s Distribution System Costs
· The Distribution System Costs incurred by a TDU to provide Wholesale Distribution Service to deliver energy from a DGR or DESR to load customers on the distribution system should be recovered through the TDU’s rates for providing delivery service to all customers on its distribution system, rather than requiring the DER to pay a Contribution In Aid of Construction (CIAC) for those costs or uplifting those costs to ERCOT
· The Distribution System Costs incurred by a TDU to provide Wholesale Distribution Service to deliver energy to a DESR for storage should be charged to and recovered from the DESR through a Commission-approved Wholesale Distribution Service rate
Texas PUC Staff has not announced a next step in the process under this project.
Stay tuned!
