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Sharon Jacobs Harvard Law School 1) Order 719 2) RICE Rules 3) Bigger-picture regulatory questions Order 719 (2008) Order 745 (2011) Order 755 (2011) Order 676G (2013) Five provisions affecting DR o Ancillary services o Accepting bids from aggregators of retail customer loads o Eliminate deviation charges during system emergencies o Market clearing price should reflect true value of energy during operating reserve shortages o More research on barriers to demand response Legal bases for regulation o Ensuring that rates are just and reasonable o Remedying undue discrimination and preference in organized markets Challenges/pushback o Source of authority o Limits of authority Department Federal of Energy Trade Commission Environmental Protection Agency NESHAPs NSPS Can operate up to 100 hours per year to participate in demand response emergencies Can operate up to 50 of those 100 hours to help maintain voltage stability and prevent power supply interruption Switch to ULSD as of 2015 Reporting requirements beginning in 2015 for larger engines Jurisdictional questions Coordination Energy vs. environment (?)
