جبران خسارت پاسخ تقاضا ، تخصیص سود و زیان خالص : نظرات

FERC's Supplemental Notice of Public Rulemaking addresses the question of proper compensation for demand response in organized wholesale electricity markets. Assuming that the Commission would proceed with the proposal “to require tariff provisions allowing demand response resources to participate in wholesale energy markets by reducing consumption of electricity from expected levels in response to price signals, to pay those demand response resources, in all hours, the market price of energy for such reductions,” the Commission posed questions about applying a net benefits test and rules for cost allocation. This article summarizes critical points and poses implications for the issues of net benefit tests and cost allocation

The Federal Energy Regulatory Commission's Supplemental Notice of Proposed Rulemaking (NOPR) addresses the question of proper compensation for demand response in organized wholesale electricity markets.1 Assuming that the Commission would proceed with the proposal “to require tariff provisions allowing demand response resources to participate in wholesale energy markets by reducing consumption of electricity from expected levels in response to price signals, to pay those demand response resources, in all hours, the market price of energy (also referred to as the “locational marginal price” or LMP) for such reductions,”2 the Commission posed questions about applying a net benefits test and rules for cost allocation. There is now an extensive record in this matter, and I have written on the various issues.3 The purpose of the present article is to summarize critical points and pose implications for the issues of net benefit tests and cost allocation. These comments highlight several questions: Why are we here? Why is this subject so confusing? Why are retail rates relevant? How can we match ends and means? Do we need a net benefits test? How should we allocate costs? Where should we go from here? The Commission's Supplemental NOPR did not address the underlying arguments presented in response to the original NOPR in this matter. But many of the basic issues in considering net benefits tests and cost allocation arise from the fundamentals that the Commission should address. Despite the important role that LMP plays in successful market design, the Commission should not assume that paying LMP is always appropriate.The Federal Energy Regulatory Commission's Supplemental Notice of Proposed Rulemaking (NOPR) addresses the question of proper compensation for demand response in organized wholesale electricity markets.1 Assuming that the Commission would proceed with the proposal “to require tariff provisions allowing demand response resources to participate in wholesale energy markets by reducing consumption of electricity from expected levels in response to price signals, to pay those demand response resources, in all hours, the market price of energy (also referred to as the “locational marginal price” or LMP) for such reductions,”2 the Commission posed questions about applying a net benefits test and rules for cost allocation. There is now an extensive record in this matter, and I have written on the various issues.3 The purpose of the present article is to summarize critical points and pose implications for the issues of net benefit tests and cost allocation. These comments highlight several questions: Why are we here? Why is this subject so confusing? Why are retail rates relevant? How can we match ends and means? Do we need a net benefits test? How should we allocate costs? Where should we go from here? The Commission's Supplemental NOPR did not address the underlying arguments presented in response to the original NOPR in this matter. But many of the basic issues in considering net benefits tests and cost allocation arise from the fundamentals that the Commission should address. Despite the important role that LMP plays in successful market design, the Commission should not assume that paying LMP is always appropriate.

Special demand response programs provide a means to work around the failure to offer customers dynamic prices that reflect the real costs of electricity. Efficient demand response programs could be approximated in many ways, but these programs would pay full LMP only under certain circumstances. Although it is always seen as politically difficult, an important task is to confront the problem directly and avoid the need for special demand response programs. Smarter pricing, smarter meters, and smarter default options for retail customers would provide better incentives and support the transformation of the electricity sector that are likely to be necessary to meet the challenges of the future.21 The Commission's work under Order 719 on scarcity pricing is important, and should be a high priority in conjunction with promotion of the smart grid.22 ☆ Editors’ Note: Prof. Hogan chose not to respond specifically to the assertions contained in the article in this issue by Jonathan Falk, Paying for Demand-Side Response at the Wholesale Level. Instead, he preferred to offer the following essay as a fair proxy for his thinking on the issues discussed in Mr. Falk's piece. This article is adapted from his remarks prepared for FERC's Technical Conference on Demand Response Compensation in Organized Wholesale Energy Markets (Docket No. RM10-17-000) on Sept. 13, 2010. 1 Federal Energy Regulatory Commission, Demand Response Compensation in Organized Wholesale Energy Markets, Supplemental Notice of Proposed Rulemaking, Docket No. RM10-17-000, Washington DC, Aug. 2, 2010. 2 FERC Supplemental Notice, at 1-2. 3 William W. Hogan, Demand Response Pricing in Organized Wholesale Markets, Prepared for ISO/RTO Council Comments on Demand Response Compensation in Organized Wholesale Energy Markets, Notice of Proposed Rulemaking, Federal Energy Regulatory Commission, Docket No. RM10-17- 000, (IRC), May 13, 2010 (available at www.whogan.com). Also, William W. Hogan, Implications for Consumers of the NOPR's Proposal to Pay the LMP for All Demand Response, Prepared for Electric Power Supply Association Comments on Demand Response Compensation in Organized Wholesale Energy Markets, Notice of Proposed Rulemaking, Federal Energy Regulatory Commission, Docket No. RM10-17-000, (“EPSA II”), May 12, 2010 (available at www.whogan.com). William W. Hogan, Providing Incentives for Efficient Demand Response (“EPSA I”), Oct. 29, 2009, at 4-6, contained in Motion for Leave to Answer and Answer of the Electric Power Supply Association and White Paper by Professor William W. Hogan, Docket No. EL09-68-000, Oct. 30, 2009 (available at www.whogan.com). Charles J. Cicchetti and William Hogan, Including Unbundled Demand-side Options in Electric Utility Bidding Programs, Pub. Util. Fortnightly, June 8, 1989, at 9-20.