By Michael Kuser
The commission partly granted NRG Curtailment Solutions’ July complaint alleging the ISO’s Tariff provisions are unjust because they require curtailment service providers (CSPs) and responsible interface parties (RIPs) seeking to participate in the ICAP market to use the services of meter service providers (MSPs) or meter data service providers (MDSPs) certified by the New York Department of Public Service to install and read non-revenue grade interval meters.
The ruling denied NRG’s request for waiver of the rules, instead convening a paper hearing to determine replacement provisions.
The commission found the rules unduly discriminatory to the extent they require CSPs and RIPs that are not transmission owners to be certified by the DPS, which certifies only entities that also provide metering services for the state’s retail electric market.
“The result, even if not so intended, is that retail market participation is a prerequisite for demand response resource participation in NYISO’s wholesale market,” the commission said. “Indeed, in this proceeding, the New York [Public Service] Commission disavows the role ascribed to it through NYISO’s requirements and explicitly states that its certification program was designed to facilitate retail billing service, not for participation in wholesale markets or for measuring load reductions.”
FERC noted the PSC “has issued a notice proposing to eliminate the state MSP and MDSP programs and the certifications related to these programs.”
The PSC filed comments in favor of granting NRG the relief it sought, saying “the future of competitive metering services is presently in question in New York. Upon information and belief, there are no known utility customers today who avail themselves of competitive metering services, nor have there been for some time.”
NYISO answered NRG’s complaint Aug. 13 and filed a supplemental answer Oct. 22, saying it is examining its metering requirements as part of its broader DER Roadmap. But FERC found the current metering requirements “in need of immediate remedy.”
The commission established a paper hearing with initial briefs due within 45 days of the order and reply briefs due within 30 days thereafter. It ordered parties participating in the hearing to address the following issues:
What metering requirements could be implemented in NYISO, would not be unduly discriminatory and yet would effectively evaluate, measure and verify customer meter data?
How would such metering requirements address the verification of meter data and auditing of metering service providers?
How would such metering service eligibility criteria ensure that metering services are available to customers in all geographic areas of NYISO?
Would such metering requirements allow self-certification for DR providers in NYISO? If not, please explain why.
FERC said it expects to be able to render a decision within four months of receiving reply briefs, or by May 31, 2019.