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NRG Suggests Requiring That Default Service Suppliers Procure Capacity From Smart Thermostats Or DERs As Part Of Resource Adequacy Solution

November 22, 2024

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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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As one of the means to address resource adequacy concerns, the Maryland PSC should consider requiring wholesale default service electricity suppliers in Maryland to bilaterally procure capacity from smart thermostat customers and distributed energy resources, a witness for NRG Energy said in pre-filed testimony in advance of a PSC technical conference on resource adequacy

NRG Energy said that the PSC should enable the offering of smart thermostats by retail electric suppliers, including by making such retail suppliers' offering of smart thermostats to customers eligible for utility subsidies for smart thermostat installation.

NRG pointed to programs approved in Ohio that allow retail suppliers to receive subsidies for the provision of smart thermostats to customers (such programs were approved at AEP Ohio [details here]and at the FirstEnergy EDCs; though one of the FirstEnergy EDCs' programs will apparently not move forward due to the FirstEnergy EDCs' withdrawal of their ESP, though a separate FirstEnergy Ohio smart thermostat program open to retail suppliers remains pending in a separate grid mod proceeding)

NRG noted that, under the AEP Ohio program, retail suppliers will have control over the smart thermostats and may aggregate the smart thermostats into the PJM capacity market as demand response

NRG said that Maryland should adopt this framework

NRG observed that having 10% of the residential load at the four Maryland IOUs and SMECO enrolled in a smart thermostat control program would constitute 271 MWs of capacity

Furthermore, NRG said that the PSC should consider mandating that SOS suppliers must procure bilaterally capacity from smart thermostats or other distributed energy resources

NRG averred that, as wholesale SOS suppliers (in their SOS supply role) do not have retail customer relationships, such a mandate would engender "side agreements" for the required smart thermostat and DER capacity between SOS suppliers and third parties who have customer relationships

NRG in its comments affirmed that it hopes to expand its recently announced VPP strategy, in partnership with RenewHome and Google Cloud, outside of Texas

NRG said that the VPP was initially launched in Texas, "due to the value its energy-only wholesale market conveys to demand-side resources[.]"

NRG also proposed mandating that the default SOS rates be a time of use rate, for all customer classes, with the ability of customers to opt-out of the default TOU SOS

Citing data from prior TOU pilots in Maryland, NRG said that if 83% of residential SOS load at the four IOUs was on a TOU rate, capacity needs would be expected to fall by 436 MWs, with NRG noting that this is based on the "low end" of observed results from TOU-prompted load changes in the pilots

PC66

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