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March 2, 2018
NEM Upcoming Events

NEM’s 21st Annual National Restructuring Conference will be held April 30 – May 2, 2018, at the Hyatt Regency Capitol Hill Hotel, Washington, DC. An agenda is forthcoming. You may register at this hotlink.

Click here to view all past updates.
Governor's Committee on Energy Choice

The agenda for the March 7th meeting of the Governor's Committee on Energy Choice has been released. Speakers and topics of the meeting will include: former FERC Commissioner Marc Spitzer will discuss federal energy policy implementation for restructured and deregulated markets; the National Conference of State Legislators will discuss model state legislation for restructured energy markets; leaders of Technical Working Groups of the Committee will provide reports and recommendations; and Committee Staff will provide an update on the Public Utilities Commission's investigatory docket on the energy choice initiative. The meeting begins at 12PM PST. The full text of the Agenda is available on the NEM Website.

Click here to view all past updates.
Natural Gas Technical Conference

The Commission will convene a natural gas technical conference on March 29, 2018, at its Harrisburg office pertaining to prior proposals on accelerated switching as well as utility business practices, including capacity release, penalties and imbalance trading. Multiple commenting parties to the proposals requested a technical conference to discuss the proposals.

The following key topic areas have been identified for discussion:

"Accelerating NGS Switching
1. Gas Nomination Process/wholesale market FERC rules. Procedures that place NGDCs in the middle of transactions between NGSs potentially violate FERC "shipper must have title" rules?
2. Impact on demand curves, capacity assignment, pricing, etc. Need for daily changes?
3. The use of estimated and customer-supplied meter reads.
4. Different standards/timeframes for different NGDCs? Different rate classes?
5. To what extent are technical concerns alleviated if limitations are imposed (i.e., one switch per billing cycle)?

Capacity Assignment
1. PTC impacts/presentation.
2. Experience in other states (New York, Virginia).
3. Does this shift competition (i.e., removes capacity from competition)?
4. Suppliers benefiting from capacity they didn't pay for/double dipping if the NGDC sells capacity?
5. Auditing issue - PGC/GCR true-up problems.
6. Potential FERC problems - must pay for capacity.

Virtual Access
1. "Slice of the pie" concept:
a. How to handle the limitations or are NGDCs' workarounds good enough?
b. Capacity should be able to serve the customer it's released for.
2. Virtualization is a "step backwards"?
3. Virtualization reduces the value of the asset?

Daily Imbalance Trading
1. What technological features are needed to make this work like an electronic bulletin board?
2. Is upstream trading sufficient or do we need some on the NGDC system?
3. Is lack of communication the bigger issue here?
4. Introduces a reliability risk rather than a benefit?
5. Impact to interruptible customers and other rate classes.

Penalties - During non-emergency conditions
1. Market Based versus flat fee.
a. At what fee level and does there have to be a minimum level?
b. Should there be safe harbors when it benefits the system?
c. Tier approach based upon?
2. Can it be pegged to a local hub for each NGDC? Multiple hubs for different areas, etc.? Some NGDCs have widely scattered service territories.
3. Interruptible constraints and problems.
4. Impact of tolerance bands within a penalty structure."

RSVPs for the event are due by March 14, 2018, to The full text of the Secretarial Letter is available on the NEM Website.

Click here to view all past updates.
Commission Approves Customer Petition to Aggregate Demand

The Commission, for the first time, considered and approved a nonresidential customer's petition to aggregate demand. Specifically, Reynolds Group Holdings sought to aggregate demand of three of its subsidiaries at six locations in Dominion's service territory. Virginia law restricts shopping for electricity to large customers with demand exceeding five megawatts. However, customers whose individual demand during the most recent calendar year did not exceed five megawatts may petition to aggregate their demands. Reynolds' aggregated demand met the standard. The impacts of granting Reynolds petition were deemed to be de minimis. The Commission found that neither the utility or its non-shopping customers "will be adversely affected in a manner contrary to the public interest by granting such petition." The Commission imposed an annual reporting requirement on Reynolds, including the names of the aggregating customers, each customer's most recent individual demand and the most recent combined demand of the aggregating customers. The full text of the Order is available on the NEM Website.

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