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Richard Brooks's picture
Co-Founder and Lead Software Engineer, Reliable Energy Analytics LLC

Dick Brooks is the inventor of patent 11,374,961: METHODS FOR VERIFICATION OF SOFTWARE OBJECT AUTHENTICITY AND INTEGRITY and the Software Assurance Guardian™ (SAG ™) Point Man™ (SAG-PM™) software...

  • Member since 2018
  • 1,540 items added with 672,714 views
  • Feb 10, 2021

The challenges presented by FERC Order 2222 are daunting, and it is my belief that no single ISO/RTO can solve all of the challenges themselves, individually. However, there is hope to meeting these challenges, if the industry works together by dividing up the work (divide and conquer) using a national forum to reach a consensus on solutions to these challenges. NAESB has launched an initiative do do just that!

I hope this NAESB initiative will find favor with the parties that need to submit compliance filings with FERC on 7/19/2021. Some of the items that are on NAESB's radar for this work effort include:

  • Address information and data requirements for DER aggregations
  • Address modifications to the list of resources in a DER aggregation

FERC Order 2222 - it takes a village and FERC support such efforts:

As the Commission found in Order No. 587, the adoption of consensus standards is appropriate, because the consensus process helps ensure the reasonableness of the standards by requiring that the standards draw support from a broad spectrum of industry participants representing all segments of the industry. Moreover, since the industry itself must conduct business under these standards, the Commission's regulations should reflect those standards that have the widest possible support. In section 12(d) of the National Technology Transfer and Advancement Act of 1995 (NTT&AA),13 Congress affirmatively requires federal agencies to use technical standards developed by voluntary consensus standards organizations, like NAESB, as means to carry out policy objectives or activities determined by the agencies unless an agency determines that the use of such standards would be inconsistent with applicable law or otherwise impractical.



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