FERC may make older cities a boat load of money

FERC -2222 has very vague provisions for allowing energy efficiency (EE) to be bid into the market. 

One plausible scenario that FERC will have to address is removal of old buildings.

Cities are constantly knocking down old homes and other old buildings that drew power from the grid. Technically under the vague definitions in FERC-2222 on EE each building torn down is an EE possibility. 

Let’s take Detroit that has knocked down over 10,000 buildings. And will knock down more than 7,000 more in 2022-3.

At roughly 3KW each, those building removal is 21 MW of permanent removal (some factories may offer 10-20MW each). 

Should FERC allow those knock downs to count as EE? How long should that EE aggregation be allowed for (1,000 years?), is it just capacity or should phantom load profiles be created for each knocked down house and bid in hourly?

FERC -2222 has a lot of work ahead to deal with this and dozens of other scenarios.

Your thoughts are welcome – OBTW this is a piece of my DistribuTECH presentation.