Chris Rauscher, Sunrun's director for Policy & Storage Market Strategy provides prudent suggestions espousing the need for greater integration of DER within wholesale markets. ISO and RTO's are well aware that energy consumers have a desire to secure long term energy through a market based capacity exchange, such as Level Ten and REBA, but there seems to be no desire to incorporate an exchange capability within the ISO business practices, forcing consumers to go "out of market" for a solution. ISO's could easily accommodate consumer desires for clean energy by providing them with a capacity exchange as an alternative to forward capacity markets and FERC has the authority to clear the path for ISO's to offer capacity exchange solutions in support of consumer choice.
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