Market Design is necessary and valuable. And the proposed SMD takes a very aggressive, non-prescriptive approach to demand response, which we as an industry, applaud. To FERC's credit, the overall approach is also market-based.
FERC's Notice of Proposed Rulemaking provides a good framework for incorporating demand response as an integral part of its SMD. Power companies and their affiliated energy service providers will find that many of their goals for demand response are supported in the proposed SMD. As FERC moves forward with its comment period, the key issues will revolve around the role of the Independent Transmission Provider, subsidies, cost recovery, and coordination among the states within regions.
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