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Independent regulatory commissions

Public Service Electric and Gas Company Submits Comments to Federal Energy Regulatory Commission on Demand Response Programs

Strategic Insights

— 2 min read

Public Service Electric and Gas Company (PSE&G) has submitted comments to the Federal Energy Regulatory Commission (FERC) in response to a complaint filed by Voltus, Inc. and Mission:data Coalition against PJM Interconnection, L.L.C. The complaint alleges that PJM's Open Access Transmission Tariff is unjust, unreasonable, and unduly discriminatory because curtailment service providers (CSPs) cannot obtain the customer meter data needed to enable participation in PJM's demand response programs. PSE&G's comments do not take a position on the merits of the complaint but aim to provide additional context on New Jersey's regulatory framework governing electric distribution companies' (EDCs) handling of customer usage data, including Advanced Metering Infrastructure (AMI) data.

Key Takeaways:

  • PSE&G is an EDC regulated by the New Jersey Board of Public Utilities (NJBPU) and is bound by state regulations requiring confidentiality of customer information.
  • New Jersey state regulations, including N.J.A.C. 14:4-7.8, prohibit EDCs from disclosing, selling, or transferring customer information to a third party without the customer's explicit consent.
  • PSE&G does not impede access to data but has acted within the boundaries of existing state regulations, which limit data disclosure but ensure protection of customer information.
  • The Complainants identified EDC practices in several states as hinderances to third-party access to customer data, but PSE&G's data access practices reflect compliance with existing New Jersey privacy and data sharing regulations.
  • PSE&G is actively participating in the NJBPU's ongoing process to establish statewide AMI data-access standards and will implement any future data-sharing mechanisms consistent with the finalized rules.
  • The circumstances described in the Complaint represent the type of necessary coordination that the Commission anticipated in Order No. 2222, rather than an indication of any deficiency in existing EDC practices.

Statistics:

  • 172 FERC P 61,247 (2021): Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators (FERC Order No. 2222).
  • 182 FERC P 61,143 (2023): PJM Interconnection, L.L.C. (FERC Order).
  • 25/10/2025: Date the submission was made to the Federal Energy Regulatory Commission.

Sources:

  • Complaint of Voltus, Inc. and Mission:data Coalition, Docket No. EL26-4-000.
  • Proposed rule N.J.A.C. 14:5-10 (New Jersey Board of Public Utilities).
  • Order No. 2222 (FERC, 2021).
  • PJM Interconnection, L.L.C. (FERC, 2023).
  • N.J.A.C. 14:4-7.8 (New Jersey Board of Public Utilities).
  • United States of America before the Federal Energy Regulatory Commission (Voltus, Inc. and Mission:data Coalition v. PJM Interconnection, L.L.C., Docket No. EL26-4-000).

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