Texas REP Urges PUC To Allow Use Of Demand Response, DERs For Proposed Generation Firming Requirements

Paul Ring | Source: Energy Choice Matters | Posted 09/04/2025

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In comments on a proposed Texas PUC rule concerning firming requirements for generation, Octopus Energy urged the PUC to allow demand response and DERs to serve as eligible resources to meet firming obligations

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In response to a proposed rule by the Texas Public Utility Commission (PUC) regarding firming requirements for electricity generation, Octopus Energy has advocated for the inclusion of demand response and distributed energy resources (DERs) as eligible options to fulfill these obligations. The draft rule currently allows for firming to be met through other electric generating facilities or battery energy storage, whether on-site or off-site.

During a recent workshop, Octopus noted that PUC staff showed openness to incorporating demand response and DERs into the firming requirements, although uncertainties about implementation remain. Octopus emphasized that the ERCOT stakeholder process should be utilized to finalize these details and urged the Commission to adopt policies that recognize facilities capable of providing demand response and aggregate distributed energy resources (ADERs) as valid contributors to meeting the firming requirements.

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Texas REP Urges PUC To Allow Use Of Demand Response, DERs For Proposed Generation Firming Requirements

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