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Comments on Petition for Declaratory Order of New England Ratepayers Association Concerning Unlawful Pricing of Certain Wholesale Sales

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June 15, 2020
Charles Cicchetti and Jon Wellinghoff
Federal Energy Regulatory Commission

Charles Cicchetti coauthored comments responding to the New England Ratepayers Association's petition to the Federal Energy Regulatory Commission. The comments discuss whether state regulators should retain jurisdiction over retail tariffs that structure a banking relationship of retail credits rather than a sale of distributed energy resources and net energy metering (NEM).

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