Should localities (counties, cities or towns) be permitted to aggregate their residential load?
Yes. The Commonwealth of Massachusetts had a provision to allow for this in their recent deregulation legislation. MDV-SEIA would support similar language in Virginia. 18. Should localities be permitted to aggregate their residential load on an “opt out” basis? Yes. 19. Should localities be permitted to form inter-locality aggregates? Yes. 20. Should localities be permitted to aggregate load with private entities outside their territorial jurisdiction? MDV-SEIA has no position on this issue at this time. 21. Should localities be permitted to aggregate load with private entities or localities outside of Virginia? MDV-SEIA has no position on this issue at this time. 22. Please identify any other issue(s) falling under this topic you believe are important, and provide comments on that issue. Aggregation is important not only in the overall market, but also in a Renewables Portfolio Standard (RPS) system. Aggregation procedures should be established in such a way that distributed renewable
