Stakeholder Meeting on Supplement to Dynamic Transfers Straw Proposal

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1 Stakeholder Meeting on Supplement to Dynamic Transfers Straw Proposal May 6, :00 AM 4:00 PM, California ISO Presenters: Mark Rothleder Jim Price Kyle Hoffman Don Tretheway

2 Agenda Time Topic Presenter 11:00 11:10 Introduction & Welcome Mercy Parker-Helget 11:10 11:20 Overview Mark Rothleder 11:20 12:15 Market Dispatch & Pricing Jim Price 12:15 1:00 Lunch Provided by ISO 1:00 1:30 Limits of Dynamic Imports Mark Rothleder 1:30 2:00 Management of Requests Mark Rothleder 2:00 2:30 Dynamic exports Kyle Hoffman 2:30 3:00 Aggregation & Generation BAAs Don Tretheway 3:00 3:45 Other Issues Jim Price 3:45 4:00 Next Steps Mark Rothleder Slide 2

3 Stakeholder comments on Straw Proposal helped in further developing issues. Continued inputs will guide Draft Final Proposal. We are here Issue Paper Straw Proposal Draft Final Proposal Board of Governors FERC Implementation Opportunities for Stakeholder Input Slide 3

4 Dynamic Transfers proposed time table provides stakeholder discussion before Board decision Date November 30, 2009 December 7 December 14 March 10, 2010 March 17 March 31 April 29 May 6 May 13 May 20 May 27 June 4 July August 2010 Activity/Milestone Publish Issue Paper Stakeholder Meeting Stakeholder Comments on Issue Paper Straw Proposal from CAISO Stakeholder Meeting at CAISO Stakeholder Comments on Straw Proposal Supplement to Straw Proposal from CAISO Stakeholder Meeting at CAISO Stakeholder Comments Due on Supplement Draft Final Proposal from CAISO Stakeholder Meeting at CAISO Stakeholder Comments Due on Draft Final Proposal Board Of Governors Decision FERC Filing Slide 4

5 Supplement adds detail to certain topics in Straw Proposal Straw Proposal clarifies ISO tariff supporting dynamic imports, facilitates imports of renewable resources, and adds pseudo-tie imports to tariff Proposals apply to both dynamic scheduling and pseudo-ties Few exceptions: allocation of dynamic schedules deviations, pseudo-tie layoffs Issues addressed in Straw Proposal: Congestion management and curtailment rules, Dispatchability requirements, Transmission reservations, including data and forecasting requirements Locational modeling and pricing Aggregation of conventional and/or renewable resources Scope of studies of intertie transfer limits for dynamic imports Pro rata allocation of deviations among BAAs Layoffs from pseudo-ties Expansion of dynamic transfers to dynamic exports Generator-only BAAs Slide 5

6 Supplement refines proposal for compliance with Market Dispatch and Pricing Issues of congestion management in ISO markets: Curtailment rules Dispatchability requirements Transmission reservations and utilization Data and forecasting requirements Locational modeling and pricing Additional analysis in Supplement to Straw Proposal: Appropriate setting and use of tolerance band on uninstructed deviations Meaningful compliance mechanism: compliance with operating orders Slide 6

7 Review: Current ISO tariff states performance requirements for uninstructed deviations Existing Dynamic Scheduling Agreement requires compliance with ISO s dispatches Section 5.1: Except for emergencies, real-time energy transfers may not vary from the day-ahead schedule adjusted by dispatch by more than the greater of 5 MW or 3% of net dependable capacity (Pmax), integrated across a ten-minute interval. If performance band is exceeded in more than 5% of ten-minute intervals on three successive days, such deviations constitute one event of non-compliance. Section allows ISO to terminate agreement after three instances of non-compliance. Tariff section 37.2 requires compliance with operating orders, & provides financial penalties for non-compliance. Slide 7

8 Review: ISO proposed new option for dynamic transfers of Eligible Intermittent Resources In effort to enable compliance, allow adjustments of dynamically transferred intermittent resources availability within operating hour, for reasons other than priceresponsive dispatches or response as regulating reserve. Dynamic resource would report update of availability to ISO as expected output during 5-minute time intervals for 2-hour forecast period, and ISO would return as dispatch (subject to congestion). In RT market, dynamic resource would schedule expected delivery during HASP operating hour, in RT bid submission (concurrent with HASP submissions). Dynamic resource would also report expected maximum delivery as transmission reservation. Slide 8

9 Analysis of existing intermittent resources variability shows ISO would need broader tolerance band Comments suggest intermittent resources have uncertainty in forecasting output, with existing tolerance band ISO analysis assumed forecasts could only use current output for subsequent interval, and reviewed resulting deviations Result: appears necessary to widen tolerance band to at least 25 MW Number of Deviations Intermittent Resources: Deviations Outside Tolerance Band MW Deviation To Be Within Tolerance Generator A Generator B Generator C Generator D Generator E

10 Analysis of existing dynamic transfers uninstructed deviations also shows need for broader tolerance band Result for intermittent resources raises question of needs for meaningful compliance by conventional dynamic resources ISO analysis compared dispatches and set points with actual delivery, by 10-minute interval during 2009 Result: appears necessary to widen tolerance band to at least 10% of PMax Number of Deviations Existing Dynamic Transfers: Deviations Outside Tolerance Band % Deviation To Be Within Tolerance Dynamic 1 Dynamic 2 Dynamic 3 Dynamic 4 Dynamic 5

11 Instead of relying on tolerance band, ISO will focus on compliance with operating orders Resulting tolerance bands would not represent adequate performance when compliance is critical Meaningful compliance requirements can build on existing tariff section 37.2 now provides financial penalties for non-compliance with operating orders. For dynamic transfers, ISO will use additional actions after three events of non-compliance with operating orders: Require additional equipment or institute other measures to ensure compliance, potentially including direct equipment control, and if needed: Consider contract termination if necessary for compliance

12 References to dynamic schedule tagging and transmission reservations NERC Standard INT R1.1. All Dynamic Schedules at the expected average MW profile for each hour. INT-008-WECC-CRT-1 WR2. The transmission profile of the Dynamic Schedule tag will reflect the maximum amount expected for the scheduling period of transmission this schedule can utilize on any applicable transmission provider s system (source, intermediary(ies), and sink system). WR3. Prior to the operating hour, the Dynamic Schedule will not be a part of the Net Schedule Interchange (NSI) between adjacent Balancing Authorities. Slide 12

13 Scheduling option still allows resource to manage deviations, and ISO to maintain efficient operation Allows ISO to dispatch other resources capable of adjustment to use available transmission: 1. Knowing upcoming changes in dynamic delivery allows efficient dispatch of other resources to meet system requirements, and 2. With at least one dispatchable dynamic transfer on same intertie, ISO can dispatch to use the available intertie capacity Can unused dynamic transfer transmission be re-dispatched in Real-Time? Proposal does not reduce existing scheduling options. Dynamic resources may bid or self-schedule in dayahead, and may update bid or self-schedule in real-time Day-ahead price applies to day-ahead schedule Real-time prices apply to instructed & uninstructed deviations from day-ahead schedule Slide 13

14 Curtailment scenarios illustrate congestion management (Scenario 1) Dynamic resources may bid maximum transmission reservation exceeding average delivery. If flows exceed limits, decrement resources exceeding maximum reservation, then economic bids, before pro rata curtailments. HASP: ATC = 1000 MW Static Firm Schedule = 600 MW Dynamic Schedules expected average = 300 MW Dynamic Schedules maximum reservation = 300 MW Real-Time Dynamic Schedule deviates +10 MW Actual Flow Limit = 1000 MW Actual Flow = 910 MW CAISO Curtailment Action: None: Actual flow does not exceed flow limit Slide 14

15 Curtailment scenarios (Scenario 2) HASP: ATC = 1000 MW Static Firm Schedule = 600 MW Dynamic Schedules expected average = 400 MW Dynamic Schedules maximum reservation = 400 MW Real-Time: Dynamic Schedule deviates +10 MW Actual Flow Limit = 1000 MW Actual Flow = 1010 MW CAISO Curtailment Action: Order Dynamic Schedule to return to 400 MW Economically dispatch combination of other dispatchable dynamics and other effective dispatchable internal resources if available Slide 15

16 Curtailment scenarios (Scenario 3) HASP: ATC = 1000 MW Static Firm Schedule = 600 MW Dynamic Schedules expected average = 300 MW Dynamic Schedules maximum reservation = 400 MW Real-Time Dynamic Schedule deviates +110 MW above expected average Actual Flow Limit = 1000 MW Actual Flow = 1010 MW CAISO Curtailment Action: Order Dynamic Schedule to curtail 10 MW to return below flow limit Economically dispatch combination of other dispatchable dynamics and other effective dispatchable internal resources if available Slide 16

17 Curtailment scenarios (Scenario 4) HASP: ATC = 1000 MW Static Firm Schedule = 600 MW Dynamic Schedules expected average = 300 MW Dynamic Schedules maximum reservation = 300 MW Real-Time Dynamic Schedule deviates 0 MW Actual Flow Limit = 1000 MW Actual Flow = 1010 MW CAISO Curtailment Action: Economically dispatch combination of other dispatchable dynamics and other effective dispatchable internal resources if available Pro-rata curtail 10 MW across all schedules including dynamic, for further mitigation if needed Slide 17

18 Curtailment scenarios (Scenario 5) HASP: ATC = 1000 MW Static Firm Schedule = 600 MW Dynamic Schedules expected average = 300 MW Dynamic Schedules maximum reservation = 400 MW Real-Time Dynamic Schedule deviates +110 MW above expected average Actual Flow Limit = 1000 MW Actual Flow = 1100 MW CAISO Curtailment Action: Order Dynamic Schedule to curtail 10 MW to return below reservation Economically dispatch other dispatchable resources if available Pro-rata cuts for remainder of 100 MW flow reduction across all schedules including dynamics Slide 18

19 Dynamic import study will examine limits on dynamic transfer of variable resources ISO tariff allows the ISO to establish limits to the amount of ancillary services and/or energy imported into the ISO BAA, whether delivered dynamically or statically. Study will determine any limitations on dynamic transfer of variable resources into ISO BAA while shaping and firming energy within the ISO BAA due to: Impacts to existing path limits that accommodate planned hourly variations from 20 minute ramping period Voltage control issues Risk to stability or excitation of low frequency modes of oscillation ISO will coordinate studies with our neighboring BAs Slide 19

20 Limits on dynamic transfers would be within overall intertie limits Total Limit including Static Schedules & Dynamics OTC Dynamic Intermittent Limit Dynamic Resources including: Dispatchable, Intermittent, Joint Ownership Dynamic Intermittent Resources Dynamic Limit Slide 20

21 ISO needs stakeholder input on process for management of requests for dynamic transfers New dynamic imports, combined with existing imports, may test the ISO s import capability Straw Proposal favored reliance on market congestion management, but some comments suggest needs for queuing of requests for dynamic transfers ISO needs further input from stakeholders before it can formulate a robust proposal on these issues

22 ISO proposes to add support for dynamic exports Straw Proposal supports continuation of existing pseudotie export for New Melones Some comments request expanded tariff support for dynamically scheduled exports and pseudo-tie exports The ISO offers New Melones pseudo-tie agreement as a prototype and invites comments, including: Whether additional provisions should apply to dynamic exports, and Whether terms and conditions for New Melones are a workable prototype for other dynamic exports

23 Supplement adds detail on aggregation of electrically close conventional and/or renewable resources Both the native and attaining BAs have roles in approving aggregations. For imports, ISO will use WECC s USF zones, within BAA boundaries. For exports, ISO will use same substation and voltage Slide 23

24 Supplement clarification for generator-only Balancing Authority Areas Case-by-case review of requests for dynamic transfers applies to all requests in developing dynamic scheduling agreement ISO will not duplicate WECC s review of qualification as BAA Review of historical or expected successful management of inadvertent energy and sufficient contingency reserves is as indicators of reliable performance as a dynamic schedule Slide 24

25 Other Issues ISO can support dividing physical generators into multiple dynamic schedules (not pseudo-ties) when clear business need exists Need clear allocation of output between dynamically-schedules Need to separate communications into data streams that appear to the ISO as if the resources are actually separate ISO can allow non-firm transmission for energy schedules No tariff changes to provisions such as obligations for operating reserves ISO would need further demonstration of business needs before supporting: Allowing a fraction of a generator to be a pseudo-tie into the CAISO, while the rest remains in the native BAA Allowing an aggregation to schedule part of its output statically and the remainder is a dynamic schedule

26 Next Steps Thanks for your participation today We look forward to your continued participation and comments: Stakeholder comments on Supplement to Straw Proposal due: May 13 Look for Draft Final Proposal: May 20 Stakeholder meeting: May 27 Stakeholder comments on Draft Final Proposal due: June 4 Schedule leads to July Board meeting and August FERC filing Slide 26