IESO Stakeholder Feedback for Demand Response Auction November Demand Response Auction Review/ Summary of October 20 Meeting

Transcription

1 IESO Stakeholder Feedback for Demand Response Auction November Demand Response Auction Review/ Summary of October 20 Meeting 1. Capacity Qualification (Slide 5) IESO CCAP = Claimed Capacity MW Floor CCAP = Average Peak Load Load Where: Average Peak Load is the participant s average load over historic system peak hours Question: Will the IESO evaluate "historic system peak hours" based on individual zone requirements Question: Would the IESO consider system limitations for minimum Demand Response in a specific zone? For example the downtown core of the City of Toronto (Or other large Urban centers) 2. Forward Period: (Slide 10) Proposal: Minimum Forward Period of 3 months (shorter term) up to 6 months (longer term) Recommendation: The City proposes minimum 1 year forward period for the DR Auction to enable new DR loads 3. Additional Questions: (Slide 23) IESO Response: DR Capacity to be auctioned within the province will not be specifically assigned to zones. Instead, there could be locational limitations, ie the amount of DR that a region is able to accept. This would be identified and shared with participants in the pre-auction report issued prior to the qualification period. Question: Can the IESO provide additional information on the methods and/or reports that are being developed for the locational limitations and minimums? Commitment Period Options 1. IESO Question Feedback (Slide 13) How does the Choice of Commitment Period impact your participation Question: Can the IESO provide participants with a report forecasting the DR availability requirements?

2 Question: Can the IESO provide clarifications on the daily hours for DR availbaility? Comment: To properly respond to this it would be beneficial to first define the hours of availability. For example some resources may be available from 12-6 all year around while other resources may have a summer peak from 2-8. Providing clarification will enable us to verify businesses cases and recommend a Commitment Period Option. Recommendation: Based on the information available, the City recommends that the IESO proceed with an annual commitment period using the "Capacity Based DR MW Profile" (Shown graphically on Slide 5). Comment: For example December, 2013 Ice storm demonstrated that weather patterns continue to change and may affect the power system all year round. Maximizing the available Demand Response resources to include the winter months would benefit the system. Furthermore winter weather has created a challenge for power system reliability in many jurisdictions including: City of Toronto: December 2013 Quebec: January, Newfoundland : January 5-6, 2014, March 3, 2014 ( 2. Question: Will the IESO allow a participant to substitute one load for an alternate load from a participant's portfolio of sites to allow for seasonal changes in demand? Delivery into the Market 1. IESO Participation (Slide 3) Cleared DR Auction offers will participate in the energy market as either: Demand Response Market Participant DR facility reducing load consumption in hourly blocks measured by baseline Wholesale Consumer - Dispatchable Load Varying load consumption as a dispatchable load in 5-minute intervals measured by revenue meter Question: Does the dispatchable load include "regulation services" such as Enbala? Question: Can the IESO provide clarification on the Dispatchable load program including how this program will differ from the existing Dispatchable load program.

3 Question : Will the IESO activate Demand Response for consecutive hours? If yes will there be a daily maximum? As an example a load was dispatched from 12-3, this load was then offered again from 4-9; will the participant have the opportunity to amend the offer? Question: Will the IESO activate dispatchable loads for consecutive 5 minutes periods? If yes, will there be a daily maximum? As an example a load was dispatched 5 times in the morning; will the participant have the opportunity to amend the afternoon offers? Question: Will the IESO program design include a cap for maximum annual DR activation. 2. Supply and Demand ( Slide4) Question: Can the IESO provide an example of who will be bidding and how the how the bids and offers will create the market clearing price? 3. Delivery (Slide 5) "The Dispatchable Load or DR Market Participant will submit bid prices and associated quantities Bid price represents the maximum price the participant is willing to pay for energy Bid quantity represents the amount of energy the participant is willing to consume at a specified price" Question: Can the IESO provide clarification on the terms "bids and offers" from Slide 4 and Slide 5, Will DR participants be offering as supply into the auction or bidding as demand? Question: Can the IESO provide a definition of the terminology "bids and offers", 4. Delivery (Slide 5) Bid price represents the maximum price the participant is willing to pay for energy Question: Will a DR participant be required to consume and pay for energy at the market price? 5. Bid Economics (Slide 6) IESO is proposing the benefit of activation in energy market is avoidance of energy cost without a utilization payment" Comment 1: Recognizing that many Demand Response loads may contribute through a stand by generator, will the IESO consider a utilization payment to offset Operation Maintenance & Administration costs.

4 Real Time Energy Market (Slide 9) 6. Question: Can the IESO provide clarification on how the Real Time Energy Market will function 7. Availability Period (Slide10) The availability period is the window of time during a day that participants with DR Capacity obligations must be available to reduce consumption or face availability payment set-offs and/or other compliance measures Question: Can the IESO provide participants with a report forecasting the DR availability requirements? Recommendation: The City recommends that the IESO consider a region or zone based hours of availability to meet a specific zone s power requirements for Demand Response. This should include an evaluation of minimal system needs based on: Short Circuit Capacity Distribution System Limitations Transmission limitations. Overall Demand by Region 8. IESO Question Page 12: Does the Time of Year impact your hours of availability? Response: With some exceptions, most of our facilities have limited variation in hours of availability based on the time of year 9. IESO Question Page 12: How does the choice of hours impact your participation in the DR Auction? Comment: Requiring Demand Response to maintain availability during early morning or evening hours may limit some resources from meeting Demand Response requirements Recommendation: The City recommends that the IESO consider the benefits of allowing a participant to maintaining the existing OPA options for availability (As shown below) Table 2 Hours of Availability Season Date Range or Month Hours of Availability (Business Days Only) All Seasons All Months 12 noon to 6pm Designated Settlement Area(s)

5 OR Season Date Range or Month Hours of Availability (Business Days Only) 4:00pm to 9:00pm 12:00pm to 9:00pm 4:00pm to 9:00pm Designated (s) Winter December 1 to March 31 Summer June 1 to September 30 Shoulder April, May, October, November Response/Demand-Response-3/Relevant-Documents-(1)/Revised-DR3-Program- Operational-Information-and-Rates_ pdf.aspx Performance Standards from the DR Auction Commitment Period-Availability (Slide #3): Question: Should global adjustment curtailment (impact on baseline) related "inavailability" be excluded from non compliance? Commitment Period - Availability (Slide 4) 1. Question Would the IESO allow participant one or two planned outages due to shutdown maintenance? 2. Recommendation: The City recommends that the IESO accept substitution for Qualified Capacity from a different resource from the participant's portfolio as an acceptable method for avoiding penalties? 3. Recommendation: The City recommends that the IESO create a variance account structure whereby a participant will be compensated for exceeding the committed capacity up to a maximum. 4. Comment: The City recommends that the IESO consider a policy that would mitigate market power of an entity offering a speculative below market rate to secure a large DR MW capacity. Commitment Period - Activation (Slide#6):" All market participants are obliged to follow dispatch instructions, as detailed in Section 7.5 of Chapter 7 of the IESO Market Rules"

6 5. Question: Can the IESO provide a link where participants can find Section 7.5 of Chapter 7 IESO rules? 6. Commitment Period Testing (Slide#7): Participants with DR capacity obligations are also subject to random activation testing 7. Question: How many random tests are proposed? Having frequent testing will interrupt operations 8. Question: Will the IESO dispatch the random tests directly to contributors or through aggregators? (Slide 3): "Will offer Buy Down capability to participants with DR capacity obligations to exit their obligation prior to the end of the commitment period" (Slide 4)"Non-compliance with availability obligation would result in availability payment set-offs and repeated non-compliance would result in termination and/or penalties" (Slide8)"Penalties for not providing required data for operation and settlement could include: Penalty charges Withholding payments until administrative requirements satisfied" 9. Question: How do proposed payment set-offs, buy down ( non-compliance ) and penalties ( administration) differ from existing program penalties? 10. Question: How will noncompliance of aggregators affect their contributors?