Load Granularity Refinements. Pricing Study Description and Implementation Costs Information Request

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1 Pricing Study Description and Implementation Costs Information Request October 28, 2014

2 Table of Contents I. Introduction... 3 II. Background... 3 III. Stakeholder Process and Next Steps... 4 IV. Pricing Study Description... 5 Data... 5 Analysis... 8 V. Potential Alternative Disaggregation Levels to Consider... 8 Existing DLAPs... 9 Full Nodal... 9 Custom Load Serving Entity-Specific LAPs... 9 Slight Disaggregation... 9 Load Aggregation to Minimize Error... 9 VI. Information Request: Implementation Cost Estimates CAISO/M&ID/M&IP 2 October 28, 2014

3 I. Introduction The California Independent System Operator ( ISO ) posted an issue paper on load granularity refinements on September 22, 2014, and hosted a stakeholder meeting on this issue on September 29, The paper and meeting presented a proposal for a study of the pricing dispersion between the individual demand nodes and the current default load aggregation points ( DLAPs ) used for bidding and pricing of load. The paper also requested stakeholders to provide in their comments descriptions of the types of costs they anticipate they would incur if the level of load disaggregation was increased from the existing four DLAPs. Stakeholders submitted their comments on October 13, This paper first outlines the final structure of the pricing study, which reflects the comments received from stakeholders. It also contains an information request on implementation costs, in the form of a matrix, asking stakeholders to provide cost estimates for potentially moving to several different potential levels of increased load disaggregation. II. Background The design of the ISO markets using locational marginal prices ( LMP ) as approved in FERC s September 21, 2006 order on Market Redesign and Technology Update ( MRTU ) included the bidding, scheduling and settlement of most internal load at three default DLAPs corresponding to the service territories of the three investor owned utilities ( IOUs ) 1. While the Federal Energy Regulatory Commission ( FERC ) approved the structure, it directed the ISO to increase the numbers of load aggregation point ( LAP ) zones in Release 2. In 2010, the ISO initiated a stakeholder process to evaluate LAP disaggregation. The ISO conducted a pricing study, which found that with the exception of one small area prices in sub-lap regions did not differ significantly from the DLAPs. The Market Surveillance Committee ( MSC ) did a spatial pricing study showing that short of nodal pricing, there was no efficient way to group nodes in large zones. Stakeholders indicated that they would face significant implementation hurdles and that many potential benefits were already available to them through other ISO processes, or would be soon. FERC accepted the ISO s request to delay disaggregation of LAPs: We find that more pricing information and additional experience with the MRTU design changes, such as proxy demand response and convergence bidding will allow CAISO to develop a proposal to further disaggregate the default LAPs, as directed. 2 FERC extended the deadline to disaggregate LAPs until October 1, In 2013, the ISO initiated a stakeholder process to again evaluate with stakeholders disaggregation of the existing LAPs. The ISO performed a simple pricing analysis comparing prices in the existing sub-laps to the DLAPs, which indicated that there were no major price disparities. Based on this information, and stakeholder input indicating that they did not see enough price disparity and they would incur 1 The ISO current has four DLAPs. When the Valley Electric Association ( VEA ) joined the ISO, a separate DLAP was created for load in the VEA service area. 2 Cal. Indep. Sys. Operator Corp., 136 FERC 61,055, at P 6 (2011). CAISO/M&ID/M&IP 3 October 28, 2014

4 substantial costs from disaggregating the DLAPs, the ISO filed a motion for a permanent waiver of FERC s directive to disaggregate to the LAPs. On June 3, 2014, FERC issued an order that denied the ISO s request for a permanent waiver to complying with FERC s previous orders to disaggregate existing LAPs. 3 The order extended for one year from the date of the order the time for the ISO to comply, or seek further relief from the disaggregation request. III. Stakeholder Process and Next Steps The ISO will host a conference call with stakeholders on November 6, 2014 to allow stakeholders to ask questions or comment on the final pricing study design, and to ask any questions about the information request on implementation cost estimates. Stakeholder responses to the information request should be sent to the ISO by November 20, The next phase of stakeholder engagement will begin in December 2014 when the pricing study results and the draft cost benefit analysis based on the pricing study results and cost estimates from the ISO and stakeholders are posted. The ISO also hopes to include in the December 2014 paper a draft proposal, or potentially draft proposals, for addressing the FERC requirements concerning load disaggregation. Due to the requirement for a filing at FERC by June 2015, the schedule below shows one round of stakeholder meeting and comments before the final proposal, but the ISO is aware of stakeholders concerns that this may not provide sufficient opportunities for stakeholders to fully comment and will adjust the schedule to include additional opportunities for stakeholder input if it becomes necessary. The end result of this next phase of the stakeholder process will be a recommendation to the ISO Board of Governors on whether to propose disaggregation of load and to what level, or to seek a ruling that the existing DLAP structure is just and reasonable. The schedule for stakeholder engagement is listed below. Date August 22, 2014 September 22 September 29 October 13 October 28 November 6 November 7 Milestone Discussed topic at August 22 MSC meeting Post issue paper Hold stakeholder meeting Receive written comments from stakeholders Post paper on how pricing study will be done and request implementation cost estimates data Conference call on pricing study design and request for implementation cost data Begin pricing study 3 Cal. Indep. Sys. Operator Corp., 147 FERC 61,181 (2014). CAISO/M&ID/M&IP 4 October 28, 2014

5 Date November 20 November 21 December January 2015 January February February & March March June 3, 2015 Milestone Implementation cost estimates data due from stakeholders Begin costs/benefits study Post pricing and costs/benefits studies results, and draft proposal for how to proceed Hold stakeholder meeting Receive stakeholder comments Work with MSC to obtain Opinion Prepare ISO documents to present to ISO Board Request approval at Board meeting File at FERC IV. Pricing Study Description The FERC order earlier this year, which rejected the ISO s waiver request, provided clear guidance about what any pricing study used to support a new request to disaggregate the existing DLAPs or demonstrate that the existing DLAPs were just and reasonable must include: Detailed description of underlying data; Analysis of a reasonable range of different alternate levels of disaggregation; Focused discussions on areas with large price differences; Properly supported estimates of implementation costs for the different levels of disaggregation; and Analysis of the entire ISO footprint, including the San Diego Gas and Electric Company ( SDG&E ) service territory. The ISO s proposed pricing study structure outlined in the September 22, 2014 issue paper was designed to address these suggestions. Stakeholders were generally supportive of the ISO s proposed design, but did offer suggestions which have been considered and added to the study when appropriate. The first section below describes the data to be used in the pricing study. The next section describes what analysis will be performed. Data The first step in designing the pricing study is to consider the data that will be studied. Stakeholders agreed with the ISO proposals to use nodal price data from the day-ahead market for the entire MRTU period. They also agreed with the ISO proposals for other factors that should be taken into account in the study. CAISO/M&ID/M&IP 5 October 28, 2014

6 Nodal Prices The pricing study will examine pricing data at the nodal level. It is impossible to avoid this, since to consider any potential level of disaggregation other than the existing DLAPs or the current sub-laps ( SLAPs ) would require the nodal pricing data to construct the SLAPs. The 2013 study using the SLAPs and DLAPs was deemed not sufficient by FERC, and to examine pricing dispersion in the SDG&E area requires the use of nodal data since the existing SLAP is the same as the DLAP. FERC also provided guidance that any study of load granularity should provide an analysis of a reasonable range of different alternative levels of disaggregation. Day-Ahead Prices The pricing study will focus on the hourly prices from the Integrated Forward Market ( IFM ), which runs the day before the trading day. Potential changes in load granularity will have the largest impact on markets in the IFM. The IFM clears the vast majority of all energy in the ISO markets so the impact on overall costs will be larger in the IFM. It is only in the IFM that load can submit price sensitive bids, which has two impacts. First, unlike real-time markets where the forecast load must clear, price sensitive demand bids can result in different amounts of load clearing in the day-ahead process. In order for a demand bid to be used in the optimization it must be spread to all load nodes; this is done through the use of load distribution factors ( LDFs ). The use of any LDFs in real-time is not as important since the load estimates are influenced by the actual loads from the state estimator, which means that the changing load bidding and pricing granularity should have a larger impact in the dayahead market. Some stakeholders suggested that studying the real-time market as well as the day-ahead might be useful. For example the State Water Project agrees that the day-ahead market is a good starting point, but points out that the real-time market prices might also contain useful information due to the volatility and importance of demand response. The ISO agrees, but timing and resource constraints may limit the ability to analyze the price dispersion of real-time prices, especially since there are four fifteen minute market ( FMM ) prices and 12 real-time dispatch ( RTD ) prices in every hour, so the data requirements would be 16 times greater. If time and resources permit, the ISO may provide some results for real-time markets. Use Entire MRTU Period The pricing study will examine data from the entire period since the start of the LMP markets. Stakeholders indicated their support for using the entire data set. Using the largest data set possible will improve the robustness of the results and minimize the chance of random anomalous data points influencing the results. It will also allow for comparisons to the previous studies which used data from the first 16 months for the 2010 studies and data from January 2011 through mid-2013 for the 2013 study. The use of such a long period of time for the pricing study allows for the analysis of and requires the inclusion in the study of changes in the electric grid and market structure which have occurred over CAISO/M&ID/M&IP 6 October 28, 2014

7 time. An important aspect of this study is to determine how stable the price dispersion results are over time, and to establish guidelines for forecasting what may cause changes in the future. Several stakeholders commented on the importance of recognizing that the results of the pricing study will be based on the historical grid, and that any implications going forward must also use information such as transmission expansion plans. There have been considerable changes in the ISO markets and grid since the LMP pricing structure approved as MRTU was implemented in Stakeholder comments suggested numerous changes that might impact the level, nature or location of price dispersion. These include: Market design changes o Virtual bidding o Minimum online commitment constraint o Fifteen minute market o Flexible ramping constraint o Introduction of Proxy Demand Resources Extreme hydrological conditions Significant economic events Changes in grid o Addition of significant transmission o Changes in generation, such as the San Onofre Nuclear Generating Station ( SONGS ) retirement or increase in renewable generation in areas which previously had little generation o Increase in distributed generation The ISO will include these suggestions in the pricing study. Additional Considerations for Study Stakeholders were also in agreement with the ISO proposal to account for potential on-peak and offpeak differences in price dispersion, as well as seasonal differences. The past studies indicate that the price dispersion was greater during the on-peak periods, because during the on-peak period the likelihood of congestion occurring is far greater. Seasonal differences may impact the typical level of price dispersion, since some seasons may see more expected congestion than others. Seasonal differences may also change the geographic dispersion of prices; especially with the increasing number of renewable resources, which tend to be clustered in specific areas, and for which seasonal weather variations may have a large impact on the energy produced, or the timing of the energy. CAISO/M&ID/M&IP 7 October 28, 2014

8 Analysis The pricing study will start with the nodal prices and the SLAP and DLAP prices and construct summary statistics for the prices and deviations from the SLAP and DLAP prices. The study will also use the structure of the 2010 MSC study 4 of pricing dispersion. This analysis will regress the hourly nodal prices on the DLAP price it is included in, using a simple regression: Where: P(I,h,k) = α j + β j *PLAP(h,k) + ε j P(I,h,k) = price at node I in LAP k during hour h PLAP(h,k) = DLAP price for LAP k during hour h If the expected value of the nodal price is the same as the expected value of the DLAP price, then α j =0 and β j =1. An examination of the results from the regressions will provide information on which nodes differ significantly from DLAP price. The size of the data set for each nodal price, over five years of data with 8760 hourly prices in each year, allows for the use of dummy variables to investigate the potential impacts of the market design or infrastructure changes that have occurred over time, as well as onpeak/off-peak and season differences. Similar to what the MSC did in 2010, the pricing study will examine the spatial dispersion of the mean nodal pricing deviations from the DLAP price, as well as the spatial dispersion of the constant and coefficient from the regressions. After the initial results are developed, the results will be used to determine more specific descriptions of the potential different alternatives for load disaggregation. These were proposed in the issue paper and are described in more detail in the following section. The spatial analysis of the price dispersion will provide the information required to determine in detail the two intermediate cases, the slight disaggregation and load aggregation to minimize error. V. Potential Alternative Disaggregation Levels to Consider The FERC 2014 order on the ISO s waiver request indicates that the future ISO filing must include an analysis of a reasonable range of different alternative levels of disaggregation. FERC further provides, in a footnote: For example, the study could include results using the current LAPs in comparison with aggregation using sub-lap groupings, sub-laps on their own, or a more granular level including individual nodes. In the September 22, 2014 issue paper, the ISO proposed to consider as bookends the existing DLAPs and fully nodal pricing. The ISO also proposed two intermediate, conceptual levels of possible load 4 The MSC presentation is available at: MSCPresentation.pdf CAISO/M&ID/M&IP 8 October 28, 2014

9 aggregation. The exact construction of these two conceptual levels will be developed using the results of the pricing study. Stakeholders generally agreed with the ISO that these four alternatives meet FERC s requirement of a reasonable range of different alternative levels of disaggregation. The next section of this paper, which is an information request on implementation costs stakeholders expect, also makes use of these alternate levels of load aggregation by requesting stakeholders identify how implementation costs will differ for the different potential levels of disaggregation. Existing DLAPs The base case for all comparisons is the current DLAP structure. Full Nodal The other bookend of possibilities is fully nodal load pricing. The study by the MSC in 2010 indicated that there was not any locational grouping other than nodal that made sense. For the implementation cost information request stakeholders are asked to consider implementation of full nodal pricing and bidding and settlement of load at the full nodal level using every applicable nodal price. Custom Load Serving Entity-Specific LAPs Another possibility is using custom load serving entity ( LSE )-specific LAPs. Under this approach, bidding and settlement would be at an aggregate level with the ISO continuing to use load distribution factors to allocate the load to various nodes, and with settlements done utilizing a single price for each LSE, but with the price constructed specifically to allow use of a price for each LSE as the weighted average of the nodal prices, with the weights being the LSE s load at each node. Slight Disaggregation An intermediate alternative level of aggregation would be to minimally increase the number of LAPs, perhaps from the current four to six, seven, or some other relatively low number. This would allow for each of the large DLAPs to be split into more homogeneous pricing areas, without significantly increasing the complexity for load serving entities. Load Aggregation to Minimize Error FERC suggested that the ISO might consider the existing SLAPs as a potential disaggregation level. However, the ISO does not believe the existing SLAPs would be the best possibility. The current SLAPs were developed several years ago during the development of the LMP market to provide a method for reporting the results of pricing studies. They were based on the Reliability Must Run ( RMR ) regions and historical congestion conditions. Since their development, the topology of the ISO grid has changed substantially as new generation and transmission have come on line and some existing generation has retired. The amount of RMR resources on the grid has also been reduced as resource adequacy has expanded to include local resource adequacy resources. These local resource adequacy areas differ from the RMR regions. Thus, the existing SLAPs are likely not representative of more recent congestion patterns. CAISO/M&ID/M&IP 9 October 28, 2014

10 Rather than use the existing SLAPs, the ISO will use the results of the pricing study and/or information about congestion, or expected congestion, to determine the best or preferred level of aggregation. This might be the level of aggregation that would minimize the errors, or deviations of the prices at each node in a LAP from the LAP price. However several stakeholders pointed out that a metric would need to be developed to determine the optimal number of pricing zones since the overall error will decrease as the number of pricing zones increases. Other stakeholders cautioned that using the historical pricing data ignores any changes that might be expected due to planned transmission expansions. VI. Information Request: Implementation Cost Estimates In order to determine the preferred level of load disaggregation, the expected benefits of different levels of increased load granularity will need to be compared to the costs necessary to implement that level of disaggregation. Adopting a more granular load aggregation may require changes to various systems and interfaces for both the ISO and market participants. The FERC decision on the ISO s waiver request made clear that any cost estimates would need to be detailed and supported, not just generic statements that there would be large costs. These costs must be considered for both the ISO and the market participants. In the September 22, 2014 issue paper stakeholders were requested to provide comments on the types of implementation costs that would be incurred in moving to a more disaggregated load structure. Several stakeholders provided detailed and extensive lists of these types of costs. At the September 29, 2014 meeting on load granularity refinements, stakeholders asked the ISO create a matrix to make it easier for them to provide the detailed implementation cost estimates required by FERC. The ISO has created such a matrix by synthesizing the stakeholder comments on types of implementation costs and combined them with the possible levels of disaggregation discussed in the previous section The ISO requests that stakeholders use the matrix below to inform the ISO of their estimated implementation costs for changes in the wholesale pricing structure. Within each of the cost categories stakeholders should indicate whether the costs are: One time implementation costs; Ongoing increased expenses for labor or operation and maintenance; or Required capital investments. Use of the matrix by all stakeholders will make it easier to combine the estimates from various stakeholders and create an overall estimated implementation cost for the alternate disaggregation level. If stakeholders identify costs that do not fit into the matrix, please include them in an alternative manner. The cost information comments should be submitted to lgr@caiso.com by November 20, The ISO will hold a conference call on November 6, 2014 to provide an opportunity for stakeholders to ask questions or comment on the information request. CAISO/M&ID/M&IP 10 October 28, 2014

11 Implementation Cost Estimates for Wholesale Market Pricing Changes Alternative Load Aggregation Levels Estimated Implementation Costs Load Forecasting Develop new systems Additional data collection and storage Additional labor costs Load Research Slight Disaggregation (Assume six LAPs) Load Aggregation to Minimize Error (Assume 23 LAPs, the same number as existing SLAPs) Custom LSE-Specific LAPs (Assume bidding and settlement done at aggregated LSE-specific LAPs within existing DLAPs) Full Nodal (Assume all bidding and settlement done at nodal level) Metering and Telemetry Infrastructure to provide meter reads for LAP level Mapping of customer meters to LAPs Telemetry Price Forecasting New Systems Ongoing costs Bidding and Scheduling Day ahead bid submission Settlements and Billing Interface with ISO Internal calculations CAISO/M&ID/M&IP 11 October 28, 2014

12 Demand Response Forecasting Settlement CRR Procurement/Settlement Forecasting Settlements Data Integration and Storage Increased data storage Data integration/mapping Other Business Integration Costs CAISO/M&ID/M&IP 12 October 28, 2014

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