RDRP Stakeholder Initiative

Transcription

1 Reliability Demand Response Product RDRP Stakeholder Initiative Draft Final Proposal Review Stakeholder Conference Call September 13, 2010

2 Reliability Demand Response Product (RDRP) We are here Project is triggered Working Group Straw Proposal Draft Final Proposal Board of Governors FERC Opportunities for Stakeholder Input Slide 2

3 Agenda- September 13, 2010 TIME TOPIC 10:00 to 10:15 Introduction Agenda Review Milestones and Schedule Review 10:15 to 11:50 Proposed Design Changes/Refinements Product Description Registration Notifications Metering Performance & Compliance Settlements 11:50 to 12:00 Wrap-up & Next Steps Slide 3

4 Today s Meeting Purpose & Goal Purpose: Review changes made to the RDRP design proposal based on stakeholder comments and CAISO refinements Goal: Stakeholders gain an understanding of changes/updates and provide input on the ISO s RDRP Draft Final Proposal Slide 4

5 RDRP Stakeholder Initiative MILESTONES & SCHEDULE Upcoming Schedule Slide 5

6 RDRP Proposed Schedule Draft Final Proposal September 1 Publish Draft Final Proposal September 13 Stakeholder Conference Call September 20 Draft Final Proposal Comments Due* * Submit comments to rdrp@caiso.com Slide 6

7 RDRP Proposed Schedule Board Approval September 23 Publish Clarified Draft Final Proposal September 29 Clarified Draft Final Proposal Comments Due* November 1,2 Board of Governors Decision * Submit comments to rdrp@caiso.com Slide 7

8 RDRP Proposed Schedule Tariff Development Mid March 2011 Publish Draft Tariff Language Late March 2011 Stakeholder Conference Call * Submit comments to caisotariff@caiso.com Slide 8

9 RDRP Proposed Schedule FERC Approval May 2011 Submit Tariff Amendment to FERC July 2011 Expected FERC Decision Slide 9

10 RDRP Stakeholder Initiative DRAFT FINAL PROPOSAL REVIEW Design Changes and Refinements Product Description Registration Notifications Metering Performance & Compliance Settlements Slide 10

11 Stakeholder Comments Comments Received from Seven (7) Stakeholders: CDWR DRA Dynegy EnerNOC PG&E SCE SDG&E Slide 11

12 Design Modifications & Refinements Dual Participation Capability Added Include Day-Ahead Energy; no A/S or RUC Removed Performance Incentive Element Defer to SCP and development of an Availability Standard for DR Test Events Will count toward Availability Limits (15 X & 48 Hours) Bidding & Scheduling Rules Distinct rules regarding DA Energy and RT Energy Slide 12

13 Bidding & Scheduling Rules that will apply to RDRP resources are: Energy may not be self scheduled Multi-segment energy bid curves can be submitted for all RDRP resources in the day-ahead market; no non-marginal clearing in the day-ahead (COG option) Day-ahead energy bids will not be constrained to be in the range of the ISO bid cap and 95% of the bid cap as are energy bids in the real-time Single segment energy bids must be submitted in the real-time for RDRP COG resources; multi-segment bids can be submitted for all other RDRP resources in real time Real-time energy bids for all RDRP resources must be in the range of the ISO bid cap and 95% of the bid cap Minimum curtailment offer must be at least 500 kw (less on an exception basis) The ISO will apply a generator distribution factor to all aggregated RDRP resources; this will not be a biddable parameter Slide 13

14 Clarifications & Refinements Adjusted Tariff Development Schedule SLIC Replaced by Term ISO Outage Management Reporting System Exceptional Dispatch Meter Data Submission Requirements Baseline Type II- Proxy Meter Data Process Outlined When RDRP can be Dispatched & the Dispatch Process Slide 14

15 Product Description Price Setting Issues Dynegy: Will RDRP be dispatched in merit order? CAISO: RDRP resources, once released for dispatch, will be committed and dispatched like any other resource, i.e. based on the resource s bid price and operating constraints, with the objective of minimizing total commitment cost. If the CAISO calls on RDRP to address a local transmission emergency how will the CAISO determine which nodal prices will be set to the RDRP price? CAISO: No special LMP pricing goes into effect as a result of dispatching RDRP resources. A RDRP resource that is dispatched can impact the LMP of a node if it is the marginal resource and increases the System Marginal Energy Cost. Slide 15

16 Product Description Price Setting Issues Dynegy: Dispatching resources for local T&D: to address reliability needs but not allowing those resources to set price, even a local price, is simply a variation of the use of exceptional dispatch, which, at FERC s direction, the CAISO has been working to reduce. Dynegy appreciates the CAISO s efforts to move the out-of-market RDRP into the CAISO s markets. Consistent with the philosophy that every action taken to ensure reliability should be done transparently, and, if at all possible, within, not outside the CAISO s markets, the use of RDRP should always set price. CAISO: The CAISO would have to issue an exceptional dispatch to a RDRP resource so that the utility could address their local system concern. An exceptional dispatch will only add additional cost to the system in the form of uplift and it will not have the intended effect of reflecting the value of the emergency-triggered DR in the LMP. For this reason, the CAISO finds that the costs far outweigh the benefits of attempting to impose CAISO dispatch on a utility s use of their emergency-triggered DR to address a local system constraint. Slide 16

17 Product Description: Residual Unit Commitment SCE: Exclusion of RDRP from Residual Unit Commitment ( RUC ). The proposal should be modified to state that RDRP will not be committed in RUC before any other resource adequacy qualifying resources. CAISO: RDRP resources that can participate in the DAM will not be eligible to participate in the RUC process due to the complexity associated with co-mingling the Energy bid into the HASP associated with awarded RUC capacity and RDRP Energy, and due to the different dispatch parameters between RUC and RDRP. Furthermore, RDRP resources that are configured to operate only in the Day-Of timeframe and can only respond to a reliability event are neither suitable, nor eligible to be considered in the ISO s Day-Ahead Residual Unit Commitment process. Slide 17

18 Product Description: Resource Adequacy/Must Offer Obligation SCE: Are the tariffs in this section applicable to RDRP in their entirety, or are they references only in part. CAISO: RA qualifying RDRP resources will have special designation like that of Hydro and Non-Dispatchable Use-Limited Resources as specified in ISO Tariff section , but without an obligation to bid in the DAM. During the ISO Tariff development stage for the RDRP, the ISO will determine whether or not to weave RDRP resources into or, if necessary, craft a new sub-section entirely. Slide 18

19 Registration RDRP Term SCE: Selection of the winter term commencing in November may cause availability and or testing problems. CAISO: No modification contemplated to change the winter term as running from November to April. These seem to be the logical months for the winter term, thus slight modifications may need to be made to retail program enrollment or adjustment windows. The ISO addresses SCE s other concern about testing early in a RDRP Term. The ISO has addressed this concern by stating in the Draft Final Proposal if no events have been called within the year, then the expectation is one test event will be performed annually, toward the end of a RDRP Term, to determine RDRP resource availability and performance. Slide 19

20 Notifications: Outage Reporting SCE: Concern expressed about ISO reliance on SLIC for outage reporting CAISO: At this juncture, the ISO proposal is to continue to rely on SLIC, using the same process as PDR, for outage reporting. Future enhancements to the ISO s DRS may accommodate outage reporting directly, but this is currently not in-scope of the enhancements for the RDRP. Acknowledging the potential future enhancement, the ISO removed the term SLIC and replaced with ISO outage management reporting system throughout the Draft Final Proposal. Slide 20

21 Notifications Exceptional Dispatch PG&E: The CAISO needs to ensure that a RDRP resource cannot be called for exceptional dispatch. CAISO: The ISO will endeavor to consistently dispatch RDRP resources through the ISO s market applications. However, all resources are subject to exceptional dispatch, including, for example, Proxy Demand Resources. Similarly, the ISO cannot exempt RDRP resources from these same tariff provisions. If system conditions are dire and a market application fails or does not commit a required RDRP resource that can resolve the reliability concern, the ISO cannot forego its ability to dispatch a RDRP resource under its exceptional dispatch authority and allow the situation to worsen. Thus, the ISO will preserve its exceptional dispatch capability with the expectation that this authority will be used judiciously and infrequently for RDRP resources. Slide 21

22 Metering: Meter Data Requirements SCE: The meter data requirements do not appear to be compatible with IOU DR programs. The RDRP requires 5 to 15 minute meter data. This requirement precludes hourly interval meters in reliability programs from participating in RDRP. CAISO: The CAISO does not envision the possibility of using hourly interval meter data to settle wholesale real-time energy transactions. The CAISO has outlined a process in the Draft Final Proposal for the DRP to provide the ISO with a Proxy Meter Data Plan that will be reviewed by stakeholders and approved by the CAISO. Assuming accurate results can be derived, the CAISO is open to proposals that would leverage the existing infrastructure that is in place for deriving the Load Impact Protocol results. Other options may be taking a sample of 15-minute interval meter data, using SCADA data, and other potential methods that are still under investigation over this next year or more. However, at this juncture, flexibility is important and there is not enough certainty to state a specific approach in the Draft Final Proposal for how Proxy Meter Data will be derived. Slide 22

23 Metering Meter Data Submission CAISO: Settlement quality meter data must be submitted by registration for its RDRP resources by noon T+5B days as follows. For RDRP resources that offer: Day-ahead energy (in addition to real-time energy): Settlement quality meter data is required to be submitted daily Real-time energy only: Settlement quality meter data is required only after an event has occurred Slide 23

24 Performance & Compliance: Performance Incentive Dynegy: The CAISO s proposal highlights the challenges of conflating energy performance with capacity availability. Performance incentives and penalties and availability penalties and incentives apply in different ways. The CAISO s proposed performance standards are not availability standards. If the only choice is between having no availability standards apply to demand response for an extended period of time, or implementing performance standards as a surrogate for availability standards until such time as availability standards are developed and applied, Dynegy would prefer the latter, even if performance standards are not availability standards. EnerNOC: If Performance Incentive was to apply, generally support staged penalty approach. A Penalty should only be applied to the MW that the resource underperformed outside of the % target. Slide 24

25 Performance & Compliance: Performance Incentive (cont d) Utilities: PG&E: PG&E opposes any performance incentives associated with RDRP resources for performance or penalties for non-performance. The issues of penalties for these programs should be discussed in the third phase of Standard Capacity Product (SCP). SCE: The availability performance standards and performance charges/incentives should not be included in the current RDRP design. It is more appropriate to develop those standards and incentives in the SCP, given that SCP is the CAISO's forum for consideration of the performance standards and incentives for all RA resources. SDG&E: SDG&E strongly disagree with the timing, rationale for and design of the proposed performance incentive. Preliminarily, from a purely procedural standpoint, SDG&E argues that the proposed incentive/penalty scheme is outside the scope of the all-party settlement that forms the basis of D CAISO: The CAISO will develop availability standards for demand resources under the Standard Capacity Product Initiative and forego the concept of a performance incentive for RDRP resources. Slide 25

26 Performance & Compliance: Testing SCE: The proposal should be modified to include test events within the availability limits of the resource. CAISO: The CAISO has modified the Draft Final Proposal to count test events toward the Availability Limits. Slide 26

27 Performance & Compliance: Testing SDG&E: SDG&E believes that events called by both the CAISO and the utility should preclude the need for an annual test. CAISO: The CAISO Draft Final Proposal states: The ISO s preference will be to rely on actual events to determine the availability and performance of RDRP resources to avoid the burden of a test event on end-use customers; however, if no events have been called within the year, then the expectation is one test event will be performed annually, toward the end of a RDRP Term, to determine RDRP resource availability and performance. Slide 27

28 Settlements Baseline Type II- Proxy Meter Data Process CAISO: The ISO s approach will be for a Demand Response Provider to submit its methodology for deriving Proxy Meter Data to the ISO for review. Any method proposed by a Demand Response Provider must be fully auditable by the ISO. As to the review process, the ISO will take 10-business days to review, comment and seek clarification from the Demand Response Provider on its proposed Proxy Meter Data methodology. Any proposed Proxy Meter Data methodology should be in conformance, as applicable, with the NAESB Phase I and Phase II measurement and verification standards. Slide 28

29 Other: Wholesale Dual Participation EnerNOC: EnerNOC supports dual participation in both emergency and economic DR programs, which is allowed by all other ISOs. PG&E: The lack of wholesale dual participation precludes a market participant from realizing the full economic value of a retail dual participation customer. For PG&E, a customer is required to sign up for both the Demand Bidding Program (DBP) and the Base Interruptible Program (BIP), where DBP is a day-ahead notification and BIP is a 30-minute reliability program. Thus, PG&E has resources capable of participating in both PDR and RDRP and would be required to decide on whether these resources should participate in a PDR or an RDRP. CAISO: The CAISO has modified the RDRP proposal to incorporate DA Energy, enabling a dual participation capability. Slide 29

30 Other: Specific Language Modifications/Additions DRA &PG&E: DRA & PG&E were concerned about the statement in the proposal that under the RDRP settlement the load-serving entity (LSE) neither benefits from, nor is harmed by, the load curtailment actions of the DRP that is providing demand response services to that load-serving entity's customers. Unless a separate settlement is obtained between the LSE and the third-party DRP, the LSE s ratepayers could be harmed. CAISO: Acknowledging this retail concern, the CAISO removed this language from the Draft Final Proposal. Slide 30

31 Other: Specific Language Modifications/Additions CDWR: SWP requests that CAISO specify the system events that trigger RDRP resources dispatch to clarify the process of dispatching RDRP resources when economic bids are still available in the bid stack. CAISO: The CAISO added additional clarifying language to further describe for what purposes the RDRP can be used and how RDRP resources are dispatched, specifically in Section 3.1- Overview and in Section Real-Time Dispatch. Slide 31

32 Eligible RDRP Dispatches System Emergencies: Transmission emergencies For example, the loss of a transmission asset that is part of the CAISO Controlled Grid Mitigating imminent/threatened operating reserve deficiencies Specifically, the ISO may access RDRP resources as specified in its Emergency Operating Procedure E-508B, at a Warning Notice, prior to the ISO having to seek Exceptional Dispatch energy/capacity from other Balancing Area Authorities Local Transmission and Distribution Emergencies: For example, to resolve a utility distribution circuit overload or to maintain a piece of electrical equipment within its emergency rating Slide 32

33 Other: Specific Language Modifications/Additions PG&E: Language Changes to the RDRP Straw Proposal for Reliability Resource Coordination CAISO: The ISO responded in the Draft Final Proposal that it will update and maintain its emergency operating procedures and processes, including updates to its emergency operating procedure E Interruptible Load Programs- to incorporate the RDRP. Notifications between the ISO and the Participating Transmission Owners will be as specified in procedure E-511. E-511 specifies coordination between the CAISO and the PTO in operating interruptible load programs. Slide 33

34 RDRP Stakeholder Initiative WRAP UP & NEXT STEPS Slide 34

35 Comments Comments due on: RDRP Draft Final Proposal by Sept. 20, 2010 Submit comments to: Slide 35