Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
PRR #
1334
Title State of charge reservation for regulation
Date Submitted 3/2/2021 3:29 PM
PRR Category B
Priority Normal
Owner Batakji, Jamal (CAISO)
Status Closed
Status End Date 6/15/2021 11:59 PM
Related BPM Market Operations
BPM Section 7.8.2.5
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Existing Language
 
See attached
Proposed Language
 
See attached
Reason For Revision
 
CAISO Tariff requires all resources awarded regulation are able to respond to automatic generator control (AGC) signals, the storage resources providing regulation must have sufficient state of charge to respond to automatic generator control signals.
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Batakji, Jamal (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

No modifications to the original PRR are proposed.
Identification of the authorship of comments

No comments were received.
Action

Approve the BPM PRR as submitted

N/A
Statement of apparent requirements of the BPM PRR

State of charge reservation for regulation
Priority and rank for any BPM PRR requiring a CAISO system change

N/A
Proposed effective date(s) of the BPM PRR

4/28/21
Other recommended actions

No other recommended actions on this PRR.
Click here to view the Final Decision for this PRR
Final Decision

Adopt the recommendation
Stakeholder Comment

Comments submitted, and a response was posted

Effective Date

6/15/2021
Action

Adopt the recommendation as originally issued

N/A
Announcements
PRR 1334 has been made available at this time to allow additional time to review and submit comments. 
Comment period will close 04/13/2021.  PRR will be discussed during the April and May BPM meetings
Posted On - 3/5/2021 7:47 AM
Impact Analysis
Impact Analysis not available.
Initial Comments
WPTF Comments on CAISO PRR 1334.pdf    
WPTF's comments on the proposed management of real-time SOC for storage resources providing regulation
4/13/2021 2:45 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
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CAISO response:
Comment # 1 regarding the conflict with MSOC:
1) If there is no RUC load balance infeasibility then the MSOC constraint is not active and no potential conflict with the 30-min proposed SOC reservation to meet the regulation award.
2) The application of the MSOC limits in real-time will only be triggered by detected energy shortage to meet load at certain hours in RUC.
3) For the pre-determined hours based on RUC solution when the MSOC is triggered due to shortage to meet load, the MSOC has higher priority over the 30-min SOC reservation for regulation down as regulation down will require the resource to be partially charged to satisfy the regulation down.
 
Comment # 2 regarding the later portion of the hour when less than 30-min time is available:
1) The  ISO is considering potential improvements which include: The 30 min reservation will be adjusted to reflect min(30 min, number of minutes corresponding to number of remaining market intervals to the balance of the hour).

4/27/21 CORRECTION on comment #1, item 3 above;
For the pre-determined hours based on RUC solution when the MSOC is triggered due to shortage to meet load, the MSOC has higher priority over the 30-min SOC reservation for regulation down as regulation down will require the resource to be partially DISCHARGED to satisfy the regulation down.
4/27/2021 11:41 AM
Responded By - Batakji, Jamal (CAISO)
Recommendation Comments
CESA appreciates the ISO’s efforts to ensure energy storage resources are able to participate in its markets in a manner that supports reliability and the State’s broader energy and environmental goals.
CESA is concerned with the potential effects of PRR 1334, as it could limit the flexible responsiveness characteristic of limited energy storage resources (LESRs) by enforcing a requirement originally conceived for conventional, thermal assets. While a modification akin PRR 1334 is reasonable given the requirements noted in Section 8.4.1.1 of the CAISO Tariff, a deeper consideration of the role and capabilities of energy storage is required to ensure robust long-term solutions are developed. In this context, CESA provides comments to enhance PRR 1334 and guarantee its application does not unduly burden energy storage resources providing Regulation.
CESA echoes the concern shared by the Western Power Trading Forum (WPTF) with relation to the application of this requirement when there are less than 30 minutes remaining in the hour when a resource is providing Regulation. As such, CESA recommends the ISO modify its proposal to be applied for the minimum of 30 minutes or the number of minutes corresponding to the remaining market intervals to the balance of the hour. CESA has not seen updated language that reflects this change and thus respectfully requests that the CAISO post it in order to allow stakeholders to provide substantive feedback.
5/18/2021 4:22 PM
Logged By - Sergio Dueñas (California Energy Storage Alliance (CESA))
WPTF appreciate's the CAISO's response to prior submitted comments. In its response to item #2, the CAISO notes it will consider making changes to the BPM language to consider adjusting the constraint when less than 30 minutes remain in a given trade hour. However, WPTF has yet to see updated language that reflect the change noted by the CAISO. Thus, WPTF respectfully requests that the CAISO post updated language for stakeholder consideration.
5/18/2021 3:02 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
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CAISO appreciates comments from participants for this PRR. After further review, CAISO had identified two reasons to continue with the current implementation. Regulation up commodity can be substituted for spinning reserve in the CAISO market since regulation up is a higher quality product than the spinning reserve. Furthermore, regulation service is a control-only service with an average zero net energy is not holding out from observation by operators. This assumption is particularly untrue for storage resources because of their fast response to AGC, which results in considerable energy charge or discharge that can materially impact the SOC required to sustain the regulation service.  The 30min sustained energy requirement for both regulation up and down will reduce the likelihood that the SOC of storage resources on regulation approaches the upper/lower limit to a degree that will jeopardize the quantity and quality of the regulation service they provide.  For those cases in which regulation up awards are substituted for spinning resources, the 30 minute SOC requirement will ensure that if a contingency event happens during the last 30 minutes of a given hour, there is a sufficient state of charge to deliver that capacity. Second, the software change required to reduce the amount of state of charge requirement as we approach the end of the hour would need to be coordinated with other constraints in the next hour. So the ISO is proposing to monitor the impact of the changes implemented in PRR 1334 and consider the impact of this change to develop future enhancement.
6/3/2021 7:43 AM
Responded By - Batakji, Jamal (CAISO)
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