RSS Feed for Proposed Revision Request - 1278

PRR - 1278

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Announcement for PRR - 1278

Description: PRR 1278 has been made available at this time to allow additional time to review and submit comments. Comment period will close 9/16/2020. PRR will be discussed during the September and October BPM meetings.
-By Hines, Nicole on Friday, August 14, 2020 7:40:32 AM

Initial Comment for PRR - 1278

Description: PG&E is concerned that PRR 1278 represents a significant change to the market optimization and bidding of non-generator resources (NGRs) and therefore requests that the CAISO: (a) reconsiders the emergency designation and (b) works with stakeholders before implementation. PG&E’s specific concerns are related to Section 7.8.2.5, which suggests that state-of-charge (SOC) constraints will be placed on NGRs in the real-time market based on day-ahead awarded ancillary services. One possible result of the PRR could be a substantial shift of batteries away from regulation services in the future.
-By MichaelVolpePGE (Pacific Gas & Electric Company) on Wednesday, September 16, 2020 5:54:35 PM

Response: CAISO: All ancillary services procured in the day-ahead market are financially binding awards; thus, the market will reserve enough state of charge from NGRs to ensure there is sufficient charge to deliver that capacity. NGRs can continue to submit bids for energy and ancillary service in the real-time market. If the NGR has enough state charge to provide either incremental energy or ancillary service, it could receive incremental awards in the real-time market.
-By Batakji, Jamal on Friday, September 25, 2020 9:03:31 AM

Initial Comment for PRR - 1278

Description: SDG&E interprets the PRR to better optimize market awards in IFM to ensure sufficient SOC is available. However, the market optimization in real time seems to also limit the storage resource's ability to provide real time AS capability because it must have sufficient SOC so that it may be able to meet its future self-schedule or AS awards from the day ahead market. This seems to mimic the minimum charge requirement proposal that is being developed in the Resource Adequacy Enhancements initiative. It would be helpful for the CAISO to explain the impact of these model changes and provide an illustrative example. Additionally, SDG&E would like to understand why this is categorized as an emergency PRR. Thank you.
-By Nuo Tang (SDG&E) (San Diego Gas & Electric Company) on Wednesday, September 16, 2020 8:03:49 PM

Response: CAISO: All ancillary services procured in the day-ahead market are financially binding awards; thus, the market will reserve enough state of charge from NGRs to ensure there is sufficient charge to deliver that capacity. NGRs can continue to submit bids for energy and ancillary service in the real-time market. If the NGR has enough state charge to provide either incremental energy or ancillary service, it could receive incremental awards in the real-time market. The emergency status of this PRR is due to the effective date of 8/27/20.
-By Batakji, Jamal on Friday, September 25, 2020 9:02:53 AM

Recommendation Comment for PRR - 1278

Description: Recommendation Comments of the California Energy Storage Alliance (CESA) on PRR 1278
-By Sergio Dueñas (California Energy Storage Alliance (CESA)) on Tuesday, October 20, 2020 4:27:37 PM

Response: The software change described in PRR 1278 is not similar to the minimum charge requirement (MCR), currently under discussion in the policy. There are two main changes explained in PRR 1278. The first change is related to reserving enough SOC to support the Ancillary Service, which is necessary to ensure that the storage device can deliver this capacity in case of a contingency event. The market application will dispatch any incremental SOC beyond which is reserved for ancillary service based on bids. The market application has a similar feature for all generating resources, where the market application reserves capacity if a generator has a day-ahead ancillary service awards. The software change implemented as part of the PR1278 related to self-schedule is also not like the Minimum Charge requirement. This change ensures that the real-time market application can respect SC's self-schedule to charge or discharge and manage the state of charge appropriately. In the absence of the constraint described in the PR1278, the storage resource state of charge may conflict with the self-schedule. The change provides self-schedule a higher priority because this is the input provided by the SC to the market; thus, the market allocates a higher priority to this self-schedule. Please note, this change impacts the real-time market when the self-schedule is within the real-time market horizon. If there are no self-schedules on the horizon for the real-time market, the market application will dispatch the storage resource based on bids.
-By Batakji, Jamal on Monday, October 26, 2020 9:23:01 AM

Recommendation Comment for PRR - 1278

Description: The CAISO received written comments on 10/20/2020 in reference to PRR 1278 from Renae Steichen at LS Power. Please see attached.
-By Hines, Nicole on Thursday, October 22, 2020 11:00:56 AM

Response: The software change implemented as part of the PR1278 related to self-schedule is not like the Minimum Charge requirement. This change ensures that the real-time market application can respect SC's self-schedule to charge or discharge and manage the state of charge appropriately. In the absence of the constraint described in the PR1278, the storage resource state of charge may conflict with the self-schedule. The change provides self-schedule a higher priority because this is the input provided by the SC to the market; thus, the market allocates a higher priority to this self-schedule. Please note, this change impacts the real-time market when the self-schedule is within the real-time market horizon. If there are no self-schedules on the horizon for the real-time market, the market application will dispatch the storage resource based on bids.
-By Batakji, Jamal on Monday, October 26, 2020 9:20:38 AM

Recommendation for PRR - 1278

Proposed Language:

No modifications to the original PRR are proposed.

Apparent Requirement: Non-generator resource update
Priority: N/A
Action: Approve the BPM PRR as submitted
Effective Date: 08/27/2020
Other Actions: No other recommended actions on this PRR.

Final Decision for PRR - 1278

Final Decision: Adopt the recommendation
Stakeholder Comment: Comments submitted and CAISO posted the responses on 10/26/2020
Action: Adopt the recommendation as originally issued
Effective Date: 08/27/2020