Comments on Draft Final Proposal - Reliability Demand Response Resource Bidding Enhancements - Track 2

1. Please share your organization’s overall position on the draft final proposal:

The California Efficiency + Demand Management Council (Council) supports the draft final proposal.

2. Please share your organization’s feedback on the Pmin re-rate solution to the “infeasible” RDRR dispatch issue

The proposed Pmin re-rate solution for discrete-dispatch RDRRs appears to be a simple yet effective solution to the problem of infeasible dispatches.  The use of a proxy minimum load cost will likely result in more efficient dispatch and the methodology for calculating it is appropriately straightforward.

3. Please provide your organization’s comments on the increase of the discrete RDRR registration cap from 50 MW to 100 MW.

The Council supports a 100 MW discrete RDRR cap coupled with the proposed mechanism for CAISO approval of larger single-source RDRRs. As the Council has stated in prior comments, it is critical that the full value of RDRR resources is recognized to ensure they can meet statewide capacity requirements.

5. Attachments

N/A

1. Please share your organization’s overall position on the draft final proposal:

Please see DMM comments in attached PDF, or at the following location: http://www.caiso.com/Documents/DMM-Comments-RDRR-Bidding-Enhancements-Track2-Draft-Final-Proposal-Mar-25-2022.pdf 

2. Please share your organization’s feedback on the Pmin re-rate solution to the “infeasible” RDRR dispatch issue

Please see DMM comments in attached PDF, or at the following location: http://www.caiso.com/Documents/DMM-Comments-RDRR-Bidding-Enhancements-Track2-Draft-Final-Proposal-Mar-25-2022.pdf 

3. Please provide your organization’s comments on the increase of the discrete RDRR registration cap from 50 MW to 100 MW.

Please see DMM comments in attached PDF, or at the following location: http://www.caiso.com/Documents/DMM-Comments-RDRR-Bidding-Enhancements-Track2-Draft-Final-Proposal-Mar-25-2022.pdf 

5. Attachments

Please see DMM comments in attached PDF, or at the following location: http://www.caiso.com/Documents/DMM-Comments-RDRR-Bidding-Enhancements-Track2-Draft-Final-Proposal-Mar-25-2022.pdf 

1. Please share your organization’s overall position on the draft final proposal:

SCE commented that RDRR start-up time is not being defined by the Masterfile, but instead by the 5/15/60 minute option, and RDRRs are not being recognized as use-limited resources with hourly, monthly, or yearly limitations. PG&E agrees with this concern and requests that the CAISO fix this issue.

2. Please share your organization’s feedback on the Pmin re-rate solution to the “infeasible” RDRR dispatch issue

3. Please provide your organization’s comments on the increase of the discrete RDRR registration cap from 50 MW to 100 MW.

5. Attachments

1. Please share your organization’s overall position on the draft final proposal:

SCE appreciates that CAISO addressed most of SCE concerns in the last round of comments.   However, CAISO still has not address in multiple iterations of SCE comments concerns regarding RDRR start-up time not being defined by the Masterfile but instead by the 5/15/60 minute option, and RDRRs not being recognized as use-limited resources with hourly, monthly, or yearly limitations.[1]

[1] See comments submitted on November 4, 2021 (Link: https://stakeholdercenter.caiso.com/Common/DownloadFile/bc08494f-d5a1-46c8-a6f5-435c63ab6589); December 22, 2021 (Link: https://stakeholdercenter.caiso.com/Common/DownloadFile/31db51fb-5645-4c95-a24e-8be8dc6fa9c0); February 16, 2022 (Link: https://stakeholdercenter.caiso.com/Common/DownloadFile/ab3d7918-33cf-4270-9862-b673fe188f4f).

2. Please share your organization’s feedback on the Pmin re-rate solution to the “infeasible” RDRR dispatch issue

3. Please provide your organization’s comments on the increase of the discrete RDRR registration cap from 50 MW to 100 MW.

5. Attachments