Comments on Business Requirements Specification - FERC Order 2222

1. Please provide the version of the FERC Order 2222 BRS your comments apply to

Please specify the version of the BRS your comments apply to

V 1.2

2. Please provide any questions or comments your organization may have regarding section 4 of the FERC Order 2222 BRS.

When providing input in the text box below, please specify the BRQ(s) your comment or question refers to.

3. Please provide any questions or comments your organization may have regarding the remainder of the FERC Order 2222 BRS

When providing input in the text box below, please specify the section your comment or question refers to.

Hi CAISO,

We would like to request an extension on the BRS comments submission from 7/30 to 8/9.

Thanks,

Kevin

4. Please provide any additional questions or comments you may have.

When providing input, limit your questions and comments to the FERC Order 2222 BRS and project.

1. Please provide the version of the FERC Order 2222 BRS your comments apply to

Please specify the version of the BRS your comments apply to

Version 1.2

2. Please provide any questions or comments your organization may have regarding section 4 of the FERC Order 2222 BRS.

When providing input in the text box below, please specify the BRQ(s) your comment or question refers to.

We do not have any questions or comments regarding section 4 of the FERC Order 2222 BRS.

3. Please provide any questions or comments your organization may have regarding the remainder of the FERC Order 2222 BRS

When providing input in the text box below, please specify the section your comment or question refers to.

BRQ009

• Can CAISO further define HDERAs?

Are they the DCR and the battery storage ?

Are they the DCR and the rooftop solar

What are the technology type generator resources for DER, which will be part of the HDERAs?

• How the capacity of the storage (Pmin and Pmax) combined with the baseline consumption (baseline of the demand response) works? – It should be the net energy but need CAISO to confirm.

BRQ010 and BRQ021

• Currently the RDRR and PDR resource level baseline methodology and technical characteristics have been submitted via DRSS. Why the HDERAs’s resource (such as new/removed underlying locations, modified maximum capacity amount, new baseline methodology, change in resource SC, etc.) need to be submitted to another different application (RIMs)?
• Can CAISO provide further clarification on the concurrent submission? – it’s in RIMs as it stated in BRQ018. However the impact application is “N/A” for these two BRQs.

BRQ003

• Baseline methodology is defined in GRDT as of now - Why the impact application on the baseline methodology is master file instead it should be GRDT and Master File?
• What are the HDERA data CAISO is referring to?

BRQ115 & BRQ119

• What MFRD is CAISO referring to? Is MFRD and Master File is interchangeable in this doc?

5.3 Business Process: Manage DAM (MMG LII) Manage RTM – SIBR

• What is MMGLII stands for?

BRQ005

• Since part of the HDERAs e.g. (DER-Storage) is not demand response resource, it that appropriate for CAISO to apply the net benefit test to the HDERA as a whole resource?

BRQ116 (BRQ 112 and 110) seems contradicting.

• The GDFs is submitted via the NRI process, which becomes default in BRQ110.
• How come in BRQ 116, GDFs become accept hourly/daily bid? – it is contradicting to BRQ112, second paragraph, “DERA/HDERA resource data modifications (e.g. changes to Baseline Methodology, GDF, DCR/DER locations, etc.) must also follow the same process.” So if the GDFs need to be changed, do we have to go through the NRI process again?

BRQ007

• Is CAISO expecting the meter data file indicate HDERA resource type? or just a generation resource type as of now like demand response resource? If so, what field in the meter data file (MDEF) will be modified?
• Can CAISO provide an example of the mathematical equation on how the HDERAs’ combined baseline is calculated?

Appendix A and BRQ008

• Can CAISO provide an example of the mathematical equation for the HDERA settlement energy quantity as how it determines the aggregate the sum of net energy from both DER and DCR?

4. Please provide any additional questions or comments you may have.

When providing input, limit your questions and comments to the FERC Order 2222 BRS and project.

General question:

Can HDERA participate in both DAM and RTM?

Market simulation comment:

It would be a tremendous help for the ISO to create a HDERA resource (including a battery component resource) type for testing purpose since we don’t have a HDEAR resource in our profile as of now. However, we are very interested to review the whole process and market result from the bid of a HDERA resource.