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Section 220.127.116.11 Regulation
In the draft tariff language, the CAISO proposed the following language: “Consistent with the requirements of this Section, the CAISO will use all reasonable efforts to commit, schedule, and dispatch Non-Generator Resources providing Regulation while recognizing the impact of Regulation Awards on their State of Charge in the Day-Ahead and Real-Time Markets.”
In the final proposal, the CAISO proposed “This formula illustrates that state of charge, in any interval, is a function of the state of charge in the previous interval, the energy dispatch instructions during the previous interval and a fraction of the regulation awards in the previous interval. The proposal notes that only the fraction ?? of the full amount of regulation will factor into the state of charge for the next interval in the real-time or day-ahead market. This multiplier will be specified in a business practice manual and may be updated as analysis drives updates of actual regulation awards and impacts to state of charge” (page 11 of the final proposal).
PG&E requests the CAISO to replace the current draft tariff language with the language from the final proposal that the state of charge will account for a fraction of the regulation awards in the previous interval and explain the multiplier to be applied will be defined in the BPM.
PG&E requests the CAISO to clarify how the CAISO would distinguish between an ED to hold SOC and an ED to reach an SOC. It is PG&E’s expectation that an NGR can only receive ED to hold SOC instructions when its current SOC is at the specified level. The draft Tariff language suggests that an NGR can receive ED to hold SOC instructions when its SOC might be below the specified level. It should be made clear that any ED instructions to charge or discharge should follow existing Tariff rules regarding Settlements and Bid Cost Recovery (BCR).
PG&E requests the CAISO to confirm whether the Charging Constraint is a Y/N parameter and where that is stipulated (e.g., Masterfile or otherwise). PG&E also suggests CAISO use a different word than “registered Charging Constraint” and use instead Charging Constraint as defined in the Masterfile or [specified where].