Provide your organization’s feedback on the Must Offer Obligations and Bid Insertion topic as described in section 4.1:
Must-Offer Obligation for Energy Storage
(response to Proposal, p.4 - Storage and Hybrid Resources)
Fundamentally, it is unfair and unjust to require storage and Mixed-Fuel Resources (MFRs, the CAISO's own term) providing generic Resource Adequacy (RA) to bid the entire positive and negative range of their storage capacity, since they only get Qualifying Capacity (and thus NQC) for the positive range.
Such resources must already bid the positive and negative range (and with economic bids) if they are counted for Flexible Capacity. This is equitable, because the Effective Flexible Capacity (EFC) values for such resources include the entire operating range, i.e., 2 x NQC. Unless the CAISO also includes a proposal to effectively double the QC and NQC for these resources, then it will be imposing a requirement without compensation.
If the CAISO believes that the entire operating range is needed for reliability, then it should propose increasing the QC accordingly, and advocate for that position before the CPUC and other Local Regulatory Authorities (LRAs). Until that change is made, no commensurate increase to the storage MOO should be imposed.
As a practical matter, nearly all storage capacity from larger facilities is contracted to provide both NQC and EFC, and the rest will undoubtedly be incented economically to offer the negative range into the market even if the MOO does not require it. Thus, the CAISO would not be “losing” much utility by retaining the MOO for those providing only NQC at the positive operating range only.
(response to Proposal, p.10 - Eligible Intermittent Resources)
This situation appears to apply to a rather specialized situation, where part of an EIR is providing RA capacity to an LSE-area off-taker and the other part is bid as an export. (The term “ELCC” appears to refer to the monthly solar or wind Technology Factor times the portion of the resource providing RA capacity, as indicated below.)
For example, 50 MW of a 100 MW solar project with FCDS might be contracted in July 2022 to a CAISO-area LSE. The RA value of the project in that month is 100MW x 39% TF = 39 MW, so the LSE off-taker is entitled to claim (39MW x 50MW/100MW =) 19.5 MW NQC for that month.
Suppose that the hourly forecasted output for HE 15 is 70 MW. LSE/SEIA assume that the Proposal intent is that: (1) at least (70MW x 50MW/100MW =) 35 MW of energy must be scheduled inside the CAISO, even though the NQC claimed by the CAISO-area LSE is 19.5 MW; and (2) no more than 70MW-35MW =) 35 MW can be scheduled as an export.
In reality, this situation seems very unlikely. Capacity committed to an off-taker under a PPA for only a portion of a project would almost certainly be covered under a separate Resource ID, which would have its own EIR forecast and MOO; thus, application of this proportional method would almost certainly not be needed, and the CAISO’s concern would not materialize.
MOO impact on Grid-Charging Management
(response to Proposal, p.8 - Storage and Investment Tax Credit (ITC) Considerations, and CAISO presentation, slide 10)
As noted above, LSA/SEIA’s comments and related presentation in the Energy Storage Enhancements initiative included strong arguments why the grid-charging management issue requires focused attention for CLRs. That input included requests to the CAISO to: (1) Clarify the grid-charging tools that may be available now; and (2) consider expanding the available tools.
On the last stakeholder call in that initiative, the CAISO said it would likely include that larger issue in the ESE initiative scope definition.
Unfortunately, CAISO issuance of the ESE Straw Proposal has been postponed from October 21st to October 28th, so it is not available yet, and there is no mention of input into that initiative in the Proposal here. Thus, it’s unclear whether the CAISO’s dismissal of stakeholder concerns in this initiative reflects anything submitted in the other one, or perhaps just an internal lack of communication.
The MOO for CLRs should be considered in the larger context of grid-charging management. We provide some excerpts from our ESE comments, and attached to these comments our ESE workshop presentation, to explain the need to address this issue comprehensively, and not in the piecemeal fashion used to date.
Specifically, LSA/SEIA ask that the CAISO revise its response in the Proposal to recognize the input provided in the ESE initiative, and then incorporate MOO concerns into what we hope will the requested, focused examination of the grid-charging management issue in the ESE initiative.
Excerpt from ESE initiative comments on initiative scope
…Under this topic, the CAISO should clarify/confirm tools that are available now, for example:
- Whether these resources could use a “limiting scheme” or tool to limit grid charging, based both on long-standing guidance in the CAISO’s 2016 Technical Bulletin on Mixed-Fuel Resources (MFRs) and subsequent statements in Hybrid Resources Phase 1 Straw Proposal and Revised Straw Proposal.
- If so, the type of limiting scheme or tool, e.g., software algorithms preventing or controlling the maximum amount of grid charging (and reflected in the Master File), or Aggregate Capability Constraint (ACC) minimum setting at zero.
The option to set ACC minimums at zero is a particularly elegant solution. It would allow storage CLRs to fully offer their entire positive and negative operating range in CAISO markets (even where not required by their Must-Offer Obligations (MOOs)) without fear that doing so would expose them to large grid-charging risks. This option would require no tariff or software change, and LSA and SEIA strongly urge the CAISO to confirm that this it is available now.
The CAISO should also consider in this initiative additional tools that are needed. These could include (but are not limited to):
- (Additional) Master File options, e.g., separate storage CLR Pmin parameters for physical limitations and market-dispatch limitations. For example, the former could apply during System Emergencies and the latter could apply at all other times.
- Expanded Storage CLR flexibility, since the Minimum State of Charge (MSOC) ensures availability for subsequent hourly schedules when supply conditions are tight (and, presumably, any MSOC replacement would do the same). For example, the CAISO could:
- Allow storage CLRs to reduce charging, to the extent that real-time VER output is below schedule when charging is occurring. This suggestion would be the “flip side” of the currently allowed flexibility to increase charging or reduce discharging where VER output is above schedule, to prevent VER curtailments.???????
- Allow storage CLRs to exercise storage flexibility (in both directions) in intervals when providing A/S, subject to the MSOC.
(CAISO declined to consider the two suggestions above in the Hybrid Resources initiative, fearing the resulting lower-than-expected storage state of charge (SOC) might leave storage CLRs unable to fulfill Ancillary Services and/or Energy schedules in later hours. However, the MSOC (and, presumably any approved successor mechanism) would address this issue by allowing use of these flexibility features only to the extent that they do not impair storage CLR ability to meet later schedules.)
- Bid/payment “adders” where storage CLR grid charging would result in loss of ITC and other tax benefits. These could be similar to greenhouse-gas adders, though possibly more complex to design.
Please provide your organization’s feedback on the proposed EIM Governing Body role as described in section 5:
Please provide your organization’s feedback on the Appendix as described in section 7:
Additional comments on the Resource Adequacy Enhancements phase 2 straw proposal: