Comments on Reliability Demand Response Resource Bidding Enhancements - Track 2

1. Please provide comments on CAISO’s Track 2 proposal to fix infeasibility issue dispatch issue in the optimization for discrete RDRR resources.

The California Efficiency + Demand Management Council (“Council”) supports the CAISO’s proposal to re-rate an RDRR’s Pmin to just below its Pmax for discrete-dispatch RDRRs. This appears to be a simple yet effective solution that will solve the problem while avoiding the need to implement significant changes to the CAISO’s market dispatch software while ensuring that RDRR-enrolled customers are not disenfranchised by infeasible dispatch instructions. The Council agrees with the CAISO’s response to Department of Market Monitoring (“DMM”), California Large Energy Consumers Association (“CLECA”), and Southern California Edison Company (“SCE”) that minimum load costs should not be reflected in RDRR bids. The customers enrolled in most RDRRs have a wide array of opportunity costs and they can change frequently, so it would be highly impractical to reflect minimum load costs in RDRR bids.

2. Please provide comments on the CAISO’s proposal to adjust discrete RDRRs operating range to reflect operational capabilities in real time.

Please see the Council’s comments to Question 1.

3. Please share your organization’s feedback on the CAISO’s proposal to increase the discrete RDRR cap to 100MW and allow for resources in excess of 100MW apply annually for an exception to the cap.

The Council acknowledges the CAISO concerns regarding the danger of imbalances due to discrete-dispatch RDRRs curtailing far more load than the current 50 MW RDRR cap would allow to be scheduled in the market. Therefore, increasing the cap to 100 MW and allowing for specific RDRRs to apply for an even higher cap is a practical and sensible approach.

4. Please provide any additional comments on RDRR Bidding Enhancements.

N/A

6. Please provide comments on the EIM Governing Body joint authority on RDRR Bidding Enhancements.

RDRRs are primarily real-time market resources, so it is logical for the EIM Governing Body to have joint authority on this initiative.

7. Attachments

1. Please provide comments on CAISO’s Track 2 proposal to fix infeasibility issue dispatch issue in the optimization for discrete RDRR resources.

Please see DMM comments in attached PDF.

2. Please provide comments on the CAISO’s proposal to adjust discrete RDRRs operating range to reflect operational capabilities in real time.

Please see DMM comments in attached PDF.

3. Please share your organization’s feedback on the CAISO’s proposal to increase the discrete RDRR cap to 100MW and allow for resources in excess of 100MW apply annually for an exception to the cap.

Please see DMM comments in attached PDF.

4. Please provide any additional comments on RDRR Bidding Enhancements.

Please see DMM comments in attached PDF.

6. Please provide comments on the EIM Governing Body joint authority on RDRR Bidding Enhancements.

Please see DMM comments in attached PDF.

7. Attachments

Please see DMM comments in attached PDF.

DMM comments will also be posted in the coming days at the following location, under "2022 comments on stakeholder processes": http://www.caiso.com/market/Pages/MarketMonitoring/MarketMonitoringReportsPresentations/Default.aspx#comments 

1. Please provide comments on CAISO’s Track 2 proposal to fix infeasibility issue dispatch issue in the optimization for discrete RDRR resources.

PG&E requests the CAISO update the implementation plan and hold additional events to address stakeholders’ questions.

2. Please provide comments on the CAISO’s proposal to adjust discrete RDRRs operating range to reflect operational capabilities in real time.

PG&E encourages the CAISO to continue discussions and hold additional stakeholder events to address the questions raised in the February 2022 working group.

3. Please share your organization’s feedback on the CAISO’s proposal to increase the discrete RDRR cap to 100MW and allow for resources in excess of 100MW apply annually for an exception to the cap.

PG&E has no comment.

4. Please provide any additional comments on RDRR Bidding Enhancements.

PG&E understands that implementation date of Track 2 is not determined yet. If the enhancements to address RDRR’s infeasible dispatch are implemented by October 2022, PG&E would be able to count those resources in our supply plan for 2023. PG&E requests the CAISO consider this detail and provide an update of the implementation timeline as soon as possible.

6. Please provide comments on the EIM Governing Body joint authority on RDRR Bidding Enhancements.

7. Attachments

1. Please provide comments on CAISO’s Track 2 proposal to fix infeasibility issue dispatch issue in the optimization for discrete RDRR resources.

2. Please provide comments on the CAISO’s proposal to adjust discrete RDRRs operating range to reflect operational capabilities in real time.

3. Please share your organization’s feedback on the CAISO’s proposal to increase the discrete RDRR cap to 100MW and allow for resources in excess of 100MW apply annually for an exception to the cap.

4. Please provide any additional comments on RDRR Bidding Enhancements.

6. Please provide comments on the EIM Governing Body joint authority on RDRR Bidding Enhancements.

7. Attachments