CAISO response to posted comments on PRR432
On pages 27 and 28 of the Metering BPM the CAISO has added the following language: Where a CAISO Metered Entity operates a resource that is connected in a radial manner to the CAISO Controlled Grid, applicable radial line and transformer losses must be programmed into the CAISO-certified revenue meter to reflect the Point of Receipt at the CAISO Controlled Grid. Loss factors for such radial lines and transformers shall be determined in accordance with Attachment B, Technical Specifications, of this BPM
Does the CAISO intend this requirement to apply to PDR or PL connected to a transmission system? If yes, then under which situations?
CAISO Response:
This BPM reference is for CAISO Metered Entities. Participating Loads are CAISO Metered Entities and are required to install revenue quality meters and provide Revenue Quality Meter Data directly via polling of these meters by the CAISO. This and other CAISO Metered Entity responsibilities as outlined in Section 5 of the BPM for Metering apply to Participating Loads.
PDR resources are Scheduling Coordinator Metered Entities and are not subject to the requirements of this referenced section of the BPM for Metering. Scheduling Coordinators that represent Scheduling Coordinator Metered Entities (Load and Generating Units) are responsible for submitting SQMD to the CAISO for these entities. SC Metered Entity responsibilities asoutlined in Section 6 of the BPM for Metering apply to PDRs.
On page 28 of the Metering BPM the CAISO has added the following language: Where a CAISO Metered Entity operates a resource that is connected to a Utility Distribution Company’s or other Distribution System operator’s Distribution System, applicable radial line and transformer losses, as well as Distribution System losses or credits, referred to as a Distribution Compensation Factor, must be programmed into the CAISO-certified revenue meter to reflect the Point of Receipt at the CAISO Controlled Grid. Loss factors for such radial lines and transformers shall be determined in accordance with Attachment B, Technical Specifications, of this BPM.
Does the CAISO intend this requirement to apply to PDR or PL connected to the UDC's distribution system? If yes, then under which situations?
CAISO Response:
See response to previous comment.
The major changes specific to PDR is the establishment of a pseudo location.
A pseudo location is designed to be used as a place holder to assist in managing a resource’s rated PMax. The pseudo location resides only in the Demand Response System and is established during the registration process of a Proxy Demand Resource. The pseudo location may be used as a location capacity buffer in order to establish a PMax greater than the initial registration of Load reduction capacity for a resource. The PMax registered including the pseudo location buffer can then be the PMax that is assigned to that Resource ID in the Master File.
Will the elevated PMax in the resource's master file affect dispatch of the PDR resource? If yes, then under which situations? Are there other impacts caused by this elevated PMax? If yes, then provide a list of such impacts.
CAISO Response:
The elevated PMax should not normally impact how the PDR is dispatched. However, it will be the responsibility of the DRP’s Scheduling Coordinator to manage the scheduling of the PDR to ensure that bids reflect the actual capacity it is able to provide.
The CAISO’s SIBR system will utilize the PMax established in the masterfile in the acceptance of bids. If a Scheduling Coordinator submits a bid for a PDR’s PMax capacity, inclusive of a pseudo location quantity, it risks being awarded and/or dispatched to that PMax capacity. If a PDR is unable to comply with an award or dispatched Expected Energy, then the resource would be subject to No-Pay (in the case of an Ancillary Services award) and/or incur costs for Uninstructed Imbalance Energy.
The potential exists, although highly unlikely,that a PDR may be instructed to its registered PMax during a CAISO emergency situationin a case where the CAISO has the authority to do. A PDR would be required to comply with these instructions per CAISO Tariff Section 4.2.1.
4.2.1 Comply With Dispatch Instructions And Operating Orders
With respect to this Section 4.2, all Market Participants, including Scheduling Coordinators, Utility
Distribution Companies, Participating Transmission Owners, Participating Generators, Participating
Loads, Demand Response Providers, Balancing Authorities (to the extent the agreement between the
Balancing Authority and the CAISO so provides), and MSS Operators within the CAISO Balancing
Authority Area and all System Resources shall comply fully and promptly with the Dispatch Instructions
and operating orders, unless such operation would impair public health or safety. A Market Participant is
not required to comply with a CAISO operating order if it is physically impossible for the Market
Participant to perform in compliance with that operating order. Shedding Load for a System Emergency
does not constitute impairment to public health or safety. The Market Participant shall immediately notify
the CAISO of its inability to perform in compliance with the operating order.
BPM for Metering, Red Line, V. 3
On page 73, last paragraph:
If there is no SQMD submitted into the DRS by T+43C Meter Data submittal deadline, the CAISO will not estimate Meter Data for the underlying Load of the PDR; the CAISO will be unable to create a baseline, nor will it calculate a PDR Energy Measurement without available SC submitted SQMD, even if it was an event day. Additionally, in accordance with CAISO Tariff Section 10.3.6.2, failure to submit Settlement Quality Meter Data by T+43C will be considered late and subject to sanctions pursuant to CAISO Tariff Section 37.5.
Comment: Could you please clarify the yellow highlight sentence above to make clear to readers:
If there is an active PDR that never bid into the market, is the T+5B and T+43C meter still required for this PDR?
CAISO Response:
No, it is not until a PDR resource is actively bidding into the market that this statement would apply.
Note: The BPM section referenced was not part of the PRR; clarification will be included with forthcoming Reliability Demand Response Program BPM changes.
If the active PDR that never bid into the market, and the meter data for this PDR is not received by ISO by T+43C, will this PDR’s SC violate the Tariff Section 10.6.3.2, and subject to sanctions?
CAISO Response:
No, it is not until a PDR resource is actively bidding into the market that this statement would apply.
Note: The BPM section referenced was not part of the PRR; clarification will be included with forthcoming Reliability Demand Response Program BPM changes.
Page 70: change to indicate that the DRP SC submits the RDT once the registration is approved
Page 71 and throughout section 12.5.5: suggest changing PMax to Maximum Generation to be consistent with wording in RDT
Page 71: add language to clarify that the psuedo generation process and the corresponding Maximum Generation (PMax) supersedes any Maximum Generation value as a result of an Ancillary Services certification test
Edits included in attachment
[url=/bpm/post/attachment/74944]Metering_BPM_v4_Redlined Olivine.doc[/url]
Posted by Spence Gerber from Olivine, Inc representing Olivine, Inc - OLVN, DOLV on Wednesday May 11, 2011 at 11:13
CAISO Response:
Changes indicated will be accepted. Edits included in attachment to comments provide additional process detail and clarity, therefore, will be incorporated in BPM as suggested.