COMMENTS BY JOINT PARTIES ON CAISO’S PROPOSED MODIFICATION TO THE RELIABILITY REQUIREMENT BUSINESS PRACTICE MANUAL, PRR 854:

EnerNOC, Comverge, CPower, EnergyHub and Johnson Controls (Joint Parties) submit comments as part of CAISO’s Business Practice Manuals (BPM) Change Management Process, to oppose Proposed Revision Request (PRR) 854 to the Reliability Requirements BPM: “Local Capacity Counting Clarification for Reliability Demand Response Resource (RDRR) and Proxy Demand Resource (PDR) Resources.”

It is Not Reasonable for CAISO to Determine Resource Adequacy Eligibility through Insertion of a Footnote in a Business Practice Manual

In Section 7.2.3 of the BPM for Reliability Requirements, CAISO’s only proposed modification to the section is to add a footnote to the section. The proposed section now reads:

The ISO will engage in procurement of Local Capacity Area Resources only where the portfolio of all Local Capacity Area Resources presented by all LSEs, after taking into account any Generating Units under Reliability Must-Run contracts, if any, and other Resource Adequacy Resources, whether or not such Resource Adequacy Resources are located in the applicable Local Capacity Area, demonstrate that the ISO is unable to comply with Applicable Reliability Criteria in that Local Capacity Area.[1] In addition to the foregoing, the ISO will forego reliability procurement until further considering any supplemental procurement by LSEs, as may be permitted by the CPUC or Local Regulatory Authority, provided to the ISO within 30 days of the date the ISO informed Market Participants that a Local Capacity Area Resource deficiency exists.

According to CAISO’s website, BPMs “contain implementation details through which the California ISO and market participants conduct business in accordance with the Tariff.”[2]In PRR 854 of the Reliability Requirement BPM, however, CAISO essentially seeks to establish new operational requirements for PDRs and RDRRs, which are not in the CAISO tariff.CAISO presents no basis for this significantchange to DR eligibility requirements. As noted above, this proposed modification is implementedthrough a footnote specifying that DR resources “must have a response time of 20 minutes or less.” The 20-minute requirement is not supported by the CAISO tariff for PDR or RDRR.

The CPUC deferred consideration of this issue and expressed its intention to address it in Phase 3 of the current RA rulemaking (D.15-06-063, p. 35).The CAISO should not abandon existing stakeholder assessments of demand response requirements to impose its preferred policies on the market. Instead, resolution should first occur in the CPUC RA proceeding where parties can have an opportunity to present arguments that are supported by evidence. After a final CPUC decision on the matter, the CAISO should change its requirements as necessary to be consistent with CPUC rules.The 20-minute requirement has notbeen adopted by any formal stakeholder process. The change is significant and the impactto DR participation as RA resources is unknown.

CAISO’s Proposal Discriminates against Demand Response

The proposed requirement justifies the new eligibility criteria of PDR and RDRR by citing “their unique use-limited nature” but offer no explanation for why these resources should be treated any differently than other use-limited resources. This change appears discriminatory because CAISO does not propose a similar requirement for other use-limited resources that may also be used to meet TOP-001 and TOP-004 NERC requirements. At a minimum, CAISO should explain why the use-limited nature of PDR and RDRR differs from the use-limited nature of other resources.

It continues to be our understanding, based on our experience across the country, that the TOP-001 and TOP-004 NERC requirements are consistent—30-minute rebalances of the system after a contingency event. However, no other ISO has applied these standards to a particular resource. Transferring CAISO’s requirement to meet NERC’s requirements to one resource type is discriminatory.

Imposing a 20-Minute Dispatch Notification Requirement is Unnecessary

CAISO argued for a 20 minute dispatch notification in the Long-Term Procurement Proceeding (LTPP) because they said they had no visibility or control over the amount of load modifying demand responsecapacity available. They never discussed application of this requirement to supply-side resources. Yet, as mentioned above, the CPUC has not adopted, and in fact they have rejected, a 20-minute dispatch requirement for DR resources to qualify as DR resources.

Supply-side resources in the wholesale market have a day-ahead and/or a real-time must-offer obligation. The CAISO will know how much DR is available and how much DR is scheduled to be dispatched as a supply-side resource. It is unclear if CAISO is requiring all DR resources that participate in its markets to be able to respond within 20 minutes or under what conditions. For example, would CAISO have the ability to override dispatch instructions received by the resource as a result of clearing in the day-ahead or real-time markets?

For all of the aforementioned reasons, an inappropriate process to incorporate a significant operational change to one type of resource without an opportunity for stakeholder input, creating a discriminatory operational requirement on one resource type, ignoring instructions from the CPUC as to process, applying a standard to supply-side DR resources, which will be obligated to offer the resource into the CAISO’s day-ahead and/or real-time markets, without knowing how that standard will interact with CAISO dispatch instructions relative to clearing in the day-ahead and real-time markets, the CAISO should not adopt this BPM change and should conduct a stakeholder process to discuss.

Melanie Gillette

Director, Western Regulatory Affairs

EnerNOC

Erika Diamond

VP and GM of Energy Markets

EnergyHub

Peter Dotson-Westphalen,

CEM |Market Development Director

CPower

Eric C. Woychik

Consultant for Comverge

Jennifer Chamberlin
Director Regulatory Affairs- Integrated Demand Resources

Johnson Controls

[1]Because of their unique use limited nature, RDRR and PDR resources must have a response time of 20 minutes or less and be able to sustain full output for a minimum of 4 hours to meet local capacity needs in accordance with NERC Reliability Standards (TOP-001, TOP-004), California ISO Planning Standards, Section VII, ISO Tariff Section 40.3.1.1. The 20 minute response time allows 10 minutes for operators to assess the contingency and trigger the RDRR and PDR resources, and complete necessary system adjustments within the required 30 minutes.

[2]