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CPUC Resource Adequacy Workshop

CPUC Resource Adequacy Workshop. Mona Tierney-Lloyd. January 18, 2011. Agenda. Determination of RA Capacity Load Impacts vs. Registered Capacity MCC Buckets Where does DR belong? BUGs in PDR. Qualifying Capacity (QC) Methodology for PDR.

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CPUC Resource Adequacy Workshop

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  1. CPUC Resource Adequacy Workshop Mona Tierney-Lloyd January 18, 2011

  2. Agenda • Determination of RA Capacity • Load Impacts vs. Registered Capacity • MCC Buckets • Where does DR belong? • BUGs in PDR

  3. Qualifying Capacity (QC) Methodology for PDR • EnerNOC supports registered capacity as a basis for QC for RA • Characteristics of a Suitable QC Methodology for PDR • Transparent • Comparable to Methodologies for Generation Resources • Comparable to Methodologies Adopted for DR Resources in Other Markets • Comparable to Manner in Which DR is Compensated • Appropriate Financial Incentives Drive Performance • D.10-06-036 agreed that dispatchable DR with comparable performance incentives and availability as supply resources should use a comparable methodology for determining qualifying capacity. Until those resources exist, continue to use LIPs. (C of L 12) • FERC has approved PDR in July 2010 • CPUC has approved Pilot Participation in PDR December 2010 • Expect CPUC to resolve outstanding issues regarding participation in PDR in Docket R.07-01-041 in 2011

  4. PDR Overview • CAISO PDR Proposal Submitted to FERC in February 2010 • Conditionally adopted by FERC in July 2010 • Provides for DR Participation in day-ahead, real-time energy markets and non-spinning reserves • DRPs register the resource including the load reduction capability • Historical data so as to permit the calculation of a resource baseline • Executed a PDR Agreement with CAISO • DRPs must post credit and agree to abide by the CAISO Tariff • Attest that the DRP is not prohibited by the RERRA and meets requirements • Identify the associated LSE • Identify the associated SC • Performance is validated through use of settlement-quality data and the baseline • Aggregated baseline for PDR using a 10-in-10 day with a 20% capped day-of adjustment • Payment is based upon the performance multiplied by the sub-LAP price for day-ahead and real-time energy

  5. RA Capacity Qualification Requirements • CAISO PDR Application to FERC (II. G. ) states that PDR qualifies for RA, as does PL, if it meets the following criteria: • Available for at least 4 hours/month • Minimum of 30 minutes/event/month • Capacity based upon the average performance/month during the availability period using a 3-year rolling average • CPUC Qualifications • Dispatchable • Available for a minimum of 48 hours over the summer months • Capacity is determined using Load Impact Protocols • Regression analysis incorporates weather and load response

  6. Comparison of QC Methodologies • Dispatchable Generation (See Section 5 CAISO Reliability Requirement BPM) • SC submits a QC along with a Pmax Test to CAISO • Pmax tests are scheduled at a time selected by the SC • So long as QC is less than Pmax and deliverability, then QC is adopted • Otherwise, previous NQC is adopted • PJM-RPM • Registered capacity is the basis for DR Capacity Payments • Availability Requirement: • Minimum of 10 events up to 6 hours/event • June-September; noon-8 PM • ISO-NE FCM (Section III.13.1.4) • Registered capacity • Includes location, summer/winter reductions, whether it is on-peak, critical peak, etc., types of end-use and estimates of reduction per type of end-use

  7. Comparison of QC Methodologies • MISO • Registered Capacity for LMRs (Load Modifying Resources) or DRRs (Demand Response Resources) • LMRs available for a minimum of 5 events for up to four hours/event during the summer months • Failure to provide the registered capacity results in a deficiency charge; twice results in disallowance to participate in the balance of the current and future planning year • DRRs participate in energy and ancillary services markets and qualify for resource adequacy. • NYISO • Special Case Resources (SCRs) • SCRs are DR or BTMG • Unforced capacity=pledged capacity adjusted for historical performance (test or event performance)

  8. Maximum Cumulative Contribution (MCC) Categories • MCC 1 is 210 hours between May and September (Use-Limited Resources) • MCC 2 is >/=160 hours/month • MCC 3 is >/= 384 hours/month • MCC 4 is all hours • EnerNOC suggests that none of these categories are appropriate for DR as even MCC 1 far exceeds the availability requirements of the CPUC’s current RA requirements for retail DR or the requirement to be available for a minimum of three consecutive days for four hours/day.

  9. BUGs in PDR • EnerNOC supports the participation of BUGs, that meet air emissions requirements, in PDR and counting toward RA • Many jurisdictions include BUGs as a DR measure, albeit with air emissions restrictions. • Can the Commission restrict the use of BUGs in PDR? • BUGs can achieve many energy policy goals: • DG is part of the loading order • BUGs can reduce on-system demand or act as a supplemental resource • Net generators would have additional requirements • BUGs can support the transmission and distribution system reliability • BUGs can displace less efficient generation or need for new central-station generation by using existing brownfield resources • With PCDs and limited dispatch, relatively environmentally benign

  10. Mona Tierney-Lloyd P. O. Box 378Cayucos, CA 93430Tel: 415.238.3788Email: mtierney-lloyd@enernoc.com

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