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Manual Revisions for Enhanced Storage Participation & FERC Order No. 841 Compliance

Proposed manual revisions to conform to revised tariff, address participant concerns, and enhance storage facility participation in New England wholesale electricity markets.

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Manual Revisions for Enhanced Storage Participation & FERC Order No. 841 Compliance

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  1. June 10-12, 2019 I NEPOOL Markets Committee Catherine McDonough 413.535.4027| cmcdonough@iso-ne.com Manual Revisions to conform to revised Tariff, address Participant concern, and clean up Enhanced Storage Participation & FERC Order No. 841 Compliance

  2. Enhanced Storage Participation & FERC Order No. 841 Compliance WMPP ID: 122 & 129 Proposed Effective Date: Immediately upon PC approval and December 3, 2019 Tariff changes enhancing ability of electric storage facilities to participate in the New England wholesale electricity markets have two different effective dates • Enhanced Storage Participation Changes (WMPP ID: 122) became effective on April 1, 2019 • Additional FERC Order No. 841 Compliance Changes (WMPP 129) will become effective on December 3, 2019 (Pending approval from FERC) In addition to the manual changes required to conform to the above mentioned tariff changes, the ISO is proposing an implementation change to Market Operations Manual (M-11) to address a participant concern regarding the maximum discharge limit of Electric Storage Facilities (ESFs) with less than one hour of Available Energy (AE) • The ISO is also proposingclean-up changes as a part of this package

  3. Summary of Manual Changes • Market Operations (M-11) • Flexible option for ESF participants to discharge more quickly • Enhanced Storage Participation conforming and clean-up changes • Forward Capacity Market (M-20) • Enhanced Storage Participation conforming and clean-up changes • Forward Reserve Market (M-36) • FERC Order No. 841 conforming change • Regulation Market (M-REG) • Enhanced Storage Participation conforming and clean-up changes • Registration and Performance Auditing (M-RPA) • Enhanced Storage Participation and FERC No. 841 conforming and clean-up changes

  4. Market Operations Manual (M-11) Flexible Option for ESF Participants to Discharge More Quickly

  5. Flexible Option for ESF to Discharge More Quickly Under the current Electric Storage Facility (ESF) rules, the Economic Maximum Limit must be set to comply with the NPCC’s one hour sustainability requirement for reserves An ESF with less than one hour of available energy (AE) must request a self-dispatch to fully discharge their facility within an hour (even when their Supply Offer is economic) Participants have proposed that an ESF with less than one hour of AE be able to opt out of providing reserves so its Economic Maximum Limit can be set to discharge its facility more quickly ISO is proposing to modify its market operation procedures to enable ESFs with less than one hour of AE to set their Economic Maximum Limit based the output that can be sustained for 15 minutes (rather than one hour) and decline to provide reserves

  6. Market Operations Manual (M-11)Flexible Option to Discharge ESF More Quickly • Added New Provision 2.2.3.1 (15)(b)(iii): “Re-declarations of the Economic Maximum Limit for Electric Storage Facilities reasonably expected to have less than one hour of Available Energy may, by request of the Designated Entity called into the Control Room Generation Desk, reflect an energy output that can be sustained for 15 minutes (rather than one hour). Once such a request is approved, the facility’s Generator Asset and DARD will not receive Real-Time Reserve Designations. An approved request will remain in effect until the Designated Entity calls to cancel the request; up to one call to initiate a request and one call to cancel a request are permitted each Operating Day.” * This change is associated with the December 3, 2019, effective date.

  7. Market Operations (M-11) Conforming and Clean-up Changes

  8. Market Operations Manual (M-11)CSF-specific Conforming Changes • Added provisions to indicate that the re-declaration of the Maximum Consumption Limit and Economic Maximum Limit for a Continuous Storage Facility (CSF) will be performed automatically based on data telemetered to the ISO by participants (2.2.2.1 (10)(b)(i) and 2.2.3.1 (15)(b)(ii)) • Added subsequent provisions that CSF participants can call the Control Room to manually revise these limits if the automatic process does not accurately reflect their limits • Added provision that a CSF DARD and Generator Asset must be self-scheduled to participate in the DAEM or RTEM (revised 2.2.2.1 (11) and 2.2.3.1 (7))

  9. Market Operations Manual (M-11) DARD-specific Conforming Changes • Removed text that refers to the DAEM bidding requirement for DARDs (1.3.1 and 2.2.2.1(8)) and removed imprecise related language (2.2.2.1(7)) • Added language to describe the DARD redeclaration process, to parallel the existing Generator Asset redeclaration language (2.2.2.1(10)) • Added caveat that provisions that relate to the Nominated Consumption Limit (NCL) do not apply to Storage DARDs (ISO does not establish or audit NCLs for Storage DARDs because they can be dispatched off at any time) (revised 2.2.2.1(11)) • Removed Offered Claim10 and Claim30 as component of valid Demand Bid for ARDs (can only supply reserves when on-line) (2.2.6(3))

  10. Market Operations Manual (M-11) DARD-specific Conforming Changes (cont.) • Expanded applicability of technical rules governing Demand Bids for DARD Pumps to include all Storage DARDs with a caveat that the Minimum Run Time and Minimum Down Time must be zero for CSF DARDs and can be up to one hour for Binary Storage Facility (BSF) DARDs (2.2.6(4)) • Added text to indicate that the Max Daily Starts Parameter is only applicable to BSF DARDs (2.2.6(4)) • Removed repetitive text related to self-scheduling DARDs (from 3.1.3) (this language is found in 2.2.2.1(9) and (10))

  11. Market Operations Manual (M-11)Recurring Clean-up Changes • Replaced acronym (e.g., spell out Reserve Adequacy Analysis) • Improved grammar • Deleted items that duplicate tariff provisions • Corrected statement of offer cap from $1,000 to $1,000/ MWh • Fixed tariff references • Renumbered provisions to accommodate new items • Replaced “Resource” with the specific asset type (e.g., Generator Asset) when the provision is only applicable to a specific asset type • Corrected headings to align with content (e.g., Technical Rules for Valid Demand Bids for Load Assets “other than Asset Related Demands”)

  12. Market Operations Manual (M-11)Recurring Clean-up Changes (cont.) • Clarified components of valid Supply Offers and valid Demand Bids (e.g., included “Availability” as component (already included in eMKT); removed nonexistent parameters; revised language describing default values) (2.2.6) • Created separate provision to describe the existing procedures for participants to re-declare physical state parameters

  13. Market Operations Manual (M-11)Additional Clean-up Changes

  14. Market Operations Manual (M-11)Additional Clean-up Changes (cont.)

  15. Market Operations Manual (M-11)Additional Clean-up Changes (cont.)

  16. Forward Capacity Manual M-20 & forward Reserve Manual M-36 Conforming and Clean-up Changes

  17. Forward Capacity Market Manual (M-20)

  18. Forward Capacity Market Manual (M-20) (cont.)

  19. Manual 36: Forward Reserve Market

  20. Regulation Market MANUAL (M-Reg) Conforming and Clean-up Changes

  21. Regulation Market Manual (M-REG)Recurring Changes • Conforming • Added that Regulation Resources are dispatchable Generator Assets (other than those associated with CSFs) or ATRRs that satisfy tariff Section III.14.2 (revised 1.1(1)) • Deleted sections that repeat the tariff and instead included tariff references (deleted 1.1(1) – 1.1(4); deletions from existing 1.1(5)(a),(b), and(f)); deletions from existing 2.3) • Clean-up • Added “Regulation Market” as a modifier to “Supply Offer”; used defined term “Regulation Resource”; added “Regulation” as a modifier to “dispatch methodology” • To clarify that these terms relate the regulation market (not to the energy or capacity markets) • Changed “Setpoint” to “SetPoint” (term used in tariff) • Improved grammar; removed redundant language • Re-numbered items to accommodate the removal of language that repeats tariff provisions

  22. Regulation Market Manual (M-REG)Additional Clean-up Changes

  23. Regulation Market Manual (M-REG)Additional Clean-up Changes (cont.)

  24. Regulation Market Manual (M-REG)Additional Clean-up Changes (cont.)

  25. Registration and Performance Auditing (M-RPA) Conforming and Clean-up Changes

  26. Registration and Performance Auditing (M-RPA)Conforming Changes

  27. Registration and Performance Auditing (M-RPA)Conforming Changes (cont.)

  28. Registration and Performance Auditing (M-RPA)Conforming Changes (cont.)

  29. Registration and Performance Auditing (M-RPA)Conforming Changes (cont.)

  30. Registration and Performance Auditing (M-RPA) Recurring Clean-up Changes • Improved phrasing • Replaced “registration form” with “registration” • Used acronyms for designated entity (DE) and designated demand entity (DDE) • Changed “Asset Registration Form” and “Attachment A” to “registration” • Corrected typos • Re-numbered sections

  31. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes

  32. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes (cont.)

  33. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes (cont.)

  34. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes (cont.)

  35. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes (cont.)

  36. Registration and Performance Auditing (M-RPA)Additional Clean-up Changes (cont.)

  37. Expected Stakeholder Schedule

  38. Acronyms Used in this Presentation • ARD – Asset Related Demand • ATRR – Alternative Technology Regulation Resource • AE – Available Energy (MWh) • BSF- Binary Storage Facility • CSF – Continuous Storage Facility • DAEM – Day-Ahead Energy Market • DARD – Dispatchable Asset Related Demand • DNE – Do Not Exceed • eMKT – eMarket • ESF – Electric Storage Facility • FERC – Federal Energy Regulatory Commission • NPCC – Northeast Power Coordinating Council • RTEM – Real-Time Energy Market

  39. Appendix: Manual Change Summary

  40. Summary of Manual Changes • Market Operations (M-11) • Implementation change to enable ESFs with less than one hour of AE to discharge more quickly by having their Economic Maximum Limit set based on the output that can be sustained for 15 minutes and opting out of providing reserves • Conforming changes to describe automatic re-declaration for CSFs and requirement that CSFs need to be self-scheduled at zero MW • Clean-up changes include description of current re-declaration process • Forward Capacity Market (M-20) • Conforming change to clarify that Coincident Peak Contribution for Storage DARDs is zero and to remove language referring to DAEM bidding requirement for DARDs • Clean-up • Forward Reserve Market (M-36) • Conforming change to lower minimum block size to 0.1 MW to comply with FERC Order No. 841 (December 3, 2019)

  41. Summary of Manual Changes • Regulation Market (M-Reg) • Conforming change to indicate that Regulation Resource can be a Generator Asset (other than one associated with a CSF) or an ATRR • Remove duplicate provisions and general clean-up • Registration and Performance Auditing (M-RPA) • Conforming changes to indicate that: • A CSF uses a single registration form • An ESF is represented by single Lead Market Participant and single dispatch location • An ESF has a minimum size of 0.1 MW (versus 1 MW) (effective December 3, 2019) • Storage DARDs are not subject to the rules for end-use load and NCL Audits • General clean-up • Replaced “registration form” with “registration” • Clarified description of obligations of DE/DDE

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