Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.2: Add tariff provisions
identifying general responsibilities of
Distributed Energy Resource Providers,
including a requirement that
Distributed Energy Resource Providers
must comply with applicable utility
distribution company tariffs,
requirements of the applicable Local
Regulatory Authority, if any.
Stakeholder Comment
SCE comments that the ISO should include language
to reflect that Distributed Energy Resource Providers
will also ensure Distributed Energy Resources that
comprise a Distributed Energy Resource Aggregation
comply with applicable tariffs to any wholesale usage
of the distribution system of a Utility Distribution
Company to which the Distributed Energy Resources
are interconnected.
1
ISO Response
The ISO will add language
section 4.17.2 to state that
“Each Distributed Energy
Resource Provider will ensure
that the Distributed Energy
Resources that comprise its
Distributed Energy Resource
Aggregation(s) comply with
applicable Utility Distribution
Company tariffs and applicable
requirements of the Local
Regulatory Authority, if any. “
It is not necessary to specify
specific tariffs of utility
distribution companies. These
tariffs will apply on their own
terms.
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.3: Add tariff section
identifying general requirements of
Distributed Energy Resource
Aggregations, including a requirement
that a Distributed Energy Resource
Aggregation that includes may not also
participate as a separate ISO Metered
Entity resource.
Stakeholder Comment
SCE comments that the ISO should clarify that a
Distributed Energy Resource participating in a
Distributed Energy Resource Aggregation may not
participate in a program under which it sells power to
its interconnected Utility Distribution Company under
the Public Utility Regulatory Policies Act.
2
ISO Response
The ISO has not adopted a
specific policy to exclude these
Distributed Energy Resources
from participating in a
Distributed Energy Resource
Aggregation. At this time, the
ISO believes the issue SCE
raises is a matter for
appropriate regulatory
authorities. Utility distribution
companies may want to
aggregate these Distributed
Energy Resources into an
aggregated resource for
purposes of participating in the
ISO’s market.
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.3: Add tariff section
identifying general requirements of
Distributed Energy Resource
Aggregations, including a requirement
that a Distributed Energy Resource
Aggregation that includes Distributed
Energy Resources located at one
PNode may consist of Distributed
Energy Resources that are different
resource types, so long the
Aggregation provides a net response at
it PNode that is consistent with ISO
Dispatch Instructions.
Section 4.17.3: Add tariff section
identifying general requirements of
Distributed Energy Resource
Aggregations, including a requirement
that a Distributed Energy Resource
Aggregation that includes Distributed
Energy Resources located at multiple
PNodes may consist of Distributed
Energy Resources that are different
resource types, so long as the
Aggregation provides a net response at
it PNode that is consistent with CAISO
Stakeholder Comment
PG&E comments that the phrase “different resource
types” is vague and asks what are the eligible
resource types?
ISO Response
The ISO has deleted the phrase
“different resource types” from
the proposed tariff language.
The ISO intended the plain
meaning of the phrase to apply,
but no longer believes it is
necessary to include in the
tariff because the ISO does not
propose to impose any limits
on the resource types that
comprise a Distribution Energy
Resource Aggregation.
PG&E comments that the phrase “different resource
types” is vague and asks what are the eligible
resource types? PG&E also comments that this
proposal is not consistent with limitations approved
by the Board of Governors on July 16, 2015 that
required Aggregations that operate across multiple
PNodes to include homogenous sub-resources and
for those sub-resources to move in a uniform
direction in response to ISO Dispatch Instructions.
The ISO has deleted the phrase
“different resource types” from
the proposed tariff language.
The ISO intended the plain
meaning of the phrase to apply,
but no longer believes it is
necessary to include in the
tariff because the ISO does not
propose to impose any limits
on the resource types that
comprise a Distribution Energy
Resource Aggregation.
3
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Dispatch Instructions and with
applicable Generation Distribution
Factors
Stakeholder Comment
ISO Response
PG&E is correct that the tariff
language as drafted is not
consistent with limitations
approved by the Board of
Governors on July 16, 2015.
ISO Management plans to
recommend that the Board
eliminate these limitations at
the Board’s November 2015
meeting. The ISO requests
stakeholders provide any
comments on this proposal as
part of this tariff stakeholder
drafting initiative. In the latest
draft tariff revisions, the ISO
has consolidated language to
reflect that Distributed Energy
Resource Aggregations must
provide a net response at the
PNode level consistent with
dispatch instructions and
applicable generation
distribution factors.
4
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.4: Add tariff section to
specify requirements for Distributed
Energy Resource Providers to provide
information concerning Distributed
Energy Resource aggregations.
Stakeholder Comment
PG&E comments that the ISO should include tariff
language to require Distributed Energy Resource
Providers to identify the location/Point of
Interconnection of its Distributed Energy Resource
Aggregations. PG&E also requests that the ISO clarify
how often an Aggregation may adjust its Generation
Distribution Factors.
ISO Response
The ISO has included language
to require Distributed Energy
Resource Providers to identify
the location of its Distributed
Energy Resource Aggregations.
The location of an aggregation
will be important to
understand how to model the
resource. The location,
however, may not in all cases
reflect the points of
interconnection of each
Distributed Energy Resource
comprising the Aggregation.
The ISO intends to allow
scheduling coordinators for
Distributed Energy Resource
Aggregations to adjust their
Generation Distribution Factors
as part of their resource bids.
5
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.5.2: Add tariff section
identifying metering and telemetry
requirements for Distributed Energy
Resource Aggregations
Stakeholder Comment
PG&E comments that the ISO should revise the tariff
language to require that Distributed Energy Resource
participating in a Distributed Energy Resource
Aggregation must use meters that comply with the
tariff of the utility distribution company as well as the
metering standards set forth in the ISO’s tariff for
business practice manual. PG&E asks if the ISO plans
to specify its technical requirements for direct
metering and, if so, in what document?
SCE comments that the ISO should revise the tariff
language to require that Distributed Energy Resource
participating in a Distributed Energy Resource
Aggregation to use meters that comply with the
wholesale distribution tariff of the utility distribution
company.
6
ISO Response
The ISO plans to defer to local
regulatory authorities rules for
metering standards for
purposes of directly metering
Distributed Energy Resources
that participate in an
aggregation. To the extent a
utility distribution company’s
tariff applies metering
standards to a Distributed
Energy Resource that seeks to
participate in a Distributed
Energy Resource Aggregation,
that tariff will apply on its own
terms. The ISO will have
default metering standards if a
local regulatory authority has
not adopted metering
standards for distributed
energy resources. These
standards will appear in the
ISO’s Business Practice Manual
for metering.
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 4.17.6: Add provisions
describing general operating
requirements of Distributed Energy
Resource Providers and Distributed
Energy Resource Aggregation.
Stakeholder Comment
ISO Response
The ISO has also added
additional language to this
section to clarify that
Scheduling Coordinators shall
submit to the ISO Actual
Settlement Quality Meter Data
or Scheduling Coordinator
Estimated Settlement Quality
Meter Data for Distributed
Energy Resource Aggregations
they represent for each
Settlement Period in an
Operating Day.
PG&E comments that the ISO should clarify that it can The ISO has incorporated
dispatch Distributed Energy Resource Aggregations
clarifying language into section
based on market awards.
4.17.6 in response to PG&E’s
comments that it will dispatch
PG&E also comments that the ISO has not identified
resources based on market
all sections of the tariff that may be applicable to
awards. With respect to tariff
Distributed Energy Resource Aggregations (e.g.
provisions related to resource
provisions related to resource adequacy deliverability adequacy deliverability for
or market power mitigation rules).
Distributed Energy Resources
Aggregations, the ISO plans to
examine this issue in a
subsequent stakeholder
7
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Stakeholder Comment
Section 10.3.2.1.1: Reformat existing
PG&E comments that tariff revisions associated with
tariff language that applies to Demand this initiative should not address Demand Response
Response Providers in order to clarify
Providers.
what tariff provisions for scheduling
coordinator metered entities apply to
scheduling coordinators for Demand
Response Providers as opposed to
scheduling coordinators for Distributed
Energy Resource Aggregations.
8
ISO Response
initiative. With respect to
market power mitigation rules,
Distributed Energy Resource
Aggregations will be subject to
all rules that apply generally to
market participants (e.g.
maximum energy bid price).
The ISO will explore in
subsequent initiatives whether
additional market power
mitigation rules are necessary
to apply specifically to
Distributed Energy Resource
Aggregations.
The ISO has reformatted tariff
section 10.3.2.1 to clarify which
provision apply to scheduling
coordinators for Demand
Response Providers as opposed
to scheduling coordinators for
Distributed Energy Resource
Aggregations. In addition, the
CAISO has made a clarifying
change to the tariff provisions
related to Scheduling
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Stakeholder Comment
ISO Response
Coordinators for Demand
Response Providers. This
clarification provides an
introductory section that
applies to Scheduling
Coordinator Metered Entities
and then a separate section
each for Demand Response
Provider and Distributed
Energy Resource Providers with
specific rules that would apply.
The ISO also clarified section
10.3.2.1.1 by cross referencing
Section 10.1.7(3), which refers
to using statistically derived
meter data as an alternative for
Settlement Quality Meter Data.
9
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Section 30.5.2.6: Add tariff provisions
identifying specific bidding rules for
Distributed Energy Resource
Aggregations.
Stakeholder Comment
PG&E asks the ISO to clarify whether Scheduling
Coordinators for Distributed Energy Resource
Aggregations may change their generation
distribution factors on a bid-by-bid basis.
Appendix A: Add definition to
Appendix A for Distributed Energy
Resource as follows:
SDG&E comments that the ISO should modify
definition of Distributed Energy Resource in order to
address the potential that resources interconnected
using a Rule 21 interconnection process may attempt
to join a Distributed Energy Resource Aggregation:
Any resource with a first point of
interconnection to a Utility
10
ISO Response
The ISO intends to allow
Scheduling Coordinators to
modify generation distribution
factors for Distributed energy
Resource Aggregations through
their bids. The ISO has also
modified language in section
30.5.2.6 to reflect that the ISO
will use default generation
distribution factors for
Distributed Energy Resource
Aggregations to the extent that
a scheduling coordinator does
not submit them with its bid.
The ISO has also made changes
to this section to reflect that
ISO’s market software will not
commit Distributed Energy
Resource Aggregations.
The ISO plans to refer
generically to a resource in the
definition of distributed energy
resource. A utility distribution
company’s tariffs apply on their
own terms to Distributed
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Distribution Company or a Metered
Subsystem.
Stakeholder Comment
SCE comments that the ISO should define a
Distributed Energy Resource as a non-demand
response resource interconnected using a utility
distributed company wholesale distribution tariff, if
the utility distribution company is subject to FERC
jurisdiction. SCE also comments that the ISO should
define a Distributed Energy Resource to exclude
resources receiving interconnection service under a
CPUC Rule 21 interconnection agreement.
PG&E offer clarifying amendments to the ISO’s
proposed definition but PG&E states it does not
support allowing behind the meter customer
resources to participate in a Distributed Energy
Resource Aggregation.
Appendix B.21: Add pro forma
Distributed Energy Resource Provider
Agreement to tariff
SCE comments that the ISO should incorporate
language into section 4.1.1 concerning application of
utility wholesale distribution access tariffs to
Distributed Energy Resources that participate in an
Aggregation. SCE also identifies several typographical
errors
11
ISO Response
Energy Resources seeking to
participate in a Distributed
Energy Resource Aggregation.
The ISO is proposing to require
Distributed Energy Resource
Providers must comply and
must ensure Distributed Energy
Resource participating in an
aggregation also comply with
applicable utility distribution
company tariffs.
The ISO has incorporated
language in proposed tariff
section 4.17.2: “Each
Distributed Energy Resource
Provider will ensure that the
Distributed Energy Resources
that comprise its Distributed
Energy Resource Aggregation(s)
comply with applicable Utility
Distributed Energy Resource Provider Initiative
Matrix of Tariff Stakeholder Comments and Additional ISO Language
Proposed Tariff Changes
Stakeholder Comment
12
ISO Response
Distribution Company tariffs
and applicable requirements of
the Local Regulatory Authority
….” It is not necessary to
identify the specific tariff of
utility distribution companies.
These tariffs will apply on their
own terms. The ISO has
incorporated SCE’s additional
typographical edits.