Comments of OhmConnect, Inc.
In Response to the Brant Local Demand Response Pilot November 8th,
2016 Meeting
Submitted by
Brian Kooiman
[email protected]
Company
Date Submitted
OhmConnect, Inc.
November 14, 2016
1. INTRODUCTION
OhmConnect, Inc. (OhmConnect) appreciates the opportunity to submit comments to the
Independent Electricity System Operator (IESO) on the Brant Local Demand Response
Pilot. We are excited that the pilot will include residential Demand Response (DR), and look
forward to offering our experience gained through participation in the California Demand
Response Auction Mechanism (DRAM). Our comments in this document focus on two main
items:
1. Aggregation of residential customers
2. Third party access to Smart Meter data
2. OVERVIEW OF OHMCONNECT
OhmConnect is a third-party Demand Response Provider (DRP) founded in 2013 and
headquartered in San Francisco, California. The company currently provides DR services to
residential retail electric customers in California pursuant to the California Public Utility
Commission’s (CPUC) Rule 24/32. OhmConnect’s free software service notifies households
of DR events and pays them for their energy reductions, without requiring purchase or
installation of additional hardware. OhmConnect is registered to participate as a DRP in the
wholesale electricity market operated by the California Independent System Operator
Corporation (CAISO),1 and is one of the largest residential participants in the California
DRAM. OhmConnect has witnessed outstanding growth in California with over 1000%
year-over-year customer growth and is currently reducing dozens of MWs in California on
a regular basis.
1 See list of CAISO Demand Response Participants; available at
https://www.caiso.com/Documents/ListofDemandResponseParticipants.pdf.
3. COMMENTS
3.1. Aggregation of Residential Customers
According to the “Brant Local Demand Response (DR) Pilot RFP & Service Agreement”
presentation dated November 8, 2016, the LDCs for the Brant Area are Energy+, Brantford
Power and Hydro One Distribution. 2 However, the “Eligibility Requirements” indicate that
Contributors must be supplied by either the Brant TS or the Powerline MTS. 3 Can the IESO
confirm that all residential customers served by Energy+, Brantford Power, and Hydro One
are eligible for participation? OhmConnect also seeks clarification as to whether aggregated
customers within a resource must be served by the same LDC in addition to being located
in the same zone. In order to build a robust resource capable of meeting the 1 MW
threshold, we encourage the IESO to allow Providers to aggregate customers across LDCs.
Furthermore, we are curious whether the requirement that resources must “have a
Demand Response Capacity greater than or equal to 5% of the Maximum Facility Load” 4
would apply to resources comprised entirely of residential Contributors, and if so how the
Maximum Facility Load will be calculated.
OhmConnect additionally seeks clarification regarding the “Proposal Form” component of
the “Proposal Package.” The “Request for Proposals” October 13, 2016 Draft notes the
following:
“Each Proposal must include Contributor Confirmations in respect of
Demand Response Contributors totalling the Demand Response Capacity.
The Demand Response Capacity of any proposed Demand Response
Contributor for which the Proposal does not include an executed Contributor
Confirmation shall be excluded for the purposes of determining the Demand
Response Capacity of the Project.” 5
To clarify, would residential Providers have to submit each residential household it plans
to include in its resource to the IESO at the time of the Proposal submission (no later than
January 13, 2017)? This requirement would provide an added challenge to residential DR,
because residential Contributors are able to move in and out of LDCs. Therefore,
OhmConnect’s pool of Contributors will likely look different at the time of delivery
compared to the time of the Proposal submission. We ask that the IESO allow residential
DR to submit a list of Contributors two weeks prior to the month of delivery, and allow the
2 See November 8th, 2016 “Brant Local Demand Response (DR) Pilot RFP & Service Agreement” presentation,
at slide 4; available at http://www.ieso.ca/Documents/consult/BrantLocalDRPilot/BLDR-20161108Presentation.pdf.
3 Ibid., at slide 7.
4 Ibid., at slide 8.
5 See October 13th, 2016 “Request for Proposals for 3.0 MW to 15.0 MW of Demand Response in the Brant
Area” draft, at p. 5; available at http://www.ieso.ca/Documents/consult/BrantLocalDRPilot/BLDR20161013-Draft-RFP.pdf.
2
list of Contributors to change each month so that the residential DR Providers can update
their Contributor lists based on residents moving.
Finally, the Demand Response Working Group (DRWG) presentation on September 30,
2016 indicated that at this time only single-family homes will be eligible to participate as
Contributors to a DR resource in the December auction. 6 OhmConnect asks that the IESO
clarify whether this requirement will also apply to the Brant Pilot. We encourage the IESO
to extend eligibility to all end-users who have Smart Meters. OhmConnect agrees that the
Smart Meters are an essential component to participation, since they provide the necessary
hourly meter data. However, we believe that customers in multi-unit dwellings can also
successfully contribute to our program, which encourages behavioral responses to DR
events. In addition, limiting eligibility to single-family homes will add another verification
step, which could slow the registration process.
3.2. Third Party Access to Smart Meter Data
The “Brant Local Demand Response (DR) Pilot RFP & Service Agreement” presentation
noted that “[f]or Virtual Contributors, Measurement Data must be submitted to the IESO for
each Settlement Month in accordance with the timelines and in the format specified.” 7
OhmConnect appreciates the opportunity to reiterate here what has been discussed within
the DRWG: an established process to provide meter data in a timely fashion is needed to
avoid creating barriers to integration of the DR resource into the IESO. The DRWG has
stated that the IESO is working to “facilitate access to data from the Smart Metering data
repository”, but that “[a]ccess to this data likely will require direct partnership between
participants and LDCs in order to provide the necessary meter data.” 8 We are concerned
that if the Measurement Data required for the Brant Pilot is similar to the data needed for
participation in the DRWG auction, then the same data acquisition challenges will apply.
Our understanding is that some customers may have access to this meter data through
“Green Button Download My Data”, and we wonder if the necessary Measurement Data
(along with Contributor information) can be collected using this tool. However, not all of
the LDCs in the Brant Area currently have the “Download My Data” capability. Therefore,
another technological solution could entail (with Contributor permission) direct access to
the Smart Meter repository. Without either of these solutions in place, or an alternative
streamlined process to access Contributor meter data, residential Providers will struggle to
integrate their resources.
In California, DRPs were in some cases unable to receive customer data from the utilities in
a timely fashion, which slowed the ability of market participants to deliver on their DRAM
contracts. To address this, a clause exists in the contracts for delivery that allows market
participants to adjust downwards the planned capacity at no penalty if certain limitations
6 See September 30th, 2016 “Residential DR Baseline” presentation, at slides 18; available at
http://www.ieso.ca/Documents/consult/drwg/DRWG-20160930-Residential-DR-Baseline.pdf
7 “Brant Local Demand Response (DR) Pilot RFP & Service Agreement” presentation, at slide 20.
8 “Residential DR Baseline” presentation, at slide 17.
3
occurred.9 We suggest that the IESO withhold from penalizing companies if DR Providers
are unable to meet their capacity obligation due to events outside of their control that
prevent access to Smart Meter data. Alternatively, the IESO could adopt the approach
currently used in the California DRAM whereby Providers can reduce their capacity if they
are unable to register all of their Contributors with the System Operator. We note that
OhmConnect also supports protection of the buyer through punitive penalties for nonperformance. Furthermore, we encourage the IESO to develop a process that clearly
outlines what customer information is required to gain access to Smart Meter data, and to
whom the DRMPs should submit that information.
4. CONCLUSION
OhmConnect thanks the IESO for considering our comments. The IESO staff has been
exemplary in their commitment to incorporating residential DR through both this Pilot and
in the upcoming December auction, and we are very appreciative of their efforts. We hope
that our comments provide additional helpful perspective as a residential DR Provider.
9 The Joint Advice Letter filed by the three California investor-owned utilities (IOUs) seeking approval of the
2018 California DRAM stipulates under Section 1.5b of the attached pro forma DRAM Purchase Agreement
that DR Sellers may reduce their contracted monthly capacity obligations if they are unable to register their
resources for reasons demonstrably beyond their control. Available at
https://www.sce.com/NR/sc3/tm2/pdf/3466-E.pdf.
4