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Participation In ERCOT Aggregated Distributed Energy Resource Pilot To Be Done Through Retail Electric Providers

October 6, 2022

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Copyright 2010-21
Reporting by Paul Ring •

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During a Texas PUC open meeting, Commissioner Will McAdams said that a proposed governing document, to be presented to the ERCOT board for approval later this month, would require that (in areas with customer choice) retail electric providers will be the entities aggregating customers under the first phase of a pilot Aggregate Distributed Energy Resources (ADER) program in the ERCOT market

"REPs will be the ones aggregating their customers, ensuring that customer protection rules apply," McAdams said in discussing the proposed governing document

Given the nature of the market design, the proposed governing documents reflect that QSEs will be entering into the ADER program (and, in general, a QSE does not necessarily need to be a REP), but a specific aggregation of premises to be an ADER must all have the same LSE, and thus, in effect, REPs will be the responsible entities for aggregating customers as McAdams said (there would not be a non-QSE or non-LSE option)

After any ERCOT board action, the PUC will also vote on the program. However, no Commissioners during an open meeting discussion today expressed disagreement with the approach to using REPs to aggregate customers

The proposed first phase of the pilot would be as follows:

• An ADER for purpose of this first phase of the Pilot Project will be modeled as a Load Resource and is an aggregation of Premises, where all the sites are located within a single Load Zone and have the same LSE and DSP. Each Premise within an ADER may be net load or net generation. The aggregation must have the capability to provide at least 100 kW of response (Demand response capability plus injection capability) and each Premise must provide 1 MW or less of response (Demand response capability plus injection capability). Premises or aggregations that are otherwise able to participate in the ERCOT market (e.g., as a DGR, DESR, SODG larger than 1 MW, or ALR) should not be included as part of an ADER. The ADER’s performance should always be represented as a net Load for purposes of telemetry and other market submissions to ERCOT.

• For the initiation of Phase 1 of the Pilot Project, the total registered MW capacity of all the ADERs must be no greater than 80 MW system wide. These ADERs will be limited to providing no more than 40 MW of Non-Spin system wide. As part of the “Details of the Aggregation” provided to ERCOT, the QSE shall indicate the anticipated MW capacity that is intended to be registered as well as an amount of Non-Spin for which the QSE is intending to qualify the ADER. These ADER MW quantities will be evaluated against these ERCOT Pilot Project participation limits. Additionally, no QSE will be allowed to register more than 20% of these system-wide limits.

• To allow for participation to be dispersed across the ERCOT region, these system-wide limits will initially be ratio-shared by Load Zone, including Competitive and Non-Opt-In-Entity (NOIE) Load Zones, with a Load Zone’s share based on net Load Zone demand coincident with ERCOT system peak for August 2022, as provided in the Demand and Energy Monthly Reports published by ERCOT.

• These ERCOT Pilot Project participation limits will be enforced as part of ERCOT’s review of a QSE’s submission for participation.

• When participation exceeds 80% of the limits described above, ERCOT shall review with the ADER Task Force any reliability concerns with potential increases in the ERCOT Pilot Project participation limits. ERCOT may increase any of the imposed participation limits, at its sole discretion and in consultation with the ADER Task Forces, after evaluating performance during the Pilot Project. Such increases will not be considered amendments to this Governing Document, and therefore will not require approval by the ERCOT Board.

As proposed, for the first phase of this Pilot Project, ADERs will be treated as ALRs for all purposes under the Protocols and will register and participate under the existing ALR participation model. ADERs must be registered and participate as ALRs except as follows:

• An ADER is allowed to have Premises that can inject energy into the distribution system, and an ADER may provide a net injection on an aggregated basis. A net injection from an ADER in response to an ERCOT Dispatch Instruction will be considered Demand response under the Protocols and other ERCOT rules. Any Premise with the potential to export energy beyond its Premise meter must have the correct meter profile code set, for meters in service territories where that is applicable, such that both the import and export channels of its Premise meter are provided to ERCOT.

• ADER withdrawal telemetry values must represent the sum of the consumption and export of each of the member Premises or devices plus any necessary MW offsets, as described in this Governing Document. Maximum Power Consumption and Low Power Consumption values must be modified to accommodate ADERs, as further provided in this Governing Document. An ADER using device-level telemetry must comply with the validation process for device-level telemetry provided in this document instead of existing validation rules.

• An ADER is not permitted to present statistical sampling for performance evaluation.

• The Resource Entity and QSE for the ADER are jointly responsible for maintaining ADER population information, as further described in subsection 5.c.3.

• ADERs will have Pilot Project-specific modeling and ERCOT Pilot Project participation limits.

• ERCOT will not use baseline evaluation for either qualification or performance validation purposes during the Pilot Project. Qualification and performance validation specific to the Pilot Project is described in subsection 5.c.4.

• Scheduled Power Consumption (SPC) +2 information will not be required to be provided for an ADER, as it is for an ALR.

• The telemetry validation procedures and metrics for ADERs are distinct from those for ALRs and are described in subsection 5.d.

• For Phase 1 of the Pilot Project, ADERs are encouraged to, but will not be required to, provide Primary Frequency Response (PFR), as is required for ALRs. This exception is specific to Phase 1 and may not be granted for future phases. ADERs unable to provide PFR may be considered for potential, alternative participation models in future phases, such as a participation model in which the aggregation may provide some Ancillary Services but is not dispatchable by Security-Constrained Economic Dispatch (SCED).

Other notable proposed provisions include:

• Following ERCOT’s acceptance of the QSE’s submission for a given ADER:

-- ERCOT shall provide the MW offset to be used to register as a CLR and operate as a net load under all circumstances, in terms of telemetry and other market submissions to ERCOT

-- The Resource Entity must register the ADER as a CLR with ERCOT using a load RARF, available here.

-- The location of an ADER in the Network Model will be identified by its Resource Dispatch Asset Code and the associated CIM Load in the model. Consistent with current practice for distribution-level single-site Load Resources, the DSP, in collaboration with ERCOT and the interconnecting TSP, if necessary, will assign each ADER to a CIM Load.

-- The total response capability of all ADERs assigned to any single CIM Load shall be capped at 100% of the rating of the CIM Load. The rating of a CIM Load is defined as the value estimated by the ERCOT State Estimator for that CIM Load at the time of the ERCOT historic coincident peak Demand.

• The telemetry and other market submissions for a registered ADER must always show the ADER as a net consumer of energy. This may require use of an offset, which will be a static MW value provided by ERCOT, as earlier described. Regardless of use of the MW offset, it will be acceptable if individual Premises that are components of the aggregation are net injectors of energy, based on TDSP metering at the Premises. In the future ERCOT plans to introduce an ADER participation model that can inject and withdraw in aggregate to and from the grid, in which the use of the MW offset would no longer be necessary.

• The ADER shall be registered and associated with a QSE.

The PUC agreed with a PUC Staff recommendation that the PUC shall develop a registration form, for ADERs registered with ERCOT to also register with the Commission as part of the pilot. This will be a "streamlined" process, and avoid the need for each premise to itself register as a power generation company (PGC)

Commission Staff agrees with the Task Force' s recommendation and proposes to develop a form for ADERs registered with ERCOT to also register with the Commission.

As previously reported, Tesla was a driver for creation of a pilot (which is open to all eligible stakeholders up to the caps noted above), and Tesla has created its own REP (see background here)

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