Frequency Response Straw Proposal Stakeholder Meeting

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1 Frequency Response Straw Proposal Stakeholder Meeting October 19, 2015

2 October 19, 2015 stakeholder meeting agenda Time Topic Presenter 1:00-1:05 Introduction Kim Perez 1:05-1:10 Updated schedule Kim Perez 1:10-1:45 ISO s Frequency Response Obligation compared to its performance 1:45-3:00 Phase 1, Near-term approaches for 2017 compliance period Cathleen Colbert and Jordan Curry Cathleen Colbert 3:00-3:45 Phase 2, Long-term approaches Cathleen Colbert 3:45-4:00 Next Steps Cathleen Colbert Page 2

3 ISO policy initiative stakeholder process POLICY AND PLAN DEVELOPMENT Issue Paper Straw Proposal Draft Final Proposal Board Stakeholder Input We are here Page 3

4 Phase 1 stakeholder schedule update Milestone Date Straw Proposal posted October 12, 2015 Stakeholder call on Straw Proposal October 19, 2015 Straw Proposal comments due November 2, 2015 Draft Final Proposal posted December 7, 2015 Stakeholder meeting on Draft Final Proposal December 14, 2015 Draft Final Proposal comments due January 4, 2015 Board of Governors meeting Feb 3-4, 2016 Page 4

5 ISO s Frequency Response Obligation compared to its performance Cathleen Colbert Jordan Curry Page 5

6 The ISO s share of WECC s Frequency Response Obligation Require each BA to provide its share of frequency response needed in the case of a WECC frequency event WECC s FRO is the minimum frequency response necessary to maintain system reliability in the event of the largest N-2 event California ISO s Estimated Requirement 2016 Units Size of the loss 2,626 MW Arizona trips load for this event (120) MW WECC stabilizes the system for this loss 2,506 MW Estimated ISO Allocation of WECC s IFRO ~30 Percent ISO Expected FRO ~752 MW Standard limits frequency deviation to Hz ISO FRO expressed in MW/0.1Hz ~258 MW/0.1Hz Page 6

7 ISO s Frequency Response Evaluation Frequency response (MW/0.1Hz): Change in Net Actual Interchange on tie lines with adjacent BAs divided by the change in interconnection frequency (0.1Hz) The ISO will report single event frequency response data for each event for at least 20 events determined by NERC NERC will determine if the ISO met the standard by comparing its FRM to its FRO estimated at ~258 MW/0.1Hz. FRM (MW/0.1Hz): The median value of the single event frequency response data reported to NERC FRO (MW/0.1Hz): BA s share of the required Frequency Response needed for the reliable operation of an Interconnection Page 7

8 % MW CAISO s Current Frequency Response ISO Frequency Response Analysis FR (MW) FRO (MW) FR/FRO (%) Figure 2 illustrates 30 disturbances sorted by increasing order of the ISO s FR/FRO measured by percentage on the right scale. The value of FR and FRO calculated by the ISO is measured by MW on the left scale. Over the time period shown, the ISO s FRM (i.e. median actual frequency response) was 85.3% of its FRO. Since NERC will consider the standard met if the actual frequency response is within 1% of the FRO, the ISO would not have met the requirements of BAL because its FRM is less than 99% of its FRO. Page 8

9 Phase 1, Near-term approaches for 2017 compliance period Cathleen Colbert Page 9

10 Frequency response initiative is to ensure sufficient frequency responsive headroom for 2017 The purpose of the initiative is to ensure sufficient frequency responsive headroom for 2017 ISO is looking at near term approaches because: ISO has not yet concluded the performance needed cannot be achieved absent a market product Not feasible to implement product by Fall 2016 release ISO will continue evaluating the ISO s performance through 2017 to determine if we need a product Page 10

11 Near-term Approaches Revise the tariff to include requirements for all participating synchronous generators with governor controls Develop look-ahead tools to assess the PFR capability of the system at various time horizons in the future based on current system conditions and if the look ahead indicates an anticipated deficiency of PFR the ISO can take actions to address the deficiency Revise the tariff to clarify the authority of the ISO to designate any reserve not previously identified as Contingency Only by a Scheduling Coordinator (SC) as Contingency Only reserves Include frequency response performance requirements for resources with governor control and frequency responsive capacity available Allocate any non-compliance penalties associated with BAL , should they be imposed on the ISO Page 11

12 Tariff Provisions ISO proposes to revise Section 4 of the tariff outlining responsibilities for participating generators having active governors to specify minimum governor performance, similar to Appendix K, Part B, 1.2. Specify droop settings by technology type Specify deadband Limit use of outer-loop controls that would otherwise override governor response ISO would require generators to provide governor control system data for inclusion in its Masterfile which is necessary as input to look-ahead tool Page 12

13 Addressing anticipated real-time PFR deficiencies ISO proposes to develop look-ahead tools assessing the PFR capability of the system at various time horizons in the future based on current system conditions Calculate frequency responsive headroom and expected PFR to determine if there is a deficiency If tool finds an expected deficiency of primary frequency responsive headroom, the ISO will take actions which could include: Increasing percent of reserves allocated to spin Increasing real-time spinning reserve procurement Issuing exceptional dispatches Page 13

14 Addressing anticipated real-time PFR deficiencies Priority Mechanism Description 1 Increase percentage allocation of reserves to spin 2 Increase overall contingency reserves procured through additional real-time spinning reserve procurement 3 Issue decremental exceptional dispatches if resources are fully loaded 4 Start up additional units through exceptional dispatch if an insufficient number of on-line resources Spinning reserve awards reserve frequency responsive headroom and the resource is compensated for its opportunity costs of not generating power to create this headroom Decremental exceptional dispatches reserve frequency responsive headroom and the ISO is currently evaluating if the dispatch can be compensated for opportunity costs Units started up provide frequency responsive headroom and compensated for commitment costs through BCR Page 14

15 ISO practice of preserving operating reserve headroom Revise section of the tariff to clarify the authority of the ISO to treat day-ahead procured operating reserve as contingency only in the real-time market regardless of the resource s election Not dispatching spinning reserve awards for energy will help the ISO preserve sufficient frequency responsive headroom Page 15

16 Performance Requirements With proposed changes to section 4 of the tariff, the ISO believes resources with governors and frequency responsive headroom available could be expected to provide primary frequency response ISO proposes applying a minimum frequency response performance requirement (i.e. response to actual events) on participating generators The ISO will continue to develop the details of a performance requirement and seeks comments on an appropriate performance requirement Page 16

17 Allocation of BAL non-compliance penalties If the ISO does not comply with the BAL standard, the ISO could be penalized up to $1 million dollars for the violation How should the ISO determine the method for allocating a penalty under its existing section 14.7? The performance requirement mentioned previously could be basis for allocating shares of any penalty Would there be a minimum performance threshold required for allocating penalty? Page 17

18 Phase 2, Long-term approaches Cathleen Colbert Page 18

19 Market constraint or product Phase 2 will evaluate if a market constraint or product is better suited to competition for frequency response capability. 1. Incorporate a market constraint to include logic that solves for the least cost commitment and dispatch constrained by the need for sufficient headroom on-line to provide the upward capability necessary to meet the FRO at any given time. 2. Create a new product that would allow economic bidding to provide a PFR product in the form of headroom from PFR-capable units. Page 19

20 Technology-neutral Market Solution The ISO believes wind, solar, and distributed energy resources could have the capability of providing PFR with a competitive market place Blade feathering on wind resource Withholding 5% margin on wind resource Smart inverters and relay devices on DER resources, including loads PV tracking mechanisms The ISO encourages increased penetration of storage The ISO encourages investment in smart inverters Page 20

21 Next steps Stakeholders are asked to submit written comments by November 2, 2015 to Draft Final Proposal will be posted on December 7, 2015 Page 21

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