NPRR 097NPRR 097

DSR and Small Capacity / Low DSR and Small Capacity / Low Operating Level Issues for Operating Level Issues for

Compliance MonitoringCompliance Monitoring

BackgroundBackground

Previous method to gauge Regulation Previous method to gauge Regulation deployment performance in Nodal Protocols deployment performance in Nodal Protocols worked for DSRs and was a compromise by worked for DSRs and was a compromise by TPTF membersTPTF members

New method adopted by TPTF in NPRR 097 New method adopted by TPTF in NPRR 097 and forwarded to PRSand forwarded to PRS

Returned to TPTF by PRS to vet concerns over Returned to TPTF by PRS to vet concerns over DSR ability to meet the new Regulation Service DSR ability to meet the new Regulation Service and Generation Resource Energy Deployment and Generation Resource Energy Deployment Performance CriteriaPerformance Criteria

New MethodNew Method

Unit by unit measurement of performance Unit by unit measurement of performance and delivery of energy and regulationand delivery of energy and regulation

Essentially a % error measurement of the Essentially a % error measurement of the difference between actual generation and difference between actual generation and expected generationexpected generation

Works well for most unit statusesWorks well for most unit statuses GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100

Problems Inherent with New Problems Inherent with New MethodMethod

Original problem presented as comments Original problem presented as comments to PRS – QSEs with DSRs forced to to PRS – QSEs with DSRs forced to choose either to pass the GREDP metric choose either to pass the GREDP metric or to follow their dynamic load or to follow their dynamic load Difficult, if not impossible, to do bothDifficult, if not impossible, to do both

Second problem – For all unitsSecond problem – For all units Units operating at low load levels or have a Units operating at low load levels or have a

smaller capacity have a very small window for smaller capacity have a very small window for errorerror

Qualification / Reporting Qualification / Reporting RequirementsRequirements

To qualify to provide Regulation 8.1.1.2.1.1 To qualify to provide Regulation 8.1.1.2.1.1 states –states – ““During at least one five minute duration interval During at least one five minute duration interval

selected to evaluate each of the Reg-Up and Reg-selected to evaluate each of the Reg-Up and Reg-Down amounts being tested, the Generation Down amounts being tested, the Generation Resource Energy Deployment Performance (GREDP) Resource Energy Deployment Performance (GREDP) calculated in accordance with Subsection 8.1.2.4.1 calculated in accordance with Subsection 8.1.2.4.1 below over the entire five minute interval must be below over the entire five minute interval must be less than or equal to less than or equal to 3.5%. 3.5%. Additionally, in all other Additionally, in all other test sequence intervals, the Resource’s measured test sequence intervals, the Resource’s measured GREDP must be less than or equal to GREDP must be less than or equal to 5%5% as as calculated for the entire duration of each test interval.”calculated for the entire duration of each test interval.”

Qualification / Reporting Qualification / Reporting Requirements (cont’d)Requirements (cont’d)

In addition, 8.1.1.4.1(4) states that ERCOT In addition, 8.1.1.4.1(4) states that ERCOT shall post to the Certified Area of the MIS shall post to the Certified Area of the MIS a report for each Generation Resource a report for each Generation Resource that includes GREDP %that includes GREDP %

The report provides intervals where:The report provides intervals where: GREDP % < 2.5%GREDP % < 2.5% GREDP % > 2.5% but < 5%GREDP % > 2.5% but < 5% GREDP % > 5%GREDP % > 5%

Tackling the DSR IssuesTackling the DSR Issues

DSR ImpactsDSR Impacts

New method requires calculations to be New method requires calculations to be calculated from the SCED Base Pointcalculated from the SCED Base Point

As long as SCED does not dispatch a As long as SCED does not dispatch a DSR from its submitted OS, the OS DSR from its submitted OS, the OS becomes the Base Point [6.4.2.2(2)(a)]becomes the Base Point [6.4.2.2(2)(a)]

For a DSR, sum of DSR OSs is a best For a DSR, sum of DSR OSs is a best case case estimationestimation of where load will be of where load will be

DSR ImpactsDSR Impacts

NOIEs have the ability to follow their telemetered load NOIEs have the ability to follow their telemetered load with DSRs and may do so with any combination of DSRs with DSRs and may do so with any combination of DSRs (ie. can move any DSR unit in their portfolio to meet (ie. can move any DSR unit in their portfolio to meet changes in load)changes in load)

If a DSR elects to follow its load instead of SCED Base If a DSR elects to follow its load instead of SCED Base Point, a natural deviation from Base Point will occur Point, a natural deviation from Base Point will occur (natural error)(natural error)

This natural error is captured in the new GREDP criteria This natural error is captured in the new GREDP criteria creating a disadvantage to NOIEs in passing the metric – creating a disadvantage to NOIEs in passing the metric – NOIEs are allowed a smaller bandwidth for error than NOIEs are allowed a smaller bandwidth for error than non-NOIEs and will fail the criteria more frequentlynon-NOIEs and will fail the criteria more frequently

DSR ImpactsDSR Impacts

NOIEs placed in an undesirable NOIEs placed in an undesirable predicamentpredicament Insulate customers from adverse pricing and fail Insulate customers from adverse pricing and fail

the GREDP metric and face possible TRE the GREDP metric and face possible TRE action action OROR

Expose customers to adverse pricing but avoid Expose customers to adverse pricing but avoid failing the GREDP metric and possible TRE failing the GREDP metric and possible TRE actionaction

Neither choice is acceptable and places an Neither choice is acceptable and places an unequal burden on NOIEsunequal burden on NOIEs

Proposed SolutionProposed Solution

Stays within framework of current GREDP Stays within framework of current GREDP calculationcalculation

Creates two methods for calculating Creates two methods for calculating GREDP GREDP Original calculation maintained for non-DSRsOriginal calculation maintained for non-DSRs New calculation for DSRs – similar to what New calculation for DSRs – similar to what

previously existed in Protocols but was struckpreviously existed in Protocols but was struck Removes the “natural error” from GREDP Removes the “natural error” from GREDP

calculationcalculation

Proposed SolutionProposed Solution

Allows for non-DSRs in a NOIE fleet to be Allows for non-DSRs in a NOIE fleet to be calculated under the original GREDP calculated under the original GREDP methodologymethodology

Maintains same reporting and qualification Maintains same reporting and qualification requirements as original GREDPrequirements as original GREDP

Will not impact non-NOIE QSEsWill not impact non-NOIE QSEs

Proposed Solution GoalProposed Solution Goal

Allows NOIEs to insulate customers from Allows NOIEs to insulate customers from adverse pricing while giving NOIEs a fair adverse pricing while giving NOIEs a fair opportunity to pass the metric and avoid opportunity to pass the metric and avoid TRE actionTRE action

Calculation for Generation Calculation for Generation Resources with non-DSR statusResources with non-DSR status

GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100

No changesNo changes

GREDP Calculation for DSR GREDP Calculation for DSR ResourcesResources

GREDP (%) = ABS[(ATDSRG – AIBPD + GREDP (%) = ABS[(ATDSRG – AIBPD + ADBPD + Intra-QSE Purchase – Intra-ADBPD + Intra-QSE Purchase – Intra-QSE Sale – AEGR) / (ATDSRL + ARI) – QSE Sale – AEGR) / (ATDSRL + ARI) – 1.0] * 1001.0] * 100

Introduces a telemetered load componentIntroduces a telemetered load component

The Low Operating The Low Operating Level / Small Capacity Level / Small Capacity

IssueIssue

Low Operating Level ImpactsLow Operating Level Impacts

5% of a small number is a small number5% of a small number is a small number

2.5% of a small number is a 2.5% of a small number is a reallyreally small small numbernumber

ImpactsImpacts

Reporting ThresholdsReporting Thresholds

2.50%2.50% 3.50%3.50% 5.0%5.0%

Operating Level

Operating Level

1010 .25.25 .35.35 .5.5

2525 .625.625 .875.875 1.251.25

5050 1.251.25 1.751.75 2.52.5

100100 2.52.5 3.53.5 55

250250 6.256.25 8.758.75 12.512.5

500500 12.512.5 17.517.5 2525

750750 18.7518.75 26.2526.25 37.537.5

ImpactsImpacts

Many units that operate at very low output levels Many units that operate at very low output levels are often older and have less sophisticated are often older and have less sophisticated controls to meet these tight standardscontrols to meet these tight standards

Many of these units provide needed Ancillary Many of these units provide needed Ancillary ServicesServices

Smaller capacity units, older units, and those Smaller capacity units, older units, and those operating at low load levels provide a valuable operating at low load levels provide a valuable service to the market (especially across peaks) service to the market (especially across peaks) and should not be penalized based on an and should not be penalized based on an extremely small bandwidthextremely small bandwidth

Ultimate Impact to the MarketUltimate Impact to the Market

Units operating at low levels are more Units operating at low levels are more likely to fail the GREDP metric although likely to fail the GREDP metric although they are providing the same quality service they are providing the same quality service as those operating at high levels – this will as those operating at high levels – this will force smaller units out of the market and force smaller units out of the market and drive up AS costs to the consumerdrive up AS costs to the consumer

Proposed SolutionProposed Solution

Introduces a 5 MW bandwidth to the Introduces a 5 MW bandwidth to the equationequation

If error is less than 5 MW then GREDP = 0If error is less than 5 MW then GREDP = 0 Consistent with the Base Point Deviation Consistent with the Base Point Deviation

Charges in Section 6 of the Nodal Charges in Section 6 of the Nodal ProtocolsProtocols

Non-DSR SolutionNon-DSR Solution

If:If:

ABS(ATG – AEGR – ABP - ARI) < 5ABS(ATG – AEGR – ABP - ARI) < 5

Then: Then:

GREDP = 0GREDP = 0

Else:Else:GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100GREDP (%) = ABS[((ATG – AEGR)/(ABP + ARI)) – 1.0]*100

DSR SolutionDSR Solution

If:If:

ABS(ATDSRG – AIBPD + ADBPD – ATDSRL+ Intra-QSE ABS(ATDSRG – AIBPD + ADBPD – ATDSRL+ Intra-QSE Purchase - Intra-QSE Sale – AEGR - ARI) < 5Purchase - Intra-QSE Sale – AEGR - ARI) < 5

GREDP = 0GREDP = 0

Else:Else:

GREDP (%) = ABS[(ATDSRG – AIBPD + ADBPD + Intra-GREDP (%) = ABS[(ATDSRG – AIBPD + ADBPD + Intra-QSE Purchase – Intra-QSE Sale – AEGR) / (ATDSRL + QSE Purchase – Intra-QSE Sale – AEGR) / (ATDSRL + ARI) – 1.0] * 100ARI) – 1.0] * 100