Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

Working Group Meeting NotesSlides for this meeting are posted at: https://gridworks.org/wp-content/uploads/2018/11/Load-Shift-Working-Group_Slide-Deck_11.14.pptx

10:00AM -10:30 AM: Intros, Updates, and Purpose Matthew Tisdale (Gridworks) opened the workshop. The following participants participated in person:

Alex Smith, Gridworks Peter Alstone, LBNL Jennifer Chamberlin, CPower Henry Richardson, WattTime Jonathan Burrows, PG&E Matthew Tisdale, Gridworks Nora Sheriff, CLECA Brian Kooiman, OhmConnect Ola Heum, SCE Ryan Bullard, SCE

Mariko Geronimo, Brattle Group Anja Gilbert, PG&E Jill Powers, CAISO Eric Kim, CAISO Jean Lamming, CPUC Michael Lee, Evolve Energy Jin Noh, CESA Robert Anderson, Olivine Alex Papalexopoulos, ECCo

International Walker Wright, Engie

The following participants participated over the phone:

Brian Gerke, LBNL Eric Woychik, Strategy Integration Steven Rymsha, Sunrun Sudheer Gokhale, Public Advocates Office

Regulatory updates: Excess Supply (XSP) DR Pilot 2015-2017 Summary and Findings report was issued

summarizing the market context, project objectives, technical results and lessons learned for future load shift products. The report is available here.

Demand Response Auction Mechanism (DRAM) proposed decision comments due on November 14.

RA enhancements stakeholder scope comments due on November 14.

Energy Division (ED) update:Jean Lamming (CPUC) provided a summary of D.16-09-056 stating the goals and principles of demand response program and D.17-10-017 that established the LSWG. Jean clarified that the LSWG final report may inform a future rulemaking on new models of demand response. The ED management has reviewed and supports the LSWG report outline.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

The ED management highlighted three topics for consideration of the LSWG final report:1. What is the reasoning for including out of market products?2. Is there an assessment of the costs/benefits to load shift?3. What LSWG products could operate in the DRAM if required?

MIDAS November 7 conference call update: The MIDAS product is designed to allow any grid state signal through a compatible API

to automatically control enabled devices to shift load. The API signal could be a single input (e.g., real-time price or marginal GHG emissions)

or a complex compilation of signals and inputs. The MIDAS team developed a straw man proposal for illustration purposes using the

WattTime GHG emissions signal.

Product updates: Critical Consumption Product (CCP) – customer notification deadline to be revised to 5

p.m. Sunrun Market Informed – clarification that the proposed load shape has been updated

to ”permanent/seasonal.” PDR LSR 2.0 – the settlement process may need to be refined to reflect the complex

nature of technology neutral product based on ESDER 3 findings (i.e., effect of multiple baselines in a day due to each event being 5 or 15 minutes).

10:30AM-11:00AM: Summary of comments received on outline

Eight LSWG participants provided comments on the final report outline; all comments are available on the Gridworks LSWG website. Matthew Tisdale (Gridworks) summarized the comments received for the WG on slides 9-11 here. The comments ranged from the organizational structure of the report to requests for clarification on specific products.

Discussion:

Peter Alstone (LBNL) offered to provide a quantitative analysis of the impact load shift will have on GHG emissions. The analysis would provide a descriptive analysis of how load shift products could impact system wide emissions using 2017 system and WattTime marginal emissions data. Peter will prepare the analysis and share with the group by November 23.

o Gridworks will organize a webinar for LSWG participants to review the GHG analysis prior to the December in-person meeting.

The WG discussed LSR 2.0 and agreed to clarify the proposal to allow aggregators to bid during positive pricing periods up to the net benefits threshold. Bidding during positive

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

price periods may be uneconomical for the customer, but should be allowed up to the net benefits test threshold.

The WG discussed the future of negative pricing in California and agreed that negative pricing is likely to continue for the foreseeable future.

The WG discussed LSR 2.0 settlement process and baseline methodology if two events (i.e., charge/discharge) occurred on the same day. Current baseline methodologies (10-in-10) do not account for these types of situations (?). The proposed performance evaluation methodology for LSR 2.0 requires additional explanation in the working group’s final report.

The WG discussed adding a section to the report addressing how load shift will interact with other Commission proceedings/initiatives. Topics discussed in LSWG (e.g., demand charges, baseline, dual participation, distribution impacts, etc.) may need to be addressed in the final report as future Commission related materials.

11:00AM-12:30PM: Exercise Comparing Products

Matthew Tisdale introduced the WG to the objectives and assumptions that will be used to evaluate the LS products in the final report. The objectives of the proposed comparison section includes:

◦ Drawing out key similarities and differences between products.◦ Showing the diversity of products and how they complement other programs/initiatives.◦ Enabling the Commission to weigh relative strengths of the products.◦ Postponing premature determinations on 'good' or 'bad' in favor of relative advantages.◦ Begin evaluating the viability of products.

The assumption of the product comparison section includes:◦ Proposals lie on a spectrum◦ Deciding between them isn't required at this time◦ Funding determinations will require more detail, but we have enough info to decide

whether to take the appropriate next steps◦ A portfolio of approaches hedges risk

With this framing in-mind, Matthew led the group through an interactive whiteboarding session addressing each of the 8 identified evaluation criteria that are summarized below. For each criteria, the working group discussed the following questions:

1. Where do the proposals sit on the spectrum?2. Why is this a key criterion? What’s important about it?

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

3. Does a product’s capabilities relative to this criterion impact its ability to meet certain grid needs? If so, which ones?

4. Are there barriers associated with this criterion that need to be reported?

The diagrams illustrate where the relative position of each proposal (plus TOU and XSP for context) along a spectrum. Whiskers are used to denote where a proposal may be positioned under contemplated implementation variations. The dotted line represents a separate classification of products.

Evaluation criteria # 1: Dispatch methodThe WG placed the products on a continuum, relative to one another, from CAISO market dispatch to out of market dispatch.

Discussion: Why is this a key criterion? What’s important about it?

o Current CPUC policy requires market integration or incorporation in the CEC’s Long Term Load Forecast for load curtailing DR to be eligible for RA value.

o At scale, load shift stands to increase market efficiency, with impacts of market integrated resources being more direct than out of market dispatch.

o Market dispatch enables easier tracking of GHG impact.o Market dispatch can increase transparency in dispatch. o Market dispatch enables energy market revenues (at a cost).

Does a product’s capabilities relative to this criterion impact its ability to meet certain grid needs? If so, which ones?

o Current CPUC policy requires market integration or incorporation in the CEC’s Long-term Load Forecast for DR to be eligible for RA value.

Are there barriers associated with this criterion that need to be reported? o Market integration through PDR has barriers which are well documented, and

addressed in the Supply Side Working Group. o Performance Evaluation will require additional reconsideration for any DR that

uses a baseline, as the technology that provides DR increases in complexity and abilities.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

Revenues from energy markets may not be sufficient to induce participation and load shift behaviors.

Evaluation criteria # 2: Settlement level The WG placed the products on a continuum, relative to one another, from aggregation to device.

Why is this a key criterion? What’s important about it?o The WG concluded this is not a key criteria

Does a product’s capabilities relative to this criterion impact its ability to meet certain grid needs? If so, which ones?

o No. Are there barriers associated with this criterion that need to be reported?

o CPUC current rules only cover settlement at the premise level, so new rules for settlement at the device-level would be needed (e.g. requirements for sub-meter, multiple DR providers for one premise potentially).

Evaluation criteria # 3: Dispatch geo-granularity The WG placed the products on a continuum, relative to one another, from DLAP to circuit.

Why is this a key criterion? What’s important about it?o In order to serve certain grid needs (i.e., avoidance of local renewable

curtailment), dispatch may need to be targeted.o Market price signals are obscured if/when they are compilation or average of

nodal prices; nodal prices provide customers greater fidelity in market price signals, leading to increased market efficiency.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

o Current approaches to managing congestion within the CAISO market may evolve. Greater capabilities to target dispatch could be more useful to the CAISO market as those approaches evolve.

Does a product’s capabilities relative to this criterion impact its ability to meet certain grid needs? If so, which ones?

o Yes. Providing local RA or distribution services or avoidance of local renewable curtailment will require corresponding targeted dispatch.

o PG&E’s XSP Pilot Report concludes, at scale, it will be imperative load shift gets integrated with distribution planning and operations to ensure that market dispatch events do not negatively impact distribution operations. This may require more granular, geographical dispatch.

Are there barriers associated with this criterion that need to be reported? o Dispatch at the nodal level is possible if an entire LSR 2.0 resource is located near

that node. Aggregations which span multiple nodes are dispatched at a weighted average price.

o Dispatch at the circuit level requires 1) insight into grid conditions at the circuit level, 2) ability to communicate dispatch signals, and 3) performance obligations on the response.

o While not a barrier, a key dependency of this is transmission-distribution system coordination.

Evaluation criteria # 4: Dispatch time granularity The WG placed the products on a continuum, relative to one another, from hourly to seconds.

*P4LS, XSP, S-MINF and CCP are all hourly Why is this a key criterion? What’s important about it?

o The ability to meet certain grid needs may depend on the dispatch time for the load shift. Quicker responses enable more grid needs to be met, but at a cost.

o Some customers may not be able to respond quickly or invest in technologies which respond quickly, impact their ability to participate in some proposals.

Does a product’s capabilities relative to this criterion impact its ability to meet certain grid needs? If so, which ones?

o Yes, grid needs like distribution capacity or resource adequacy have defined dispatch time requirements.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

o CAISO markets clear at 15 and 5 minute increments, determining whether and how much renewable curtailment occurs. Alignment with those time increments provides for a more direct impact on renewable curtailment.

Are there barriers associated with this criterion that need to be reported? o More granular dispatch requires investment in automation technologies which

has a cost. o All load shift may not need to be equipped with automation technologies.

Requiring them to shoulder such cost unnecessarily may decrease customer participation.

Evaluation criteria # 5: Role of IOU The WG placed the products on a continuum, relative to one another, from large to small.

Evaluation criteria # 6: Role of aggregator The WG placed the products on a continuum, relative to one another, from large to small.

Evaluation criteria # 7: Role of customer The WG placed the products on a continuum, relative to one another, from mass market to targeted.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

Discussion ( Criteria 5-7):

Why are these key criteria? What’s important about them?o The respective roles of utilities, aggregators and customers must be coordinated

to create a functioning load shift market.o The Commission has expressed a preference for third-party demand response

through competitive markets.o Different customer classes have different tolerances and capabilities for

participation in demand response programs. o The respective roles of IOUs and aggregators impacts how you would incentivize

customers to take desired actions. Does a product’s capabilities relative to this criterion impact its ability to meet certain

grid needs? If so, which ones?o Yes. The IOU serves as both an Load Serving Entity and Utility Distribution

Company. In some cases, they also serve as the aggregator and Demand Response Provider. Connecting the dots between these different functions within the utility may be easier than connecting them if there are different organizations and institutions involved. For example, for an LSE to begin anticipating load shift in its load bids into energy markets, the LSE needs to be confident in the availability and dependability of that shift. Communicating that availability between two companies may be more difficult than one company.

o The automation of the response may impact what is the appropriate role for each of these actors. Higher automation may shrink the role of everyone involved.

o Are there barriers associated with this criterion that need to be reported?

o Complexity in coordination.

Evaluation criteria # 8: Launch viability The WG placed the products on a continuum, relative to one another, from hard to hardest.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

Discussion:The WG agreed to complete a high-level, non-binding assessment of each proposal’s viability. The WG agreed a more thorough, systematic approach would be needed for any decision-making, but a high-level brainstorm was found to be helpful.

The WG discussed what criteria might be used to assess viability, including: - How much the product may appeal

to customers- Funding- Supporting IT systems- Supporting processes

- Performance Evaluation Methods- Regulatory hurdles- Rate design - Policies

The WG discussed the possibility for a checklist to better convey the viability criterion for the various LS products.

3:45PM-4:30PM: Putting the Pieces Together The Working Group identified the following high-level themes as the primary, most important takeaways.

Discussion: Energy price arbitrage opportunities are fleeting.

o Existing resources rely on RA contracts. What would load shift resource rely on? Capacity payments for Flex RA? GHG savings? Other? Optionality? Participation payments? Payment for providing another service (i.e., Dx. Service)?

Generally, expand opportunities in DR in line with grid needs. Lately opportunities have been shrinking, which is the wrong direction.

Experiment with different approaches to Load Shift before locking in on one “winner.” Expand the Commission’s Multi-Use Application to other DER so that it could include all

BTM DERs that can act as load shift resources. Anticipate future grid: rates, roles, challenges. Load shift capabilities provide option

value. There are different third-party business models and interests. Similarly, different

customers who want to engage in different ways. Don’t assume one-size will fit all. Technology neutral should continue to be a goal.

Meeting Notes Load Shift Working Group (LSWG)

In person meeting: CPUC Goldengate Room, 505 Van Ness AvenueNovember 14, 2018

Time & location matter – tied to grid needs.

Next Steps: There will be a webinar prior to the December meeting to review/discuss Peter

Alstone’s GHG analysis. The WG was reminded of the remain production schedule: