CAISO Seeks Stakeholder Feedback on Hybrid Resource Market Participation

Stoel Rives - Renewable + Law
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Stoel Rives - Renewable + Law

The California Independent System Operator (CAISO) is accepting stakeholder comments until August 13, 2019 on its new Hybrid Resources Issue Paper, kicking off a stakeholder initiative expected to proceed until April 2020. Initial comments submitted now will help shape the direction of the initiative and potential market changes.

Though not exclusively limited to renewables + storage (the CAISO defines “hybrid” to mean any combination of multiple technologies or fuel types combined into a single resource with a single point of interconnection), the CAISO emphasizes the anticipated impacts of increased storage market penetration, including new operational and forecasting challenges,  as a driving force for the initiative. The CAISO has observed that the number of hybrid resource configurations seeking interconnection comprises approximately 41% of the CAISO’s Generator Interconnection Queue’s total capacity.

Key to the initiative is determining whether a framework should be developed for resources intending to participate in the market under a single resource ID.  Though the CAISO expressed a strong preference for hybrid resources utilizing multiple resource IDs, some developers prefer a single one (in part due to ITC eligibility uncertainty). The CAISO is interested in hearing from stakeholders on an incredibly wide range of identified topics, including:

  • Whether other options (besides single or multiple resource IDs) should exist
  • CEC RPS reporting guidelines that should be considered through this initiative
  • General forecasting issues, including feedback on the need for additional requirements for forecasting resources with a single resource ID, as a single resource ID hybrid configuration would not be considered a Participating Intermittent Resource and thus would not have a forecast
  • Potential changes that could address operations risks arising from the decreased dispatchability of single resource ID hybrid resources and considering the existing bidding and market timeframes
  • Potential modifications to modeling for planning and operations purposes, such as new types of generator limiting schemes to consider cumulative generation (net output), rather than just individual generation from each resource
  • Whether changes, new data points, or additional certifications may be required to preserve ancillary service capacity and for hybrid resources to provide these services
  • Any potential issues that should be considered related to hybrid resources deliverability
  • Potential approaches for (i) evaluating capacity values of hybrid resources under single resource ID configurations, (ii) establishing a default Qualifying Capacity (QC) methodology for single resource ID configuration hybrid resources and (iii) evaluating the potential impacts this proceeding may have on settlement, configuration, and operational impacts on storage developers
  • Any metering, telemetry, and settlements related issues that may need to be considered through this initiative

Through this initiative, the CAISO intends to address early on the issues that it anticipates will become more pressing to reliability as hybrid resources become more prevalent on the grid. Stakeholders, including both developers and load serving entities, have the opportunity to help shape the CAISO’s hybrid resources policy now.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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