California Tariff Proposal Opens Wholesale Market to Small Distributed Energy Resources

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1 RESEARCH North America Power and Utilities Smart Grid California Tariff Proposal Opens Wholesale Market to Small Distributed Energy Resources Aggregation Key for Boosting and Accommodating Distributed Renewable Growth March 21, 2016 Policy Brief Author Erin Carson Chief Policy Strategist Janis Kreilis Analyst Contact (212) Key Takeaways: The California Independent System Operator has filed tariff revisions with the Federal Energy Regulatory Commission to enable aggregated distributed energy resources to participate in its wholesale markets New York REV and Texas DREAM initiatives have also proposed similar measures for market restructuring to integrate the value of distributed energy resources into the bulk power system The future grid will likely involve a significant level of distribution-connected generation, driven by declining costs of small-scale renewable generation and evolving technologies, such as distribution-level storage devices DER dockets in California, New York, Hawaii, and Texas could also identify optimal solutions to balance renewable energy growth with grid safety and reliability Related Research Washington DC Regulators Propose Additional Requirements For Exelon- Pepco Merger State Commission Findings Influence Ongoing Net Energy Metering Valuation Debate Entities Mentioned: California Independent System Operator Electric Reliability Council of Texas Federal Energy Regulatory Commission New York Independent System Operator New York Public Service Commission This report is for industry information only and we make no investment recommendations whatsoever with respect to any of the companies cited, mentioned, or discussed herein. Please refer to the end of this report for analyst certification(s) and other important disclosures.

2 Insight for Industry States Propose Market Rule Changes to Accommodate Growing Penetration of Distributed Energy Resources On March 4, 2016, the California Independent System Operator (CAISO) filed tariff revisions with the Federal Energy Regulatory Commission (FERC) to enable aggregated distributed energy resources (DERs) to participate in the ISO s energy and ancillary services markets. DERs refer to customer side or distribution-grid side resources, such as rooftop solar, energy storage, plug-in electric vehicles, and demand response, which are growing and expected to play an important role in the future resource mix. California s proposal is a significant step for distributed resources. As DER providers aggregate different resource types that would otherwise be too small to participate in the wholesale market, the state could rely more on DERs in meeting its energy requirements and mandates. At the same time, the ISO would be able to select a wider range of resources when balancing supply with demand and integrate more renewables into the grid. Apart from California, New York and Texas have also proposed changes to market rules and regulations to foster DER growth. New York s Reforming the Energy Vision (REV) framework seeks to reform the utility regulatory structure to create distributed service platform providers that will open new market opportunities for DERs. Similarly, the Electric Reliability Council of Texas (ERCOT) is examining market structures, including aggregated DERs, to increase their share in its wholesale markets. While wholesale markets have traditionally focused on large generating and load-curtailment resources, growing adoption of behind-the-meter DERs, especially variable generation, is having a profound effect on the grid, originally designed for one-way flow from central generating facilities to customers. As the grid is likely to experience more multi-directional flows and greater variability in the future, system operators would require changes to planning and operation of the distribution system to accommodate such new uses and capture the full value of DERs. The combination of enhanced technology capabilities, environmental regulations, and fossil-fuel retirements are expanding customer adoption renewable technologies, and access to wholesale markets will be a critical advancement for rooftop solar and solar with storage. Under the new CAISO rule, companies and utilities would be able to purchase and consolidate the output of rooftop solar systems, batteries, and plug-in electric vehicles from multiple residential and commercial generators into a bundled capacity to be sold in the ISO market. In this regard, the CAISO noted that an important aspect of the proposed framework pertains to its scalability and ability to accommodate different business models. A platform that allows high levels of DER integration and consumer market interaction if designed, tested, and coupled with flexible rate structures could lead to a more efficient and reliable grid. Increasing DER adoption has prompted several utility commission proceedings and state legislative actions to facilitate DER integration and grid As the grid is likely to experience more multidirectional flows and greater variability in the future, system operators would require changes to planning and operation of the distribution system to accommodate such new uses and capture the full value of DERs 2

3 modernization, underscoring the increasing role of states in guiding industry evolution to accommodate DER in the generation mix. CAISO Tariff Revisions Mark First Step in Enabling Aggregated DER Participation in Wholesale Energy Markets The CAISO tariff proposal sets the stage for enabling aggregated DER participation in the wholesale energy market in the light of the evolving grid and growing distributed generation, which is expected to represent an increasingly important part of the future resource mix. Under the proposal, the ISO would treat DER aggregation as a market resource and rely on aggregated meter data from the DER provider, instead of metering each subresource. This new model would accommodate smaller distribution-connected generation and emerging resource types that may require a different model for wholesale market participation. Effective integration of these resources into the ISO market and operations would contribute to emissions reductions and operational benefits to the grid. Currently, the CAISO tariff lacks a clear platform for effective market participation of smaller DERs such as rooftop solar, energy storage, and plug-in electric vehicles. As a result, the ISO s proposed revisions will establish a framework to help DERs meet the 0.5 MW minimum participation requirement. Under the CAISO proposal, each bundle of DERs that includes resources located at different pricing nodes would be no larger than 20 MW. By striking a balance between sufficient size and varied pricing, the ISO expects the framework to facilitate market participation of micro-grids interconnected to distribution systems, third party aggregators operating distributed energy resources, or utility distribution companies operating these resources. The CAISO proposal would recognize a DER provider as a market participant and a DER aggregation as a market resource. DER aggregations would be scheduling coordinator metered entities, similar to proxy demand resources and reliability demand response resources that already participate in CAISO markets. The DER provider, working through a scheduling coordinator, would have the ability to determine how to disaggregate CAISO dispatch instructions to individual resources in the aggregation. CAISO would not directly meter the resources in an aggregation; rather, the scheduling coordinator would submit settlement quality meter data to the ISO. The metering arrangement between the scheduling coordinator and the resource rather than the ISO and the resource would avoid the technical and communication burden associated with having direct metering between each sub-resource and the ISO (Figure 1). The proposal also includes rules governing participation by these resources in the CAISO s markets and distinctions between requirements for scheduling coordinators representing demand response providers and those representing DER providers. The metering arrangement between the scheduling coordinator and the resource rather than the ISO and the resource would avoid the technical and communication burden associated with having direct metering between each sub-resource and the ISO 3

4 Figure 1 DER Interaction with CAISO through Scheduling Coordinator Source: CAISO The CAISO proposes to rely on existing market models and tariff rules to the maximum possible extent, in order to avoid major market system changes and ensure faster implementation. The ISO provides a broad definition for DER as any resource with a first point of interconnection to a utility distribution company or a metered subsystem, including distributed generation, energy storage, and plug-in electric vehicle charging stations. These resources could be in front of or behind a customer meter. The DER provider would interface with utility distribution company or metered subsystem that operates the distribution system in the CAISO balancing authority area to which its resources are connected. Resources participating in a retail net energy metering program (NEM) would not be eligible for wholesale market aggregation, as they bank excess energy for later withdrawal and because exports to the grid under NEM do not constitute a sale for resale under the Federal Power Act. The CAISO tariff revisions would permit non-nem distributed energy resources to participate in an aggregation as a wholesale market participant, subject to a review by utility distribution companies or metered subsystems to address concerns regarding compliance with the utility s applicable tariff or local regulatory authority s requirements and resolve any safety and reliability concerns on their distribution systems. This measure would ensure that the CAISO proposal does not undermine distribution system operations. The CAISO proposal would permit non-nem DER to participate in an aggregation as a wholesale market participant, subject to a review to ensure compliance with applicable tariff or local regulatory requirements and resolution of any safety and reliability concerns on distribution systems 4

5 Among other requirements, a DER would not participate in more than one DER aggregation and each resource in a DER aggregation would not participate as a market resource separate from the aggregation. These requirements would provide distinct identification of individual resources in a DER aggregation, prevent double counting or double enrollment, and ensure the CAISO is not modeling DER both as part of an aggregation and as a stand-alone resource. The proposal would require each DER aggregation to be located in a single subload aggregation point to prevent additional congestion on the grid. The proposed framework would facilitate an increase in the mix of resources participating directly in the wholesale market to help balance supply and demand and provide ancillary services. The CAISO expects the proposed framework to pave the way for other market rules that may govern the interface between the transmission grid and resources interconnected at the distribution level. Stakeholders, including California Energy Storage Alliance, San Diego Gas & Electric, Southern California Edison, and Solar City generally support the proposal. The Pacific Gas and Electric Company recommended a MW cap on total aggregation participation for an interim period to address market manipulation concerns. CAISO expects to explore enhancements by gaining operational experience with interconnection, multiple-use business cases, and DER integration into transmission system operations that could lead to additional market rule enhancements for DER aggregations. The ISO has requested FERC approval to implement the tariff revisions from June 3, New York and Texas on Course with California to Create Market Structures for DERs Apart from California, New York and Texas have initiated similar efforts underscoring the importance of a broader restructuring of energy markets for DER integration. While these states have different DER adoption levels, policy objectives, and market structures, their initiatives share a common goal of reducing market barriers and creating value streams for DERs. New York and Texas are in different stages of establishing market structures aimed to capture the value of distributed energy resources. New York New York s REV initiative, unveiled in 2014, seeks to transform the state s utility regulatory structure by creating distributed service platform (DSP) providers for integrating greater levels of DERs and empowering customers with better energy management options. The DSP is the functional center of the REV framework and is defined as an intelligent network that will provide safe, reliable, and efficient electric services by integrating diverse resources to meet customers and society s evolving needs. The REV Track 1 proceeding focuses on the development of DER markets and DSP providers, while the parallel Track 2 focuses on reforming utility ratemaking practices and revenue streams to accommodate the DSP provider model. REV seeks to implement regulatory changes informed by demonstration projects, the proposals for which have been submitted by utilities to NY PSC. These revisions will enable utilities to advance DER and energy efficiency New York s REV initiative, unveiled in 2014, seeks to transform the state s utility regulatory structure by creating distributed service platform (DSP) providers for integrating greater levels of DERs and empowering customers with better energy management options. 5

6 markets, deploy price signals that reward investments in system efficiency improvements, and evolve the regulatory system to leverage innovation, technology, and private investment. Moreover, the New York Public Service Commission (NY PSC) will continue to explore changes to the utility compensation structure, including new performance metrics and rate plans for utilities and markets using data from demonstration projects. The New York Independent System Operator s (NYISO) strategic plan commits to planning processes that account for the growth of DER and intermittent renewable resources at the bulk level. The NYISO market design will drive changes that support the integration of new resource types. The 2015 State Energy Plan, which provides a roadmap to advance the REV initiative, targets 50 percent electricity generation from renewable resources by 2030, providing a clear signal to advance an energy future focused on distributed generation and renewable energy. Reorientation of New York s electric industry and ratemaking structure toward a consumer-centered approach will expand utility functions and provide equal priority to both novel and traditional energy infrastructure. Texas In Texas, ERCOT has established the Distributed Resource Energy and Ancillaries Market (DREAM) Task Force to provide a forum for stakeholders and staff to develop DER-related market rules. The DREAM Task Force is tasked with considering and recommending a potential market framework that would allow DERs to participate more substantially in the ERCOT wholesale market. The ERCOT staff has proposed pathways that would facilitate registration of individual DERs, including DER aggregators, in the wholesale market. In August 2015, ERCOT staff issued a concept paper proposing three regulatory marketstructure options for DER in ERCOT markets: DER Minimal would be settled at load zone settlement point prices, essentially unchanged from current practice; DER Light single-site or aggregations would participate passively in the energy market while settled at nodal prices via mapping of the DER locations to their appropriate load points; DER Heavy single-site or aggregations would participate actively in the energy and ancillary services markets while settled at nodal prices via mapping of the DER locations to their appropriate load points. It would be treated similarly to generation resources in the current market construct and would be assigned a logical resource node settlement point, and a settlement point on the transmission grid. In Texas, the ERCOT staff has proposed pathways that would facilitate registration of individual DERs, including DER aggregators, in the wholesale market The ERCOT approach seeks to augment existing market products to increase accessibility to market participants. It would facilitate registration of DERs through market changes, including aggregations of solar, storage, and other 6

7 DER to utilize the state s grid edge potential. Texas has not experienced notable growth in distributed generation due largely to the lack of NEM rules that have dramatically improved the economics of customer-sited solar photovoltaics 44 states including California and Hawaii. State Commission Efforts Also Driven by Growing DERs In several states, utility commissions have initiated formal investigations and plans to facilitate greater DER integration and implement grid modernization activities. While New York s REV seeks a fundamental restructuring of the centralized utility model in response to technology advancements and customer trends, California and Texas and considering wholesale market opportunities for DER. The CAISO proposal would create a new category of market participant to facilitate DER aggregation, while ERCOT s DREAM is exploring market structure options to increase DERs including aggregations. New York s REV proceeding, California s Distribution Resources Plans and Hawaii s grid modernization proceedings have made significant progress towards necessary enhancements and have been the most widely discussed. Other state utility commission proceedings on grid modernization and distributed generation include: California: Docket No. R Instituted in August 2014 to establish policies, procedures, and rules to guide California investorowned electric utilities (IOUs) in developing their Distribution Resources Plan proposals District of Columbia: Formal Case No Instituted in June 2015 to identify technologies and policies that can modernize the District s energy delivery system for increased sustainability and that will make the District s system more reliable, efficient, cost-effective, and interactive Hawaii: Docket No Instituted in August 2014 to investigate DER policies of the islands utilities: Hawaiian Electric Company, Hawaii Electric Light Company, Maui Electric Company, (the HECO Companies), and the Kauai Island Utility Cooperative; and modernization-related issues including time-of-use rate proposals Massachusetts: Proceeding No Instituted in October 2012 to investigate grid modernization; resulted in a June 2014 order requiring each utility in the state to develop and implement a 10- year grid modernization plan, to be updated regularly Minnesota: Proceeding Instituted in May 2015 the MN PUC to inquire into electric utility grid modernization with a focus on distribution planning New Hampshire: Docket No. IR Instituted in July 2015 to gather information about grid modernization and to explore the extent of workable grid modernization in the state New York: Case No. 14-M-0101 Instituted in April 2014 to implement the REV initiative that seeks to reform state s utility regulatory structure by creating distributed service platform (DSP) New York s REV proceeding, California s Distribution Resources Plans and Hawaii s grid modernization proceedings have made significant progress towards necessary enhancements and have been the most widely discussed 7

8 providers for greater DER integration and better energy management options for consumers Furthermore, several states have taken legislative actions to advance DER deployment, while others are considering studies to identify and quantify the impacts of DERs (Table 1). Table State Legislative Actions Related to Distributed Energy Resources State Bill Number Date of Last Action Description Minnesota HF March, 2016 HB January, 2016 Would allot money from the environmental and natural resources trust fund to conduct pilot programs using energy efficiency and distributed energy resources to achieve forecasted electric energy loads in communities Would establish a working group with members from the community associations institute, Hawaiian Electric Industries, a utility cooperative, solar industry, and storage and distributed energy resources industry to address the installation of electrical submeters in condominiums SB February, 2016 Passed One Chamber Would require implementation of pilot microgrid projects in schools to demonstrate viability of such projects Hawaii HB March, 2016 Passed One Chamber HB March, 2016 Passed One Chamber Would encourage and facilitate microgrid deployment in a manner that expands access to locally generated renewable energy and advanced DER and promotes efficient electricity distribution to consumers Would protect ratepayers from potentially unnecessary additional costs by requiring electric utility rates to be derived from an earnings impact mechanism that ties utility revenues to the achievement of specified performance based metrics including DER interconnection to meet demand HB January, 2016 Would prohibit the state s investor-owned electric utilities or their affiliated interests from building or acquiring new or additional generation resources in Hawaii, in order to begin transitioning towards an electric utility of the future, which plays the role of system planner and operator of grids supplied with high levels of renewable energy from DER and independent power producers California AB February, 2016 Would require assessment of alternative means of achieving a sufficient supply of electric power including energy efficiency, demand response, and DER to accommodate recent projected demand before certifying a site and related facilities that use fossil fuel resources 8

9 California AB February, 2016 AB February, 2016 Would require electrical corporations to identify nonbypassable charges that would be collected annually from customers served by DER installed after January 1, 2016 and require the amount to be recovered from customers in the same customer class Would require a study on the impacts of distributed energy generation on the state s grid, including evaluation of the current use of and opportunities for green workforce training programs relating to DER deployment AB January, 2016 Passed One Chamber Would promote DER deployment to provide a stable and reliable supply of electricity and prioritize deployment of smart grids, microgrids, and reliable energy resources that reduce emissions; would require electrical corporations to identify and recover nonbypassable charges for clean DER installed after January 1, 2016 from customers in the same customer class Mississippi HB February, 2016 West Virginia SB January, 2016 HB February, 2016 Would provide for the Mississippi Distributed Energy Resource Program; would require the public utilities staff to report to the PSC on costs and charges attributable to DERs within current costs of service ratemaking methodologies, among others Would deploy DER projects as part of energy efficiency or demand-side energy initiative projects to promote customer energy efficiency and management of electricity consumption under the Alternate and Renewable Energy Portfolio Standard Would promote development of reliable DER by extending and modifying existing tax incentive for certain net metering systems while providing rate-recovery mechanisms to ensure that DER integration does not impact system reliability after the current 0.5 percent net metering threshold is reached Washington HB , March, 2016 Passed One Chamber Would encourage a systematic evaluation of existing and emerging policies that promote cost-effective DER integration, recognizing that that the architecture to control or coordinate the operation of intelligent devices of future smart grid at the distribution level is not yet certain New York A January, 2016 Would establish the clean energy fund to improve energy efficiency and facilitate the development of clean energy technologies; promote distribution of clean energy resources, require net metering for wind facilities, among others Source: EnerKnol 9

10 Regulatory Changes and Policy Tools Key to Accommodate Growing DER Share In advancing a proposal to better integrate smaller-scale distributed resources into wholesale markets, the CAISO recognizes that DER is growing at a significant pace to become an important part of the future resource mix. California is already a leader in solar PV, plug-in EVs, and grid-scale energy storage, which are at the forefront of the distributed energy revolution. The proposal stands up to California's ambitious renewable portfolio standards and the increasing DER penetration. As DERs become more prevalent, grid operators will be responsible for facilitating such resource participation while ensuring system reliability. The future grid will likely involve a significantly high level of distribution-connected generation, driven by declining costs of small-scale renewable generation and evolving technologies such as distribution-level storage devices. Technology advancements and declining prices of distributed solutions are providing customers with better control and choice over energy consumption and DER ownership opportunities. Rapid DER growth in regions like Hawaii and California demonstrate the need for operational changes and market frameworks for quick adoption of DERs. Importantly, as several states are seeking NEM alternatives to ensure that customer-generators have a reasonable share in infrastructure costs, opportunities to participate in wholesale markets could become increasingly important for DER economics. For example, in Hawaii or Nevada, where net metering programs for solar generation have been either shut down or curtailed, wholesale markets could provide a source of additional revenue for the generators. Since the continued increase in DER must be accommodated in the generation mix, states will have an increasing role in guiding the industry evolution. DER developments in states such as California, New York, Hawaii, and Texas are being closely watched to identify optimal solutions that balance renewable energy growth with grid safety and reliability. As several states are seeking NEM alternatives to ensure that customer-generators have a reasonable share in infrastructure costs, opportunities to participate in wholesale markets could become increasingly important for DER economics 10

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