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Comments submitted in response to NPRR 667: Ancillary Service Redesign

Luminant Energy suggests critical updates to NPRR 667 for quick-start generation resources, including separate clearing processes for FFR and PFR, and changes to AS metrics and disqualification.

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Comments submitted in response to NPRR 667: Ancillary Service Redesign

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  1. Comments submitted in response to NPRR 667: Ancillary Service Redesign Luminant Energy Company LLC

  2. Quick Start Generation Resources • Quick start generation resources provide a unique service • Available from cold start within 10 minutes • Dispatchable to a SCED-determined base point • Can provide 0 to HSL dispatchability for changing / post-disturbance system conditions • Current market rules allow quick-start resources providing Non-Spin to participate in SCED-dispatched energy markets while maintaining an ancillary service obligation.

  3. Quick Start Generation Resources NPRR 667 does not allow 10-minute resources providing Contingency Reserve or Supplemental Reserve to release to SCED and maintain a CRS/SRS obligation. Luminant suggests this feature is critical and appropriate for quick-start resources. This allowance rewards the resource for its premium speed and flexibility for the most relevant product in real-time.

  4. QSGR Language

  5. QGSR Language

  6. MCPC for FFR/PFR NPRR 667, as written, sets the MCPC for FFR as a multiple of PFR. As suggested by Luminant and other MP during the FAST workshops, it is more appropriate to clear FFRS as a separate product with a floor of the clearing price set by the PFRS clearing price. Forcing FFR to clear at a multiple of PFR reduces competition, and transfers the value of substitution to the suppliers of FFR. Luminant proposes that FFR and PFR compete in separate offer-stacks, allowing a cost-optimized substitution, with the floor price for FFR determined by PFR. This will allow load to recognize the value of substitution.

  7. Section 4.5.1 DAM Clearing Process

  8. Equivalency Ratio could take FFR above the VOLL The relationship between the MCPC of PFRS, FFRS, and the equivalency ratio are not compatible with the settlement equations proposed in NPRR 667. (See word-document example)

  9. NPRR as Written AS Metrics and Disqualification

  10. Luminant suggested changes to AS Metrics and Disqualification

  11. New Metric for Resources providing Regulation • For ERCOT’s new metric intended to grade a unit’s performance when providing regulation, Luminant suggests that the existing dead band variables for GREDP (X% and Y MW) would be appropriate to use instead of creating two new TAC approved variables (U% and W MW). • Luminant accepts ERCOT’s proposed new GREDP pass-rate for resources carrying regulation that is only measured during the intervals when the resource is carrying regulation. • The ability of a unit to follow the UDBP is not dependent upon if it is carrying regulation, it is a function of its control system • A resource should not be expected to stay within a tighter dead band when carrying regulation • It is not unreasonable to expect a resource to be within the existing dead band more frequently when carrying regulation

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