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EnerNOC, IECG, and Verso

In response to ISO proposals affecting Demand Response (DR) assets mapped to resources with Capacity Supply Obligations (CSO), EnerNOC, IECG, and Verso recommend strategies for increasing DR participation in the Winter 2013/2014 program. Limiting participating assets will aid implementation, enabling better settlements and control awareness. Assets capable of delivering incremental energy should be included instead of prohibited, maintaining market efficiency and reducing energy costs. Dispatching DR before OP4 conditions presents additional operational and environmental benefits.

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EnerNOC, IECG, and Verso

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  1. EnerNOC, IECG, and Verso Demand Response Solution for Winter 2013/2014 May 13, 2013

  2. Recommendations for ISOs Proposal • ISOs proposal to prohibit assets that are mapped to resources with CSO from being included in the winter program will significantly limit DR participation • ISO has cited implementation difficulties as an obstacle to allowing these assets, including challenges with settlements as well as ensuring that the control room is aware that an asset mapped to a resource with CSO might be curtailed as a result of the winter program before reaching OP4 conditions • Recommendation: In order to make this feasible to implement, strictly limit the number of assets mapped to resources with CSO that can participate, so manual solutions can be developed. Doing settlements for a small handful of assets will be manageable, and the control room will know exactly what assets are curtailed before OP4 conditions are reached

  3. Recommendations for ISOs Proposal • ISO has expressed their need for incremental energy and a concern that assets mapped to resources with CSO would not provide incremental energy • In reality, assets that are allowed to participate in the winter program would be capable of delivering MW well in excess of what they would in the FCM • Banning these assets will deprive the market of this incremental energy • Dispatching DR earlier than OP4 would also carry meaningful benefits: • Lower energy costs for load • Could preserve fuel for fuel-dependent units • Environmental benefits • Prevents OP4 from being reached • As our previous proposal have indicated, we are flexible regarding a dispatch trigger (i.e. price-based or some other pre-OP4 trigger)

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