Tesla’s US Energy Markets Policy Lead, Arushi Sharma Frank, was recently asked to testify at a Public Utility Commission of Texas Open Meeting. A photo of Frank wearing an LFDECARB tee shirt popped up on Twitter. The tee shirt itself is a message focused on decarbonization by the group Bros for Decarbonization. You can learn more about the group here.
Frank confirmed that it was an impromptu request to testify. She also shared exactly what she talked about.
— ArushiSF (@ArushiSF) June 17, 2022
The document Frank shared was a filing receipt for supplemental comments from Tesla signed by Frank. There’s also a video of her testimony which you can watch here. In the document, Tesla said that it appreciated the opportunity to share its comments regarding PUCT’s discussions that were held on June 16, 2022 — the open meeting regarding Tesla’s proposal OBDRR041 as well as its prior work demonstrating how virtual power plants (VPPs) work.
I recently published an article about Tesla’s VPP workshop, which was related to OBDRR041. Tesla also said that it appreciated the Commission’s comments related to its Distributed Energy Resource (DER) pilot projects. Tesla especially supported the conversation between Commission representatives and the staff at the Electric Reliability Council of Texas (ERCOT), as well as with the market participants. The conversation covered the real implementation of the system through a pilot as opposed to a task force approach. The latter, Frank noted, could unnecessarily create delays in implementing a grid service solution for DERs.
— ArushiSF (@ArushiSF) June 17, 2022
Looking At The Document & Tesla’s Statements
The Commission’s decision to encourage ERCOT to get stakeholders together and develop a pilot project allowing the market solution of exports from VPPs to be tested is also something Tesla expressed its appreciation for. This allowed for addressing issues raised by utilities and other market participants that have concerns about the potential impacts of site-exporting DERs on distribution facilities. It also allowed for a discussion of the net impact and benefits to the transmission grid.
Tesla also clarified and provided information as a response to a few discussion topics and questions that were raised at the open meeting. These topics included the OBDRR041 status, the ERCOT Pilot Proposal, and a question posed to Tesla by Chairman Lake at the open meeting.
Tesla noted that since the OBDRR041 is currently tabled at the ERCOT Technical Advisory Committee, it would not seek a vote until there was further development of issues and positions from ERCOT and the potential members of the committee.
“At this time, Tesla believes that OBDRR041 may remain tabled at the Technical Advisory Committee pending consideration of the feasibility of a Virtual Power Plant pilot as the Commission proposed at the Open Meeting.”
ERCOT Pilot Proposal
Tesla expressed its views on the formal ERCOT Pilot Proposal that was introduced at the Open Meeting. Tesla noted that for a formal ERCOT pilot approach to be a feasible alternative to OBDRR041, a pilot should :
- Have ERCOT’s support and the market’s acceptance and approval from ERCOT’s governing board.
- Be amenable to commercialization in that sufficient participants could be aggregated across sufficient distribution service areas (more than one, but in capped quantities, in each service area as described in a proposed pilot framework).
- Adequately capture data addressing clearly identified distribution utility concerns, in parallel to or as part of the pilot’s scope.
- Have provisions to ensure market services compensation commensurate with grid services provided by pilot participants
- Have an identified “start date” and “end date” which are technically feasible for involved parties.
In addition to that last point, Tesla added that the following are requirements in Section 25.361 (k) regarding pilot development and approval:
“ERCOT may conduct a pilot project upon approval of the scope and purposes of the pilot project by the governing board of ERCOT. Proposals for approval of pilot projects shall be made to the governing board only by ERCOT staff, after consultation with affected market participants and commission staff designated by the executive director.
“The ERCOT governing board shall ensure that there is an opportunity for adequate stakeholder review and comment on any proposed pilot project.”
Tesla noted that pilot project proposals approved by the ERCOT governing board should include the following:
- The scope and purposes of the pilot project;
- The designation of temporary exceptions from ERCOT rules that ERCOT expects to authorize as part of the pilot project;
- Criteria and reporting mechanisms to determine whether and when ERCOT should propose changes to ERCOT rules based on the results of a pilot project.
- An estimate of costs ERCOT will incur attributable to the pilot project.
- An estimated date of completion of the pilot project.
Tesla’s Response To Chairman Lake
Tesla expressed its appreciation for Chairman Lake, who stated that “nothing teaches like experience, so the sooner you get something in the field, the more you learn faster.”
Tesla also responded to a question posed by the chairman and said that it’s concerned that it will not be able to scope a pilot program in a Non-Opt-in-Entity (NOIE) area. Currently, Texas homeowners are unable to participate in VPPs due to the law. Tesla said:
“Primarily, this approach may not be economically rational as it could mean a substantial resource investment in a pilot that is not scalable to a commercial retail offer where Tesla could continue to directly serve those customers and grow the program’s strength and viability.
“The customers in a pilot should be able to continue to benefit from the value for their systems beyond the end-date of the pilot, in a commercially viable solution – but with a NOIE-only pilot, Tesla would have no control, legally or otherwise, over the continued participation of such customers once the pilot closes, even if a viable market participation framework is implemented following that pilot’ s conclusion.
“Any formal program participation of those customers would be solely at the option of the NOIE serving those customers. More simply, the purpose of a pilot is to study a solution that can be scaled following adoption of market rules based on pilot learnings. To build a program off the learnings of a pilot, the customer base involved in the pilot should be able to continue service under that formalized program, so that parties involved are not running the risk of raising a wholly new set of unstudied issues in a new distribution system type that was not part of the pilot.”
Frank also shared a link to over 60 pages of data from Tesla. Deep dive coming soon.
It’s that exhausting day when comments are due. Anybody want to read our 60+ pages, which are mostly data? @PUCTX thanks for the opportunity! #ercot #txlege #texas #powerwall #VPP #Decarb #LFG $tsla #energytwitter #girlsrock https://t.co/4JZXAevvVV
— ArushiSF (@ArushiSF) June 15, 2022
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