Tesla’s head of energy market policy, Arushi Sharma Frank, was recently asked to testify at a public meeting of the Texas Public Service Commission. A photo of Frank in the LFDECARB T-shirt appeared on Twitter. The T-shirt itself is a message focused on the decarbonization of the Bros for Decarbonization group. You can learn more about the group here.
Frank confirmed that it was an impromptu request for testimony. She also shared exactly what she was talking about.
You are all lucky…. Did I have to testify today ?! Maybe it was a shirt fault. I talked about that -> https://t.co/DlZfkBJ2k6 pic.twitter.com/2i7aIe4FfT
– ArushiSF (@ArushiSF) June 17, 2022
The document that Frank shared was a confirmation of the submission of additional comments from Tesla signed by Frank. There is also a video with her testimony, which you can watch here. Tesla said in a document that she appreciated the opportunity to share her comments on the PUCT discussions that took place on June 16, 2022 – an open meeting on Tesla’s design OBDRR041, as well as her previous work demonstrating how virtual power plants (VPPs) work.
I recently published an article about the Tesla VPP workshop, which was related to OBDRR041. Tesla also stated that it appreciated the Commission’s comments on its Distributed Energy Resource (DER) pilot projects. Tesla particularly supported the dialogue between Commission representatives and employees of the Texas Electric Reliability Council (ERCOT), as well as with market participants. The interview concerned the actual implementation of the system through a pilot project, as opposed to the working group approach. The latter, Frank noted, could unnecessarily delay the implementation of grid services for DER.
– ArushiSF (@ArushiSF) June 17, 2022
A look at Tesla’s document and statement
The Commission’s decision to encourage ERCOT to bring together stakeholders and develop a pilot project to test the market solution for PPP exports is also something that Tesla has expressed its appreciation for. This has made it possible to address the problems raised by energy companies and other market participants who are concerned about the potential impact of on-site DERs on distribution facilities. This also allowed a discussion of the net impact and benefits for the transmission system.
Tesla also clarified and provided information in response to several discussion topics and questions raised at the open meeting. These topics included the state of OBDRR041, the ERCOT pilot proposal and the question raised by Tesla’s Lake President at an open meeting.
Tesla noted that as OBDRR041 is currently being submitted to the ERCOT Technical Advisory Committee, it will not seek to vote until the problems and attitudes of ERCOT and potential committee members have further developed.
“At this point, Tesla believes that OBDRR041 may remain submitted to the Technical Advisory Committee until the feasibility of a virtual power plant pilot project is considered, as proposed by the Commission at an open meeting.”
ERCOT pilot proposal
Tesla expressed its views on the formal ERCOT pilot proposal, which was presented at the Open Meeting. Tesla noted that in order for ERCOT’s formal pilot approach to be a viable alternative to OBDRR041, the pilot should:
- Have ERCOT support and market acceptance and approval from the ERCOT Management Board.
- Be open to commercialization in the sense that a sufficient number of subscribers could be aggregated across sufficient areas of distribution services (more than one, but in limited quantities, in each service area, as described in the proposed pilot framework).
- Adequately capture data that addresses clearly identified distribution service issues, in parallel with or as part of the scope of the pilot project.
- Have provisions to ensure that market services are compensated in proportion to the network services provided by the participants in the pilot project
- Have a specified “start date” and “end date” that are technically feasible for the parties involved.
In addition to this last point, Tesla added that the following are the requirements in § 25.361 (k) concerning the development and approval of pilots:
“ERCOT may carry out a pilot project after approval of the scope and purposes of the pilot project by the ERCOT Management Board. Proposals for the approval of pilot projects shall be submitted to the Governing Board only by ERCOT staff in consultation with the relevant market participants and Commission staff appointed by the Executive Director.
“The ERCOT Management Board shall ensure that there is an opportunity for adequate stakeholder reviews and comments on any proposed pilot project.”
Tesla noted that the pilot project proposals approved by the ERCOT Management Board should include the following:
- Scope and purposes of the pilot project;
- Indication of temporary exceptions to the ERCOT rules that ERCOT expects to allow in the pilot project;
- Reporting criteria and mechanisms to determine whether and when ERCOT should propose changes to ERCOT rules based on the results of the pilot project.
- Estimate of the costs ERCOT will spend on the pilot project.
- Estimated completion date of the pilot project.
Tesla’s reaction to President Lake
Tesla expressed his appreciation to President Lake, who said that “he will not learn anything as an experience, so the sooner you get something in the field, the faster you will learn.
Tesla also answered the President’s question, saying she feared she would not be able to include the Non-Opt-in-Entity (NOIE) pilot program. Currently, homeowners in Texas cannot participate in VPP due to the law. Tesla said:
“This approach may not be primarily economically rational, as it could involve a significant investment of resources in a pilot project that cannot be scaled to a commercial retail offering, where Tesla could continue to directly serve these customers and increase the program’s strength and viability.”
“Customers in the pilot project should be able to continue to benefit from the value of their systems after the end date of the pilot project in a commercially viable solution – but with only NOIE pilot, Tesla would have no control, legally or otherwise, on the continued participation of such customers after the pilot. project, even if a viable market participation framework is implemented at the end of the pilot project.
“Any formal participation of these customers in the program would be solely at the discretion of NOIE, which serves these customers. Simply put, the purpose of the pilot project is to study a solution that can be scaled after the adoption of market rules based on pilot knowledge. In order for the program to be built on the lessons learned from the pilot project, the customer base involved in the pilot project should be able to continue service under this formalized program so that stakeholders do not run the risk of creating a whole new set of unexplored issues in the new project. type of distribution system that was not part of the pilot project. “
Frank also shared a link to more than 60 pages of data from Tesla. A deep dive is coming soon.
It’s an exhausting day for comments. Does anyone 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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