Tesla’s head of U.S. energy market policy, Arushi Sharma Frank, was recently asked to testify at an open meeting of the Texas Public Enterprise Commission. A photo of Frank in an LFDECARB T-shirt appeared on Twitter. The T-shirt itself is a message from the Bros for Decarbonization group focused on decarbonization. You can learn more about the group here.
Frank confirmed that it was an impromptu request to testify. She also shared what she was talking about.
You were all lucky… I had to testify impromptu today ?! Maybe it’s the wrong shirt. This is what I was talking about -> https://t.co/DlZfkBJ2k6 pic.twitter.com/2i7aIe4FfT
– ArushiSF (@ArushiSF) June 17, 2022
The document Frank shared was a receipt for additional comments from Tesla that Frank signed. There is also a video of her testimony that you can watch here. Tesla said in the document that it appreciates the opportunity to share its comments on PUCT’s discussions held on June 16, 2022 – an open meeting on Tesla’s proposal OBDRR041, as well as previous work showing how virtual power plants (VPPs) work.
I recently published an article about Tesla’s VPP workshop, which was related to OBDRR041. Tesla also said it appreciated the Commission’s comments regarding its Distributed Energy (DER) pilot projects. Tesla particularly supported the conversation between the representatives of the Commission and the staff of the Texas Electricity Reliability Council (ERCOT), as well as with market participants. The conversation covered the actual implementation of the system through a pilot as opposed to the working group approach. The latter, Frank noted, could unnecessarily create delays in implementing network service solutions for DERs.
– ArushiSF (@ArushiSF) June 17, 2022
Looking at the document and Tesla’s statements
The Commission’s decision to encourage ERCOT to bring together stakeholders and develop a pilot project that will enable testing of the market solution for exports from the VPP is also something for which Tesla expressed gratitude. This has made it possible to address issues raised by utility companies and other market participants who are concerned about the potential impacts of SERs exporting the site to distribution facilities. It also provided an opportunity to discuss the net impact and benefits of the transmission network.
Tesla also clarified and provided information in response to several topics and issues raised at the open meeting. These topics included the status of OBDRR041, the ERCOT pilot proposal and a question asked to Tesla by President Lake in an open meeting.
Tesla noted that, since OBDRR041 is currently on the ERCOT Technical Advisory Board, it will not seek a vote until the issues and views of ERCOT and potential board members have been developed.
“At this point, Tesla believes that OBDRR041 could remain at the Technical Advisory Board meeting until the feasibility of a virtual power plant pilot is considered, as proposed by the Commission at the Open Meeting.”
ERCOT pilot proposal
Tesla presented its views on the formal ERCOT pilot proposal presented at the Open Meeting. Tesla noted that a formal ERCOT pilot approach would be a viable alternative to OBDRR041, the pilot should:
- Have the support of ERCOT and the market of acceptance and approval by ERCOT’s board of directors.
- Be subject to commercialization so that a sufficient number of participants can be aggregated in sufficient service distribution areas (more than one, but in limited quantities, in each service area as described in the proposed pilot framework).
- Adequately collect data related to clearly identified distribution utility problems, in parallel or as part of a pilot area.
- Have provisions to ensure compensation for market services commensurate with the network services provided by pilot participants
- Have identified “start date” and “end date” that are technically feasible for the parties involved.
In addition to this last point, Tesla added that the following requirements in Section 25.361 (k) regarding pilot development and approval are:
“ERCOT may conduct a pilot project after approval of the scope and purpose of the pilot project by the ERCOT Steering Committee. Proposals for the approval of pilot projects are submitted to the Steering Committee only by ERCOT staff, after consultation with affected market participants and commission staff designated by the Executive Director.
“The ERCOT Steering Committee will ensure that there is scope for adequate review and stakeholder comments on any proposed pilot project.”
Tesla noted that pilot project proposals approved by the ERCOT Steering Committee should include the following:
- Scope and purposes of the pilot project;
- Determining temporary exemptions from ERCOT rules that ERCOT expects to approve as part of a pilot project;
- Reporting criteria and mechanisms for determining whether and when ERCOT should propose changes to ERCOT rules based on the results of the pilot project.
- Estimation of ERCOT costs attributable to the pilot project.
- Estimated completion date of the pilot project.
Tesla’s response to President Lake
Tesla expressed gratitude to Chairman Lake, who stated that “nothing is learned as experience, so the sooner you get something on the field, the more you will learn faster.”
Tesla also responded to a question asked by the chairman and said he was concerned that he would not be able to cover a pilot program in a non-entity area (NOIE). Currently, homeowners in Texas are unable to participate in VPPs due to the law. Tesla said:
“Primarily, this approach may not be economically rational because it could mean significant investment of resources in a pilot project that is not scalable to commercial retail offer where Tesla could continue to directly serve these customers and increase the strength and sustainability of the program.
Pilot customers should be able to continue to benefit from their systems even after the pilot program is completed, in a commercially viable solution – but with a pilot who is only a NOIE, Tesla would have no control, legally or in on the contrary, through the continued participation of such customers after the pilot closes, even if a sustainable framework for market participation is implemented after the conclusion of that pilot.
“Any formal participation in the program of these customers would be exclusively at the choice of NOIE, which serves these clients. Simply put, the purpose of pilots is to study solutions that can be extended after the adoption of market rules based on pilot learning. In order to build a program based on pilot learning, the base of users involved in the pilot should be able to continue the service according to this formalized program, so that involved parties do not run the risk of launching a completely new set of unexplored issues in a new type of distribution system. pilot project. ”
Frank also shared a link to over 60 pages of data from Tesla. Deep diving is coming soon.
It’s that exhausting day to comment on. 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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