Tesla’s U.S. Energy Markets Policy Director Arushi Sharma Frank was recently asked to testify at a public meeting of the Texas Public Utilities Commission. A photo of Frank wearing an LFDECARB T-shirt was spread on Twitter. The T-shirt itself is a message from the Bros. for Decarbonization team aimed at decarbonization. You can get detailed information about the group here.
Frank confirmed that this was an unexpected requirement to testify. He also shared exactly what they said.
Good luck to all of you … I had to testify suddenly today ?! Maybe it was the shirt’s fault. That’s what I’m talking about -> https://t.co/DlZfkBJ2k6 pic.twitter.com/2i7aIe4FfT
– ArushiSF (@ArushiSF) June 17, 2022
The document shared by Frank was a receipt from Tesla for additional comments signed by Frank. There is also a video of his statement, which you can watch here. In the document, Tesla said it appreciated the opportunity to share PUCT’s June 16, 2022 discussions – an open meeting on Tesla’s proposal OBDRR041, as well as comments on previous work demonstrating how virtual power plants (VPPs) work.
I recently published an article about Tesla’s VPP workshop related to OBDRR041. Tesla also praised the Commission’s comments on the Distributed Energy Resource (DER) pilot projects. Tesla, in particular, supported the Commission’s talks with Texas Electric Reliability Board (ERCOT) staff, as well as with market participants. In contrast to the working group approach, the conversation covered the real application of the system through a pilot. The latter, Frank noted, can create unnecessary delays in the implementation of network service solutions for DERs.
– ArushiSF (@ArushiSF) June 17, 2022
We look at the document and Tesla’s statements
The commission’s decision to encourage ERCOT to bring together stakeholders and develop a pilot project that would allow VPPs to test their export market solutions is also something Tesla is grateful for. This helped address issues raised by utilities and other market participants who were concerned about the potential impact of DERs exporting the area on 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 issues and questions raised at the open meeting. These topics include the status of OBDRR041, the ERCOT Pilot Proposal, and a question posed to Tesla by President Lake in an open meeting.
Tesla said that since OBDRR041 is currently being discussed in the ERCOT Technical Advisory Committee, it will not seek a vote from potential members of ERCOT and the committee until issues and positions are further developed.
“Currently, Tesla believes that OBDRR041 can be discussed in the Technical Advisory Committee until the possibility of a Virtual Power Plant pilot is considered, as proposed by the Commission at the Open Meeting.”
ERCOT Pilot Offer
Tesla expressed its views on the official ERCOT Pilot Proposal presented at the Open Meeting. Tesla noted that for the formal ERCOT pilot approach to be a possible alternative to the OBDRR041, the pilot must:
- Have the support of ERCOT and the acceptance and approval of the market by the ERCOT Board of Directors.
- Be prepared to commercialize so that enough participants can gather in enough distribution service areas (more than one, but limited, in each service area as described in the proposed pilot framework).
- Adequately obtain information that solves distribution problem problems that are clearly defined in parallel to or as part of the pilot’s scope.
- Have provisions to compensate for market services commensurate with network services provided by pilot participants
- There should be a defined “start date” and “end date”, which is technically possible for the parties.
In addition to this end point, Tesla added that Section 25.361 (k) contains the following requirements for pilot training and certification:
“Once the ERCOT board approves the scope and objectives of the pilot project, it can implement the pilot project. Proposals for the approval of pilot projects should be submitted to the board by ERCOT staff only after consultation with the commission appointed by the affected market participants and the CEO.
“The ERCOT Board of Directors must ensure that stakeholders have the opportunity to adequately review and comment on any proposed pilot project.”
Tesla noted that pilot project proposals approved by the ERCOT board should include:
- Scope and objectives of the pilot project;
- Establishing temporary exceptions to ERCOT rules that ERCOT expects to be approved as part of a pilot project;
- Criteria and reporting mechanisms to determine whether and when ERCOT proposes changes to ERCOT rules based on the results of the pilot project.
- Calculation of costs related to ERCOT pilot project.
- Estimated completion date of the pilot project.
Tesla’s response to President Lake
Tesla thanked Chairman Lake, saying, “Nothing teaches as an experience, so the sooner you get something in the field, the sooner you learn.”
Tesla also responded to a question from the chairman and said he was concerned that it would not be able to cover the pilot program in the field of Non-Opt-in-Entity (NOIE). Currently, Texas homeowners are legally barred from participating in VPPs. Tesla said:
“First of all, this approach may not be economically rational, as it could be a significant resource investment for the pilot that cannot be measured by a commercial retail offer where Tesla can continue to serve those customers directly and increase the power and vitality of the program.
“Pilot customers should be able to continue to benefit from the value of their systems after the pilot’s expiration date through a commercially viable solution – but only with a NOIE pilot will Tesla have no legitimate or control. otherwise, even if the existing market presence framework is implemented after the pilot’s opinion, on the continued presence of such customers after the pilot is closed.
“The participation of these customers in any official program will only be at the choice of NOIE, which serves those customers. Simply put, the goal of the pilot is to learn a scalable solution after the adoption of market rules based on pilot learning. In order to build a pilot-based learning program, the customer base involved in the pilot must be able to continue to serve within that formalized program so that stakeholders do not run the risk of raising completely new unexplored issues in a new project. a type of distribution system that is not part of the pilot. “
Frank also shared a link to more than 60 pages of Tesla information. Deep diving is coming soon.
It’s a tiring day when the comments are over. Anyone want to read our 60+ pages that are mostly data? @PUCTX Thanks for the opportunity! #erkot #txlege #texas #power wall #VPP #Dekarb #LFG $ tsla #enerjitwitter #girls https://t.co/4JZXAevvVV
– ArushiSF (@ArushiSF) June 15, 2022
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