September 29, 2021

ESA Asks FERC to Approve CAISO Update to Hybrid Resource Rules

Today, ESA jointly submitted comments with the California Energy Storage Alliance (CESA) to the Federal Energy Regulatory Commission (FERC) in support of CAISO’s proposed clarifications to market rules that will remove barriers for hybrid and co-located resources to participate in CAISO’s markets.
In our comments, we express support for provisions to enhance market participation by hybrid and co-located resources, including the removal of operating constraints to enable full participation of hybrid resources and telemetry requirements that will enable hybrid resources to be dispatched more effectively. We emphasize support for CAISO’s proposed temporary exemption from general resource adequacy rules that would double-penalize hybrid resources for periods of non-performance due to charging needs, noting that CAISO is in the process of developing a resource availability approach more suitable for hybrid resources.
Lastly, we support CAISO’s proposed changes in provisions related to aggregate capability constraints for co-located resources. The aggregate capability constraint helps manage the interconnection limit when a resource’s aggregate maximum generating capabilities exceed the interconnection limit. CAISO’s proposed changes will allow for additional granularity for complex configurations of co-located resources to utilize multiple distinct aggregate capability constraints, within the overall constraint of their interconnection, thus enabling them to have more flexibility to operate under distinct contracts as well as undertake more efficient dispatch.

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