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Texas REP Group Argue Allowing VPP Provider Other Than Customer’s REP Would Harm Reliability, Slow VPP Development
The REP Group consisted of, “Octopus Energy, NRG Energy, Vistra Corp., Shell Energy North America, and Base Power Company participating as members of the Aggregate Distributed Energy Resources Task Force (ADER TF), collectively ‘ADER REPs,’ as well as REPs that are members of the Texas Energy Association of Marketers (TEAM) (collectively ‘REP Group’).”
Excerpts from REP Group Comments:
{***} Past efforts by ERCOT’s DREAM Task Force and Loads in SCED v2 Subgroup of DSWG, demonstrated the possibility, but extreme complexity, of allowing multiple players using devices at the same premise to simultaneously participate in markets. Therefore, the REP Group avers that although it may be possible to have customers selecting VPP providers that are not their REP, such business models are not optimal from a customer or market efficiency perspective or from a reliability perspective under the ERCOT market construct. Furthermore, such arrangements are not a panacea for increasing ADER participation (and could even slow market development); therefore, the complexity that such arrangements entail make them impractical for the ADER pilot project. Accordingly, these comments discuss the need to avoid conflicts regarding controllable customer devices and offer potential solutions for consideration by the ADER TF and the Commission.
REPs Are Appropriately the Primary Point of Contact for Customers Participating in Dispatchable Aggregations of Distributed Energy Resources
The REP Group maintains that Load Serving Entities (LSEs) including Retail Electric Providers (REPs), are best suited and situated to facilitate load resource participation within the framework of ERCOT’s competitive wholesale and retail markets.3 In competitive portions of ERCOT, REPs are the primary customer-facing entity for electric service and bear the financial responsibility for customer usage in wholesale settlement. Consequently, the competitive ERCOT market structure naturally results in LSEs (such as REPs) having the primary VPP customer relationship for economic efficiency, reliability, and a better customer experience. {***}
REP-Driven VPP Solutions Pave the Way for Increasing Participation in the ADER Pilot
{***} If the question posed by Commissioner Glotfelty’s August 14, 2024, about expanding business models in the ADER pilot was posed due to concern about the pilot not yet being at capacity, then it would be advisable to focus on whether there are technical, operational, or ancillary service market design frictions to pilot participation that are inhibiting more robust participation. To that end, the REP Group offers that ADER participants must weigh the relative costs and benefits of participating in the ADER pilot versus other methods of financially benefiting from having dispatchable DERs. As benefits are added to ADER pilot (e.g., increased ease of participation, market signals that economically incentivize participation), the greater the odds participants will choose that path. {***}
REP Comments Regarding Third Party Aggregator Participation ADER Pilot (11/18/2024)
Project 53911 (08/12/2022)
Aggregate Distributed Energy Resource (ADER) ERCOT Pilot Project
