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Agenda item #1. Current interval RQMD status at each utility.
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Current interval RQMD status at each utility 1. RQMD interval data for interval billed customers will be available 1st quarter 2015 on our CDA platform as will monthly RQMD data for anchor billed customer. The individual interval will be flagged as RQMD at the time the customer is billed. 2. Currently, RQMD interval data is generally not available for anchor billed customers. This data goes through a daily VEE process but the data that isn’t able to be VEE’d (exceptions) are not fixed or worked. The data from these exception days are not posted on MyEnergy or CDA.
Plans for creating and transferring interval RQMD to non-utility DRPs (including timeline and funding) • Interval billed customers will receive RQMD information via CDA in early 2015. Funding was provided in the CDA proceeding. • For anchor billed customers (mass market), PG&E would establish a process in which exceptions are worked at the end of the month. This data would then be considered RQMD and would be posted on CDA at the time the bill is created. The exception work is a manual process and would require 1-2 FTEs per 100,000 accounts to perform the work. The funding is requested in PG&E Rule 24 Cost Recovery Application.
PG&E’s VEE Processes Available 1st quarter 2015 1-2 FTEs per 100,000 customers
Proxy data (GB, CDA, etc.) as statically valid RQMD on an aggregated basis for each Resource ID • Overall, the daily VEE data for anchor billed customers is very good. The exception rate is about .15%. If Proxy RQMD is aggregated to a high volume, the resultant SQMD data will likely be as accurate as any statistical sampling methodology. Guidelines will need to be created if we go down this path. • PG&E currently has the ability to store the hourly interval data for 7 years. It is currently available in our billing systems for 13 months. • PG&E is testing a new daily high/low validation process for all interval data which would further reduce exceptions. May need change to DASMMD.
3rd party VEE GB data and create interval RQMD Discussed in Agenda item #1.
Utilities’ proposed solutions, e.g., provide interval RQMD upon requests • Under PG&E’s Rule 25 proposal, PG&E would flag the interval data provided through CDA as “RQMD” at the end of the month in CDA. This will provide interval billed customers with the data that they need for ISO settlement within a day or so after the customer is billed. DRPs will have enough time to generate SQMD by T+48B settlement requirements. • PG&E generally does not have plans to provide RQMD data to mass market, BUT it does for Rule 24 mass market participants. Our funding request for RQMD for the mass market was denied in our GRC. For mass market Rule 24 participants, PG&E would work exceptions at the end of the month and repost correct data as “RQMD” at the time of billing. This will provide interval billed customers with the data that they need for ISO settlement within a day or so after the customer is billed. DRPs will have enough time to generate SQMD by T+48B settlement requirements.
Concerns about Proxy RQMD Approach The value for Proxy RQMD solution only arises in an “automated”, mass market environment. If mass market implementation is required in the short term, focus should be put on issues like APIs, registration and CISR processes that would help move the high volume implementation timeline forward. Proxy RQMD does not impact manual processing limitations or implementation schedule. A determination should first be made whether this approach is better than other approaches. For instance, the Proxy RQMD proposal will only address hourly data, statistical sampling could address 15 minute interval data for ancillary service products. Statistically sampling is being discussed in the Baseline Working Group. PG&E has some concern that the CAISO would later view the individual proxy data, with gaps, as non-compliant with its standards and penalize IOUs with adjustments under Rule 24. This issue can be at least partially assuaged with formal acknowledgement by ISO that the data is Proxy Data is “acceptable” for SQMD and that the DRPs have a 2% data accuracy band like the IOUs do for scheduled loads.
Potential Solutions If Commission would temporarily grant slight simplifications to the Rule 24 tariff processes, PG&E could accommodate up to 10,000 mass market customers in the DRAM in 2016.
Suggestions to SIMPLIFY RULE 24 to allow for inclusion of Mass market in DRAM Pilot – Manual implementation • Do not require IOUs to automatically de-enroll a PDP participant when the participant is included in a third party PDR registration. Instead use the same approach as other DR program participants under the registration review process. • Rather than requiring that IOUs provide CISR-DRP information on when a customer can de-enroll from an IOU program without a financial penalty, only require that IOUs inform DRPs of the first date customer could become available to leave program regardless of financial penalty. • To ease dual participation tracking, in instances where the IOU receives a customer request for participation in an IOU DR program and that customer is already participating in PDR, allow the IOU to have the customer’s enrollment start date in the IOU program be set to the first available program start date that is after the termination date of the active or pending registration. Customer would be provided notice of the delayed enrollment due to dual participation rules. • Do not require IOUs to provide the P-Node in its CISR DRP response. • Do not require meter change-outs for MM customers if reprograming their existing meter is insufficient to provide DRP with requested interval data length (i.e. 15 min)
Things to keep in mind about RQMD • The Direct Access Standards for Meter and Meter Data (DASMMD) defines the VEE requirements by which IOUs and ESP MDMA’s must process customer usage data for the purposes of billing (RQMD) and further processing settlement (SQMD) at the ISO. • For PG&E, residential customer accounts are generally billed using anchor reads • because there has been little need to this point to bill them using the interval data. • Therefore, residential customer interval data is does not go through all the VEE • processes but it goes through most of the processes. • PG&E’s Rule 24 full market implementation vision (Appendix B) contemplates: • Up to 100,000 residential customers have interval exceptions “worked” to create RQMD data • The 100,000 accounts can serve as a statistical sampling population if greater volumes needed • Interval data for all customers, including residential participants, will be posted on CDA to provide • vendors with RQMD data. • The residential 15 min data from these accounts can also be used for the statistical sampling • of “day-of” products.