2022 – Tesla’s political leader certifies at the PUCT open meeting that Tesla is focused on supporting the Texas Grid

Arushi Sharma Frank, Tesla’s head of US energy market policy, was recently asked to testify at an open session of the Texas Public Utilities Commission. A photo has surfaced on Twitter of Frank wearing an LFDECARB shirt. The shirt itself is a message from the Bros for Decarbonization group, which focuses on decarbonization. You can learn more about the group over here.

Frank asserted that the testimony was spontaneous. She also shared exactly what she was talking about.

Documentation Frank shared a signed mail receipt from Frank for supplemental feedback from Tesla. There is also a video of her statement that you can watch here. In the document, Tesla said it appreciates the opportunity to share its comments on the PUCT discussions, which took place on the June 16, 2022 – open meeting on Tesla’s proposal OBDRR041, as well as its previous work demonstrating how to create virtual power plants (VPPs) for occupancy.

I recently published an article in a VPP workshop at Tesla related to OBDRR041. Tesla also said it appreciates the Commission’s comments on its distributed energy resource (DER) pilot projects. In particular, Tesla supported discussion between commission representatives and employees of the Electricity Reliability Council of Texas (ERCOT) as well as with market participants. The discussion relates to the actual implementation of the system through a pilot project rather than a team approach. The latter, according to Frank, can cause unnecessary delays in the implementation of a network service solution for DERs.

See the document and the Tesla data

The Commission’s decision to encourage ERCOT to bring stakeholders together and develop a pilot project to test an export market solution for VPPs is also something Tesla appreciates. This made it possible to address issues raised by utilities and other market participants concerned about the potential impact of exporting customs declarations on distribution facilities. It also provided a discussion about the net effects and benefits of the transmission network.

Tesla also explained and provided information on some of the discussion topics and questions raised in the open session. These topics included the status of OBDRR041, the experimental proposal for ERCOT, and a question that President Lake posed to Tesla in the open session.

Case OBDRR041

Tesla noted that since OBDRR041 is currently being submitted to the ERCOT Technical Advisory Committee, it will not request a vote pending further development of ERCOT’s issues and positions and potential members of the committee.

“At this time, Tesla believes that OBDRR041 can still be submitted to the Technical Advisory Board pending the feasibility of a pilot project for the virtual power plant, as proposed by the committee at the open session.”

A demo proposal for ERCOT

Tesla expressed his views on the official ERCOT pilot proposal presented at the open meeting. Tesla has determined that for the official ERCOT pilot approach to be a viable alternative to OBDRR041, the pilot must do the following:

  • Secure ERCOT support and market acceptance and approval by the ERCOT Board of Directors.
  • Be marketable as sufficient number of subscribers can be grouped into sufficient distribution service areas (more than one service area, but in limited numbers, in each service area as outlined in a proposed pilot framework).
  • In parallel with or as part of the pilot project, collect appropriate data that address clearly identified utility issues.
  • Arrangements are made to ensure that the market service is compensated in proportion to the network services provided by the pilot participants
  • Specify a “start date” and an “end date” that is technically feasible for interested parties.

In addition to this last point, Tesla added that the following requirements are in Section 25.361(k) related to development and pilot approval:

“ERCOT may conduct a pilot project after approval by the ERCOT Board of Directors of the scope and purposes of the pilot project. Proposals for approval of pilot projects are only submitted to the Board by ERCOT staff after consultation with relevant market participants and Commission staff nominated by the Executive Director.

“The ERCOT Board will ensure that there is an opportunity to adequately review and comment on any proposed pilot project.”

Tesla indicated that pilot project proposals approved by the ERCOT board of directors should include:

  • Scope and purpose of the pilot project;
  • Set temporary exceptions to ERCOT rules that ERCOT is expected to agree to as part of the pilot project;
  • Standards and reporting mechanisms to determine if and when ERCOT should propose changes to the ERCOT Rules based on the results of a pilot project.
  • An estimate of the costs to be incurred by ERCOT as a result of the pilot project.
  • Estimated date for completion of the pilot project.

Tesla’s response to President Lake

Tesla appreciated Chairman Lake, who stated that “nothing teaches like experience, so the sooner you get something in practice, the faster you learn.”

Tesla also responded to a question from the president, saying it was concerned that it would not be possible to run beta software in a non-optional space (NOIE). Currently, Texas homeowners cannot participate in VPPs due to the law. Tesla said:

“First of all, this approach may not make economic sense because it may involve a significant investment of resources in a non-scalable pilot program for a retail commercial offering where Tesla can continue to serve these customers directly and increase the strength and profitability of the program.”

“Customers in a trial period should be able to continue to reap the value of their systems in a commercially viable solution after the trial end date — but with NOIE’s only beta release, Tesla will have no legal control or continued participation in such customers after completion. from the pilot program, even if a viable market participation framework is implemented after completion of this pilot.

“Any formal participation in the program by these clients will be at the discretion of NOIE serving only those clients. In simpler terms, the purpose of the pilot project is to explore a solution that can be scaled up based on pilot experience after market rules have been adopted. In order to build a program from Learn Pilot , the customer base participating in the pilot program must be able to continue serving under this formal program so that the parties involved do not risk creating an entirely new set of issues that have not been investigated in a new program to address the type of distribution system that was not part of the pilot. “

Frank also shared a link to over 60 Tesla data sites. Deep dive soon.


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