Tesla’s head of US vitality market coverage, Arushi Sharma Frank, was not too long ago requested to testify at an open session of the Public Utility Fee of Texas. A photograph surfaced on Twitter of Frank sporting an LFDECARB t-shirt. The t-shirt itself is a message from the group Bros for Decarbonization, which focuses on decarbonization. You possibly can be taught extra concerning the group right here.

Frank confirmed that the testimony was spontaneous. She additionally shared precisely what she was speaking about.

You had been fortunate… I needed to testify spontaneously in the present day?! Perhaps the shirt was accountable. I talked about that ->https://t.co/DlZfkBJ2k6 pic.twitter.com/2i7aIe4FfT

— ArushiSF (@ArushiSF) June 17, 2022

That doc Frank shared a submission receipt signed by Frank for supplementary feedback from Tesla. There’s additionally a video of her testimony obtainable so that you can watch right here. Within the doc, Tesla stated it appreciates the chance to share its feedback on the discussions of PUCT, which passed off on June 16, 2022 – the open assembly on Tesla’s proposal OBDRR041, in addition to its earlier work exhibiting how digital Energy vegetation (VPPs) work.

I not too long ago printed an article about it Tesla’s VPP workshop, which was associated to OBDRR041. Tesla additionally stated it appreciates the fee’s feedback on its Distributed Vitality Useful resource (DER) pilot initiatives. Particularly, Tesla supported the dialogue between representatives of the fee and the employees of the Electrical Reliability Council of Texas (ERCOT) in addition to with the market individuals. The dialogue involved the precise implementation of the system by means of a pilot venture versus a activity drive method. The latter, in accordance with Frank, may trigger pointless delays in implementing a grid service answer for DERs.

A hyperlink to the video of #TX PUC Open Assembly is right here! See above in Lesson 2 for the Fee’s dialogue of #DERs and #VPPs https://t.co/BAl0Ua5oFO

— ArushiSF (@ArushiSF) June 17, 2022

Have a look at the doc and Tesla’s statements

The Fee’s resolution to encourage ERCOT to convey stakeholders collectively and develop a pilot venture to check the market answer of exports from VPPs can be one thing Tesla expresses its appreciation for. This made it doable to deal with points raised by utilities and different market individuals involved concerning the potential influence of site-export DERs on distribution amenities. It additionally allowed for a dialogue on the web impacts and advantages for the transmission grid.

Tesla additionally clarified and offered info on some dialogue matters and questions raised on the open session. These matters included the OBDRR041 standing, the ERCOT pilot proposal, and a query that Chairman Lake requested Tesla on the open session.

OBDRR041 standing

Tesla famous that since OBDRR041 is presently being submitted to the ERCOT Technical Advisory Committee, it won’t request a vote pending additional improvement of the problems and positions of ERCOT and the potential members of the committee.

“Right now, Tesla believes that OBDRR041 can nonetheless be submitted to the Technical Advisory Board pending the feasibility of a digital energy plant pilot venture, as proposed by the Fee on the open session.”

ERCOT pilot proposal

Tesla expressed its views on the formal ERCOT pilot proposal offered on the Open Assembly. Tesla decided that for a proper ERCOT pilot method to be a viable various to OBDRR041, a pilot ought to do the next:

Safe the help of ERCOT and the acceptance and approval of the market by the board of ERCOT.
Be commercializable as sufficient subscribers may very well be aggregated into ample distribution service areas (a couple of, however in restricted numbers, in every service space as outlined in a proposed pilot framework).
In parallel or as a part of the pilot venture, acquire acceptable knowledge addressing clearly recognized utility points.
Make preparations to make sure market service compensation commensurate with the community companies offered by the pilot individuals
Have an recognized “begin date” and “finish date” that’s technically possible for the events concerned.

Along with that final level, Tesla added that the next necessities are in Part 25.361(ok) associated to pilot improvement and approval:

“ERCOT might conduct a pilot venture after the scope and functions of the pilot venture have been authorised by the Board of ERCOT. Proposals for the approval of pilot initiatives are solely submitted to the Administration Board by ERCOT employees after session with involved market individuals and Fee employees nominated by the Government Director.

“The ERCOT Governing Board will guarantee that there’s a possibility to adequately evaluate and touch upon any proposed pilot venture.”

Tesla famous that pilot venture proposals authorised by the ERCOT Board of Administrators ought to embody:

scope and function of the pilot venture;
The designation of short-term exceptions to the ERCOT guidelines that ERCOT is predicted to approve as a part of the pilot;
Standards and reporting mechanisms to find out if and when ERCOT ought to suggest adjustments to ERCOT Guidelines based mostly on the outcomes of a pilot venture.
An estimate of the prices that ERCOT will incur because of the pilot venture.
An estimated date for the completion of the pilot venture.

Tesla’s response to Chairman Lake

Tesla expressed his appreciation for Chairman Lake, who acknowledged that “nothing teaches like expertise, so the earlier you get one thing in observe, the quicker you be taught.”

Tesla additionally responded to a query from the chairman, saying that it was involved it might not be doable to run a pilot program in a non-opt-in-entity (NOIE) area. Presently, Texas owners can not take part in VPPs because of the legislation. Tesla stated:

“Initially, this method is probably not economically rational because it may contain a big useful resource funding in a pilot that isn’t scalable to a industrial retail providing the place Tesla may proceed to serve these clients straight and improve the energy and profitability of this system.”

“Clients in a pilot ought to be capable of proceed reaping the worth of their techniques in a commercially viable answer past the tip date of the pilot – however with a NOIE-only pilot, Tesla would haven’t any management, legally or in any other case continued participation of such clients after the completion of the pilot, even when a viable market participation framework is carried out after the completion of that pilot.

“Any formal program participation by these clients could be solely on the discretion of the NOIE serving these clients. In easier phrases, the aim of a pilot venture is to discover an answer that may be scaled up based mostly on pilot expertise after market guidelines are adopted. So as to construct a program from the learnings of a pilot, the shopper base concerned within the pilot ought to be capable of proceed service below this formalized program in order that the events concerned don’t threat creating a wholly new set of uninvestigated points in a brand new program to deal with distribution system sort that was not a part of the pilot venture.”

Frank additionally shared a hyperlink to over 60 websites of Tesla knowledge. Deep dive is coming quickly.

It is this busy day when feedback are due. Anybody need to learn our 60+ pages of principally knowledge? @PUCTX Thanks for the chance! #erkot #txlege #Texas #powerwall #VPP #Decarb #LFG $tsla #energytwitter #girlsrock https://t.co/4JZXAevvVV

— ArushiSF (@ArushiSF) June 15, 2022


 

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