NYISO last week proposed shortening the activation notice period for special-case resources from 21 hours to four, which caused consternation among program participants at the Installed Capacity Working Group’s meeting.

SCRs are large consumers that act as demand response resources at the direction of NYISO itself. As part of its Engaging the Demand Side initiative, the ISO has proposed to increase the required duration of SCRs’ load curtailment from four hours to six. That proposal has received broad support from stakeholders, with some caveats. (See NYISO Proposes Changes to Special-case Resource Program.)

Among those discussed at the Aug. 29 meeting was NYISO’s proposal to not give SCRs the option of curtailing load for only four hours. Michael Ferrari, a market design specialist with NYISO, said to have both the four-hour and six-hour options would require an annual elections process in which resources would have to declare ahead of the capability year what class they were in.

Zach Smith, senior project manager for NYISO, said adding the additional options would delay implementation and it did not want to delay a reliability program with broad stakeholder support.

Aaron Breidenbaugh, senior director of regulatory and government affairs for CPower, said this was the first time he heard NYISO say it was not doing something for a reason other than operational difficulty.

“Previously we’ve heard that operations can’t handle multiple durations in real time, and I suspect they’ll have a harder time if they only have four hours,” Breidenbaugh said.

NYISO staff acknowledged this was the primary issue with having multiple durations.

Notice Period

The ISO wants to reduce the current notice period to help maximize the grid operator’s flexibility and reduce the likelihood of false notifications, Ferrari said.

But this proposal left some stakeholders surprised and frustrated.

One stakeholder who represents Multiple Intervenors — a group of large industrial, commercial and institutional consumers — said the proposal was a “dramatic change” to spring on the demand side.

NYISO said in July it was considering shortening the notification period, though it did not say by how much.

“This whole project is supposed to be about NYISO engaging the demand-side participants in these programs,” the stakeholder said. “While participants could perform with less than 21 hours’ notice, they strongly desired some advanced-day notification, preferably prior to the end of the prior work day.”

To adjust load or activate generation, work schedules needed to be shifted in the event of a call, they said. The manufacturers who participate in the program go to great lengths to reduce their load when called on.

“They will see this proposed change as the straw that breaks the camel’s back and causes them to leave the program,” they said. “If that’s not a concern for NYISO, that’s fine. But I think NYISO should be aware that this could have a dramatic impact on participation.”

The stakeholder said Multiple Intervenors would be happy to have more meetings with NYISO, but they would not perform survey work for the ISO to assess their members’ sentiments.

“We’re not going to do a survey and do the NYISO’s work for it,” they said. “If you want that information, hold a meeting. We’ll participate.”

Jay Goodman, another representative of Multiple Intervenors, asked whether NYISO could provide any historical data on events in which it has called on SCR program participants and did not get corresponding activations. A NYISO staff member said they don’t believe such information is published.

“I do want to note,” Goodman said, “it’s frustrating in the context of a project that is supposed to be engaging with the demand side, where requests for information not only from the demand side but the MMU, is met with the response of ‘No, we can’t provide that information. We won’t provide that information.’”

Goodman went on to ask why NYISO hadn’t brought up the four-hour notice period with the demand side directly, during earlier meetings with Multiple Intervenors. Ferrari said the four-hour notice period had not been decided on by NYISO internally yet.

“The city is shocked as well to this significant change to the program,” said Couch White attorney Amanda De Vito Trinsey, speaking on behalf of New York City.

“This causes a lot of industrial issues, but even for non-industrial customers, this is still a very significant impact on their operations and their ability to respond in a four-hour period,” she said. “I encourage NYISO to come back right away with something to review.”

A representative of the New York State Energy Research and Development Authority said they were disappointed that NYISO wasn’t presenting a more flexible program and didn’t have more information available for reasonable stakeholder follow-up questions.

Another stakeholder compared the various revisions to the SCR programs to multiple ruptured bulkheads on the Titanic. No one issue was going to kill the program, but all of them together would drive participants out.

“The first hole was having revenue reduced by one-third because of capacity accreditation; wham bam, now we’re up to four bulkheads,” they said. “Like, how much more do you think you can do in the guise of catering to operational needs and desires and still have a viable program? I’d say you’re past that point.”

They went on to say this felt like evidence NYISO wanted to get rid of the SCR program entirely. If NYISO wants to save the program, it needs to tone down some of the changes, they said.

“Thank you for your comments,” said Ferrari. “If you’ll allow me to take liberties with your analogy, there are a lot more icebergs in the water. … The grid is changing; it’s a much more dynamic system; and you know we haven’t made changes to this program in a quarter-century.”