rates, and is as asserted by never ‘free’ PG&E and SDG&E in their comments on the Proposed Decision.” Multiple-Use Applications Verified D.18-01-003, Appendix A, Rules 9 and 11 In considering the treatment of and “service TURN noted that one revenue stacking,” TURN Reply Cmts on challenge of ensuring that MUA storage Joint Staff Proposal for assets have the chance to provide and be MUA, 6/30/17, pp. 3-4 paid for all their potential services but – only for those services they actually provide is the number of discrete venues in which – such services may be provided (such as to D.18-01-003, p. 15; the to the customers “behind meter,” Appendix A, Rules 5, distribution grid, to the 6, 7 transmission grid, to bilateral Resource Adequacy (RA) capacity markets, TURN Reply Cmts on and/or to CAISO energy markets). TURN Joint Staff Proposal for suggested that the Commission put the onus MUA, 6/30/17, pp. 5-6 on the utilities procuring storage to meet their ES program targets to ensure that all the services they purchase from an MUA storage asset (and resulting payments they D.18-01-003, p. 17; expect to make) are properly counted once, Appendix A, Rule 10 but only once. TURN explained that the TURN Reply Cmts on of all aspects of utility utilities’ knowledge Joint Staff Proposal for operations from the customer to the MUA, 6/30/17, pp. 6-7 generator should enable them to assess which services can be and thus “stacked” which revenues may be reasonably paid. To implement this approach, TURN suggested that the Commission require that purchasers of MUA storage services include contract language to ensure that all the services they purchase from an MUA storage asset (and resulting payments they expect to make) are properly counted once, but only once, such as through an affidavit from the MUA asset owner. The Commission in D.18-01-003 addressed the concerns TURN raised (as did other parties) about transparency and in Rule 9 and Rule 11. Rule 9 requires: “In response to a utility request for offer, the storage provider is required to
rates, and is never ‘free’ as asserted by PG&E and SDG&E in their comments on the Proposed Decision.” Multiple-Use Applications In considering the treatment of “service and revenue stacking,” TURN noted that one challenge of ensuring that MUA storage assets have the chance to provide and be paid for all their potential services – but only for those services they actually provide – is the number of discrete venues in which such services may be provided (such as to customers “behind the meter,” to the distribution grid, to the transmission grid, to bilateral Resource Adequacy (RA) capacity markets, and/or to CAISO energy markets). TURN suggested that the Commission put the onus on the utilities procuring storage to meet their ES program targets to ensure that all the services they purchase from an MUA storage asset (and resulting payments they expect to make) are properly counted once, but only once. TURN explained that the utilities’ knowledge of all aspects of utility operations from the customer to the generator should enable them to assess which services can be “stacked” and thus which revenues may be reasonably paid. To implement this approach, TURN suggested that the Commission require that purchasers of MUA storage services include contract language to ensure that all the services they purchase from an MUA storage asset (and resulting payments they expect to make) are properly counted once, but only once, such as through an affidavit from the MUA asset owner. The Commission in D.18-01-003 addressed the concerns TURN raised (as did other parties) about transparency and in Rule 9 and Rule 11. Rule 9 requires: “In response to a utility request for offer, the storage provider is required to D.18-01-003, Appendix A, Rules 9 and 11 TURN Reply Cmts on Joint Staff Proposal for MUA, 6/30/17, pp. 3-4 D.18-01-003, p. 15; Appendix A, Rules 5, 6, 7 TURN Reply Cmts on Joint Staff Proposal for MUA, 6/30/17, pp. 5-6 D.18-01-003, p. 17; Appendix A, Rule 10 TURN Reply Cmts on Joint Staff Proposal for MUA, 6/30/17, pp. 6-7 Verified
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