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ORTP EXEMPTION FOR DISTRIBUTED RTRS

N O V E M B E R 1 3 , 2 0 1 4

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• Effective for FCA9, up to 200 MW per year of Renewable Technology Resources will be eligible to request exemption from Offer Review Trigger Price mitigation.

• Distributed Generation assets that meet the criteria for Renewable Technology Resources are not eligible for this exemption because they are classified as Demand Capacity Resources.• ISO Tariff Section III.13.1.1.1.7 states that a Renewable Technology

Resource is a Generating Resource that satisfies 4 criteria

THE ISSUE

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• ISONE has expressed the following concerns with allowing DG to request the RTR ORTP exemption:• It would be complex to implement the exemption if the DG asset is

aggregated with other assets in a Demand Resource, since one or more of those assets may not be a renewable resource.• In particular, if the RTR cap is reached and the qualified DG MW

are pro-rated, what happens to the Qualified Capacity of the entire Demand Resource?

• Understanding the mechanics of this scenario will require more time than is available prior to FCA9.

• Some participants have expressed concerns regarding the calculation of Qualified Capacity and performance if a Demand Capacity Resource includes both RTR and non-RTR assets in an aggregation.

CONCERNS

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PROPOSED SOLUTION

• Effective for FCA10, revise the definition of Renewable Technology Resources to include both Generating Capacity Resources and On-Peak Demand Resources that satisfy the requirements specified in Section III.13.1.1.1.7.• If an On-Peak Demand Resource is an aggregation, then every

asset in the aggregation must satisfy all of the RTR criteria.

• Action requested:• Vote on proposed MR1 revisions (next slide):

• MC: November 12-13• PC: December 5; FERC filing shortly thereafter

• This should support an implementation date prior to the March 3, 2015 close of the FCA10 Show of Interest Window

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PROPOSED TARIFF REVISIONS

Section I.2.2: Renewable Technology Resource is a Generating Capacity Resource or

an On-Peak Demand Resource that satisfies the requirements specified in Section III.13.1.1.1.7.

Section III.13.1.1.1.7 To participate in the Forward Capacity Market as a Renewable

Technology Resource, a Generating Capacity Resource or an On-Peak Demand Resource (including every asset that is part of the On-Peak Demand Resource) must satisfy the following requirements: (c) participate in a Forward Capacity Auction for a Capacity

Commitment Period beginning on or after June 1, 2018 as a New Generating Capacity Resource or New Demand Resource pursuant to Section III.13.1.1, and;

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THANK YOU FOR YOUR

CONSIDERATION.