Diving Into Tesla’s 60+ Pages Of PUCT Filings (Mostly Data)

Tesla has over 60 pages of Public Utility Commission of Texas (PUCT) filings that have recently been shared publicly, and we’re about to dive into them. Grab some water and a coffee and let’s go.

Tesla and its team, including its US Energy Markets Policy Lead, Arushi Sharma Frank, have been working hard to help Texan Powerwall customers be able to take part in virtual power plant (VPP) pilot programs. In May, Tesla held a VPP workshop for the Electric Reliability Council of Texas (ERCOT) and Frank was one of the key leaders hosting the meeting.

Recently, Frank was asked to testify at an open meeting of the PUCT, and there she shared Tesla’s comments and statements addressing questions and other concerns relating to VPPs.

It’s that exhausting day when comments are due. Anybody want to read our 60+ pages, which are mostly data? @PUCTX thanks for the opportunity! #ercot #txlege #texas #powerwall #VPP #Decarb #LFG $tsla #energytwitter #girlsrock https://t.co/4JZXAevvVV

— ArushiSF (@ArushiSF) June 15, 2022

Frank tweeted a thank you to the PUCT for the opportunity of allowing Tesla to provide comments. In addition, she followed up with two more tweets, with one mentioning her favorite part of the filings — Tesla describing a phenomenon called “clumping.” Clumping is a reference to capturing the full value of distributed energy renewables capacity in an aggregate load resource (ALR).

63 Pages Of Data For PUCT

In total, there were 63 pages. I’m only going to go over some of the data briefly. I think it’s important to highlight Tesla’s hard work because if Texas allows its residents who own Powerwall batteries systems to participate in VPPs, this opens the door for other states in the Deep South to at least consider clean energy solutions for various problems, especially grid-related. Texas is well known for its grid instability, and if it allows Tesla Powerwall customers to take part in VPPs, this could mean saving lives during disasters.

Included in the filings were comments from Tesla, a request from Tesla that the Commission direct ERCOT to prioritize several actions such as allowing ALRs (Aggregated Load Resources) to provide injection capacity from individual sites in a framework by December 2022, an informal narrative of Tesla’s VPP demonstration in ERCOT, and 47 slide pages detailing the ERCOT/Tesla ancillary service demonstration.

I think the most important part for us outsiders observing here is the 47 slides, because they highlighted a lot of data that shows just how the Texas grid will benefit from VPPs. The 47 slides showed several key meetings between Tesla and ERCOT about the demo program.

Key Meeting Between Tesla & ERCOT Shows Tesla Has Been Working Hard Trying To Convince Texas To Allow VPPs

In March, there were four meetings in which Tesla defined clumping, Frank’s favorite part, as well as two telemetry signal approaches. Following that were weekly meetings around the demo results with the last demo result being April 15, 2022. On April 9, Tesla and ERCOT revisited clumping and the two telemetry signals approach.

This tells me and anyone paying close attention that Tesla has been quietly working with ERCOT to help the Texas grid for quite some time. This, I think, is a good thing, especially for Texas.

Tesla Seeks To Register The First ALR In ERCOT

According to the documents, Tesla wants to register the first ALR in ERCOT and participate in services that are currently unavailable. These services include non-spin and sCED load reduction dispatch. Tesla wants to do this with the full value of grid services that injecting devices can provide in an ALR.

Tesla said that it will lead efforts to modify the utility’s ALR Policy Other Binding Document to make it fit with practical operational, registration, and qualification issues. It clarified that ERCOT can exchange two telemetry points with an aggregation-qualified scheduling entity (QSE).

Tesla ERCOT Demo Tests

Tesla’s first demo looked at the comparison of battery and premise-level telemetry. Below is a chart showing the initial conditions, test steps, data collected, and pass criteria.

This first test results show that VPPs work beautifully in Texas. According to the results, the load decreased during the evening while in the morning it decreased while exporting to the grid. And during the daytime, the exporting of energy to the grid only increased. Tesla explained further:

“Discharging from the customer’s battery using a step function can clearly be identified in the premise-level data.

“At different times of day, premise-level data will look differently, depending on the current load:

1. Evening time: during the evening peak, user load is typically high, and discharging the battery will show up as a decrease in premise-level load.

2. Morning time: during the night/morning time, user load is typically lower, and discharging the battery will both decrease load, and export energy to the grid.

3. Daytime: during the daytime, solar is exporting to the grid, and discharging the battery will increase the export.”

You can view the full demo, test results, and all of Tesla’s comments here.

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