ORTP EXEMPTION FOR DISTRIBUTED RTRS

J U LY 1 0 , 2 0 1 4

• 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

• 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.• 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.

• Other concerns pertain to how performance would be measured for Distributed RTRs.

CONCERNS

PROPOSED APPROACH

• GP Renewables proposes to extend the eligibility of resources seeking the RTR exemption from ORTP mitigation to the following:• On-Peak Demand Resources that consist of one or more Distributed

Generation assets; • If the Resource is an aggregation, then each asset in the aggregation

must satisfy all criteria listed in ISO Tariff Section III.13.1.1.1.7 (a-d).

• GP Renewables will delay its requested implementation to FCA10, to allow for further consideration of the concerns expressed by ISONE and NEPOOL stakeholders.

Thank you for your consideration.

QUESTIONS?

Q