Response to the IESO’s White Paper on

OPTIONS TO ENHANCE DER PARTICIPATION

December 10, 2020

TABLE OF CONTENTS

 Introduction to SensorSuite Inc.

 SensorSuite’s Perspective
 Change in Business Models
 Insights into Urban Consumer Behaviour
 Customer Savings
 Evidence-Based Data Drives DER Adoption
 LDC as a Facilitator
 General Feedback
 Appendix
 Specific Feedback on Recommendations

2
WHAT IS SENSORSUITE?

SensorSuite® Inc. (“SS”) is a complete energy intelligence platform for

facility owners and managers. SS’s Energy Cloud Ecosystem (“ECE”) delivers high
resolution and real time data enabling their customers to make better
informed decisions while extracting more value out of their electricity, gas
and water assets.

ECE can be leveraged to aggregate and co-ordinate DERs.

OUR COMPLETE ENERGY INTELLIGENCE PLATFORM

VOLTAGE,
84 CURRENT, USE,
MURBs IN IESO DEMAND, POWER
AREA FACTOR,

1Billion 13MW
OUTSIDE TEMP

DATA POINTS PER CONTROLLABLE IN

YEAR ACROSS 16+ IESO AREA
PARAMETERS

103
MULTI-UNIT RESIDENTIAL
BUILDING (MURB) EXTRACTING >
MURBs ACROSS VALUE FROM
CANADA

4
 ENERGY CLOUD ECOSYSTEM
MACHINELINK BOILERLINK
Realtime, IOT enabled asset IOT Cloud Connected
monitoring and maintenance Boiler sensor and control
support solutions

ECE
CO2
Carbon Monitoring INTELLIGENT
THERMOSTAT
Cloud Connected Through
an Industrial 900Mhz Mesh
Network

ENTERPRISE
REPORTING SUITE LOAD SHIFTING
Portfolio Reporting Supporting Energy Arbitrage and Demand
Budgeting, ESG, Maintenance and Response Revenue Programs
Tenant Engagement

UTILITY SERVICES
Electricity, Gas and Water Utility Cloud connected IOT HVAC
Invoice Serving and Analysis sensor and control solutions.
Powered by REM™

Coming End Q4 2020:

EV LINK
- BAS Integration (BACnet/Modbus) Electric Vehicle Charging

- Variable Frequency Drives (VFD’s)

and Billing Solutions
5
 ENHANCED VISUALIZATION TOOLS
Asset Level Building Level Enterprise Level

Demand Response

1.8
Available MW

Cloud based, asset level monitoring and Real time optimisation of electric Aggregation from asset level to building
control tools for electric, gas and water heating circuits to improve comfort and level to create a virtual, interactive and
assets eliminate needless waste of energy energy efficient grid resource

6
• SS thanks and appreciates the efforts of the IESO in promoting deployment and operations of DERs.
• IESO’s foresight to develop a market ecosystem that not only facilitates DER off-take, but also
increases market competition, creates customer choice, and addresses climate goals is praiseworthy.
• SS is ready and able to bridge the data gap with exiting customer assets, and to help the IESO/LDC
leverage energy resources to advance the DERs market.
• SS is providing key points in the following slides and is providing greater technical detail in the
appendix.

SENSORSUITE’S PERSPECTIVES

7
• SS believes that for the integration of DERs and its
aggregation, it is imperative to move from traditional
planning to an “Integrated Distribution Planning” process
(Illustrated)
• There is a need to expand objectives to include clean
energy and climate goals, market options, flexibility,
consumer-centricity, etc.
• Proactively include prosumers and other stakeholders in
the planning process via stakeholder consultations and
other participatory options.
• Need to increase data visibility and advanced forecasting
with more granular data.
• Include DER operators, planners, aggregators, as part of
the planning process to help develop a conducive market
ecosystem and achieve common goals. DERs should
become a mainstream player in the long-term planning
process.
• Bridge any information/planning gap between the G-T-D,
system planner, and DER operators/aggregators.
Fig. Source: Smart Electric Power Alliance

ENABLING DER INTEGRATION REQUIRES A CHANGE IN BUSINESS MODELS

8
 Fig. (b): MURBs serviced by SS in
• With ~4% market penetration in Southern ON in the Southern ON (60)
MURB space*, SS not only gathers rich datasets with
millions of data points over multiple parameters, but also
understands consumer driven change in the DER space.
• Urban consumers in high demand regions are already Fig. (a): Estimated no. of MURBs built
rallying for a change as the requests to set up EV before 1990 in Southern ON
charging infrastructure has increased significantly in the
buildings SS services. SS’s ability to help visualise DER at
the system level in real time can be easily leveraged by
the IESO/LDC to better understand consumer behaviour,
and to test aggregation opportunities. Fig. (c): MURBs serviced by SS in
ON (84)
• SS is equipped to lead pilots, and associate with the IESO
and/or the LDC under various options proposed in the
white paper viz. multi-nodal aggregation, improving data
telemetry and visualisations, peak management/peak
shaving specially in the high density urban setting i.e.
MURBs and helping develop standardised protocols and
procedures, etc.

DELIVERING INSIGHTS INTO URBAN CONSUMER BEHAVIOUR

Note: The geotag for MURBs

9 in figures (a) & (b) is sourced from the buildings database available at www.costar.com. The actual numbers may vary for Fig (a)
* MURBs with 100+ units
 Parameters Particulars
• The REM (Responsive Energy Management) Tool is REM Control Period May’19 to Apr’20
the SS energy efficiency optimization tool that
combines data from external and internal sources Heating Load Savings 30.48% (189,152 kWh)
and uses machine learning to optimize energy use Total Consumption 11.70 kWh/sq.ft.
of various connected equipment. Predicted HL 7.56 kWh/sq.ft.
• The graph represents energy savings in one of the Actual HL 5.26 kWh/sq.ft.
SS’s serviced MURBs located in Ontario. HL Savings 2.51 kWh/sq.ft.
• The REM Tool created ~31% savings, in this one 140,000 600.0
example. 120,000 500.0

Heating Load (kWh)

Avg. Monthly HDD

100,000 400.0
80,000 300.0
60,000 200.0
40,000
• With the ability to aggregate SS’s entire MURB 20,000
-
2019- 2019- 2019- 2020- 2020- 2020- 2020- 2020-
100.0
0.0

portfolio at multi-nodal levels, and ready to go 06-01 11-01 12-01 01-01 02-01 03-01 04-01 05-01

industry standard data telemetry, SS can facilitate 2019-

05-02
2019-
10-02
2019-
11-02
2019-
12-02
2020-
01-02
2020-
02-02
2020-
03-02
2020-
04-02
IESO/LDC to develop a robust market ecosystem Predicted HL (kWh) 21,890 32,192 91,328 103,784 116,376 114,996 80,519 59,531

amidst ongoing disruption. HL with SS

HL Savings Realised
14,709 17,705 70,704 81,741 51,387 90,795 61,359 43,065
7,181 14,487 20,624 22,044 64,990 24,201 19,160 16,466
Heating degree-days 15.5°C -
99.7 146.6 415.9 472.6 530.0 523.7 366.7 271.1
min/max (°C-d)

DELIVERING INSIGHTS INTO URBAN CONSUMER BEHAVIOUR

10
• SS captures real-time operational data such as
temperature, phase wise voltage and current
profile, power demand, energy consumption,
etc., and SS can develop forecasts and insights
that can drive business decisions.
• The system is paid for by using efficiency gains
by customers and has additional value by
supporting grid optimization and resiliency,
requiring minimal incentives (double advantage
of supporting grid optimization and resiliency,
with minimized incentives).

EVIDENCE-BASED DATA DRIVES DER ADOPTION

11
• The white paper under section 2.5, Potential to
Aggregate Under Existing Market Rules envisages
the need to develop new business models to
promote DERs.
• To facilitate DER adoption, maintain grid reliability,
and facilitate financial transactions, it is imperative
to consider the options of developing utility
facilitated business models.
• SS opines that as more grid interactive DERs (both
generation and load side) interconnect with the Source: Scott P. Burger et. al, MIT USA

grid, these LDC facilitated business models shall

help develop a strong market ecosystem. Under
such models, the utility only acts as a facilitator to
prospective DER providers/aggregators and will
help them to understand the needs and nuances
from the grid reliability, data visibility, and safety
perspective.
Source: Ronnie Khanna et. al, USAID PACE-TA Program, India

LDC AS A FACILITATOR

12 Note: The schematics of the business models presented above are indicative. There is a need to understand ON’s market requirements, DER technology, stakeholders, and
financials, etc. to develop tailored business models.
Sr. Proposed option in the white Support of Considerations
No. paper
1. Business Models SS can leverage its experience and can work with the IESO/LDC to develop innovative
business models which can help DER aggregators in the province. These business models can
also explore the possibilities and issues around mixed aggregation.

2. Option 1(b) Reducing the Minimum Size A phased approach should be supported with a year-on-year reduction strategy/target
Threshold –Phased Approach considering all of the possible DER technologies including energy storage and hydrogen.

3. Option 2 Clarifying Existing Aggregation Rules Based on SS’s market experience, it is suggested that the IESO shall undertake stakeholder
and Processes consultations with various DER players, operators, aggregators, and the LDCs, to formulate a
robust and holistic set of rules and processes catering to market vision and requirements. SS’s
market insights, data

4. Option 3(b) Modifying Aggregation SS’s existing DR portfolio is equipped to support the multi-nodal aggregation pilot and is
Boundaries: Multi-Nodal Aggregations therefore ready to commence immediately (in terms of technology and data telemetry). The
outcome of this pilot will help the IESO to develop a holistic multi-nodal aggregation plan and
will also contribute to the IESO’s real-time visibility projects.

SENSORSUITE SUPPORTS WHITE PAPER RECOMMENDATIONS

13
Sr. No. Proposed option in the white paper Support of Considerations

5. Option 4(b) Modifying Aggregation The white paper highlights inherent challenges around such a scheme (e.g. visibility of the resources’
Compositions: Mixed DR Contributors response to dispatch instructions, granularity of metering to settle the aggregation, measurement &
verification of the aggregations’ response). However, mixed DR aggregation balances multiple demand
uncertainties as well due to different consumption and end use patterns across consumer segments.
SS’s can provide the IESO/LDC, in real-time, multiple data points such as energy consumption, demand,
voltage, current, weather, to name a few, using its proprietary tools deployed at various load-controlled
residential premises.

6. Option 6(a) Permitting Alternative Telemetry SS captures millions of data points at the residential facilities under its control. It can provide real time data,
Sources: Device-Level Data over a high speed and secure connection, at a scan rate, latency, and accuracy at par or better than specified
for dispatchable loads (>= 1 MVA & <20 MVA) under Table 9. Therefore, perfectly positioned to facilitate the
IESO’s vision for a pilot through the Grid Innovation Fund (GIF).
As mentioned previously, this pilot may also be bundled with the multi-nodal aggregation to study and
understand multiple impacts. This will help test real-world performance, M&V requirements, assess
cybersecurity concerns, open avenues for alternative telemetry and enhance competition.

7. Data Aggregator As highlighted earlier, SS, as an energy IOT company, is collecting and managing energy data. It’s experience
commensurate with the IESO’s requirements as a data aggregator. SS’s understanding of data collection and
telemetry may be leveraged by the IESO/LDC to help facilitate multiple DER programs.

SENSORSUITE SUPPORTS WHITE PAPER RECOMMENDATIONS

14
 RECAP KEY POINTS

▪ LDCs needs a change in Business Model to be more ubiquitous to enable DERs.

▪ Granular data points drive energy savings for urban customers.
▪ Aggregated urban customer data is critical to optimization for MURBs.
▪ Customer-paid-for energy savings systems best support DER adoption.
▪ LDC is a facilitator between market participants, customers and prosumers.

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APPENDIX
 OPTION 1(B) REDUCING THE MINIMUM SIZE THRESHOLD –PHASED
APPROACH

▪ A phased approach should be supported by definite year-on-year reduction strategy/targets considering all of the possible DER
technologies, including energy storage and hydrogen.
▪ A year-on-year reduction target provides prospective DER providers/aggregators, nearing their contract end, the ability to
strategize their participation in the envisaged DER market. This will not only increase competition within the IESO administered
market (IAMs), but can also impact rates.
▪ Under section 3.1. it is stated that:
▪ “…
▪ While lowering the minimum-size threshold is the most direct pathway to enhancing DER participation in the IAMs, system
operators responding to FERC Order 841 pointed out that other barriers identified during the FERC proceeding would also need to
be addressed to achieve this objective [11]. These include the high costs of adhering to telemetry requirements, the complexities of
co-ordination between ISOs and distribution utilities, and the requirements to upgrade ISO/RTO dispatch systems and software – all
of which can impede the participation of DERs in wholesale markets.”
▪ SS has already put in place adequate data telemetry equipment under its residential buildings' portfolio and is collecting real-time
data to facilitate its customers. Therefore, SS can leverage its rich data-set and run a pilot with the IESO/LDC and the results may
then be used to develop a future program. This will also help the IESO/LDC understand the additional cost burden, and other
underlying complexities.

17
 OPTION 2 CLARIFYING EXISTING AGGREGATION RULES AND
PROCESSES

▪ As the paper highlights, the existing market rules and processes were developed at a time before the modern-day DER became
mainstream.
▪ SS believes that given the variety of DER options available in today’s market, there is a need to develop a dedicated set of
aggregation rules and processes tailored to meet ensued market requirements.
▪ These rules and processes, may also include the data telemetry requirements, various technical/operational/safety standards that
align with the system’s requirements and are risk averse. Such clarity helps the DER provider/operator to participate in a non-
discriminatory market.
▪ Based on SS’s market experience, it is suggested that the IESO shall undertake stakeholder consultations with various DER players,
operators, aggregators, and the LDCs, to formulate a robust and holistic set of rules and processes catering to market vision and
requirements.

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 OPTION 3(B) MODIFYING AGGREGATION BOUNDARIES: MULTI-
NODAL AGGREGATIONS

▪ This is certainly a welcoming step as this has the potential to aggregate many potential DER assets/projects at multiple locations
across the province. Additionally, this is also in line with the existing hourly demand response (HDR) program and dispatchable
generation and load aggregation.
▪ SS opines that in order to implement this holistically, the LDCs may be advised/directed to identify and publish such aggregation
nodes, like the NYISO’s approach.
▪ Furthermore, urban (particularly residential and C&I) sub-load nodes may also be identified similar to CAISO’s initiative. This will
not only help envisage the possibility of future grid congestion, but also can also help deploy load-modifying demand response at
such nodes. This will help LDCs defer investment in infrastructure augmentation by deploying peak-shaving and/or load modifying
strategies at pain areas in the grid.
▪ Relatively smaller zones provide better visibility to the system operator and the LDCs alike. This also helps maintain grid reliability
and safety in providing real-time services like operating reserves and energy. SS’s existing DR portfolio is equipped to support the
multi-nodal aggregation pilot and is therefore ready to commence immediately (in terms of technology and data telemetry). The
outcome of this pilot will help the IESO to develop a holistic multi-nodal aggregation plan and will also contribute to the IESO’s
real-time visibility project.
▪ Additionally, it is imperative to state that such a proposal requires appropriate LDC’s support.

19
 OPTION 4(B) MODIFYING AGGREGATION COMPOSITIONS: MIXED
DR CONTRIBUTORS

▪ Allowing mixed DR contributors to participate in DER aggregation shall catapult Ontario’s electricity sector to the forefront.
▪ The white paper highlights inherent challenges around such a scheme (Eg. visibility of the resources’ response to dispatch
instructions, granularity of metering to settle the aggregation, measurement & verification of the aggregations’ response).
However, mixed DR aggregation balances multiple demand uncertainties because of different generation, consumption and end
use patterns across prosumer/consumer segments.
▪ The paper also points out that the residential smart meters are recorded once every hour, or at a 15-minute interval than the 5-
minute interval required for dispatch.
▪ Historically, C&I consumers have better visibility at the system level due to higher demand. SS’s has the ability to provide the
IESO/LDC in real-time, various data points such as energy consumption, demand, voltage, current, weather, to name a few, using
its proprietary tools deployed at various load-controlled residential premises.
▪ This alternative data telemetry, from almost all of the population centers of the province, will help the IESO test multiple options
in a single pilot, namely, multi-nodal aggregation, mixed DR, and alternative telemetry with little to no additional cost implications
on data collection and transmission.
▪ Learnings from this pilot will aid in improving M&V, aggregation, data telemetry requirements/standards, metering type,
measurement intervals, dispatch model optimization, etc.

20
 OPTION 6(A) PERMITTING ALTERNATIVE TELEMETRY SOURCES:
DEVICE-LEVEL DATA

▪ SS agrees with the IESO that in order to have greater system reliability and safeguard grid operations, and yet facilitate DER’s
growth, there needs to be appropriate data telemetry in place. Particularly (a) static data – DER type, location, capability; (b)
operational data/telemetry providing real-time visibility; (c) revenue grade data to facilitate settlement.
▪ Given the technological advancements, there is a possibility that future DERs may have the ability to modify their
output/consumption independent of the metrological conditions (energy storage, hydrogen, etc.)
▪ Thus, there needs to be put in place uniform and technology neutral data telemetry standards. Also, these protocols need to
conform to the highest standards around data privacy, sharing, security, and control.
▪ SS is already capturing energy consumption, demand, weather, phase wise voltage and current, to name a few, at the residential
facilities under its control. It can provide real time data, over a high speed and secure connection, at a scan rate, latency, and
accuracy at par or better than specified for dispatchable loads (>= 1 MVA & <20 MVA) under Table 9. Therefore, perfectly
positioned to facilitate IESO’s vision for a pilot through the Grid Innovation Fund (GIF).
▪ As mentioned previously, this pilot may also be bundled with the multi-nodal aggregation to study and understand multiple
impacts. This will help test real-world performance, M&V requirements, assess cybersecurity concerns, open avenues for
alternative telemetry and enhance competition.

21
 OPTION 7(A) ENHANCING T-D INTEROPERABILITY: MODIFYING
CONNECTION PROCESS FOR AGGREGATIONS

▪ As DERs primarily connect on the distribution side, it is imperative that LDCs have a say in the entire interconnection and
approval process. This shall also be applicable for the DER aggregators. However, there needs to be a transparent and time bound
interconnection process in place, tailored to meet the DER aggregation requirements.
▪ On November 26, 2020, the Ontario Energy Board (OEB) published Information and Template forms for Preliminary Consultation
on DER Connections.
▪ SS opines that to develop a robust DER market ecosystem in the province, there needs to be IESO lead stakeholder consultations,
with participation from the OEB and LDCs on developing standardized interconnection process for DER aggregation.

22
 Contributions by:
Contact Details:
Sumit Sood
Glen Spry
Carolyn Pittman
President and CEO
[email protected] Helen Platis
Frank Carnevale