Comments on BRS v1.4 Review for EDAM ISO BAA Participation Rules Track A

Extended day-ahead market ISO balancing authority area participation rules

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Comment period
Jan 29, 08:00 am - Mar 07, 05:00 pm
Submitting organizations
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Pacific Gas and Electric
Submitted 02/20/2025, 09:05 pm

Contact

Michelle Gong (mvgw@pge.com)

1. Please provide the version of the EDAM ISO BAA Participation Rules Track A BRS your comments apply to
Please specify your name, organization, and the version of the BRS your comments are referencing.

Michelle Gong, Pacific Gas & Energy, BRS v1.4

2. Please provide any questions or comments your organization may have regarding section 4 of the EDAM ISO Balancing Authority Area Participation Rules Track A BRS.
When providing input in the text box below, please specify the BRQ(s) your comment or question is referencing. Please note that there are currently two companion initiatives for EDAM which will implement at the same time: 1) EDAM Implementation, which addresses the entire market framework for the EDAM footprint, and 2) EDAM ISO BAA Participations Rules, which applies specific operational and settlement participation rules to the EDAM market for the ISO BAA (‘CISO’). This document pertains to the latter, but utilizes the framework defined in the former (as noted by cross-reference and an "Existing" requirement type).

Section  

BRQ 

BRQ detail 

PG&E Question 

4.1.1

N/A; Day-Ahead Operating Stressed Hour Assessment Process section

MW supply reserve available for imbalance surplus beyond the BAA’s RSE requirement

Suggestion to update: “MW residual supply above the BAA's RSE.”

It is confusing to have the words "reserve" and "imbalance".  

4.1.1

BRQ-004

Confidence factor (ratio ranging from 0 = no risk, to 1 = maximum risk)

Per CAISO’s Pending EDAM ISO BAA Tariff Policy from November 10, 2023, the Confidence Factor (pg. 54) references that the CAISO BAA will utilize a confidence factor of 0% during all system conditions and during stressed conditions, the confidence factor will remain at zero and non-stressed conditions, it will utilize a confidence factor above zero.

 

Thus, the statement should read: “confidence factor (ratio ranging from 0 = maximum risk, to 1 = no risk)

4.1.1

N/A; Day-Ahead Operating Stressed Hour Assessment Process section

In reference to the CAISO BAA operators providing confidence factor and reliability margin inputs for their own EDAM Export Transfer Constraint.  

In the BRS, we would like to see details including where/how the confidence factor and reliability margin as input for the IFM process. We would like to see the CF factor set at 0 for both stressed and non-stressed conditions. Functionality should be built in to allow Operators to adjust the confidence factor in non-stressed conditions (but Operators still should not be able to raise the confidence factor above zero until such a process has been vetted through a BPM change).

The reliability margin should be set to zero during non-stressed system conditions and Operators should have the ability to set it higher during stressed system conditions.

 

Before the CF and the hourly RM (Reliability margin) is broadcasted/reported in SIBR, where is the actual constraint in IFM system and how is it built in the system? If CAISO can update the BRQ with a section describing what is to be built.

ISO response

 Section

 BRQ 

BRQ detail 

PG&E Question 

CAISO Response

 4.1.1

  N/A;

Day-Ahead Operating Stressed Hour Assessment Process section

MW supply reserve available for imbalance surplus beyond the BAA’s RSE requirement

Suggestion to update: “MW residual supply above the BAA's RSE.”

It is confusing to have the words "reserve" and "imbalance".  

The final proposal paper for EDAM ISO BAA Participation Rules states the net EDAM export transfer constraint governs the potential usages of surplus supply beyond RSE requirements (demand forecast requirement, imbalance reserve requirement, and ancillary service requirement); the amount of supply reserved will be governed by the EDAM reliability margin of the net EDAM export transfer constraint. EIMPR-BRQ-004 further clarifies this as the "MW value that provide allowable surplus to transfer beyond RSE requirement". Thank you for the suggestion for additional clarity, the ISO will provide that as part of EDAM BPM and/or Market Instruments BPM content which are targeting 7/1/25 to start BPM change management process

 4.1.1

BRQ-004

Confidence factor (ratio ranging from 0 = no risk, to 1 = maximum risk)

Per CAISO’s Pending EDAM ISO BAA Tariff Policy from November 10, 2023, the Confidence Factor (pg. 54) references that the CAISO BAA will utilize a confidence factor of 0% during all system conditions and during stressed conditions, the confidence factor will remain at zero and non-stressed conditions, it will utilize a confidence factor above zero.

 

Thus, the statement should read: “confidence factor (ratio ranging from 0 = maximum risk, to 1 = no risk)

In the EDAM ISO BAA Tariff Filing for 11/14/23  (see Nov13-2023-TariffAmendment-CAISO-Balancing-Authority-Participation-ExtendedDayAheadMarket-ER24-379.pdf), the advisory note provided on pg 54 mentions the Confidence Factor for the Net Export Transfer Constraint will be preset to 0% upon inception of  EDAM until the market risk was assessed and understood prior to applying higher risk Confidence Factors to the CISO BAA.

 

To clarify this statement, it’s useful to describe CF as a multiplier used to manage the risk of delivery in EDAM.  Less certainty (e.g. lower risk position) would move CF towards 0% (or 0) and lower the amount of transfer allowed by the Net Export Transfer Constraint (keeping non-RSE eligible supply local to its native BAA). More certainty (i.e. higher risk position) would move CF towards 100% (or 1) and raise the amount of transfer allowed by the Net Export Transfer Constraint (allowing more non-RSE eligible supply to participate in EDAM transfers).

 

Important to also note that the final policy paper provides that "ISO will utilize the BPM  [change management] process for any proposed revisions to the confidence factor value setting during non-stressed conditions." This point will be solidified in the forthcoming EDAM BPM.

 4.1.1

 N/A;

Day-Ahead Operating Stressed Hour Assessment Process section

In reference to the CAISO BAA operators providing confidence factor and reliability margin inputs for their own EDAM Export Transfer Constraint.  

In the BRS, we would like to see details including where/how the confidence factor and reliability margin as input for the IFM process. We would like to see the CF factor set at 0 for both stressed and non-stressed conditions. Functionality should be built in to allow Operators to adjust the confidence factor in non-stressed conditions (but Operators still should not be able to raise the confidence factor above zero until such a process has been vetted through a BPM change).

The reliability margin should be set to zero during non-stressed system conditions and Operators should have the ability to set it higher during stressed system conditions.

 

Before the CF and the hourly RM (Reliability margin) is broadcasted/reported in SIBR, where is the actual constraint in IFM system and how is it built in the system? If CAISO can update the BRQ with a section describing what is to be built.

The EDAM BRS describes the functionality/system requirements for the EDAM Net Export Constraint for the CISO BAA, as will be submitted by the CAISO in its role as the CISO BAA Operator, while the CISO BAA Participation Rules BRS provides the business process requirements to support those functional/system changes. The details on how the confidence factor and reliability margin are input to IFM are provided in the EDAM BRS BRQ 13010.

CISO BAA confidence factor will be set to 0 for stressed and non-stressed conditions upon inception of EDAM; this is defined in both the final proposal paper for EDAM ISO BAA Participation Rules as well as section 2.4 of the draft Business Practice Summary - Extended Day-Ahead Market published on 7/10/2024.

The functionally as described in the EDAM BRS will allow operators to adjust the confidence factor in non-stressed condition. The final policy paper as provides that "The ISO will utilize the BPM [change management process] for any revisions to the confidence factor during non-stressed conditions". This point will be solidified in the forthcoming EDAM BPM.

In regards to the reliability margin, the final policy specified the criteria by which the operators will set the reliability margin in both stressed and non-stressed conditions in order to allow the CISO BAA flexibility in how it utilizes it in varying system conditions. The approved tariff language in 33.31.32 supports that proposal stated that the CAISO may specify a reliability margin to use in accordance with the EDAM BPM. The draft BPM content was published as the Business Practice Summary noted above and aligns to policy and tariff. Additional changes to the criteria are not anticipated and participants can watch for the formally EDAM BPM draft which is targeting 7/1.

The CF and RM for CISO BAA will be published via OASIS, please see EDAM BRQ 20156 and the

Business Practice Summary - Extended Day-Ahead Market noted above.

3. Please provide any questions or comments your organization may have regarding the remainder of the EDAM ISO BAA Participation Rules Track A BRS
When providing input in the text box below, please specify the section your comment or question refers to.

N/A currently. We are conducting our review internally and plan to submit CIDI tickets for any additional comments/questions.

4. Please provide any additional questions or comments you may have.
When providing input, please limit your questions and comments to the EDAM ISO BAA Participation Rules BRS and project.

N/A currently. We are conducting our review internally and plan to submit CIDI tickets for any additional comments/questions.

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