Comments on July 13, 2021 workshop presentations and discussion

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

Please see attached BANC comments.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

Please see attached BANC comments

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

Please see attached BANC comments

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Please see attached BANC comments

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Please see attached BANC comments

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Please see attached BANC comments

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

Please see attached BANC comments

8. Please provide comments on any other aspects of the initiative or workshop presentations.

Please see attached BANC comments

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

The Bonneville Power Administration (Bonneville)[1] appreciates the opportunity to submit comments on the July 13^th Stakeholder Workshop initiating the CAISO’s External Load Forward Scheduling Rights policy initiative. Bonneville thanks the CAISO for encouraging other stakeholders to present and provide different viewpoints on principles, objectives, and initial thoughts on approaches for external loads to attain scheduling rights in the forward trading horizon.

Bonneville strongly supports the presentation made by Salt River Project, Arizona Public Service, and Tucson Electric Power.  Wheel-throughs in the West are not only necessary to support resource adequacy in the West, but also the inter-seasonal flow of energy around the West that has been the foundation for inter-regional transmission investments connecting the Pacific Northwest with the Southwest.

Bonneville also supports the presentation made by Powerex and agrees in particular that a phased approach and additional transparency are needed.

[1] Bonneville is a federal power marketing administration that markets electric power from 31 federal hydroelectric projects and some non-federal projects.  Bonneville, through its merchant, Power Services, sells power at wholesale to meet the firm requirements of certain utility and federal agency customers in the Pacific Northwest, including preference customers such as public utility districts, municipal utilities, and cooperative utilities.   In addition, Bonneville owns and operates over 15,000 miles of high-voltage transmission lines in the Pacific Northwest.  Bonneville’s balancing authority area is adjacent to the CAISO’s.  Bonneville is also a co-owner of, and the path operator for, the northern portion of the Pacific Northwest-Pacific Southwest Intertie, which consists of AC and DC lines connecting the Pacific Northwest with the Southwest and the CAISO balancing authority area.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

Bonneville supports a phased approach to this initiative.  It is unlikely a durable, long-term approach can be agreed upon and implemented ahead of summer of 2022.  A phased approach will allow the time and policy space to consider the many facets that could be impacted by a durable, long-term solution, including not only the month-ahead, day-ahead, and real-time aspects considered in the interim solution, but also the implications to longer-term transmission planning and linkages with resource adequacy that may need to be considered.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

No comment at this time.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Bonneville believes that any long-term, durable solution or any changes to the interim framework should adhere to the following principles:

• provide open access to the CAISO controlled grid;
• support reliable load service in the CAISO and Balancing Authorities in the West;
• increase access to the CAISO controlled grid, including consideration of wheel-through and other uses in the transmission planning processes;
• contribute to and equitably allocate the cost of the CAISO controlled grid; and,
• build upon long-standing commercial market frameworks in the West.

Bonneville continues to believe that the interim proposal moved away from comparability[1], and as postulated, inhibits reliable load service and has impacted competitive markets in the West.

[1] “[A]n open access tariff that is not unduly discriminatory or anticompetitive should offer third parties access on the same or comparable basis, and under the same or comparable terms and conditions, as the transmission provider's uses of its system.” Order 888, Final Rule, Federal Energy Regulatory Commission, April 24, 1996, page 37.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Problem Statement: To provide comparable access across multiple time horizons (ie. long-term annual or monthly, as well as short-term day-ahead or hourly) for the competing uses of the ISO grid.

It is important to consider how the California parties and those outside of the CAISO balancing authority area choose to use or procure resources (and transmission service when needed outside of the ISO) to assure reliable load service affects transmission congestion.  There are currently no simultaneous procurement windows in which the competing uses of the CAISO controlled grid procure transmission service and gain access to the transmission system, except in the day-ahead horizon – long-after many power supply transactions, both internal and external to the CAISO, have been consummated.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Bonneville – and other entities throughout the West – have long offered multiple transmission products under an Open Access Transmission Tariff (OATT) framework that:

• Provides comparable access to the Bonneville transmission grid,
• Supports reliable load service,
• Increases access to the Bonneville grid,
• Contributes to the cost of building and maintaining new and existing grid elements, and
• Builds upon long-standing commercial frameworks in the West. 

Bonneville is open to other possible frameworks for a long-term transmission access solution, but believes there is merit in comparing any proposed long-term transmission access framework not only to the unique, short-term transmission access framework that exists in the CAISO, but also the prevailing long-term, open-access transmission framework in the West.  Further, Bonneville requests that the CAISO share the findings of their research into the solutions that other ISO / RTO employ for their long-term transmission access frameworks, as there may be important lessons to be learned from the approaches of other organized markets.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

See above.  No further comment at this time.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

No comment at this time.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

Please see DMM comments in PDF attachment.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

Please see DMM comments in PDF attachment.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

Please see DMM comments in PDF attachment.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Please see DMM comments in PDF attachment.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Please see DMM comments in PDF attachment.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Please see DMM comments in PDF attachment.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

Please see DMM comments in PDF attachment.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

Please see DMM comments in PDF attachment.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

The CAISO External Load Forward Schedule Rights Process Workshop meeting on July 13, 2021, included presentations from load serving entities (LSE) within and outside of California that rely on California’s transmission to meet their system needs.  The LSEs’ presentations provide perspectives on the CAISO’s transmission reservation policies.

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) has concerns regarding the current CAISO transmission reservation policies and the consideration of California transmission capacity in the CAISO Day-Ahead Market.  The following provides background on these concerns.

CAISO Current Transmission Reservation Policy

• The CAISO does not currently set-aside transmission capacity to serve native load or provide firm transmission rights to external entities per its Tariff.  

• Federal Transmission Reservation Policies and Allowances

Consistent with FERC open transmission access orders, the CAISO’s transmission reservation process must ensure that California’s transmission system can reliably serve native load and provide adequate information on available transmission capacity.[1]  FERC Orders No. 888 and 890 require transmission operators to fairly allocate transmission capacity to support native load and external system users.[2]^,[3]  These FERC Orders also allows transmission operators to reserve transmission capacity to meet native load.[4]^,[5]

CAISO Available Transmission Capacity

• It is not clear that CAISO has excess transmission capacity to serve wheel through transactions during all months of the year.  Pacific Gas and Electric Company (PG&E) stated that “it is clear that the CAISO’s transmission service at key interties as well as Path 26 is fully subscribed.”[6]  In addition, the Department of Market Monitoring (DMM) stated that “it may well be the case that there is no excess capacity beyond that needed to meet the needs of the CAISO load.”[7]

Short-Term Solution

To address possible reliability challenges related to transmission capacity, the CAISO proposed a temporary amendment to its Tariff to modify load, export, and wheeling priorities in the CAISO’s Day-Ahead and Real-Time Markets.  This amendment allows the CAISO to address system constraints when the constraints occur with the prioritization for native load and wheel through transactions that are scheduled in advance and meet other conditions.[8]  FERC approved this temporary solution in June 2021.[9]  This solution will expire June 1, 2022.[10]

Cal Advocates supports this temporary solution and recommends that this Tariff amendment remain in place until a long-term solution can be implemented.

Long-Term Solution

For the long-term, Cal Advocates recommends the CAISO change its transmission reservation policy and reserve transmission capacity to meet California’s reliability requirements, especially if California’s transmission is currently fully subscribed.  The following are other recommendations to address the problems mentioned above and during the July 13, 2021, stakeholder workshop.

Recommendations

1. Cal Advocates supports the recommendation from the California Community Choice Association (Cal CCA), PG&E, Southern California Edison Company (SCE), San Diego Gas and Electric Company (SDG&E) and Six Cities (California LSEs) to consider firm transmission requests from entities outside California in the CAISO’s annual Transmission Planning Process (TPP). 
2. Cal Advocates supports the California LSE’s recommendation to pass on the costs of any identified transmission upgrades to accommodate firm transmission requests to the entities that would benefit from the upgrade or are the cause of the upgrade.
3. Cal Advocates supports the CAISO providing greater transparency on its transmission capacity to accommodate wheel through transactions in the CAISO TPP.  DMM made a similar request in a related stakeholder process and in its comments on the CAISO tariff revision discussed above.[11]^,[12]
4. To ensure reliable service to native load, Cal Advocates requests that the CAISO maintain its recent tariff change to prioritize native load during extreme weather events or other tight system conditions until a long-term solution can be determined.

[1] Federal Energy Regulatory Commission, Docket No. RM95-8-000, RM94-7-001, Order No. 888, Issued April 24, 1996 (FERC Order 888), p. 4.

[2] FERC Order 888, p. 57.

[3] FERC Order 890, Preventing Undue Discrimination and Preference in Transmission Service, Issued February 16, 2007 (FERC Order 890), p. 1.

[4] FERC Order 888, p. 172.

[5] FERC Order 890, pp. 66-67.

[6] Comments of Pacific Gas and Electric Company Before the Federal Energy Regulatory Commission, Doc No. ER21-1790, May 19, 2021, p. 4.

[7] Motion to Intervene and Comments of the Department of Market Monitoring of the California Independent System Operator Corporation, Docket No. ER 21-1790, May 19, 2021, p. 10.

[8] CAISO Docket No. ER21- Tariff Amendment to Implement Market Enhancements for Summer 2021 – Load, Export, and Wheeling Priorities, April 28, 2021, pp. 3-10.

[9] FERC Order Accepting Tariff Revisions, Subject to Further Compliance, issued June 24, 2021, Docket No. ER21-1790-000.

[10] CAISO Docket No. ER21-1790, Compliance Filing – Market Enhancements for Summer 2021, Load, Export and Wheeling Through Priorities, July 26, 2021, p. 7.

[11] Department of Market Monitoring, Comments on Maximum Import Capability Enhancements, Issue Paper, April 1, 2021, p. 1.

[12] Motion to Intervene and Comments of the Department of Market Monitoring of the California Independent System Operator Corporation, Docket No. ER 21-1790, May 19, 2021, p. 6.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

If a long-term solution cannot be implemented by Summer 2022, Cal Advocates recommends expedited studies on California RA import transmission needs to the California border and other native load transmission needs within California’s border.  The results from this study, when publicly presented, will clarify for stakeholders the amount of excess transmission capacity the CAISO has to accommodate wheel through transactions.  These study results can also be used to ensure reliable transmission to serve native load.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

For the short-term and the long-term, Cal Advocates supports priority of native load on the California transmission system, which California continues to pay for and maintain.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

If transmission capacity is not available to satisfy external transmission requests (i.e., requests from non-CAISO entities to access the CAISO transmission system), system upgrades can be implemented, if and only if, the entity requesting the capacity commits to paying for any necessary upgrades and on-going maintenance consistent with FERC Order No. 890.[1]

[1] FERC Order 890, Docket Nos. RM05-17-000, RM05-25-000, Preventing Undue Discrimination and Preference in Transmission Service, issued February 16, 2007, p. 51.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

To ensure reliable delivery of internal resources to serve California load, the CAISO should assure transmission capacity to deliver these resources.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Please refer to the comments provided in response to question 1.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

The CAISO’s primary statutory mandate should be to provide grid services to California consumers.  The CAISO is a state-chartered benefit goods corporation with an independent governing board appointed by the Governor of California.  The CAISO was created by the California State legislature by Assembly Bill (AB) 1890[1] and signed into law by the Governor of California in 1996.  AB 1890 states in part that the CAISO market structure will provide low cost and reliable electric service and assurances that electric customers will have protections in this new market.[2]

AB 1890 is clearly focused on the California consumer.

“It is the intent of the Legislature to protect the consumer . . .”  California Assembly Bill, AB 1890, 1996, Section 1 (d)

Control of the transmission system of California electric utilities was turned over to the CAISO.

“It is the intent of the Legislature that California’s local publicly owned electric utilities and electric corporations should commit control of their transmission facilities to the Independent System Operator . . .” California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600. (a)

The only mention of addressing external users of the transmission system in AB 1890 deals with current existing wheeling transmission services.

“The utility specific rates shall honor all of the terms and conditions of existing transmission service contracts and shall recognize any wheeling revenues of existing transmission service arrangements to the transmission owner.”  California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600 (a)(1)

As affirmed in Federal Circuit Court in 2004, the CAISO remains a state-chartered corporation with independent governance separate from FERC oversight.[3]

It is clear from the intent stated in AB 1890 that the CAISO was created for the benefit of California consumers. [4] 

Efforts, such as AB 813 (Holden),[5] have failed to turn the CAISO into a regional transmission organization (RTO).[6]  The CAISO, therefore, must focus on its primary mission; namely, providing grid services to California consumers.  External entities not providing grid services directly to California consumers should not be afforded primary status in accessing CAISO grid services, such as wheeling across the CAISO.  The CAISO was created by the California Legislature to serve California consumers, and the Legislature required transmission owners to give up control of their transmission system to the CAISO. [7]  External entities are not transmission-owning members of the CAISO.  They are not under obligations to serve California consumers.  If grid services are to be made available to non-CAISO transmission owners, then the grid services must be placed in a secondary position when the primary mission is delivering grid services in support of California consumers.

FERC was directed under the Federal Power Act of 2005 to create non-discriminatory transmission access which it did under FERC Orders 888, 889, and 890.  As a state charted independent system operator, the CAISO must offer and comply with FERC orders in a non-discriminatory basis.  However, AB 1890 is clear that the requirement that created the CAISO is to provide benefit to the California consumer first and foremost. [8]  Not to do so would require the CAISO to violate its state charter.

In order to wheel power from Canada or the Pacific Northwest across the California transmission system to Arizona or New Mexico, transmission capacity must be made available that does not impede the CAISO’s ability to serve native load which is the primary mission for the CAISO’s state charter.  Grid services may only be offered to external entities, as available, after California consumers have had their grid service needs satisfied. 

If external parties expect to access the CAISO grid services without restriction, then they may submit their requirements during the CAISO’s annual Transmission Planning Process (TPP).  Unlike Open Access rules for vertically owned and operated utilities, the current CAISO Tariff does not include provisions for firm transmission services.  If, within the TPP, the analysis shows a need to construct dedicated transmission services for wheeling across the CAISO transmission system, then the CAISO would need to file an amendment to the FERC Tariff creating a category for firm wheeling services and assign costs to the benefitting parties. [9]

[1] California Assembly Bill, AB 1890, 1996

[2] California Assembly Bill, AB 1890, 1996, Section 1 (a),

“It is the intent of the Legislature to ensure that California’s transition to a more competitive electricity market structure allows its citizens and businesses to achieve the economic benefits of industry restructuring at the earliest possible date, creates a new market structure that provides competitive, low cost and reliable electric service, provides assurances that electricity customers in the new market will have sufficient information and protection, and preserves California’s commitment to developing diverse, environmentally sensitive electricity resources.” 

[3] California Assembly Bill, AB 1890, 1996, Section 1 (d) “It is the intent of the Legislature to protect the consumer…”  

[4] California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600. (a)

“It is the intent of the Legislature that California’s local publicly owned electric utilities and electric corporations should commit control of their transmission facilities to the Independent System Operator . . .”

[5] California Assembly Bill (AB) 813, Author Assemblymen Chris Holden, 2018, An act to add Chapter 7 (commencing with Section 8390) to Division 4.1 of, to repeal Section 352 of, to repeal and add Section 359 of, and to repeal Article 5.5 (commencing with Section 359.5) of Chapter 2.3 of Part 1 of Division 1 of, the Public Utilities Code, relating to electricity.

[6] California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600 (a)(1)

“The utility specific rates shall honor all of the terms and conditions of existing transmission service contracts and shall recognize any wheeling revenues of existing transmission service arrangements to the transmission owner.”

[7] California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600. (a):

It is the intent of the Legislature that California’s local publicly owned electric utilities and electric corporations should commit control of their transmission facilities to the Independent System Operator…

[8] California Assembly Bill, AB 1890, 1996, Section 1 (a):

It is the intent of the Legislature to ensure that California’s transition to a more competitive electricity market structure allows its citizens and businesses to achieve the economic benefits of industry restructuring at the earliest possible date, creates a new market structure that provides competitive, low cost and reliable electric service, provides assurances that electricity customers in the new market will have sufficient information and protection, and preserves California’s commitment to developing diverse, environmentally sensitive electricity resources.

[9] California Assembly Bill, AB 1890, 1996, Section 12, Division 4.9, Subsection 9600 (a)(1):

The utility specific rates shall honor all of the terms and conditions of existing transmission service contracts and shall recognize any wheeling revenues of existing transmission service arrangements to the transmission owner.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

Cal Advocates has no additional comments at this time. 

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

Salt River Project Agricultural Improvement and Power District (SRP), NV Energy, Arizona Public Service and Tucson Electric Power, collectively referred to as the Desert Southwest Energy Imbalance Market (DSW EIM) entities in these comments, appreciate the CAISO’s recognition that wheeling and exports are important to the entire Western Interconnection and the CAISO’s acknowledgement that the interim solution approved for summer 2021 is not a durable long-term framework.  The DSW EIM entities are seeking equitable rights based on Open Access principles with consideration to bi-lateral business practice standards, such as North American Energy Standards Board (NAESB) and / or WSPP, guidance on priority, timelines, and duration.  

The DSW EIM entities look forward to working with the CAISO to develop both near-term enhancements and a collaborative long-term durable solution that has been characterized by some as “looking out for your neighbor.”   The DSW EIM entities are hopeful that a comprehensive, workable, and transparent near-term and long-term solution can be identified.  We expect that the CAISO will implement the solution in a manner where transmission access and costs are allocated equitably and commensurate with the benefits received.

The stakeholder presentations at the July 13 workshop reinforced the DSW EIM entities expectation that it will be challenging to develop an equitable long-term framework that meets the needs of the CAISO’s internal load serving entities (LSEs) as well as the needs of external LSEs to serve their own load. To clarify, the contracts that DSW EIM entities have entered into are necessary to reliably serve our own customer load.  It will be important for all stakeholders to work together and identify opportunities for possible compromise while maintaining focus on reliability, predictability, and inclusion of the principle of similar transactions being on par with similar transactions.

As this initiative moves forward, it will be important to remind all stakeholders that real-time transactions, both bilateral and through the Integrated Forward Market, largely serve the same purpose for both internal and external loads to maintain reliability.  Real-time and day-ahead transactions on high energy demand days are primarily driven by the need to support loss of generation, system events, or changes in forecasted load.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

The DSW EIM entities are open to CAISO’s proposed phasing of this initiative and support exploration of near-term enhancements that would be implementable by summer 2022, provided that such intermediate proposals are progressive and consistent with a long-term framework. We understand that developing an equitable, long-term, holistic framework for scheduling priorities is a complex process, and may have several other affected processes that may require adjustments and modifications arising from this process. The CAISO’s targeted January 2024 implementation may be reasonable if this is driven by impacted processes and associated timelines, and the DSW Entities can support this timeline, provided that a clear long-term binding framework can be identified prior to summer 2022.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

The DSW EIM entities acknowledge, as stated in CAISO’s FERC Tariff submittal, that the current CAISO wheel through tariff revisions will sunset on May 31, 2022.  We support the following near-term enhancements that were shared at the July 13 workshop:

Enhancements presented by Powerex and BANC, specifically:

• Need for Transparency (BANC and Powerex)
  • Provide additional transparency of import Resource Adequacy (RA) and PT Wheel requests
  • Reporting to provide market participants with the quantity of RA contracts and PT Wheels at each intertie
• Requiring valid e-Tags for Import RA and PT Wheels prior to initiating curtailments (Powerex) to avoid the risk of inefficiently over-curtailing real Import RA and PT Wheel schedules
• Validation Improvements (BANC)

Consistent with BANC’s proposal for increased transparency and simplicity, the DSW EIM entities request that the CAISO provide the following short-term enhancements:

• Step-by-step procedure from start to end for registering through the Intertie Resource Data Template (IRDT) and then bidding a self-schedule or high priority wheel-through transaction
• List of definitions and equivalent terms, such as PT, standard (STD), high priority
• Links to relevant Business Practice Manuals (BPMs), Scheduling Infrastructure Business Rules (SIBR) manual sections, and IRDT documentation that describe in detail how these relate to each other

Expanding on BANC’s request for after the fact curtailment reporting, the DSW EIM entities request that the CAISO provide the following short-term enhancements:

• Open Access Same Time Information System (OASIS) report showing percentage curtailment of high priority items such as CAISO load, PT wheels by interval and location.  The report should also include a reason for curtailment, if applicable.
• OASIS report showing location and total quantity of CAISO load curtailment relative to scheduled load
• OASIS report showing location and quantity of high priority transactions by Scheduling Coordinator and resource ID, including wheels, relative to scheduled quantities
• All items above must be verifiable to be curtailed on a pro-rata basis
• All items above should be posted as soon as the curtailment comes through the Automated Dispatch System (ADS)

Transparency should center around ensuring all EIM Entities can replicate information and verify that CAISO interruptions for wheel-throughs and exports occur consistent with the conditions in the CAISO tariff and Business Practice Manuals.  To provide all entities early and full transparency on actions CAISO plans to take.  Ideally, CAISO should provide any and all information available that CAISO may leverage to determine would affect the risk of curtailment in advance of the Integrated Forward Market (IFM) and in advance of the day-ahead bilateral trading period so that the market (both IFM and bilateral) can effectively work towards economic and reliable alternate solutions.  If, for example, CAISO substitutes a high probability forecast with operator adjustments and bias just prior to the Residual Unit Commitment (RUC) run, that can be problematic for several reasons. However, as CAISO staff indicated verbally to SRP at a meeting on July 27, the Day Ahead Market Enhancements (DAME) stakeholder process will contemplate a new methodology for “imbalance reserves” that will be used so operators do not have to manually adjust and bias forecasts on a regular basis.  The DSW EIM entities will be following the DAME stakeholder process and evaluating whether the imbalance reserves will reduce manual adjustments.  To increase transparency, we request as a near-term enhancement, that the CAISO provides weekly and /or monthly reports (through OASIS or other platform) showing all RUC award adjustments.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

One of the initiative principles CAISO staff presented at the July 13 workshop was to maintain the efficiencies of the ISO markets in dispatching resources, on a least cost basis, to serve load and meet market needs.

The DSW EIM entities request that the CAISO reframe this principle to focus on reliability rather than efficient market design.  We recommend the following rephrasing to consider “reliably serve load, dispatching resources on a least cost basis when reliability can be met.” This initiative is not about efficiency, but rather about reliability.  FERC Order 888 and Open Access Transmission Tariff (OATT) processes need to be considered in this initiative.

The DSW EIM entities request that this initiative be grounded in the basic principle of FERC Order 888 where access to a public utility’s transmission system is on a comparable basis to native load as this is a cornerstone of FERC’s open access policies.  Hence, the comparability standard, should be included as a principle.  For example, “an open access tariff that is not unduly discriminatory or anticompetitive should offer third parties access on the same or comparable basis, and under the same or comparable terms and conditions, as the transmission provider's uses of its system.”[1]  Thus, comparability requires that external LSEs be able to access the CAISO transmission system on a basis comparable to CAISO native load.[2] 

As SRP discussed at the July 13 workshop, the use of wheeling is common and necessary across the West, especially for net import regions, including California and the Desert Southwest.  The DSW EIM entities want the following principles and objectives to be implemented as part of the long-term solution:  

Principles:

• Transmission priorities should be consistent with timing and purpose of transaction for internal and external load
• All LSEs, internal and external to CAISO, should have the right to substitute energy and capacity for forward contracts
• CAISO should establish consistent requirements for internal and external load to establish forward priorities
• CAISO should provide full transparency on any load forecast differences between IFM and RUC prior to IFM run
• External load serving entities do not seek superior scheduling rights but do seek equitable rights based on open access principles

Objectives:

Forward transactions for external load should have the ability to carry at least load equivalent priority.

• The DSW EIM entities are not opposed to separate forward scheduling transmission access charges, but such charges should also include higher priority service.

Firm transmission is not an equitable “proxy” for forward transactions such as Resource Adequacy (RA) if that requirement is not equally applied and enforced:

• Forward transactions should have alternate representations to firm transmission external to the CAISO border.

Qualifying contracts for external RA requirements should have source substitution rights consistent with internal LSEs.

• The same events and risks to current CPUC / CAISO RA contracts should apply to contracts secured by external LSEs for their RA.  Temporary or sustained interruptions to generators tied to a transaction should not cause a loss of registered rights for wheel-through entities.

CAISO activity on and around day ahead for exports (and now wheel-through) has profound and direct consequences on bilateral markets.

• Any limitations or adjustments that may occur between forecasts for the IFM) and RUC need to be transparent and made public prior to the run of IFM.

Day Ahead transactions, both bilateral and through an IFM, have the same purpose for internal and external loads, and therefore should carry similar priority for internal and external loads given similar purpose and needs.

• Low loads and temperatures offer opportunities to reduce and minimize costs
• High loads and temperatures require markets to help mitigate unit (RA) losses, unforeseen system events (wildfire, etc.), and planning forecast error to maintain reliable plans and load service

Alignment with bi-lateral standard business practices, such as NAESB and / or WSPP, for priority, timelines and duration should form the basis of this initiative and be considered by the CAISO. 

• Several transmission scheduling intervals should be examined and considered as part of this initiative.  Interval horizons would range from short-term, such as hourly, daily, monthly, to long -term, which would be greater than a year.  The DSW EIM entities request that the same transmission offerings be available through CAISO’s grid as what the SW OASIS offers.  These offerings include yearly, monthly, daily, hourly, firm, and non-firm priorities. 
• As this initiative progresses, the DSW EIM entities request discussion during a stakeholder meeting on whether transmission offerings would be limited to what is left over at the California border(s) after CA LSEs procure for their native load/RA requirements or other framework. 
• The DSW EIM entities understand that curtailments are issued on a pro-rata basis. If the line is not fully subscribed, the derate will remove available transmission capacity. If the line is fully subscribed, usage will be curtailed pro-rata. 

The CAISO long-term framework should include substitution provisions that allow external entities to maintain transmission priority in the case of unplanned events/contingencies that make a resource documented in a contract unavailable. This type of provision is consistent with OATT practices.

[1]  Inquiry Concerning the Commission's Pricing Policy for Transmission Services Provided by Public Utilities Under the Federal Power Act, Policy Statement, 69 FERC ¶ 61,086 (1994.

[2] See Transmission Access Policy Study Group v. FERC, 225 F.3d 667, 681 (D.C. Cir. 2000) (“Open access is the essence of Orders 888 and 889. Under these orders, utilities must now provide access to their transmission lines to anyone purchasing or selling electricity in the interstate market on the same terms and conditions as they use them own lines.”).

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

The CAISO’s current problem statement focuses on constrained system conditions. The DSW EIM entities encourage the CAISO to not limit the scope of this initiative to times when the CAISO system and supply resources for load service are constrained.  We request that the CAISO consider proposals to offer transmission service to external entities in an equitable manner as internal LSEs at all times with non-discriminatory rules applied when constrained conditions occur.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

The CAISO’s lack of a robust transmission service forward reservation and allocation process creates inefficiencies in the external Balancing Authorities at the cost of ratepayers that are internal and external to the CAISO. Consistent with the Federal Energy Regulatory Commission’s long-standing open access policies that provide for the allocation of scarce transmission on the basis of timing, duration and price, the DSW EIM entities are willing to reserve and pay for long-term firm transmission if, in return for paying the price of that service, we have a priority right to use that capacity when there is more demand than the transmission system can accommodate.

The DSW EIM entities are requesting that CAISO provide a framework that is to the greatest extent possible equivalent to what we provide to our transmission customers. For example, under SRP’s OATT, in the case of a transmission de-rate, non-firm transmission customers would always be curtailed before firm transmission customers. If additional curtailment is necessary, any firm transmission curtailment would be pro rata with no difference between curtailment priority for the DSW EIM entities’ internal load or external firm transmission customers. In addition, on the DSW EIM entities’ systems, hourly firm transmission has an equal priority to long-term firm transmission.  This treatment includes wheel-throughs.

The Western EIM has profoundly impacted liquidity of bilateral real-time markets as a result of the EIM base schedule submittal timelines and imbalance applications.  For this reason, The DSW EIM entities request that the framework for forward scheduling include not just long-term scheduling but also a mechanism to ensure transmission for day-ahead and real-time transactions.

CAISO activity on and around day ahead for exports (and now wheel-through) also has profound and direct consequences on bilateral markets. Any limitations or adjustments that may occur between the IFM and RUC need to be transparent and public prior to the run of IFM.

At the July 13 workshop, CAISO staff stated that they are gathering information from other regional transmission operators to understand how other market operators schedule forward transmission.  The DSW EIM entities request that this information be shared with stakeholders in an issue paper and be a topic at a future stakeholder meeting. The DSW EIM entities would like for the CAISO to examine a framework similar to those used by PJM, NYISO, and ISO-NE, which offer long-term firm point-to-point transmission service to support bilateral transactions of wheel-throughs and exports that provide equal reservation priority with native load and network service. We look forward to engaging in this conversation through honest dialogue and lessons learned from other market operators on how to best develop a durable solution to this initiative.  

To the extent that accommodation of wheel-throughs should have an impact on long-term transmission planning for the CAISO, external entities such as the DSW EIM entities should have a reasonable opportunity to participate in that process to ensure wheel-through needs are adequately accommodated both in the near-term and long-term.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

By aligning the requirement and timing of when an LSE must commit to how much native load scheduling rights it will be using and releasing any unused capacity for further commercial use between the OATT paradigm and CAISO’s market paradigm will eliminate significant seams issues.  Native load customers on all other OATT systems must release any capacity they no longer intend on using on a day ahead timeframe.  If California LSEs tagged their awarded schedules day ahead, any remaining capacity could be made available to any other entities following open access principles of timing, duration, and price, as is required of all other transmission providers.   

Any action taken by CAISO to manage congestion should be based on internal load and internal congestion on its system.  If such issues arise and are attributable to or are affecting imports and wheel-throughs, CAISO should ensure actions and timelines do not supersede or subvert congestion management protocols and timelines employed by neighboring balancing areas.  Such action can ensure that CAISO minimizes any potential impacts on transmission priorities in adjacent balancing areas given the seam between NERC transmission priorities and CAISO’s proposed priorities. 

8. Please provide comments on any other aspects of the initiative or workshop presentations.

The DSW EIM entities are committed to engaging in this initiative process to identify long-term, durable, transparent, and equitable solutions that are implementable.  Our engagement will also focus on potential economic impacts this initiative will have on our customers.  The CAISO’s Tariff changes create a structure where the DSW EIM entities must purchase more expensive firm transmission, whereas the CAISO LSEs can purchase lower cost non-firm transmission but receive the same priority transmission service.  The DSW EIM entities are concerned with this paradigm and will be interested in understanding what the costs and reliability impacts are associated with both a short-term and long-term solution to this initiative.

Given the importance and significance of this initiative to the DSW, analyzing the impacts of this initiative holistically will be important.  Hence the DSW EIM entities request that the CAISO clarify in the issue paper and at the next stakeholder meeting how this initiative will relate to other CAISO processes and initiatives. 

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

The Imperial Irrigation District (“IID”) thanks the California Independent System Operator Corporation (“CAISO”) for the opportunity to submit comments in this stakeholder process involving external load forward scheduling rights.  IID urges the CAISO to adopt transparency measures to better predict wheeling and exports curtailments before-the-fact.  In particular, IID seeks better clarity to be able to participate in to market activities and having better awareness before and after the Day-Ahead Market closes.

Transparency and transaction validation are primary considerations for IID’s operations in achieving better certainty as to awards, Residual Unit Commitment (“RUC”) reductions, and energy flow for Load-Serving Entities (“LSEs”) outside of the CAISO.

Presently, IID has not been able to secure exports that rely on Non-Resource Adequacy (“Non-RA”) resources or high priority wheel-throughs, nor has confidence that it will be able to secure such resources and capacity when the CAISO’s Tariff provisions accepted under Federal Energy Regulatory Commission (“FERC”) Docket No. ER21-1790 go into effect.  Accordingly, it is imperative that IID understand how much capacity is left after allocations are made to Non-RA exports and high priority wheel-throughs.  The capacity left available after those allocations would be helpful for operations to know ahead of the market run as well as for after-the-fact for validation.  In addition, greater transparency concerning conditions at multiple interties would assist IID and similarly situated entities identify alternative procurement options after the Day-Ahead Market closes. 

In inquiry tickets submitted ahead of the July 13, 2021 workshop, IID echoed other stakeholders’ comments seeking greater transparency. Specifically, IID sought and continues to participate in CAISO simulations and seeks basic information such as wheels reserved as PT and unreserved transmission left after and before the markets run.  IID understands that the implementation of new exports and wheeling priorities will impact these quantities, but more information would be an improvement, as the information presently available to IID is somewhat of a black box, and greater availability of information will help bridge this gap.  

IID has explained in prior CAISO processes the challenge that IID is placed in without greater transparency.  The September 2020 change effectuated through Business Practice Manual (“BPM”) Proposed Revision Request (“PRR”) 1282 created considerable obstacles for IID in obtaining alternative supply.  PRR 1282 resulted in non-award of schedules to IID through the Real-Time Market that were scheduled in the Day-Ahead Market.  IID argued that, as an entity located outside of the CAISO’s Balancing Authority Area (“BAA”), IID should be able to rely on its Day-Ahead E-Tag submittals carrying through with priority into the Real-Time Market.  Under PRR 1282, the CAISO’s market timeline for declining exports through publication of Residual Unit Commitment (“RUC”) awards for the day ahead horizon was too late for market participants to respond by obtaining equivalent, day-ahead products in Western markets outside of the CAISO markets, as such markets were formally closed.  In other words, IID could not, at that point, turn to those Western day-ahead markets an option to substitute for non-awarded schedules.  

The PRR 1282 mechanism and modified priorities carried through in substantially the same form through the CAISO’s Market Enhancements for Summer 2021 Readiness stakeholder process and subsequent FERC Tariff revisions.  IID requests in this stakeholder process the types of transparency described above in order to mitigate the disadvantage IID faces in securing substitute power after the close of the Day-Ahead Market.
 
 

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

IID provides no response at this time, but reserves the right to state a position at a later date.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

IID provides no response at this time, but reserves the right to state a position at a later date.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

IID provides no response at this time, but reserves the right to state a position at a later date.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

IID provides no response at this time, but reserves the right to state a position at a later date.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

IID provides no response at this time, but reserves the right to state a position at a later date.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

IID provides no response at this time, but reserves the right to state a position at a later date.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

IID provides no response at this time, but reserves the right to state a position at a later date.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

The Joint California LSEs appreciated the opportunity to hear from different stakeholders on their perspectives for the direction and guiding principles for this initiative. In particular, after a challenging and contentious stakeholder initiative to create an interim solution for summer 2021, the Joint California LSEs value the openness and cooperative nature of the other stakeholders participating in the workshop. We hope that all stakeholders share a goal of creating a long-term, durable solution that equitably balances the need and right to protect the reliability of service to native load along with providing fair and open access to the CAISO grid for external parties. The Joint California LSEs look forward to engaging further with the diverse group of stakeholders to create a long-term policy that provides certainty that the CAISO can serve native load and affords external parties confidence in their ability to access the CAISO grid.

While generally a constructive workshop, the Joint California LSEs have concerns that some stakeholders may still be focused upon matters that have already been settled by FERC. The continued argument that the CAISO RA framework undermines external transmission rights is unproductive, as it is irrelevant to the core issues in this initiative and disregards FERC policy. This initiative is not focused on the FERC-accepted CAISO RA framework but, rather, on fairly allocating the CAISO’s limited transmission capacity during tight system conditions. The proper venue to express perspectives regarding the RA framework is the ongoing RA Enhancements initiative. Moreover, the question of whether the CAISO is undermining external transmission rights has already been addressed by FERC in its recent order accepting the export, load, and wheeling priorities tariff amendments. FERC

disagree[d] with protestors that CAISO’s proposal constitutes a degradation of any firm transmission products. CAISO’s proposal only established scheduling priorities across the CAISO-controlled transmission system. Firm transmission rights to the boundary of CAISO’s system do not grant firm transmission rights across CAISO’s system, which, as noted above, do not exist.

(P 146). Indeed, this is true for any use of transmission crossing multiple Balancing Authorities.  Holding of firm transmission rights in one BA does not provide for firm transmission rights in any other BA.  Continuing to entertain this erroneous argument will only frustrate the advancement of this initiative. 

In addition, parties that express concern regarding the perceived devaluation of transmission rights on external systems  should recognize that, under the current tariff provisions, wheeling transactions over the CAISO system provide no long-term, on-going support for the costs of the CAISO grid. In contrast to CAISO LSEs, who pay CAISO grid costs on an on-going basis, entities that use the CAISO grid for wheeling transactions pay the Wheeling Access Charge only when they choose to schedule wheeling transactions. Such intermittent payments are not comparable to the cost responsibilities borne by CAISO LSEs, and they do not provide a basis to argue for a curtailment priority equivalent to CAISO load.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

The Joint California LSEs propose CAISO work toward taking a conceptual long-term framework and a First Phase of Implementation to the CAISO Board in March 2022 followed by development of long-term implementation details in a later stage(s). Acknowledging the difficulty of implementing a long-term solution due to the likely changes with interdependent CAISO processes (e.g., MIC, TPP), the First Phase could use simplified studies and processes until long-term studies and processes can be developed and implemented. 

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

The Joint California LSEs continue to support the enhancements as described in our presentation in the “Suggested First Phase” slide (Slide 8, see below), as it would move the CAISO toward a long-term solution similar to the common practices of other RTO/ISOs.

The Joint California LSEs believe that one early phase enhancement where there may be alignment with external entities is the implementation of a new product where external parties would pay the CAISO directly for a high curtailment priority when capacity is available. Although we supported the external firm transmission rights requirement as an interim solution to ensure that an external entity is adequately committed to the CAISO grid such that a high curtailment priority within the CAISO system is appropriate, we do not view this as the most efficient market design. The Joint California LSEs suggest removing the need for this proxy by creating a high curtailment priority product as described in our presentation. Through the payment for this product, an external party would be providing sustained cost support for the CAISO grid. Moreover, it is consistent with the standard practices of other BAAs and RTOs.  

In regard to PT exports, the Joint California LSEs would like the CAISO to consider certain enhancements to ensure that (1) a PT export is actually deliverable to the indicated export intertie, and (2) resources significantly deviating from their export schedules are curtailable. It is unclear if these enhancements can be implemented in a near-term timeframe, but we believe these should be explored as a part of this initiative.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Again, the Joint California LSEs support the framework described in our presentation on Slide 6. We believe this framework represents a reasonable solution that appropriately balances the need to reliably serve native load while also providing fair access to external entities. Moreover, it is consistent with the standard practices of other RTO/ISOs.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Consistent with our presentation (Slide 4), the Joint California LSEs offer the following problem statement:

Develop principles and provisions for access to the CAISO grid for wheeling transactions and exports consistent with FERC’s Open Access Transmission policy, including priority for native load requirements.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

The Joint California LSEs believe the recent FERC decision approving the export, load, and wheel-through tariff amendments provides the CAISO with helpful guiding principles for near- and long-term solutions. In particular, we would like to highlight the following principles from that decision:

• The transmission operator can reserve capacity in order to reliably serve its native load (P 143)
• The requirements for native load and external entities do not need to be equal (P 152)
• External transmission rights should not affect the priority internal to the CAISO (P 146)

The standard practices of other RTOs/ISOs have informed our long-term framework, and we encourage the CAISO to continue to look toward these standard practices to evaluate how they can be applied within the CAISO market.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

The inconsistencies between the OATT paradigm’s transmission framework and the CAISO’s market design, which completely lacks physical transmission rights, create significant seams issues. The Joint California LSEs believe that the CAISO should not weaken the CAISO’s market-based open access paradigm and need not seek to perfectly align its practices with those of OATT BAAs. Instead, the CAISO should strive to create a process that provides additional clarity to external parties through the CAISO’s existing market structures. Through clearer rules around prioritization, the confusion and lack of certainty regarding wheeling access claimed by external entities regarding their resource planning and transacting should be alleviated. Given the different models, it is unlikely that seams issues will be fully addressed through this initiative, at least during the initial phase.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

8. Please provide comments on any other aspects of the initiative or workshop presentations.

For Powerex's comments, please see powerex.com/sites/default/files/2021-08/2021-08-04%20Powerex%20comments%20LT%20rights.pdf

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

PGP appreciates CAISO’s stakeholder-driven approach to the workshop. It was very helpful to hear and discuss principles and specific recommendations shared by CAISO and stakeholders both for near term enhancements to the current scheduling rights framework and long-term changes.

PGP believes the goals/objectives of the long-term solution should focus on establishing a framework that allows external entities the ability to acquire firm transmission rights (those above CAISO’s native load needs) over a variety of different time frames. PGP believes a comprehensive framework that assigns priority for transmission scheduling during all time periods, not just stressed conditions, is more equitable and likely to achieve our objective of addressing the seam between CAISO and the rest of the West on this issue. In addition, PGP believes a forward transmission procurement framework is essential because today there is no process in place for external entities to signal a need for additional transmission build, which may be necessary in the near future.

PGP appreciates the CA LSEs developing a vision for a long-term solution. PGP believes some of the elements shared have merit, such as a study process to account for long-term and short-term transmission requirements for native load and a queue for entities looking to procure long-term rights for curtailment priority equivalent to native load. However, the overall framework that CA LSEs recommend appears to focus on transaction prioritization through existing transmission service options when supply resources for load are constrained. 

PGP believes it would be beneficial to further explore both approaches (transaction prioritization under existing transmission service options or a process that develops a forward transmission procurement framework) to understand the key differences in the outcomes/results they would produce. In addition, PGP also seeks clarity on whether the intent of the CA LSE proposal is to develop a transaction prioritization process that would only be triggered during tight system conditions.

PGP believes Powerex’s proposal for near-term enhancements is worth exploring in more detail. Specifically, PGP supports Powerex’s suggestion of providing additional transparency of import RA and high-priority PT wheel requests by reporting to provide market participants with the quantity of RA contracts and PT wheels at each intertie. We agree that allowing market participants to evaluate remaining “priority capability” at a given intertie would enhance the situational awareness of market participants and hopefully reduce the risk of curtailment. With respect to the recommendation to require valid E-tags for import RA and PT wheels prior to initiating curtailments, PGP believes this proposal has merit as it could help avoid the risk of inefficiently over-curtailing real import RA and PT wheel schedules.

Finally, PGP believes it will be important to ensure that any solution devised ensures that there is a fair and open process for external entities to secure and ensure wheel through rights on the CAISO system so that they can reliably serve load.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

PGP supports a phased approach to the initiative. PGP agrees that developing a long-term solution is likely not possible before Summer of 2022 and supports a phased approach that considers near-term enhancements. PGP believes the near-term modifications should prioritize those that would best enhance CAISO’s and the external LSEs’ ability to have sufficient information to proactively manage their systems reliably and to reliably serve their load. 

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

PGP does not at this time have any specific recommendations on short-term enhancements, however, our perspective on approach and reactions to stakeholder presentations on this topic are addressed in response to question 1.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

 PGP offers the following objectives for a long-term solution:

• Provide ability for external entities to acquire firm transmission rights in excess of CAISO’s native load needs over a variety of different time frames 
• Utilize best practices from other RTOs/ISOs to inform possible long-term solutions
• Seek to minimize seams issues by aligning CAISO’s framework for transmission rights with the OATT framework used by entities outside the CAISO to the greatest extent possible
• Not deter competitive trade across Western markets or future regionalization efforts
• Transparency and validation of market activities and clarity and alignment of CAISO tariffs, BPMs, etc. 

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

The current CAISO framework for transmission scheduling rights represents a seam between the CAISO BAA and the rest of the Western interconnection which utilizes an OATT framework. This has contributed to uncertainty for both the CAISO and external load serving entities.  To ensure reliability of load service, external load serving entities need a process that allows them to request and secure long-term firm transfer service through the CAISO’s system. A long-term solution should focus on addressing this seams issue by aligning CAISO’s framework for transmission rights with the OATT framework used by entities outside the CAISO to the greatest extent possible while maintaining consistency with FERC’s Open Access Transmission policy.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

PGP supports CAISO establishing a forward transmission procurement framework that aligns as closely as possible with the OATT framework utilized in the rest of the Western interconnection and is informed by best practices used by ISOs/RTOs across the country. Please see the response to question one for details on this recommendation.  

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

            Please see response to question 5.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

PGP appreciates CAISO affirming that it is compiling information from other RTOs/ISOs with respect to scheduling priorities/transmission service reservations to determine best practices and plans to share this with stakeholders in the issue paper. We believe this is essential background information that will help CAISO and stakeholders develop solutions in this initiative and look forward to reviewing this documentation.

PGP also believes it would be helpful for CAISO to provide an overview of its MIC allocation process and transmission planning process for stakeholders and how they will be implicated in any possible solutions in this initiative. 

PGP believes it is essential to address the seams issues that are presented in this initiative, both for reliability in the region, as well as for future regional cooperation and market expansion efforts. We are encouraged by the solutions-minded approach demonstrated by the CAISO and stakeholders at this first workshop and look forward to participating in this initiative as it moves forward. 

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

Please see attached document.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

Please see attached document.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

Please see attached document.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Please see attached document.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Please see attached document.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Please see attached document.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

Please see attached document.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

Please see attached document.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

Please see attached comments of Shell Energy. 

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

Please see attached comments of Shell Energy. 

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

Please see attached comments of Shell Energy. 

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

Please see attached comments of Shell Energy. 

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

Please see attached comments of Shell Energy. 

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

Please see attached comments of Shell Energy. 

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

Please see attached comments of Shell Energy. 

8. Please provide comments on any other aspects of the initiative or workshop presentations.

Please see attached comments of Shell Energy. 

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

No comments at this time.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

No comments at this time.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

Introduction:  SVP appreciates the opportunity to comment on the External Load Forward Scheduling Rights Initiative in advance of CAISO publishing its Issue Paper.  In these comments, SVP identifies a narrow issue that should be clarified to enhance the CAISO 2021 Readiness Scheduling Priorities Tariff Revisions, recently approved by FERC in Docket No. ER21-1790.  SVP’s comments at this time are limited to a proposed definitional clarification related to the new Post-HASP process, and SVP reserves the right to comment on other issues as this initiative develops.

Comments:  CAISO Tariff Section 34.12.3 addresses proration of transmission capacity in the post-HASP process, when HASP cannot meet CAISO Forecast of CAISO Demand or fully accommodate a Priority Wheeling Through transaction.  The provision prorates transmission capacity between “CAISO Load and Priority Wheel Through transactions.”  CAISO’s Tariff includes a definition of CAISO Demand, but it does not define “CAISO Load.”  The Tariff defines “CAISO Demand” as:  “Power delivered to Load internal to CAISO Balancing Authority Area.”  While CAISO[1] and Load[2] are defined terms in the Tariff, the meaning of the two terms together would not necessarily capture all Load within the CAISO Balancing Authority Area.  Alternatively, it could be interpreted as Load of the CAISO as an end-use customer. 

For clarity, SVP suggests that CAISO add the following term and definition to its Tariff: “CAISO Load – Load internal to the CAISO Balancing Authority Area.” 

Adding the definition of CAISO Load will clarify the Post-HASP process treats schedules to non-PTO LSEs equally with those of PTO LSEs and Priority Wheeling Through schedules.  The definition is also consistent with CAISO’s treatment of non-PTO entities in its TAC Structure Enhancements Draft Final Proposal, aligning non-PTO entities’ demand billing determinants with those of PTO/UDCs because the non-PTO loads are served by the CAISO transmission system similarly to other CAISO internal loads.[3]

CAISO Tariff Section 34.12.3 also refers to a Business Practice Manual (“BPM”) wherein CAISO describes its post-HASP process.  Presumably (though SVP seeks confirmation in this regard), the referred to BPM is Proposed Revision Request (“PRR”) 1360 to the Market Operations BPM, effective July 15, 2021.[4]  When describing the post-HASP process in section 2.5.5.2.3 of the BPM, CAISO again refers to allocating available transmission capacity between Priority Wheeling Through transactions and “CAISO load.”  Adding the definition of “CAISO Load” to the Tariff will also provide clarity to the BPM.

Alternatively, CAISO could accomplish the same result by replacing “CAISO Load” in Tariff Section 34.12.3 and the BPM with “Load within the CAISO Balancing Authority Area,” which is a phrase used in other portions of the Tariff.

[1] “CAISO” is defined as: “The California Independent System Operator Corporation, a state chartered, California non-profit public benefit corporation that operates the transmission facilities of all Participating TOs and dispatches certain Generating Units and Loads.”  CAISO Tariff at Appendix A.

[2] “Load” is defined as: “An end-use device of an End-Use Customer that consumes Power. Load should not be confused with Demand, which is the measure of Power that a Load receives or requires.” Id.

[3] See TAC Structure Enhancements Draft Final Proposal at Section 7.1.1.4, pages 35-37.  http://www.caiso.com/InitiativeDocuments/DraftFinalProposal-TransmissionAccessChargeStructureEnhancements.pdf

[4]The Market Operations BPM language added by PRR 1360 is linked here: https://bpmcm.caiso.com/Lists/PRR%20Details/Attachments/1360/MO%20BPM_Summer%20Readiness_Load%20exp%20wheeling%20priorities_eff%20July_20210527.docx

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

No comments at this time.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

No comments at this time.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

No comments at this time.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

No comments at this time.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

No comments at this time.

1. Please provide your organization’s perspective on the stakeholder presentations and any near-term or long-term enhancements that were presented, as well as any other aspects of their presentation.

See attached comments.

2. Please provide your organization’s perspective on the proposed phasing of the initiative.

See attached comments.

3. Please provide your organization’s suggestions on near-term enhancements to the interim scheduling priority framework and requirements that could be implemented by summer 2022.

This includes suggestions on improvements regarding establishment of PT wheel and PT export status, and associated validations and processes.

See attached comments.

4. Please provide your organization’s suggested principles and/or objectives for a long-term, durable, framework.

See attached comments.

5. Please provide your organization’s perspectives on a problem statement that should guide development of a long-term framework.

See attached comments.

6. Please provide your organization’s suggestions for any approaches or frameworks that the ISO should consider for a long-term solution.

If possible or if available, please include references to any supporting documents whether FERC guidance, benchmarking of practices, or any other supporting information.

See attached comments.

7. Please provide your organization’s perspectives on any seams issues between the Open Access Transmission Tariff (OATT) paradigm and the CAISO’s organized market paradigm that should be addressed as part of the long-term framework development.

See attached comments.

8. Please provide comments on any other aspects of the initiative or workshop presentations.

See attached comments.