Please provide your organization's comments on the clarifying language in the final proposal.
Platte River Power Authority (Platte River) appreciates the California Independent System Operator’s (CAISO) efforts to develop its May 18, 2021, Western EIM Sub-Entity Scheduling Coordinator (SESC) Role Final Proposal (Proposal) and generally supports the concepts in the Proposal.
Platte River’s comments to the Proposal are (1) Expectations added for the use of manual dispatch should apply to EIM entities and EIM sub-entities alike, and (2) transmission information and governance is essential to effective market operations and may not be adequately addressed in the Proposal.
Platte River agrees with the expectations added for the use of manual dispatch but disagrees that this language should only apply to EIM sub-entities and not also to EIM entities. The language states in part that, “[T]he CAISO expects the use of [manual dispatches] to be for reliability related actions in accordance with previously agreed upon circumstances and conditions, such as participation within a reserve sharing group or similar operational purpose.” Platte River previously requested in its February 18, 2021, comments to CAISO’s January 21, 2021, Revised Straw Proposal similar language to address both EIM sub-entities' and EIM entities’ use of manual dispatch, which was not adopted. The use of manual dispatches by either an EIM entity or an EIM sub-entity could have far reaching, material impacts on other market participants and should only be used by all EIM market participants in accordance with the language cited above.
Transmission information and governance
Platte River supports the additional language in the “Roles and Responsibilities,” the “System Access – BAAOP,” and “Outage Management” sections regarding the submittal of transmission information and roles and responsibilities related to transmission use. However, due to the broad nature of the language in the Proposal, Platte River is not sure that the interaction between EIM sub-entities, EIM entities, and CAISO related to transmission has been fully addressed. Platte River reiterates the redlines and comments it submitted to Sections 29.17 and 29.26 of the April 15, 2021, version of the redlined Tariff and Section 2.5 of the April 15, 2021, version of the redlined EIM Sub-Entity Agreement and asks CAISO to ensure that Platte River’s redlines and comments have been appropriately addressed in the Proposal. How transmission information is communicated and how transmission use is governed needs to be clear to facilitate effective communication and correct market operations.