Please provide your organization's comments on the resource sufficiency evaluation load conformance impact analysis.
PG&E supports the conclusions of the CAISO’s load conformance analysis and opposes proposals to incorporate load conformance into the RSE requirements
The main conclusion of CAISO’s analysis is that the use of load conformance does not enhance the CAISO BAA’s ability to pass the RSE tests. The analysis found that, rather than benefiting the CAISO BAA, load conformance can be detrimental to the CAISO BAA’s ability to pass the RSE’s flexible ramping test (by reducing the amount of ramping capability that could otherwise be counted in the RSE). Based on this analysis, PG&E believes there is no justification for proposals to add load conformance to the RSE requirements. Both DMM and the MSC have also recommended that load conformance should not be incorporated in the RSE capacity test requirements. The relationship between load conformance and changes in different sources of supply was shown to be complex and highly variable, and PG&E agrees with CAISO’s warning of the “inherent difficulty and potential inaccuracies” of attempting to derive a relationship that could be utilized in the RSE.
The systematic use of load conformance by CAISO operators to gain additional ramping capability also highlights the importance of validating and implementing the planned improvements to the Flexible Ramping Product (FRP). PG&E encourages the CAISO to prioritize successful implementation of the FRP improvements in the Fall of 2022.
Motion to intervene and comments of the Department of Market Monitoring of the California Independent System Operator Corporation. Docket ER22-1278. April 1, 2022. Pg. 8 at http://www.caiso.com/Documents/Motion-to-Intervene-Comments-ER22-1278-WEIM-RSE-Enhancements-Apr-1-2022.pdf
Opinion on Energy Imbalance Market (EIM) Resource Sufficiency Evaluation Enhancements. Members of the Market Surveillance Committee of the California ISO. February 2, 2022. Pg. 13 at http://www.caiso.com/Documents/MSCFinalOpiniononEIMResourceSufficiencyEvaluationEnhancements-Phase1.pdf
 “Load Conformance Impact on the Resource Sufficiency Evaluation.” Guillermo Bautista Alderete, Sheng Chen, Scott Lehnman. CAISO Market Analysis and Forecasting. Pg. 23 at http://www.caiso.com/InitiativeDocuments/Analysis-LoadConformanceImpactonResourceSufficiencyEvaluation.pdf
Please provide your organization's comments on the analysis for the flexible ramping uncertainty calculation in the WEIM.
Please provide your organization's input on the format of how the data in the RSE load conformance impact analysis is presented.
Please provide your organization's input on the format of how the data in the flexible ramping uncertainty calculation analysis is presented.
Please provide additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 1B analysis mentioned above.