Comments on Draft Tariff language

1. Please provide any redline changes and embedded comments your organization may have on the Price Formation Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

Please see the attached Comments from the Department of Market Monitoring.

1. Please provide any redline changes and embedded comments your organization may have on the Price Formation Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

PGE has no further comments or suggested changes to the Price Formation Enhancements draft tariff language.

PGE appreciates the price formation enhancements workgroup as part of the overall CAISO stakeholder process. PGE is pleased with the CAISO's responsiveness and believes the stakeholder process is working as intended. 

1. Please provide any redline changes and embedded comments your organization may have on the Price Formation Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

SDG&E appreciates the opportunity to comment on the revised draft tariff language for the Price Formation Enhancements initiative. In particular, SDG&E commends CAISO’s continued efforts to engage with stakeholders and ability to identify solutions to address, or limit, areas of concern.  SDG&E believes limiting bidding flexibility for energy storage resources to the real-time market only, is the most prudent course at this time. Although some concerns remain about potential cost-impacts, we recognize these enhancements add valuable bidding flexibility for use-limited resources for Summer 2024.

The revision of the draft tariff language and final proposal to apply the energy storage bidding rules to only the real-time market is important to the success of this interim solution. Further, SDG&E does not oppose the exclusion of hybrid resources in the draft tariff language, although we believe enhancements for these resources should be considered in a more permanent policy proposal.

Prior to the full go-live of this interim solution for Summer 2024, SDG&E is interested in further clarification of the testing that will take place. CAISO has also expressed that it will be monitoring the market closely for any unintended consequences once this initiative is implemented, which SDG&E is supportive of.