Comments on Comments due on draft tariff language

1. Please provide any comments your organization may have on the Storage Bid Cost Recovery and Default Energy Bids Enhancements draft tariff language.

PG&E appreciates the CAISO’s efforts on providing draft tariff language related to the Storage Bid Cost Recovery (BCR) initiative. PG&E offers the following questions/comments to ensure clarity:

1. The term ‘Real-Time Market Energy Bid’ is used in the draft tariff language but not currently defined in the tariff. Will this become a newly defined term in the tariff or will the CAISO rephrase this language without using capitalization?  

2. The term ‘Real-Time Market Energy Bid’ is ambiguous since it could refer to either a discharge bid or a charge bid. PG&E recommends specifying in which scenarios each bid applies, particularly when (a) incremental energy flips the schedule from charge to discharge and (b) decremental energy flips the schedule from discharge to charge. The CAISO has alluded to using a weighted average (of discharge bid and charge bid) in the case of flipped schedules, however this is not clear from the draft tariff language.

3. The CAISO should correct the typo in section 29.11 (f) (3): “patriciate” should be changed to “participate”:

“The CAISO will calculate Real-Time Market Energy Bid Cost for EIM Participating Resources that are storage resources and patriciate as Non-Generator Resources in accordance with 11.8.4.1.5.1…”