Arizona Public Service
Submitted 05/10/2023, 03:38 pm
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
APS appreciates the opportunity to comment on the Transmission Service and Market Scheduling Priorities (TSMSP) Phase 2 draft tariff language and April 14, 2023 stakeholder call. In addition to the detailed comments in the tariff sections outlined below, APS appreciates the opportunity and looks forward to providing feedback on the effectiveness of the proposal and suggested improvements during the meetings outlined in section 23.3.5.
As noted in our letter to the CAISO Board of Governors and WEIM Governing Body dated January 27, 2023, APS reiterates concerns around availability of ATC to those who seek high priority wheeling status, the interplay of historical lookback in place of utilizing forward looking contracts in the ATC methodology, and the timelines and true priority of this transmission service in the context of entities WRAP requirements. APS would re-request and support that one of the upcoming workshops on EDAM tariff highlight the ability to utilize the CAISO transmission system for WRAP transactions including the priority treatment of transmission under the EDAM and the TSMSP phase 2 tariffs.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
No comments at this time.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
APS would agree with the discussion around section 23.2.3 from the stakeholder call that “immediately” within this section as it pertains to the notice of termination or modification of the underlying contract supporting a high priority wheel needs a defined deadline or definition. It is especially important to give a timeframe in which to report the modification, since the section also allows for a replacement contract to be executed to replace the modified or terminated contract. A market participant would not necessarily have a replacement contract executed if it must notify CAISO immediately upon the original contract being terminated or modified.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
Section 23.3.2 highlights the process in which a CAISO LSE could inform CAIOS of replacement or incremental non-RA contracted capacity before the 13-month ahead release of transmission. It is unclear in this update process if CAISO LSE can similarly inform the CAISO of historical contracts that are known to not continue into the future but were included in the historical non-RA contract values, so that the capacity could be released as ATC. It is also unclear what the need to identify replacement contracts is if there would be no relinquishing of the capacity held from historical non-RA showings.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
No comments at this time.
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
As mentioned on the stakeholder call, APS believes that the following sentence is incorrect and was acknowledged by CAISO as such, “At a minimum, Wheeling Through priority requests in the Day-Ahead horizon must be supported by a firm power supply contract of at least four (4) hours for each day during the seven (7)-day horizon for which the Scheduling Coordinator seeks a Wheeling Through priority.” This should be corrected to reflect that a contract is only needed for the day in which you are requesting high priority wheeling, and not for the (7) day horizon. A requirement for a 7-day contract would be more appropriate for a weekly reservation than a daily wheeling reservation that is being outlined in section 23.5.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
APS requests additional information and verification that a re-sell can only be performed if the Assignee is utilizing the same import AND export locations. Throughout the proposal development and in the final proposal the import location was analyzed to determine available ATC with little to no consideration of export locations. If an entity finds itself re-selling its granted high priority wheeling rights requiring the import and export locations to match would significantly reduce the likelihood of identifying a willing buyer. Since export location isn’t considered in the granting of the rights, APS would believe that only the import location, hours, and MW values would need conveying to the Assignee.
This section also should be edited to reference the requirements surrounding the relinquishing of high priority rights back to CAISO for amended or cancelled contracts before the commencement of the high priority rights. A market participant may conclude that they should re-sell established rights, but this should be the path the market participant takes only after the start date when they are no longer able to relinquish the rights back to CAISO as detailed in section 23.2.3. CAISO supported this on the stakeholder call that the re-sell section shall only apply if the start date has passed.
APS would contend that section 23.7 should include information around ETC selling/re-assignment to high-priority wheel throughs. During policy development it was noted that there may be times when the ATC of an import location is 0, and in these times, customers seeking a high-priority wheel could procure existing transmission commitments (ETC) from those that hold them. Though this was discussed it is unclear in the tariff language how such a transaction would occur, and if this capability is captured in existing tariff language. If it is captured in existing tariff language a reference to that language would be beneficial. It would be important to note the requirements associated with a transfer of ETC to high priority wheeling in terms of import/export locations, or other consistencies that must be kept in place (CRR, MW, hours, etc.).
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
No comments at this time.
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
The post-HASP process should not be triggered by a constraint on Path 26 based off the final proposal and discussions throughout the stakeholder process. In the proposal it was determined that internal constraints wouldn’t be considered in the granting of high priority wheeling rights or the establishment of the ATC so it is unclear why the Post-HASP Process would need to consider the constraints on Path 26 either.
The language in Section 34.12.3 around CAISO operators’ discretion in, “consistent with good utility practice should use reasonable efforts not to curtail Priority Wheeling Through transactions without also having to shed CAISO load proportionally.” is of high concern. The language appears to defeat the purpose and establishment of pro-rata adjustments to priority wheels equal to CAISO load in the proposal. It is leaving the door open to the scenario where priority wheels are curtailed and no CAISO load is shed, which introduces a high degree of subjectivity and ambiguity to high priority wheels being equal priority and subject to curtailment pro-rata with CAISO load.
10.
Provide your organization’s comments on the draft changes made to Appendix A:
No comments at this time.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
No comments at this time.
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
No additional comments at this time.
Bay Area Municipal Transmission Group (BAMx)
Submitted 05/10/2023, 04:41 pm
Submitted on behalf of
City of Palo Alto Utilities and Silicon Valley Power (City of Santa Clara)
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
Bay Area Municipal Transmission Group (BAMx)[1] is pleased to submit these comments on the Transmission Service and Market Scheduling Priorities Draft Tariff language published on March 27, 2023 and discussed with stakeholders on April 14, 2023.
[1] BAMx comprises City of Palo Alto Utilities and City of Santa Clara, Silicon Valley Power.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
BAMx suggests clarifying edits to the draft tariff language in Sections 23.2.4, 23.3.2 and Appendix L.1.3.3.3, as described below and in the attached document.
BAMx also requests that CAISO identify when the “Available Transfer Capability Implementation Document” described in Appendix L.1.5 will be made available.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
BAMx suggests referencing the process for considering native load needs for context prior to discussing the daily request window process.
“CAISO LSE native load needs will be considered in determining ATC pursuant to Section 23.3 and Appendix L. In addition…”
23.3.2 New Contract Information
To account for the possibility of entities replacing resources internal to the CAISO with imports, BAMx suggests the redlined addition shown below:
An LSE can make that demonstration by showing Load Serving Entity resource plans, its expected load growth, incremental procurement ordered or approved by Local Regulatory Authorities, replacement of generation internal to the CAISO BAA, or other relevant information demonstrating the additive nature of the new contract.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
No comments at this time.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
No comments at this time.
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
No comments at this time.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
No comments at this time.
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
No comments at this time.
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
No comments at this time.
10.
Provide your organization’s comments on the draft changes made to Appendix A:
No comments at this time.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
BAMx suggests the following edits to Appendix L.1.3.3.3 to:
- More clearly link the adjustments to ATC to the showings.
- Reflect that increases in RA and non-RA Showings vs. the assumed amounts will eat into the TRM, but will not necessarily change the ATC.
- Acknowledge the relationship between the TRM and changes in the shown RA, while preserving the concept of respecting previously committed wheel through priorities.
L.1.3.3.3 Monthly Update of Native Load Needs – Following the RA and non-RA import contract showings at the end of the RA cure period under Section 40 of the CAISO Tariff, the CAISO will update or “true up” the amount of transmission capacity set aside in ETComm to meet native load needs at each Intertie to include the sum of the most recent actual showings of (i) RA import supply contained in monthly Resource Adequacy Plans and (ii) non-RA import supply delivered at the Intertie reported to the CAISO for that same calendar month.
If the amount of transmission capacity set aside at an Intertie to meet native load needs for a calendar month based on historical RA and non-RA import showings for that month (and including transmission capacity to serve expected native load growth) is greater than the most recent actual showings of RA import supply contained in monthly Resource Adequacy Plans and non-RA import supply to be delivered at the Intertie for that same month, the resultant excess transmission capacity will be released as ATC and will be available for awarding as monthly Priority Wheeling Throughs pursuant to the monthly request window process in Section 23.4 of the CAISO Tariff. If the amount of transmission capacity set aside at an Intertie to meet native load needs for a calendar month based on historical RA and non-RA import showings for that month (and including transmission capacity to serve expected native load growth) plus the amount of TRM set aside to account for uncertainty associated with actual monthly Resource Adequacy and non-Resource Adequacy showings, is less than the most recent actual showings of RA import supply contained in monthly Resource Adequacy Plans and non-RA import supply to be delivered at the Intertie for that same month, the ATCTRM at the Intertie that has not been awarded in a prior monthly request window, will be reduced to account for the additional RA and non-RA import showings at the Intertie. If no ATC remains at an Intertie because it has been awarded in prior months’ request windows pursuant to Section 23.4 of the CAISO Tariff and the TRM cannot accommodate all native load needs, then the amount of transmission capacity set aside at the Intertie to meet native load needs for a calendar month, including transmission capacity to serve expected native load growth and the TRM, will be limited to the total amount originally calculated by the CAISO even if the actual RA and non-RA import contract showings for the month exceed the amount of ATC the CAISO has set aside for native load in accordance with Section L.1.3.3. Under these circumstances, the CAISO will continue to honor the scheduling priority of the Wheeling Through transactions for which ATC previously has been awarded. The examples below in this Section L.1.3.3.3 illustrate the aforementioned processes.
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
No comments at this time.
California ISO - Department of Market Monitoring
Submitted 05/10/2023, 09:30 pm
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
Please see DMM comments in PDF attached at the bottom of this comment template. DMM comments will also be posted in the following location, under the heading "2023 comments on policy initiatives":
http://www.caiso.com/market/Pages/MarketMonitoring/MarketMonitoringReportsPresentations/Default.aspx#comments
NV Energy
Submitted 05/09/2023, 09:48 am
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
NV Energy appreciates the opportunity to comment on the initial draft tariff language to implement the Transmission Service and Market Scheduling Priorities Phase 2 initiative as approved by the CAISO Board of Governors February 1, 2023. NV Energy understands the purpose of these comments is to discuss whether the proposed provisions are consistent with the approved January 18, 2023, Final Proposal and not to revisit policy choices.
That having been said, the proposed language serves to highlight unjust and unreasonable aspects of the proposed design. Section 23.3.2 states, “[b]efore the CAISO initially establishes ATC for a month that is thirteen (13) months away, under the process and deadlines established in the Business Practice Manual, CAISO Load Serving Entities (LSEs) may show to the CAISO any new contracts for imports or inform CAISO of any expired contracts to serve their load that are not reflected in the historical data the CAISO will consider in establishing the initial ATC for that month.” In other words, it is not sufficient that only CAISO LSEs receive priority to reserve transmission prior to other eligible customers and the advantage that their reservation is based on the highest historical amount in that month over the past two years, but the CAISO will allow their LSEs to increase the amount of their reservations above the historic maximums if they can show newly executed contracts. If the CAISO is going to provide an update at T-13 months, NV Energy does not object if it is a true, mandatory update -- one that can increase or decrease the native load reservation based on the latest data. The door must swing both ways. If, for example, there are higher hydro conditions at 13 months than in the historic test years, more ATC should be available for Priority Wheeling Through transactions. CAISO should not go to FERC with a one-sided program whereby CAISO LSEs have the discretion to modify their native load reservation, one that would likely be used only to decrease ATC available for external entities.
In addition, NV Energy continues to question how the wheel through market rules will work with the Western Power Pool’s (WPP) Resource Adequacy Program (WRAP). NV Energy encourages CAISO to expand the scope of any EDAM workshops on interoperability to include wheeling through the CAISO Controlled Grid. While it is vital to ensure that EDAM respects the firmness of the OATT priorities of transmission customers of EDAM Entities, it is just as important that CAISO’s long-term wheel through approach is consistent with the FERC-approved firm transmission requirements of WRAP.
While the draft tariff language does not include a provision for long-term transmission requests, it is incomplete in another extremely important way. CAISO needs to include provisions enabling entities to utilize import capacity held by customers with existing transmission rights (ETCs) or transmission ownership rights (TORs) to convert them to Priority Wheeling Throughs. In the January 18, 2023, Final Proposal, the CAISO stated:
It is important to highlight as well that if the resulting ATC calculated by the ISO is limited, entities seeking to wheel through the ISO can also consider alternate approaches to wheeling through the ISO, such as working with entities that have existing transmission contracts (legacy) and potentially contract for their import capability that they may have at individual interties.
There is no provision in the draft tariff language that specifies how an entity in the Desert Southwest can work with an entity that has import rights at Malin to obtain a Priority Wheeling Through transaction utilizing these ETC or TOR rights. It is vital that this linkage be specified in the CAISO Tariff as the proposed definition of “Priority Wheeling Through” in Appendix A is “A Wheeling Through Self-Schedule that has obtained a priority under Section 23”. Thus, the means of accessing these ETC and TOR rights to obtain Priority Wheeling Through transaction status also must be included in Section 23.
Additionally, the inclusion of Path 26 in the proposed section 34.12.3 on the post-HASP process appears inconsistent with the Final Proposal which stated clearly and unequivocally that “[t]he design in this proposal focuses on the calculation of ATC across the interties to derive an amount of transmission capacity that can be made available for wheeling through customers to establish in advance a market scheduling priority equal to load.” With respect to Path 26 the Final Proposal contains the following:
Second, the ISO’s recent assessment of heat wave events suggests internal transmission network constraints generally do not pose an impediment to supporting wheels through or exports from the system while at the same time serving native load, including in more stressed system conditions. This seems to be the case in part because during peak conditions where there is internal congestion and internal generation is committed and dispatched for local area purposes – northern generation is dispatched to serve northern load and solve local area congestion while southern generation dispatched generally to serve southern load and solve local area congestion on the system – reducing north to south flow and limiting the risk of congestion or overloading through the middle of the system, including path 26 under various stressed system conditions that impedes the ability to serve load in an area due to competing wheel through uses of the system.
For example, the graphs below illustrate the loading patterns on path 26 north to south and path 15 south to north during high load conditions in September 2022 when load was within 90% or more of the peak. The graphs illustrate that although the load was near or at the peak, and there were a sizable number of wheels through the system, path 26 and path 15 loading was manageable and did not trigger internal reliability constraints. Currently, there appears to be a sizable amount of supply both in the north and the south of the system that the market can re-dispatch to accommodate different uses of the system, including accommodating large quantities of imports and wheels through the system without triggering internal reliability limits. Looking forward, with potential future resource retirements, we expect that there will remain sufficient resource dispatch capability on either side of path 26 to continue to manage flows, primarily driven by new resource additions across the balancing area
Despite these clear statements that the firm transmission available for Priority Wheeling Through transactions is based only on a review of import capacity, CAISO for the first time in the tariff language not only places a curtailment risk based on “the event an Intertie is constrained in the import direction by a scheduling limit,” but also includes or if “Path 26 is constrained in the north-south direction”. This appears to be a significant departure from and modification of the proposal as approved by the EIM Governing Body and the Board and contradictory to the statements made in the Final Proposal.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
23.1 Categories of Transmission Capacity
The proposed changes in section 23.1 appear to be incomplete and fail to specify the graduated levels of curtailment priority contained in the Final Proposal. The five categories of transmission priorities are as follows:
- ETCs
- Native Load, TRM, CPMs and Priority Wheeling Throughs that secured capacity in the monthly and daily processes
- Native Load that did not secure ATC
- Low Priority Wheels
- Transmission capacity that may remain for any other uses, such as non-firm Existing Rights for which the Responsible PTO has no discretion over whether or not to provide such non-firm service.
In particular, CAISO must recognize that Priority Wheeling Through transactions have a priority equal to CAISO LSE load that also secured import capacity in through the process in Section 23 and ahead of any CAISO demand that is not supported by a forward reservation of transmission capacity.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
23.2 Accessing Available Transfer Capability
As noted above, NV Energy dos not object if the 13-month update is a true, mandatory update that can decrease the native load reservation based on the latest data as well as increase the native load amount.
23.2.1 and 23.2.4 - in (4) the draft proposal states, “all eligibility requirements to support a monthly or daily Wheeling Through priority have been met”. The specific requirements should be identified in the tariff. It is unclear what the “all eligibility requirements” would be other than those already delineated in 23.2.1. (1), (2), and (3).
23.2.2 – If a Priority Wheeling Through transaction does not convey a physical transmission right, the CAISO should confirm that the provisions in section 23 are meant to develop a level of firmness equal to OATT 7F such that Priority Wheeling Through reservations will qualify under the FERC-approved provisions of WRAP.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
23.3 Miscellaneous ATC Requirements
23.3.1 – Not just any contract for resource adequacy capacity should be used to reduce ATC. For example, if a contract only provides capacity in the event a previously accounted for external resource adequacy resource becomes unavailable, this backstop capacity would not increase the need for import capacity. Rather it would simply substitute for the previously reserved resource. To prevent double counting, the CAISO must specify that replacement capacity contacts should be excluded. A similar issue arises in section 23.3.3.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
23.4 Obtaining Monthly Wheeling Priority
With regard to the last sentence, “[a] Scheduling Coordinator for Priority Wheeling Through does not lose an awarded scheduling priority if it does not schedule in the Day-Ahead Market”, NV Energy seeks to confirm the CAISO’s intention to maintain a process similar to that required under the FERC-approved OATT by which transmission customers may make changes down to 20 minutes before real-time and maintain their scheduling priority. Such flexibility would be consistent with charging Priority Wheeling Through transactions on a demand basis rather than the hourly rate associated with non-priority wheels.
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
No comments.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
23.7 Sale or Assignment of Wheeling Through Priority
As noted above, the CAISO must provide a specified means in the tariff that holders of ETC and TOR import rights can utilize, assign, or sell all or a portion of those rights to support Priority Wheeling Through transactions.
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
26.1.4.5 Priority Wheeling Throughs
The first sentence reads, “Scheduling Coordinators for customers with a monthly or daily Wheeling Through priority will pay the applicable Wheeling Access Charge based on the MW amount and total hours of the priority for the applicable period.“ NV Energy seeks to confirm that this will be a monthly payment following the service month.
The last sentence should be modified as follows: “To the extent a Priority Wheeling Through customer schedules a Wheeling Through transaction in excess of its Priority Wheeling Through quantity or outside of the hours associated with its Wheeling through priority, such volumes are not covered by the Wheeling Through priority and will be separately charged at the applicable Wheeling Access Charge based on the amount of the scheduled energy delivered.” The proposed addition clarifies that any non-priority wheel is not assessed a demand charge.
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
34.12.3 Post-HASP Process
As NV Energy noted previously, the inclusion of Path 26 is inconsistent with the Final Proposal. In addition, the following draft language contains the following provision:
provided that CAISO operators (1) will review the application of pro rata curtailments of Priority Wheeling Through transactions and in their discretion approve or disapprove such curtailments after considering the reliability impacts and (2) consistent with good utility practice should use reasonable efforts not to curtail Priority Wheeling Through transactions without also having to shed CAISO load proportionally. CAISO operators will consider overall system conditions and the reasons for the potential need for curtailment, including whether actual load is at risk of curtailment excluding load conformance, prior to issuing curtailments. In no event, will the CAISO reduce Priority Wheeling Through transactions solely in the event of a CAISO supply shortfall that triggers a power balance infeasibility.
This language appears to suggest that a CAISO operator could have the discretion somehow to curtail a Priority Wheeling Through transaction without a mandatory pro rata reduction of CAISO load – that should not be the case. If there is a system derate such that not all transactions can be accommodated, CAISO load must be required to undergo a proportional reduction. It is one thing for Western Balancing Authorities to communicate and work cooperatively to address potential emergency conditions that can affect one or more of their respective Balancing Authority Areas. It is quite another for a single Balancing Authority, acting as a transmission provider, to apply discretion in the application of open-access curtailment principles. The CAISO uses load conformance in a manner similar to an EIM Entity making non-firm external purchases if there is insufficient ATC to designate an external network resource. As such load conformance should not cause a pro rata curtailment of a Priority Wheeling Through transaction. CAISO should not be in a position to create a transmission constraint through using load conformance when there is also a power balance infeasibility triggering both conditions that would apply a pro rata curtailment of Priority Wheel Throughs.
10.
Provide your organization’s comments on the draft changes made to Appendix A:
No comments.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
Appendix L – Method to Assess Available Transfer Capability
L.1.3.3.1 – Native Load Growth
NV Energy seeks to clarify if this provision related to native load growth is only applicable to the longer-term monthly process and would not be used in daily ATC calculations.
L.1.3.3.3 Monthly Update
While NV Energy appreciates the CAISO’s inclusion of an example, as currently drafted the example is difficult to follow.
L.1.4 – Not used
Shouldn’t there be a daily update?
L.1.5 - TRM
Shouldn’t there be a process whereby TRM could be releases if uncertainty decreases, especially in the daily time horizon?
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
No additional comments.
Pacific Gas & Electric
Submitted 05/11/2023, 01:19 pm
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
PG&E has concerns that the pace of tariff development will limit the necessary time for stakeholders to provide sufficient feedback to the CAISO. PG&E strongly encourages the CAISO to accelerate the timing of tariff drafting and revisions to receive additional feedback, on areas of the tariff that have not yet been released for comment.
PG&E has concerns that the tariff is reinforcing a policy that codifies a policy that does not provide equivalent treatment across all market participants. The draft tariff does not fully reflect the objective of providing equitable treatment across all market participants, (for example section 34.12.3, addressed Question 9).
PG&E commends the CAISO’s commitment to having annual stakeholder engagement process for modifying the structure of the transmission priorities and scheduling services. The specific process for this has not been clearly communicated in either the policy or the tariff. The CAISO should specify which year is focused on in the workshop. That process or what activities the CAISO is committing to should be explicit and what can be modified through that workshop should be explicitly incorporated into the tariff.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
No comment currently, PG&E reserves the right to comment on this matter in future stakeholder comments.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
In section 23.2.3, the draft tariff language reads that Scheduling Coordinators must notify the CAISO “immediately”, but the term is not defined. A more precise definition may aid the enforcement of this requirement, for example “within 24-hours”.
The CAISO should also make it explicit or reference to the relevant section of the tariff what the repercussions would be if SCs do not meet this requirement.
23.2.3 allows for the SC to resell under certain circumstances. These circumstances should be more clearly defined. Since there is no requirement for assignees to have an underlying supply contract, PG&E encourages the CAISO to review activities of the resale market.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
23.3.2 addresses a case where a new contract is needed to replace the existing contract. Greater specific would be beneficial, for example, how long will an LSE have to sign a new contract and what occurs if the CAISO identifies that the initial contract was terminated much earlier than the LSE communicated to the CAISO.
Section 23.7, further addressed in question 7, requires LSEs to not be able to resell their priority to get out of a supply contract, how will that be enforced in the case where an LSE has learned that a supply contract will be terminated and then resells the priority.
The CAISO should make it clear that if any of the terms of the new contract deviate from the original contract that the reservation is then returned and made available to all other market participants.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
In section 23.3.4, the description is awkwardly phrased, and the CAISO should work to rephrase the points being addressed.
In section 23.3.5, the description on the summer meeting is addressed. Two summers will need to be addressed in those meetings, i.e., the prompt year and the following year, this should be explicitly addressed. PG&E suggests that the CAISO consider segmenting the process into three distinct parts of the stakeholder meetings. PG&E recommends that a segment be dedicated to the review of the new data and information that has been obtained from the prior year(s) ATC reservation process. PG&E also recommends that a segment be focused on the prompt year and if any changes can be made in the near-term, even though reservations have already been made. Finally, there should be a segment stakeholder workshop that is focused on the following year’s changes. This would allow for there to be 1) a clearly understood set of new facts, 2) an opportunity to focus on near-term modifications and accounting for realistic timing constraints, and 3) the mid-to-long-term modifications that may be needed.
An alternative structure would be for there to be two separate meetings. PG&E recommends that the CAISO consider having a spring meeting (focused on the year after the prompt year) and a fall meeting (focused on the prompt year).
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
No comment currently, PG&E reserves the right to comment on this matter in future stakeholder comments.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
In 23.7.1, it states “A Wheeling Through Priority Reseller will not resell a Wheeling Through priority to enable avoidance of the firm power supply contract requirement of Section 23.2.1”. The CAISO should examine how this will be assessed, when this will be assessed, and what actions are to be taken should a violation be identified.
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
Section, 26.1 and 26.1.4 have not been completed by the CAISO and it should be urgently completed for stakeholders to provide adequate feedback.
PG&E continues to recommend that the CAISO provide language that would allow for future updates to the rates and charges to occur, should the CAISO decide to create time-differentiated pricing in future there should be language where those changes could be included in the tariff.
The following sentence from section 26.1.4.5 should be modified “Scheduling Coordinators for customers with a monthly or daily Wheeling Through priority will pay the applicable Wheeling Access Charge based on the MW amount and total hours of the priority for the applicable period.” It should be updated to “Scheduling Coordinators for customers with a monthly or daily Wheeling Through priority will pay the applicable Wheeling Access Charge(s), in accordance with its the structure identified in the BPM, based on the MW amount and hours of the priority for the applicable periods.”
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
To avoid discrimination against CAISO LSEs, a third constraint should be explicitly included in Section 34.1.12.3. The following sentence should be modified:
“The ATC the CAISO awards to Priority Wheeling Through transactions in the post-HASP process cannot exceed the Priority Wheeling Through quantity the CAISO calculates in this pro rata allocation, provided that CAISO operators (1) will review the application of pro rata curtailments of Priority Wheeling Through transactions and in their discretion approve or disapprove such curtailments after considering the reliability impacts and (2) consistent with good utility practice should use reasonable efforts not to curtail Priority Wheeling Through transactions without also having to shed CAISO load proportionally.”
To the following:
“The ATC the CAISO awards to Priority Wheeling Through transactions in the post-HASP process cannot exceed the Priority Wheeling Through quantity the CAISO calculates in this pro rata allocation, provided that CAISO operators (1) will review the application of pro rata curtailments of Priority Wheeling Through transactions and in their discretion approve or disapprove such curtailments after considering the reliability impacts, (2) consistent with good utility practice should use reasonable efforts not to curtail Priority Wheeling Through transactions without also having to shed CAISO load proportionally and, (3) consistent with good utility practice should use reasonable efforts to not shed CAISO load without also having to curtail Priority Wheeling Through transactions.”
10.
Provide your organization’s comments on the draft changes made to Appendix A:
No comment currently, PG&E reserves the right to comment on this matter in future stakeholder comments.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
In section L.1.3.3.1 the draft tariff reads “[…] comparing the load forecast for the applicable future period to the forecasts used with the set of CAISO RA requirements applicable to that period for the previous two (2) years […].” It is not stated where the load forecast will be created for doing the comparison. The CAISO should be clear on what frequency the load forecast will be updated and what entity will be providing that load forecast.
The examples used in L.1.3.3.3 are helpful, though presenting them in a similar format to the ATC Algorithm used in L.2.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
The following sentence should be modified:
“The CAISO may establish TRM in all applicable horizons, including prior to Market Close of the DAM and RTM.”
To:
“The CAISO shall establish TRMs in all applicable horizons, including prior to Market Close of the DAM and RTM.”
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
The following sentences should be modified:
“The CAISO does not use CBMs. The CBM value is set at zero.”
To:
“The CBM value is set to the value in the BPM.”
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
No comment currently, PG&E reserves the right to comment on this matter in future stakeholder comments.
Powerex
Submitted 05/10/2023, 03:21 pm
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
Powerex submits the following comments on the CAISO’s March 27, 2023, Transmission Service and Market Scheduling Priorities Phase 2 Draft Tariff Language (“Draft Tariff”). Powerex’s prior comments explain its view that the CAISO’s policy in this initiative is contrary to open access principles and operates as a barrier to competitive wholesale markets.[1] Powerex’s present comments focus solely on potential gaps between the Final Proposal and the Draft Tariff.
The Draft Tariff contains provisions governing the submission and processing of requests for Wheeling Through priority on a monthly (Section 23.4) and a daily (Section 23.5) basis.[2] These provisions appear to apply to requests for Wheeling Through priority supported by an allocation by CAISO of ATC.[3]
The Draft Tariff does not appear to address certain elements of the Final Proposal that were reviewed by and approved at the February 1, 2023, Joint Session of the CAISO Board of Governors and the WEIM Governing Body. In particular, to address concerns that ATC to support Wheeling Through priority is likely to be very limited or completely unavailable during certain summer months, the Final Proposal explains that entities will also have:
additional options to establishing priority across the ISO system, whether it is acquiring ATC through the ISO processes or working with parties holding existing transmission contracts to establish wheeling through priority across the system.[4]
The Final Proposal further describes in detail two mechanisms that will be available for market participants to use existing transmission contracts to establish Wheeling Through priority:
- “…contract with holders of legacy transmission contracts to support wheel through transactions across the ISO system given there is 1200 MW of capacity tied up under legacy agreements that must be respected.”[5]
- “… instances where legacy transmission contract holders release some of their rights to the market in return for CRRs, and this is done generally on a quarterly basis. This can create additional ATC typically 3-4 months out[.]”[6]
Powerex requests that the CAISO include the provisions for supporting Wheeling Through priority with existing transmission contracts in a revised version of the Draft Tariff.
[1] Powerex’s comments on the Draft Final Proposal are available here.
[2] Provisions for obtaining priority Wheeling Through priority on a long-term basis (Section 23.6) appear to be contemplated but have not yet been proposed by CAISO.
[3] See, e.g., Section 23.4 (“Scheduling Coordinators can request a monthly Wheeling Through priority for any month(s) ATC is calculated and available[.]”; “The CAISO will award ATC to support Priority Wheeling Through requests…”; “…priority requests … will be awarded ATC…”). Similar language appears in Section 23.5 for daily requests.
[4] Final Proposal at 26, emphasis added.
[5] Final Proposal at 57, emphasis added.
[6] Id., emphasis added.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
See comments above.
Powerex’s comments are also available at CAISO Transmission Service and Market Scheduling Priorities Draft Tariff Comments.pdf (powerex.com)
Salt River Project
Submitted 05/10/2023, 04:54 pm
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to comment on draft tariff language for the Transmission Service and Market Scheduling Priorities (TSMSP) Phase 2. The draft tariff language contains elements that may not be supportive of an equitable and workable framework for establishing market scheduling priority for wheeling through the CAISO system. SRP requests and encourages the CAISO to provide clarification and address concerns noted in the following comments.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
SRP encourages the CAISO to consider Nevada Energy’s (NVE) comment to specify graduated levels of curtailment and recongize that Priority Wheeling Through transactions have a priority equal to CAISO Load Serving Entities load.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
No comment at this time.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
SRP is concerned the tariff may provide CAISO Load Serving Entities an unfair advantage over non-CAISO Load Serving Entities with the 13-month limitation for ATC posting. While entities compete for ATC using the 13-month bidding window, this appears to provide only CAISO Load Serving Entities the ability to procure incremental capacity by providing updated import contracts in advance of calculating the monthly ATC. This will allow CAISO native load to be updated and the remaining ATC for non-CAISO entities that must bid on priority wheel through would be reduced. Additionally, there appears to be flexibility built into the Transmission Reliability Margin (TRM) that enables CAISO Load Serving Entities to adjust their capacity need by simply updating their TRM when entering a long-term contract. SRP recommends the CAISO regularly demonstrates to stakeholders through reporting that the tariff does not discourage competition and disadvantage non-CAISO Load Serving Entities.
SRP also requests that the CAISO exclude replacement capacity contracts for resource adequacy capacity from the ETC component of the ATC calculation. By allowing replacement capacity contracts, CAISO Load Serving Entities may have the ability to double count transmission needs through securing ETC for resource adequacy and non-resource adequacy imports. CAISO Load Serving Entities may also be using the capacity procurement mechanism to secure additional capacity for load uncertainty.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
SRP encourages the CAISO to clarify how the proposed process for obtaining a monthly wheeling through priority is an enhancement or equal to the North American Energy Standards Board (NAESB) standards as well as how the process will provide equitable treatment among participants. The NAESB standards have established consistent processing of requests and/or reservations when the transmission system is oversubscribed and there is a competing request, which have been accepted by the industry.
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
No comment at this time.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
No comment at this time.
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
No comment at this time.
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
SRP requests the following redline edit to section 34.12.3: CAISO operators will consider overall system conditions and the reasons for the potential need for curtailment, including whether actual load is at risk of curtailment excluding load conformance, prior to issuing curtailments. CAISO operators will ensure the capacity procurement mechanism and load biasing are not utilized as a contribution to curtailments.
SRP is concerned that the CAISO operators’ consideration of system conditions enables use of the capacity procurement mechanism and load biasing. The use of the capacity procurement mechanism provides the CAISO the ability to engage in backstop procurement if ATC is not available. There is potential for the CAISO to curtail priority Wheel Throughs at the discretion of the CAISO operators, based on the use of load biasing without conducting pro-rata curtailments to CAISO load. The load biasing may also provide additional imports into the CAISO. SRP requests a physical limitation under transmission be required to leverage the capacity procurement mechanism and load biasing and not intentional actions of the CAISO's operations. Further, SRP encourages the CAISO to provide transparent reporting to stakeholders in the event of curtailments.
10.
Provide your organization’s comments on the draft changes made to Appendix A:
No comment at this time.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
No comment at this time.
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
SRP encourages the CAISO to clarify how High-Priority Wheel Throughs are sufficient to meet the Western Resource Adequacy Program (WRAP) forward showing, which requires firm transmission. SRP encourages the CAISO to expand the scope of the upcoming EDAM tariff workshops to address how the High-Priority Wheel Throughs are consistent with the WRAP requirements.
Six Cities
Submitted 05/10/2023, 03:05 pm
Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
1.
Please provide a summary of your organization’s comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
The Six Cities appreciate the opportunity to provide comments on the draft tariff language for the Transmission Service and Market Scheduling Priorities Phase 2 initiative. Most of the Cities’ comments, questions, and suggested revisions are shown in redline format in the attached mark-up of the draft tariff language, with comments and questions included in the reviewing panel. The Cities’ suggested revisions to text are highlighted in yellow.
2.
Provide your organization’s comments on section 23.1 Categories of Transmission Capacity:
See the attached redline.
3.
Provide your organization’s comments on section 23.2 Accessing Available Transfer Capability, and all related subsections:
See the attached redline.
4.
Provide your organization’s comments on section 23.3 Miscellaneous ATC Requirements, and all related subsections:
See the attached redline.
5.
Provide your organization’s comments on section 23.4 Obtaining a Monthly Wheeling Through Priority:
See the attached redline.
6.
Provide your organization’s comments on section 23.5 Obtaining a Daily Wheeling Through Priority:
See the attached redline.
7.
Provide your organization’s comments on section 23.7 Sale or Assignment of a Wheeling Through Priority, and all related subsections:
See the attached redline.
8.
Provide your organization’s comments on section 26.1.4.5 Priority Wheeling Throughs:
See the attached redline.
9.
Provide your organization’s comments on section 34.12.3 Post-HASP Process:
See the attached redline.
10.
Provide your organization’s comments on the draft changes made to Appendix A:
Consistent with their comments on Section 23.5, the Six Cities recommend adding a definition of “LSE Import Priority” to Appendix A.
11.
Provide your organization’s comments on the draft changes made to Appendix L:
A) Please provide your comments on the draft changes made to Appendix L, Sections L.1 through L.1.3.3.3.3.
B) Please provide your comments on the draft changes made to Appendix L, Section L.1.5.
C) Please provide your organization’s comments on all other draft changes to Appendix L (Sections L. 1.1.6 – L.4.4.
See the attached redline.
12.
Provide any additional comments on the Transmission Service and Market Scheduling Priorities Phase 2 draft tariff language and April 14, 2023 stakeholder call discussion:
The draft tariff language does not address the relative priority for an export from a resource located within the CAISO BAA to an external BAA versus the export leg of a Priority Wheeling Through. Is the priority for exports addressed elsewhere in the tariff, or is this a gap in the priorities framework?
