Comments on Submit EDAM BRS v1.6 Comments

ISO response

Thank you for your questions. Please find the answers below. Please feel free to submit additional questions via the commenting tool.

ISO response

1. EDAM-BRQ-07100: What do ITIEs stand for?
   • Answer: ITIE stands for Import Intertie and represents the resource model for interties into the CAISO.
2. EDAM-BRQ-07105 and EDAM-BRQ-07113: Can CAISO please help to explain how practical it is for the SCs to both submit and obtain third-party approval by 8:00 am for DA as mentioned in the above BRQs? Can CAISO please elaborate more about the timing aspect for RA obligation reassignments in the 02/11 EDAM Interties Training?
   • Answer: It is recommended that the reassignments be submitted with enough lead-time to provide 3rd-party SCs adequate time to approve. This approach and approval timeline are similar to the current substitution submission, review, and approval timelines.
3. EDAM-BRQ-07115 and EDAM-BRQ-07116: For how many years does the ISO intend to store and report data for CPUC /market monitor purposes?
   • Answer: The market monitor (DMM) has access to our data directly, so they will review this data as part of their normal process. The CPUC receives RA data via a subpoena regularly; the CAISO will report data to the CPUC as long as it is requested in the subpoena.
4. EDAM-BRQ-07125: Operation-based question - Can CAISO clarify if an RA obligation is only partially reassigned because some resources are EDAM eligible and others are not, how are the remaining, non-reassigned MWs treated? Are those no EDAM MWs subject to RAAIM penalties, even if reassignment wasn’t possible?
   • Answer: The RA source may be partially an EDAM BAA supply resource and partially an external import. The SC must reassign the first part to the EDAM resource and bid the second part at the System Resource; both parts are subject to RAAIM penalties.
5. EDAM-BRQ-07125: More of a policy-based question: How does the market distinguish between system-level MWs that should have been reassigned but were not, versus MWs that remain on system resources because reassignment wasn’t possible? In cases of partial reassignment, what charges or penalties apply to the remaining system-level MWs?
   • Answer: The market distinguishes the partial RA sources from the RA reassignment specification; please see the answer to question #4 above.
6. EDAM-BRQ-07125: Can CAISO please cover this topic in the 02/11 CAISO training on EDAM interties.
   • Answer: The main topics covered during the 2/11 Intertie Scheduling Readiness training are the following:
     1. Scheduling at non-CAISO EDAM BAA Interties
     2. Scheduling at CAISO BAA Interties with non-Edam BAAs
     3. Scheduling at CAISO BAA Interties with EDAM BAA
     4. Scheduling RA Imports at CAISO BAA Interties
     5. Scheduling Exports from the CAISO BAA
   • Under agenda item #4, the training covers the requirements for Reassignment of an RA Obligation in Real Time, but does not address the details about Partial Reassignment and the treatment of remaining non-reassigned resources.

ISO response

1. EDAM-BRQ-11295 – EDAM-IST-BRQ-11530: The SBIR requirements are scheduled to go live on 08/01/26. Could CAISO please clarify under which EDAM scope this SIBR change falls?
   • Answer: EDAM-BRQ-11295, 11295a, and 11295b are for EDAM Entities to access RSE and Intertie bids for their BAA. EDAM-IST-BRQ-11400 through EDMA-IST-BRQ-11530 fall under the Inter-SC Trade scope. Delivery for these requirements remains on track for August, 2026.
2. EDAM-BRQ-HASP-16187: Do the new HASP flag rules apply only within CAISO or across all EDAM BAAs?
   • The HASP flag rules apply to each resource type listed in the table provided in the requirement. For CAISO internal resources, the participation flag is set to yes for DAM, HASP, and RTM, while the various resource models in the EDAM and EIM BAAs have different Y/N combinations for the HASP participation flag.