Comments on Flexible Ramping Product Refinements - Draft Tariff Language

Flexible ramping product refinements

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Comment period
Aug 12, 01:30 pm - Aug 25, 05:00 pm
Submitting organizations
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Six Cities
Submitted 08/25/2020, 03:07 pm

Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California

Contact

Bonnie Blair

bblair@thompsoncoburn.com

202-585-6905

1. Provide summary of your organization’s comments on the draft tariff language (optional):

No summary.

3. Provide your organization’s comments on section 4.13.3 - Identification of Reliability Demand Response Resources (RDRRs) and Proxy Demand Resources (PDRs)

No comment.

4. Provide your organization’s comments on section 11.25.1 - Settlement of Forecasted Movement

See below.

5. Provide your organization’s comments on section 11.25.1.1 - Generally

 See edits included in the attached mark-up.  In the last line, the revised term “sufficiency” included in the mark-up is consistent with other tariff provisions (e.g., Section 29.34(m)).

 

6. Provide your organization’s comments on section 11.25.1.2 - Fifteen-Minute Market (FMM)

No comment.

7. Provide your organization’s comments on section 11.25.1.3 - Real-Time Dispatch (RTD)

No comment.

8. Provide your organization’s comments on section 11.25.1.4 - Allocation of Residual Forecasted Movement Settlements

No comment.

9. Provide your organization’s comments on section 11.25.2.1 - Payment to Resources

No comment.

10. Provide your organization’s comments on section 11.25.2.2.1 - Settlement Process
(b) Daily. The CAISO will initially – (c) Monthly. The CAISO will resettle the costs of the Uncertainty Awards by –

 See edits included in the attached mark-up.  In the last line of sub-part (a), the revised term “sufficiency” included in the mark-up is consistent with other tariff provisions (e.g., Section 29.34(m)).

See also suggested edits to Section 11.25.2.2.2 in the attached mark-up.

 

11. Provide your organization’s comments on section 11.25.3 - Rescission

 Although the captions for sub-sections 11.25.3.1 and 11.25.3.2 are different, the language of the two sub-sections is exactly the same.  Why?

12. Provide your organization’s comments on section 11.25.3.1 - Amount of Rescission

See No. 11 above.

13. Provide your organization’s comments on section 11.25.3.2 - Order of Rescission

See No. 11 above.

14. Provide your organization’s comments on section 44 - Flexible Ramping Product

See the edit to sub-section 44.2.1.2 in the attached mark-up.

15. Provide your organization’s comments on section 44.2.1.1 - Generally

No comment.

16. Provide your organization’s comments on section 44.2.1.2 - Nodal Procurement

See edit included in the attached mark-up.

17. Provide your organization's comments on section 44.2.4.3 - Nodal Procurement

No comment.

18. Provide your organization's comments on Appendix A - Definitions

No comment.

19. Provide your organization's comments on Appendix C - Locational Marginal Price
D. Marginal Congestion Component Calculations (Day-Ahead and Real-Time)

See edits included in the attached mark-up for Sub-part C of Appendix C.

 No comment on Sub-part D of Appendix C.

 

20. Provide your organization’s comments on any other section of the tariff you believe requires modification in light of this initiative’s proposed changes.

No additional comments.

22. If you wish to provide comments in redline form in addition to comments submitted in the commenting tool, please update the word document with your redlines and uploadin the "attachment" field below.

 See edits included in the attached mark-up.  Language to be stricken is identified by strike-through font.  Additions are identified by underlined font.  All suggested revisions to the CAISO’s draft tariff language are highlighted in yellow.

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