Comments on Draft Tariff Language

1. Please provide your organization's comments on the Subscriber PTO Market Scheduling Option Draft Tariff Language

4.3A.7.2 - The main addition to this section is a very difficult sentence to parse.  My first suggestion is that it be broken up into two or more sentences for clarity. Second, the two main subjects of the sentence both seem to be refering to Non-Subscriber Usage Payments Amounts, each with its own commencement date.  

For a two-year period, Non-Subscriber Usage and Non-Subscriber Usage Payment Amounts will be calculated for import Schedules at a Scheduling Point on the Subscriber Participating TO’s transmission facilities, but will not be collected or allocated to the Subscriber Participating TO as provided for in CAISO Tariff, Appendix F, Section 15.1. The two-year period will commence upon the Commercial Operation Date of the last Generating Unit interconnected to the Subscriber Participating TO’s transmission facilities on which that last Generating Unit is entitled to schedule using Subscriber Rights

This exception will apply only to the first Subscriber Participating TO that turns over Operational Control of its transmission facilities and, during this entire period, the CAISO will publish annually the amount of import Schedules and the Non-Subscriber Usage Payment Amount that would have resulted absent this Section 4.3A7.2.

Section 4.3A.9 - again, why not break up into more sentences? 

Subscribers may release Subscriber Rights they hold for use by the CAISO in exchange for CRRs to effectuate a conversion, as provided below. If the Subscriber's request meets the criteria outlined in 4.31.9(a), the converted CRRs will be administered in accordance with Section 36 in the same manner as other CRRs.  Additional details about the associated timelines, procedures and characteristics of this conversion and the treatment of CRRs generally are set forth in the Business Practice Manuals.

1. Please provide your organization's comments on the Subscriber PTO Market Scheduling Option Draft Tariff Language

Pattern appreciates that the effort in policy found in the SPTO CRR Whitepaper Proposal and is reflected into the draft Tariff language. This is evident in sections 4.3A.7.3 and 4.3A.9.

In 4.3A.7.1 in the original tariff language it clearly stated how subscribers that self-schedule bids will not pay Access Charges. With the expanded ability through the Whitepaper proposal to facilitate subscribers hold CRRs, Pattern suggests that where ETC volumes are converted to CRRs, that those volumes also will not pay Access Charges in keeping with the intent of the SPTO model and following the 4.3A.7.3 Transmission Revenue Requirements. To accomplish this, adding into the sentence that Economic bids on volumes that CRRs are held on the transmission assets and Entitlements will not pay Access Charges for such use be included.

Pattern would like to avoid confusion around the execution of pausing Non-Subscriber Usage Payment amounts in 4.3A.7.2. SPTO is a framework for incorporating transmission assets into CAISO. As written there is a period between the Commercial Operation Date of the transmission facility and the Commercial Operation Date of the last Generating Unit in which NSUR could potentially be calculated and issued. A generating unit is broadly defined. As a result, to avoid that unintended outcome and align with the spirit of the CRR Whitepaper proposal, Pattern recommends a date certain for the termination of the NSUR collection exception period of two years which would roughly be Q3, 2028.