2.
Please provide any questions or comments your organization may have regarding section 5 of the EDAM BRS.
When providing input in the text box below, please specify the BRQ(s) to which your comment or question refers.
Please note that there are currently two companion initiatives for EDAM that will be implemented at the same time: 1) EDAM Implementation, which addresses the entire market framework for the EDAM footprint, and 2) EDAM ISO BAA Participations Rules, which applies specific operational and settlement participation rules to the EDAM market for the ISO BAA (‘CISO’). This document pertains to the former.
With Version 1.5, CAISO has removed Inter-SC Trade (IST) BRQs in Sections 5.1, 5.6, and 5.15. Based on CAISO’s previous plans, UAMPS expected to be able to use IST functionality in EDAM to settle efficiently with counterparties when transacting capacity shares of resources and associated energy to meet RSE requirements and in general to gain economic efficiencies and take advantage of hedging opportunities. UAMPS has already begun building implementation and go-live processes around the IST functionality and finds this late change to the EDAM implementation scope challenging as the absence of IST functionality will most likely increase costs for UAMPS and degrade its market benefits. UAMPS expects to have many bilateral transactions each day, especially during the first few years of EDAM operations when market liquidity internal to EDAM will be limited. Additionally, UAMPS has scenarios where it holds longer term PPAs, but will not be the SC in EDAM for the generation. In these scenarios, without ISTs, UAMPS would have to figure out a way to contract individually with the counterparties rather than through a defined market settlement. UAMPS expects it will take significant contract work to come to an agreement with each counterparty in how the market settlements would impact existing and future bilateral transactions. Further, the individual solutions would be prone to calculation error. Rather than have every SC in EDAM going through this same problem, it would make much more sense to have it all settled through the market using ISTs as previously proposed.
UAMPS is requesting more information on when the CAISO expects to be able to implement ISTs for EDAM. UAMPS sees this as critical EDAM functionality and requests the CAISO keep stakeholders, its Board, and the WEM Governing Body informed going forward on the implementation timing and any hurdles or resource limitations that are preventing its deployment prior to go-live.
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5.7.1 (EDAM-BRQ-12030) - Report DA RSE requirement movement between EDAM BAAs; and 5.16.1 - (EDAM-BRQ-20082b) - New Aggregated RSE requirement Transfer between EDAM BAAs: UAMPS understood that EDAM resources could provide RSE-eligible capacity to other BAAs by establishing the transfer system resource prior to the binding DA run and supports this functionality in EDAM. However, UAMPS is concerned that moving the load-based RSE requirement between BAAs has the potential for unintended consequences in how it may influence DAM and RTM bidding requirements and behavior. UAMPS would prefer the CAISO enable resource transfers rather than load-requirements transfers.
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5.7.1 (EDAM-BRQ-12050) - Activate load modification by Demand Response in RSE: UAMPS requests the CAISO clarify for non-CAISO EDAM BAAs that there is an expectation that the EDAM Entity will develop Business Practices and processes to enable the following demand-side resource functionality included in this BRQ specifically for third-party Load SCs in their EDAM area prior to EDAM go-live - "For demand response are NOT modeled as DAM supply resource (PDR,DDR) in the market, allow EDAM entity to submit the load adjustment (through ALFS, same as in WEIM, subject to attestation)". UAMPS has had encouraging dialogue with PacifiCorp but wishes to ensure this critical functionality is available and supported such that UAMPS' RSE requirement is not overstated.
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Section 5.8 (EDAM-BRQ-13052/54) - Disruption of EDAM BAA, Transitionary Pricing: UAMPS requests the CAISO provide information to EDAM stakeholders regarding the impact of the transitionary pricing market functionality on third-party LSEs within an EDAM Entity BAA, explain its impact on self-scheduled intertie transactions, clarify whether it is applicable only to the non-CAISO EDAM BAAs, and explain any impacts to the integration of the WEIM-only footprint with the EDAM+WEIM footprint in RT following a PBC relaxation and the enaction of transitionary pricing. UAMPS notes that the DAM settlements are significantly more impactful than WEIM settlements and therefore more care should be taken to inform the market of out-of-market adjustments that will impact participant positions.
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Section 5.8 - (EDAM-BRQ-16140) - WEIM ABC functionality shall NOT apply to EDAM BAA: UAMPS understands that the EDAM model requires all resources to be dispatched and settled through the market - i.e.. However, EDAM is also unique in that it does not have a full must-offer obligation or coordinated RA program, and does not co-optimize AS or reserve sharing. UAMPS therefore questions whether some alternative form of the WEIM ABC functionality is needed for EDAM that would allow resources not on forced outage to mark themselves as available for emergency dispatch in coordination with the EDAM Entity but not available in the standard market optimization. This functionality would be similar to CAISO's Conditionally Available Resource or Use-Limited Resource model but would recognize the voluntary nature of EDAM and the lack of must-offer obligation, and therefore would provide more freedom to asset owners to determine how their resources are dispatched in the market in cases where resource limitations may not be able to be appropriately modeled in normal dispatch. SPP and MISO have similar functionality tied to unit offer commitment status (e.g., market-available vs. reliability-only) and UAMPS believes this functionality would benefit LSEs and asset owners in the non-CAISO BAAs.
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Section 5.9 (?) - EDAM resource requirements for providing RCU/D: UAMPS was recently made aware that the CAISO intends to limit RCU/D awards within non-CAISO EDAM BAAs to resources that are 5-min dispatchable, while maintaining the ability for resources within the CAISO EDAM BAA or those participating in the CAISO's intertie market to submit RCU/D bids from resources that are 15-min or hourly dispatchable resources. UAMPS requests the CAISO clarify whether this is in fact the case, and if so, to identify where in the Tariff the CAISO is deriving the authority to block non-CAISO EDAM BAA resources from providing RCU/D capacity to the market and where this aspect of market operations is covered in the BRS/BRQ.
ISO response
Response to Question 1 - Inter-SC Trade Functionality: Stakeholders previously agreed to defer this functionality until after the May 1, 2026, EDAM go-live. The CAISO understands this concern, is evaluating this request, and will communicate directly with stakeholders on the implementation status to support Inter-SC trades in EDAM.
Response to Question 2 - Report DA-RSE Requirement Movement (5.7.1): The RSE requirements include demand, uncertainty, and ancillary services requirements. The RSE application does not employ a network model; thus, it does not optimize transfers; it simply uses an RSE-eligible transfer to transfer RSE requirements. Transferring resources instead would require a very complex mechanism to track these resource transfers and support partial resource transfers, since an EDAM BAA may have multiple RSE-eligible transfers to multiple EDAM BAAs. Furthermore, the RSE results would be inferior since the optimization of the portfolio of all resources in an EDAM BAA is more efficient in satisfying transferred RSE requirements, considering resource inter-temporal constraints. The CAISO requests that UAMPS provide a more detailed description of the potential for unintended consequences in bidding behavior that pose a concern.
Response to Question 3 - Activate load modification by Demand Response in RSE (5.7.1): EDAM Entities are responsible for developing internal processes to receive and aggregate non-market participating demand response schedules from third-party load SCs within the participating EDAM entity BAA footprint. The EDAM Entity is responsible for submitting the aggregated EDAM Entity BAA total demand response schedule using the automated load forecast adjustment service described in the BRS. The load forecast adjustment functionality already exists in WEIM using a less automated process, so the assumption is that EDAM Entity internal processes to receive and aggregate non-market participating demand response from third-party load SCs would already exist to some extent.
Regarding how EDAM BAA load, RSE requirements, and RSE surcharge failures are allocated to sub-BAA EDAM LSEs, the CAISO will facilitate further discussion to clarify these questions and evaluate any next steps.
Response to Question 4 - EDAM Disruption and Transitional Pricing: (5.8.1): Transitional pricing is only applicable to the transitional period of the first six months of joining EDAM. Transitional pricing is conditionally triggered when there is under-generation or over-generation in an EDAM BAA’s PBC; the Market will use the last economic bid for setting the price.
Response to Question 5 - WEIM ABC Functionality (5.11.1): EDAM does not support “conditionally scheduled” capacity from EDAM resources in an EDAM BAA for the purpose of solely meeting the requirements of that BAA. All EDAM resources are optimally scheduled in the EDAM Area to meet the EDAM Area requirements with optimally scheduled EDAM Transfers among them. Furthermore, ABC in the WEIM is employing the software functionality for regulation, whereas EDAM supports regulation self-provision for meeting RSE regulation requirements; hence, there is no spare capacity model for a feature like ABC in EDAM.
Response to Question 6 - EDAM Resource Requirements for Providing RCU/RCD (5.9.1): RCU/RCD is procured hourly in EDAM with a 60-minute ramp capability requirement, but it is dispatched in FMM on a 15-minute basis. Any physical resource in an EDAM BAA can be certified to provide RCU/RCD. These resources participate in EDAM by bidding at their physical location, not at an intertie (Tariff references: §33.31.2.4, §31.5). Intertie resources (System Resources or Tie-Gens) modeled at an EDAM external intertie sourced at a non-EIM BAA can be certified for RCU/RCD if they are 15-minute dispatchable in the FMM.
