Comments on Issue Paper/Straw Proposal

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

APS is supportive of the creation of a sub-entity scheduling coordinator to be able to submit information on non-participating resources, loads, and interchange within an EIM Entity and appreciates the opportunity to submit comments on this stakeholder initiative. APS would like to request some further information pertaining to the scope of the initiative and what the eligibility criteria would be for sub-entities.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

APS would like to request more understanding of the network modeling expectations for sub-entities within the full network model and if it will be performed by the EIM entity or the sub-entity.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

No comments on this topic.

4. Provide your organization’s comments on the settlements proposal for this initiative.

Can CAISO expand or give example on the allocation of over/under scheduling allocations to sub-entities when an EIM Entity fails balancing test and exceeds the threshold? Will the sub-entity load get allocated charges for over/under scheduling purely based on their share of the metered demand within the entire EIM Entity, or will CAISO evaluate the sub-entities contribution to the over-under scheduling penalties by looking at their base schedules and metered demand separately from the EIM Entity?

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

 No comments on this topic.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

 APS would like to request additional design in the policy around how the energy transfers in and out of the sub-entity to the EIM Entity will be accounted for. One way since these are non-participating loads and generators could be to establish a TID with the sub-entity (TID-SE) at a physical location.

7. Provide your organization’s comments on the outage management proposal for this initiative.

No comments on this topic.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

APS would like to know if the EIM Entity will be a party to these pro forma agreements? On the stakeholder call it was discussed that any EIM Entity and sub-entity relationship would require approval by the EIM Entity. Is this approval best handled by including the EIM Entity on the pro forma agreements, or will the sub-entity and CAISO be the only parties to the pro forma agreements?

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

No comments on this topic.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

APS agrees with primary approval of the EIM Governing Body.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

The area in which we have most interest in is the eligibility requirements to be a sub-entity. Based on the stakeholder call the initial scope appears to be for load serving entities that are well-defined within an EIM entity BA. Well-defined meaning that their load can be easily bifurcated from that of the EIM Entity at a relatively high voltage level of the transmission system. Can CAISO provide more details surrounding load metering and how loads become eligible to be a sub-entity? APS assumes there would be a requirement for telemetry of the sub-entity load in Real-Time to be able to produce the ELAP for the sub-entity and based on CAISO Tariff Section 29.10, is this a correct assumption? Is there an expectation to update Section 29.10 during the draft tariff language phase of the initiative with more information regarding the metering requirements of sub-entity load?

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

The Bonneville Power Administration[1] takes no position on the CAISO’s proposal at this time.  The CAISO’s proposal is fairly high-level and lacks many details.  Bonneville’s comments below generally request certain clarifications from the CAISO at this initial stage of the initiative. 

[1] Bonneville is a federal power marketing administration within the U.S. Department of Energy that markets electric power from 31 federal hydroelectric projects and some non-federal projects in the Pacific Northwest with a nameplate capacity of 22,500 MW. Bonneville currently supplies 30 percent of the power consumed in the Northwest. Bonneville also operates 15,000 miles of high voltage transmission that interconnects most of the other transmission systems in the Northwest with Canada and California. Bonneville is obligated by statute to serve Northwest municipalities, public utility districts, cooperatives and then other regional entities prior to selling power out of the region.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

This aspect of the CAISO’s proposal needs a substantial amount of additional details before Bonneville can take a position on it.  At minimum, the CAISO should provide additional details regarding:

1. What is the definition and eligibility requirements of a sub-entity?  Will the definition and eligibility requirements be uniform across the EIM footprint, or will each EIM Entity have authority to determine its own definition and requirements?  On what grounds would an EIM Entity have to reject a sub-entity designation as suggested on the CAISO’s conference call?
2. How will resource sufficiency (RS) be determined, who is responsible for RS, and in what time horizon will RS be determined?  On the CAISO’s conference call, CAISO staff suggested that the EIM Entity would remain fully responsible for RS and there would be no changes to RS.  If so, the proposal should make that clear.
3. How will the CAISO determine load aggregation points (LAP) for sub-entities?  Bonneville suggests that there should be transparency and consistency regarding how the CAISO would determine the LAP on the sub-entity level.
4. How would the current EIM timelines work with a sub-entity involved?  Would the sub-entity need to submit a base schedule to the EIM Entity earlier than T-55? Is T-55 (or sometime before T-55) the financially binding timeline for a sub-entity?
5. The CAISO’s proposal states that the EIM Entity will have the ability to modify a sub-entity’s schedule for reliability purposes after T-55.  Who determines and bears the financial impacts if the EIM Entity alters a sub-entity schedule after T-55?

3. Provide your organization’s comments on the forecasting proposal for this initiative.

The CAISO’s proposal regarding sub-entity forecasting appears to be a reasonable approach so long as the sub-entity’s forecast(s) are timely submitted within market timelines and shared with the EIM Entity. 

4. Provide your organization’s comments on the settlements proposal for this initiative.

The CAISO’s proposed settlement structure for sub-entities generally appears to be a reasonable approach.  Bonneville does have a couple of clarification requests. 

1. If a BAA is balanced such that there are no over/under scheduling charges at the BAA-level but a sub-entity is not balanced, will the sub-BAA entity be subject to an over/under scheduling charge?  If so, who will perform the settlement of that charge—the CAISO or EIM Entity?
2. Today, the CAISO does not settle imbalance on points of intrachange (i.e., points of interconnection between two utilities within an EIM Entity’s BAA).  Under this proposal, will that practice change?  Specifically, will the CAISO calculate imbalance settlements at points of interconnection between the sub-entity and the EIM Entity? What about between two sub-entities within the same EIM Entity BAA?  Who would be responsible for designating an agreed upon intrachange point, including submittal of scheduled intrachange and metered actuals?  

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

The CAISO’s proposal to allow sub-entities to utilize the appropriate CAISO systems to submit base schedules, access or submit forecasts, and settlements appears to be a reasonable approach.  As discussed further in no. 7 below, Bonneville believes that EIM Entities with BAA-level reliability responsibilities should be coordinating and managing all outages within the BAA.  While a sub-entity may have access to the CAISO’s outage systems, the CAISO should not allow the sub-entity to take any action regarding outages that undermines an EIM Entity’s ability to meet its reliability requirements.

Additionally, Bonneville recommends that the CAISO provide much more detail in the next proposal on the types of data, fidelity, and frequency that sub-entities will be required to share with the CAISO and/or EIM Entity(ies).  The CAISO should also address how contingencies regarding erroneous or non-functioning data feeds will be addressed.    

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

The CAISO’s proposal to allow a sub-entity to submit intertie schedules as part of its initial T-75 base schedule is a reasonable approach.  The sub-entity will submit its base schedules to both the CAISO and EIM Entity.  As Bonneville understands it, the EIM Entity will be responsible for approving the sub-BAA entity’s base schedule prior to the T-55 deadline and can modify a sub-entity’s base schedule as necessary to maintain system reliability.

7. Provide your organization’s comments on the outage management proposal for this initiative.

Outage coordination and management within a BAA must be done through the EIM Entity, who maintains BAA-level reliability responsibility.  In other words, the CAISO should not allow a sub-entity to coordinate outages with the CAISO directly because it would likely undermine the EIM Entity’s ability to maintain BAA-level reliability.  Moreover, the proposal should clearly acknowledge an EIM Entity’s ability to deny outages when they conflict with already planned coordinated outages in the BAA.  Allowing EIM Entities to utilize the CAISO’s webOMS platform to coordinate outages is a reasonable approach.     

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

At a conceptual level, the CAISO’s proposal to utilize comparable template agreements for sub-BAA entities and associated scheduling coordinators as it does for EIM Entities and EIM Entity Scheduling Coordinators is a reasonable approach to create the appropriate contractual relationships, as well as the terms and conditions for sub-BAA entity market participation.  As this initiative proceeds forward, the CAISO should prepare template agreements for review so commenters can have something more concrete to comment on.  The template agreements should address the relationship and expectations between the sub-BAA entity and EIM Entity, as well as the relationship between the sub-BAA entity and the CAISO.  Ultimately, these agreements may end up being three-party agreements between the CAISIO, EIM Entity, and sub-entity.  

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Refer to response for question no. 5. 

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

Bonneville supports the EIM Governing Body having primary approval authority for this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Bonneville has a couple of other comments on this issue paper/straw proposal.  First, the CAISO should clearly articulate what the intended benefits of allowing sub-entities to schedule directly with the CAISO in the EIM are.  The proposal does not make clear what the intended benefits are.

Second, the CAISO should identify and work through specific scenarios where one or more sub-entity(ies) exist within an EIM Entity BAA in the revised proposal.  Based on the CAISO’s conference call, there could be a few scenarios to consider such as one sub-entity with loads and resources in the same BAA; multiple sub-entities with loads and resources in the same BAA; and a sub-entity with generation in one BAA and load in another BAA.  Bonneville’s BAA could potentially have multiple load serving entities that might want to participate as sub-entities.  Some more specific guidance from the CAISO on these scenarios would be particularly beneficial to Bonneville and other stakeholders.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

4. Provide your organization’s comments on the settlements proposal for this initiative.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

7. Provide your organization’s comments on the outage management proposal for this initiative.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

Deseret Power interprets this proposal as responsive to our long-standing requests for (i) additional market transparency for Load Serving Entities (“LSEs”) within an EIM Entity; and (ii) a pathway for all LSEs within the EIM footprint to settle energy imbalance charges directly with the Market Operator.

The aspects of the proposal which propose the creation of unique LAP pricing for each EIM sub-entity scheduling coordinator should be broken out from the rest of this initiative and considered independently or the entire initiative should be rejected.  The use of LAP pricing was introduced to protect LSEs on highly congested sections of the transmission system while still providing proper market signals and are necessary to prevent discrimination among prices charged to retail load because of historic transmission system design which never contemplated an LMP framework.  LSEs located on robust sections of the transmission system will always prefer abolishing the use of LAP pricing in favor of entity specific LMPs while LSEs on less robust portions of the transmission system, typically rural, will oppose the abandonment of LAP pricing.

In the absence of congestion products within the EIM, all LSEs within an EIM Entity should settle load imablances using the same LAP pricing, or a high bar (e.g., a make whole payment) should be set which demonstrates that the resulting LAP pricing would be non-discriminatory for all impacted LSEs within a given EIM Entity.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

Deseret opposes the proposal to assign each EIM sub-area scheduling coordinator its own load aggregation point (LAP) with a unique LAP price for settling load imbalances.  This portion of the proposal should be broken out as a separate initiative or the entire initiative should be rejected in order to preserve non-discriminatory pricing for all LSEs.  Allowing a single LSE to create its own LAP price will necessarily impact all other LSEs sharing a common LAP price.

If proposed in a separate initiative, Deseret would be open to the concept of a single LAP Price for all loads served by a single Transmission Provider within an EIM Entity.  Transmission Customers of a common Transmission Provider pay common transmissions rate which support the development of that Transmission Provider’s system.  If there are stronger and weaker segments of that system, all Transmission Customers should equally share in the resultant costs and benefits.  One possible solution would be to calculate an “exit fee” for a transmission customer that would like to pursue the use of a load-weighted LMP price for settling load imbalances for their load points.  The “exit fee” would have to be sufficiently high to compensate the remaining LSEs for expected congestion costs.

The argument that the use of an LAP price mutes market signals created by an LMP is a "strawman" argument.  The LMPs produced by the market model are still visible and available to the market.  The development of the LAP price is a post-process which occurs after the market model has run.  Entities looking to locate generation or transmission would be entitled to the benefit of those same LMPs.

No entity should be able to derive an economic advantage in the EIM by submitting and receiving data directly to the Market Operator rather than through a host EIM Entity.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

CAISO forecasting services for variable energy resources’ supply output should be available to Variable Energy Resources regardless of whether the resource is an EIM Participating Resource or the scheduling coordinator becomes an EIM sub-entity scheduling coordinator.  If the costs the CAISO is incurring for providing this forecast service is being recovered through a bundled Scheduling Coordinator fee, this service and the associated cost should be broken out and made available to any entity that operates a variable energy resource within the EIM footprint.

4. Provide your organization’s comments on the settlements proposal for this initiative.

Deseret is supportive of the increased transparency for settlements included in this initiative. This proposal also begins to provide a pathway for entities with loads and resources within the EIM which are not actively participating in the EIM to settle directly with the Market Operator using well defined settlement timelines, data exchange formats, and provides entities with fair, simultaneous access to market data.

We suggest that while some charges will continue to be financially settled between the EIM Entity and the Market Operator, all settlement data, including BCR charges, provided to the EIM Entity Scheduling Coordinator should also be available to any EIM sub-entity scheduling coordinator.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Deseret supports the proposed system access for EIM sub-entity scheduling coordinators.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

We strongly agree that the EIM Entity is responsible for ensuring balanced Base Schedules.  This also requires the EIM Entity to ensure all Base Schedules are feasible.

Deseret further proposes that the pass or fail -- binary results -- of the four Resource Sufficiency tests for each EIM Entity be made available to all LSEs with loads within the EIM footprint for all financially market runs.  These results are essential to LSEs’ ability to accurately monitor the efficiency of the market and the validity of market results.

Deseret does not oppose allowing the EIM Entity to retain responsibility for the scheduling of base ETSRs and associated ETSR EIM energy transfer system resources.

7. Provide your organization’s comments on the outage management proposal for this initiative.

We are supportive of allowing EIM sub-entity scheduling coordinators to provide Outage information via webOMS so long as the outage information is considered preliminary and subject to the approval of all applicable reliability entities including the EIM Entity. 

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

Deseret supports the development of new pro forma agreements. These agreements should be flexible enough to allow an entity to become an EIM sub-entity scheduling coordinator while still retaining the EIM Entity Scheduling Coordinator as its Scheduling Coordinator.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Deseret supports the coordination of outages within webOMS.  This would ensure that the market is provided the best available information on outages in a timely manner via a transparent process.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

Deseret support the proposed classification.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Regardless of the outcome of this initiative, for the sake of market transparency, many of the features identified in this proposal should be available to Non-participating generator and loads within an EIM Entity including a pathway for LSEs to settle directly with the Market Operator.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

Idaho Power Company (Idaho Power) is not opposed to the proposal but has questions and caveats.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

Idaho Power is not opposed to the sub-entity scheduling coordinator role in concept, but has several questions.  First, CAISO should provide more details on the eligibility criteria for entities to become  sub-entity scheduling coordinators.  Idaho Power understands that load-serving entities are eligible.  CAISO should clarify whether stand-alone non-participating resources that are not associated with their own load are also eligible.  If so, CAISO should also clarify how the proposal would apply to such generators, and should provide additional details on any other eligibility criteria. 

CAISO should provide additional information regarding which entity—the existing EIM entity, or the sub-entity scheduling coordinator—will be responsible for the Settlement-Quality Meter Data (SQMD) plan compliance and the attestation and affirmation processes.

Please also clarify whether the sub-entity scheduling coordinators will be subject to the Grid Management Charge or scheduling coordinator charges.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

Idaho Power has concerns with the proposal that a sub-entity scheduling coordinator may unilaterally choose whether to use its own VER or load forecast.  If the sub-entity scheduling coordinator’s forecast is significantly off, then the EIM entity may be left scrambling to adjust base schedules after T-55 to try to pass the resource sufficiency tests.  Idaho Power understands from the proposal that CAISO intends to allow EIM entities to adjust the sub-entity scheduling coordinator’s base schedules in this manner.  CAISO should document and memorialize this ability of EIM entities to adjust the sub-entity base schedules if necessary to pass the tests, with or without the approval of the sub-entity scheduling coordinator. 

Further, even with this ability, EIM entities may need to take action to try to pass the tests in a relatively short amount of time if the forecasts are materially off.  Idaho Power is concerned that this potential need for additional action by the EIM entity to balance or pass the tests after T-55 could create reliability concerns, additional risk of not passing the test, or additional risk of an entity or sub-entity leaning on others.  CAISO should clarify how these risks can be mitigated.  The sub-entity scheduling coordinator ultimately should bear the risk of inaccurate forecasting.  If these risks remain, Idaho Power believes it may be more appropriate for EIM entities to determine whether sub-entity scheduling coordinators may choose whether to use their own VER and load forecasts, or whether the sub-entity scheduling coordinators use the same forecast source as the EIM entity.  

4. Provide your organization’s comments on the settlements proposal for this initiative.

CAISO should provide additional information, including details and examples, regarding the settlement impacts of the proposal.  In particular, please provide additional detail and specific  examples regarding over- and under-scheduling charges, including if the sub-entity scheduling coordinator submits its own schedule or not, and if the balancing test is passed or not, and how those various scenarios would impact charge codes 6045 and 6046. 

From the stakeholder call, Idaho Power understands that CAISO is proposing to continue to allocate neutrality charge codes to EIM entities, and not sub-allocate it to the sub-entity scheduling coordinators.  Please provide rationale and support for this decision to keep neutrality at the BAA level and reasoning why sub-allocating these charge codes is not appropriate for the sub-entity. 

In addition, since the Real Time Imbalance Energy Offset (RTIEO) charge codes include Instructed Imbalance Energy (IIE) and Uninstructed Imbalance Energy (UIE), will the BAA neutrality calculation continue to include the sub-entity’s IIE and UIE amounts in the calculation? If not, how will these calculations be affected with this proposal? Please provide an example of how the neutrality offsets will be calculated under this proposal.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

No comments.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

Sub-entity scheduling coordinators will need to comply with the base schedule submission timelines and other requirements in the applicable EIM entity’s OATT.  Further, CAISO has indicated that EIM entities will have the ability to adjust the sub-entity scheduling coordinators’ base schedules as necessary to pass the flexible ramping sufficiency test.  As mentioned above, CAISO should clarify and memorialize this ability of EIM entities to adjust sub-entity scheduling coordinators’ base schedules.

7. Provide your organization’s comments on the outage management proposal for this initiative.

No comments.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

No comments.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

 Idaho Power believes it is appropriate for the EIM Governing Body to have primary approval authority over this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Idaho Power requests that CAISO provide a matrix showing the various requirements and impacts of this proposal, by entity:  CAISO, EIM entity, and sub-entity scheduling coordinator. 

Similarly, EIM entities will need time to determine what tariff or systems changes might be needed and to make those changes.  The implementation schedule should allow time for those changes to be made.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

The proposed partial direct settlement with sub-entities for some, but not all, applicable EIM charge codes would likely necessitate LADWP OATT revisions and EESC settlement software enhancements. Therefore, LADWP suggests CAISO implement a uniform settlement approach to either settle only with the EESC or settle all charge codes with sub-entities, to avoid the need for additional EIM Entity OATT revisions, EESC settlement software changes, and additional data to perform sub-allocations to transmission customers and sub-entities.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

4. Provide your organization’s comments on the settlements proposal for this initiative.

The proposed partial direct settlement with sub-entities for some, but not all, applicable EIM charge codes would likely necessitate LADWP OATT revisions and EESC settlement software enhancements. Therefore, LADWP suggests CAISO implement a uniform settlement approach to either settle only with the EESC or settle all charge codes with sub-entities, to avoid the need for additional EIM Entity OATT revisions, EESC settlement software changes, and additional data to perform sub-allocations to transmission customers and sub-entities.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

7. Provide your organization’s comments on the outage management proposal for this initiative.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

PacifiCorp appreciates the opportunity to comment on the CAISO’s EIM Sub-Entity Scheduling Coordinator Role issue paper/straw proposal published November 5, 2020 (“Straw Proposal”).  PacifiCorp is supportive of the CAISO’s proposals, but believes that considerable clarification and additional details are needed for stakeholder discussion. PacifiCorp provides the following comments on the CAISO’s Straw Proposal.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

Please see PacifiCorp’s comments set forth below. 

3. Provide your organization’s comments on the forecasting proposal for this initiative.

The CAISO proposes that the EIM entity scheduling coordinator will “use these forecasts to create a forecast for the EIM entity control area.”  PacifiCorp requests clarification regarding how the EIM entity will obtain the EIM sub-entity’s load forecast in order to create the EIM entity control area forecast.

Currently, the CAISO’s load forecast for the EIM entity’s balancing area includes all sub-entity load information. PacifiCorp seeks to understand the CAISO’s statement that “the EIM entity scheduling coordinator will then use these forecasts to create a forecast for the EIM entity control area.” It seems those sub-entity load forecasts would already be included in the CAISO-created EIM entity area load forecast, regardless of whether the sub-entity submits its own load forecast or elects to have the CAISO create the sub-entity load forecast. The language in the Straw Proposal appears to suggest that the sub-entity load would be removed from the EIM entity load forecast and then the EIM entity would need to put it back in to create a forecast for the EIM entity control area.

In addition, PacifiCorp seeks clarification regarding whether it is absolutely necessary for the CAISO to obtain real-time telemetry of an EIM sub-entity’s load if the EIM sub-entity chooses to use its own demand forecast instead of the CAISO-created forecast. From a scheduling perspective, practices in place at the EIM sub-entity level today will continue to be able to support real-time operations without the need for real-time EIM sub-entity load telemetry. In such a scenario, might the CAISO be able to rely solely on the EIM sub-entity’s after-the-fact load (and other settlement quality meter) data for settlements and invoicing related purposes, thus removing the need for real-time telemetry of an EIM sub-entity’s load? If the CAISO requires the EIM sub-entity to telemeter its real-time load data, but the EIM sub-entity elects to use its own demand forecast, how would the CAISO use the real-time telemetered load data from the perspective of this proposal’s objectives?

4. Provide your organization’s comments on the settlements proposal for this initiative.

PacifiCorp requests clarification of the CAISO’s statement that each EIM sub-entity scheduling coordinator must submit meter data for its associated load serving entity “in the same manner” as the EIM entity scheduling coordinator. Further, PacifiCorp seeks additional information regarding what the CAISO intends to propose as metering (and telemetry) requirements for EIM sub-entities and who would be responsible for compliance with those metering requirements. PacifiCorp would be supportive of a proposal that maintains the submission of meter data by the EIM entity rather than the EIM sub-entity. PacifiCorp would also support a proposal that allows both the EIM sub-entity and the EIM entity to submit meter data, along with implementation of a process by which the CAISO would reconcile or validate those submissions to ensure accurate data is used for settlements.

PacifiCorp also seeks clarification of the CAISO’s paragraph on over-scheduling and under-scheduling.  PacifiCorp’s interpretation is that if the EIM entity fails the balancing test or passes the balancing test but the balancing area load deviation is greater than the subsequent 5% threshold, any over-scheduling and under-scheduling charges will be assessed at the EIM entity area level, as is done today. However, if the EIM entity passes the balancing test or the deviation is within the subsequent 5% threshold, the CAISO will allocate a ratio share of the over-scheduling and under-scheduling charges to the EIM sub-entity scheduling coordinator based on the deviation between metered demand within the sub-entity area and the EIM sub-entity’s submitted base schedules. PacifiCorp requests confirmation or correction of this understanding.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

PacifiCorp has no comments at this time. 

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

PacifiCorp requests that the CAISO provide additional information and details regarding how imports and exports solely between the EIM sub-entity and the EIM entity within the EIM entity balancing authority area (”Intrachange”) will be handled. Specifically, PacifiCorp seeks information regarding the potential need for new mirrors and how to account for Intrachange in the intertie schedules.

For example, if the EIM sub-entity creates an Intrachange schedule in order to balance its sub-area, PacifiCorp seeks to understand how this would be reflected in the hourly or real-time schedule submissions. In this case, the parent EIM entity does not submit any Intrachange schedules to the CAISO, however the EIM sub-entity may require this Intrachange schedule to ensure that the sub-area meets the hourly resource sufficiency test requirements. If this submission is made for the EIM sub-entity, the existing system would require significant changes from a BAA boundary perspective as this would not meet the parent EIM entity’s criteria for interchange.

7. Provide your organization’s comments on the outage management proposal for this initiative.

PacifiCorp has no comments at this time. 

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

PacifiCorp supports the CAISO’s proposal to develop new pro forma EIM sub-entity and EIM sub-entity scheduling coordinator agreements.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

This request is redundant – see request #5 above.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

PacifiCorp supports the CAISO’s proposal that the EIM Governing Body should have primary authority in the approval of the proposed changes in this initiative. 

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

PacifiCorp has no comments at this time. 

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

Platte River Power Authority (“Platte River”) appreciates the California Independent System Operator’s (“CAISO”) efforts to develop its November 5, 2020 Western EIM Sub-Entity Scheduling Coordinator Role Issue Paper/ Straw Proposal (the “Straw Proposal”) and generally supports the concepts in the Straw Proposal.

Platte River understands this initiative responds to the Energy Imbalance Market (“EIM”) implementation agreement between the CAISO and Public Service Colorado (“PSCo”), which was filed with FERC and became effective on July 29, 2020 (the “PSCo EIM Implementation Agreement”).[1]  The PSCo EIM Implementation Agreement includes a set of principles[2] recognized by the parties as essential to PSCo’s participation in the EIM. These principles govern PSCo’s transition to the EIM from the Joint Dispatch Agreement (“JDA”) among Platte River, Black Hills Colorado Electric, LLC, Colorado Springs Utilities, and PSCo. Because the transition to the EIM may require termination of the JDA, recognizing the JDA’s provisions as part of the EIM implementation is essential.[3]  As a JDA party, Platte River appreciates the opportunity to submit comments on CAISO’s Straw Proposal. 

Platte River’s comments focus on the need to (1) further detail how the high-level EIM sub-entity scheduling coordinator role will be implemented and operate within the CAISO EIM, including those for modifying base schedules, (2) provide details on which billing determinants will be available to EIM sub-entity scheduling coordinators, (3) explore the use of webOMS as a potential backup for outage communications, and (4) address the EIM sub-entity scheduling coordinators’ need to access the CAISO Automated Dispatch System (“ADS”).    

[1] See FERC Docket No. ER20-1937, and FERC approval letter and CAISO/PSCo Implementation Agreement.

[2] See PSCo EIM Implementation Agreement at Section 14.

[3] See PSCo EIM Implementation Agreement, Exhibit B.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

The Straw Proposal’s high-level description of the delegation of authority and responsibilities between the EIM entity scheduling coordinator and the EIM sub-entity scheduling coordinators appears to be in general alignment with the JDA structure. However, more detail is needed on (1) how JDA provisions will translate into EIM operating rules and protocols, (2) how this new role will be incorporated into current CAISO EIM processes, and (3) the roles and responsibilities of CAISO, the EIM entity scheduling coordinator, and the EIM sub-entity scheduling coordinator. Platte River requests additional specifics in the Straw Proposal to flesh out these details.

For example, the proposal states that any base schedule modifications by the EIM entity scheduling coordinator should be communicated to the EIM sub-entity scheduling coordinator. Is communication of base schedule changes a requirement? Will notification of base schedule modifications be communicated using CAISO’s base schedule aggregation portal (BSAP) or by some other method?  Platte River emphasizes the importance of (1) understanding the parameters that would govern an EIM entity scheduling coordinator’s ability to modify the base schedules of an EIM sub-entity scheduling coordinator, and (2) how EIM sub-entity scheduling coordinators will receive reasonable notice and maintain adequate visibility between T-55 and T-40 to appropriately respond to modifications of the base schedules by the EIM entity scheduling coordinator to minimize operational and economic impacts.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

Platte River Power Authority supports the forecasting concepts as described in the Straw Proposal.

4. Provide your organization’s comments on the settlements proposal for this initiative.

Platte River understands the CAISO EIM settlements process will create invoices at the EIM sub-entity scheduling coordinator level as well as the EIM entity scheduling coordinator level to settle EIM revenues and costs. To clarify expected impacts of the proposed initiative on the settlements process, Platte River requests a pro forma update to the Charge Code Matrix with the EIM sub-entity scheduling coordinator role added. Further, Platte River does not understand which billing determinants EIM sub-entity scheduling coordinators will have for non-resource specific EIM entity scheduling coordinator allocated revenues and costs. Platte River requests further details on which billing determinants will be available to EIM sub-entity scheduling coordinators to ensure sufficient data to validate settlements.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Platte River’s primary tool to communicate outage information will be Sunnet iTOA. However, Platte River would like to consider using webOMS as a backup option should Sunnet iTOA be unavailable. Is this a possibility? If so, what are the costs and processes to implement and maintain webOMS access for EIM sub-entity scheduling coordinators that are not currently members of RC West?

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

Platte River Power Authority supports the energy transfer concepts as described in the Straw Proposal.

7. Provide your organization’s comments on the outage management proposal for this initiative.

Please see Platte River’s response to question 5 above.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

Platte River looks forward to working with CAISO and other stakeholders on the tariff revisions and corresponding pro forma agreements needed to implement this initiative.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

[Please note that the sub-text for the prompt appears to duplicate the sub-text to comment prompt number 5. Platte River’s comments here respond to the language in bold regarding system access generally.]

The Straw Proposal does not discuss access to ADS. Sub-entity scheduling coordinators need access to ADS to respond to CAISO EIM dispatch instructions. How will CAISO provide ADS access to EIM sub-entity scheduling coordinators? Will the EIM entity scheduling coordinator also be able to view ADS instructions to EIM sub-entity scheduling coordinators?  If so, will the EIM entity scheduling coordinator have any power to accept or decline CAISO dispatch instructions on behalf of EIM sub-entity scheduling coordinators?

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

Platte River does not currently have any comments on this section.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Platte River commends CAISO’s continued commitment and current efforts to identify and implement targeted improvements to the CAISO’s EIM by leveraging the power of geographic diversity to better integrate renewables, enhancing reliability through increased operational visibility across electricity grids, and improving congestion management for transmission facilities across the western interconnection.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

In its EIM SESC Role Initiative, the CAISO should:

1. Remain as the primary authority and provide final approval for all market related changes including those of the EIM.

The CAISO currently has primary authority over all EIM activities, including market structure, market design, scheduling and settlements.  The costs for these activities are clearly defined and included in the CAISO’s grid management charge (GMC).[1]  Therefore,  to avoid duplication of its EIM functions and responsibilities with another entity and to promote EIM  administrative cost effectiveness for ratepayers, the CAISO should retain this primary authority and final approval for all EIM activities

1. Limit the EIM Governing Body’s role to arbitrate inter-EIM BAA settlement issues. 

The EIM Governing Body’s current role is to propose changes to the real-time market for EIM participants and to arbitrate inter-EIM BAA settlement issues.  The five members who serve on this EIM Governing Body do so on a voluntary basis, without any defined cost to ratepayers.[2]  Therefore, to avoid duplication of the CAISO’s functions and responsibilities for EIM activities and to mitigate incremental administrative costs for EIM activities, the EIM Governor Body’s functions should be limited to its current role as stipulated in its Charter such as the policy changes to EIM market rules and arbitration of inter-EIM BAA settlement issues. 

[1] CAISO Briefing on Draft 2021 Budget and Grid Management Charges, dated 11/16/2020.

[2] Charter for the EIM Governing Body, dated 3/27/2019.  

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

The EIM Governing Body’s role should be limited to arbitrating inter-EIM BAA settlement issues which is the same as the currently process for the real-time market.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

Cal Advocates has no response to this topic at this time.

4. Provide your organization’s comments on the settlements proposal for this initiative.

Cal Advocates has no response to this topic at this time.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Cal Advocates has no response to this topic at this time.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

Cal Advocates has no response to this topic at this time.

7. Provide your organization’s comments on the outage management proposal for this initiative.

Cal Advocates has no response to this topic at this time.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

Cal Advocates has no response to this topic at this time.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Cal Advocates has no response to this topic at this time.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

The CAISO should retain final authority over EIM activities and provides final approval for all market related changes, including those of the EIM, market design, scheduling and settlements. Therefore, to avoid duplication of its CAISO’s functions and responsibilities for EIM activities and to promote EIM administrative cost effectiveness for ratepayers, the CAISO should continue to have primary approval authority for this initiative to allow separate scheduling and settlement for entities within an EIM BAA.  The role of the EIM Governing Body should be limited to that of an arbitrator for EIM entities that submit disputes on inter-EIM BAA settlement issues.  

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Conclusion

To avoid duplication of its EIM functions and responsibilities with another entity and to promote EIM  administrative cost effectiveness for ratepayers, the CAISO should remain as the final approval authority for all SESC settlements under this initiative.  The role of the EIM Governing Body should be limited to arbitrating inter-EIM BAA settlement disputes.  

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

The Public Generating Pool (PGP[1]) appreciates the opportunity to comment on the Western EIM sub-entity scheduling coordinator role initiative dated November 5, 2020.  There are PGP members embedded within EIM BAAs that are interested in exploring whether or not the additional flexibility provided by the EIM sub-entity scheduling coordinator (ESCC) role could provide benefit.  However, there is a need for greater detail in this proposal before PGP can take a position on whether to support this initiative.

[1] PGP represents eleven consumer-owned utilities in Washington and Oregon that own almost 8,000 MW of generation, approximately 7,000 MW of which is hydro and over 97% of which is carbon free. Four of the PGP members operate their own balancing authority areas (BAAs), while the remaining members have service territories within the Bonneville Power Administration’s (BPA) BAA. As a group, PGP members also purchase over 45 percent of BPA’s preference power.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

PGP has a several questions on the relationship between the EIM Entity and the ESCC.

• This initiative proposes that each ESSC function as its own load serving entity (LSE).  Does CAISO intend to apply its own tariff language on the definition of LSEs to other entities outside of CAISO’s footprint, or can each EIM entity make their own determination of what constitutes an LSE for the purposes of this initiative? 
• Is the EIM entity expected to honor any requests from an LSE that would like to participate as an ESCC, or can the EIM Entity decline a request?
• Can an EIM entity compel an LSE to become an ESCC, or does the LSE have the discretion to determine whether or not to become an ESCC? 
• What implications might there by for an EIM entity that has multiple LSEs, some of which decide to participate, and others that choose not to? 
• Can CAISO provide additional clarity around which ESCC roles and responsibilities would be determined by the CAISO versus those determined by the EIM entity?
• Is the expectation that the each ESSC should have the same roles and responsibilities, or will each EIM Entity have the discretion to tailor roles and responsibilities to each ESSC?

PGP believes there should be more certainty in the language to address communication between the EIM Entity and the ESSC with respect to base schedule submissions. This initiative states that “Base schedules submitted by the sub-entity scheduling coordinator can be modified by the EIM entity scheduling coordinator; any modification should be communicated to the EIM sub-entity”.  While it is necessary for the EIM Entity to “maintain flexibility and control of the resources”, PGP believes that the language used in this section should change from “should be communicated” to “must be coordinated” in order to ensure that both the EIM Entity and the ESSC are consistently seeing the same data. 

3. Provide your organization’s comments on the forecasting proposal for this initiative.

The ability for each ESSC to control the forecasts used for loads and variable energy resources could be an attractive feature for LSEs considering becoming an ESSC.  However, there is no discussion about the treatment of non-conforming load that may reside in the ESSC’s footprint. Could CAISO please provide additional information about the treatment of non-conforming load? 

Also, this section proposes that the ESCC load forecast be used by the EIM Entity as input into the CAISO’s day ahead reliability assessment process. Could CAISO please provide additional information about the expectations of the EIM Entity in supplying a day-ahead load forecast and how that is similar or different than what occurs today? 

4. Provide your organization’s comments on the settlements proposal for this initiative.

CAISO proposes to retain the allocation of bid cost recovery charges (BCR) at the EIM Entity level in order to provide flexibility between the EIM Entity and the ESSC.  Can CAISO shed more light on the nature of this flexibility and why it important?  PGP would also like to know if there are any downsides if these BCR charges were allocated to the ESSC rather than the EIM Entity. 

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

What are the requirements (software, cyber, job functions/roles, etc…) that an ESSC must adhere to in order to access these systems?

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

No comments at this time

7. Provide your organization’s comments on the outage management proposal for this initiative.

EIM Entities have their own outage coordination procedures.  As written, this proposal appears to allow ESSC participants to submit outages directly to the CAISO rather than through their host EIM Entity.  While the proposal allows for EIM Entity review via the webOMS system, PGP believes that this likely falls short of processes established by the host EIM Entity to review-and-approve outages requests in order to meet NERC reliability requirements.  PGP would like CAISO to consider outage submission at the EIM Entity level rather than at the ESSC level to ensure that existing processes for reliable outage coordination are maintained.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

There is not enough information to comment on the nature of these new agreements at this time.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

Is this the same question as #5?

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

PGP concurs that the EIM Governing Body should have primary authority in the approval of the proposed changes

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

PGP believes that there is potential benefit for this proposal, but the creation of new business processes by the EIM Entity to manage this role must be as streamlined and as efficient as possible.  In addition, any new data exchanges must ensure that both the EIM Entity and the ESSC always have the most accurate information available.

There are a few topics not addressed in this proposal that should be discussed in the next draft proposal

• What is the role of the EIM Entity/ESSC in dispute resolution for settlements?
• Will this ESSC role be extended to EDAM?
• What specific charge codes will be settled with the ESSC?
• Is there any analysis that has been performed on whether more granular LAPs result in a more efficient market outcome?

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

?SCE supports some elements of the straw proposal and requests that the CAISO provides further elaboration on the settlement elements of the proposal. Although metering data will be provided by EIM entity scheduling coordinator and EIM sub-entity scheduling coordinator within the balancing authority areas where such relationships exist, what matters is how well those representations align with the network model being used to support the dispatch of resources within the market for the satisfaction of demand across the market footprint. 

Further, given that sub-allocation is subject to the EIM entity’s OATT, the incentives incorporated within that entity’s OATT should not be at odds with the incentives provided within the CAISO markets. Any failure of such alignment has the potential to produce unintended outcomes and consequences though with small magnitude should have minimal effect on the broader market. 

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

While the roles and responsibilities identified for the EIM sub-entity are reasonable, the real impact of the EIM sub-entity scheduling coordinator’s role resides in the granularity of the network and dispatch models used relative to the level at which the settlement of transactions occurs within the EIM balancing authority areas particularly where there is a transactional relationship between the EIM entity scheduling coordinator and the EIM sub-entity scheduling coordinator. SCE supports the proposed roles and responsibilities for the EIM sub-entity scheduling coordinator. 

3. Provide your organization’s comments on the forecasting proposal for this initiative.

SCE supports the proposal’s facility for accommodating forecasts from third parties and the CAISO’s offer of support to hybrid and co-located resources in satisfying their forecasting needs.

4. Provide your organization’s comments on the settlements proposal for this initiative.

SCE is unable to support this element of the proposal at this juncture. Further details are necessary on which charges will be settled at the balancing authority area level versus the sub-entity level thereby providing transparency of the likely cost shifts that underlie such settlement approaches. 

The CAISO’s willingness to leave sub-allocation arrangements to the terms and conditions within the OATT of respective EIM entities presents the opportunity for EIM entities to integrate sub-allocation arrangements in a non-uniform manner which will present market participants with differing incentives for market participation. 

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination. 

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

SCE supports retention of the scheduling of base ETSR and associated ETSR system resources as a role to be performed by the EIM scheduling coordinator rather than be distributed between the EIM entity SC and EIM sub-entity SC. While this arrangement preserves flexibility in scheduling arrangements for such transactions, the question that arises is whether EIM sub-entities can be out of BAA load-serving entities who engage in ETSR transactions. 

7. Provide your organization’s comments on the outage management proposal for this initiative.

SCE supports the proposed arrangements for outage management and the facility that webOMS provides in support of the arrangements. 

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

?SCE supports the CAISO’s proposal to introduce new pro forma agreements that will govern the activities of EIM sub-entity scheduling coordinators. Such agreements are intended to offer binding commitments for sub-entities interested in undertaking the role. 

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

SCE supports this proposal for system acess.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

SCE supports the classification of this initiative as the primary authority of the EIM Governing Body since this role will very likely be more prevalent within the EIM balancing authority areas than within the CAISO BAA. 

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

None.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

The Southwest Public Power Agency (SPPA) appreciates the opportunity to comment on the California ISO’s proposal to establish an EIM Entity Sub-Entity Scheduling Coordinator (SESC) Role.

SPPA is a joint action agency established under Arizona state law, comprising publicly owned, not-for-profit irrigation and electrical districts, municipal electric utilities and tribal utilities. SPPA Members include: Aguila Irrigation District, Ak-Chin Energy Services, Buckeye Water Conservation & Drainage District, City of Safford, Electrical District No. 2 of Pinal County, Electrical District No. 3 of Pinal County, Electrical District No. 4 of Pinal County, Electrical District No. 6 of Pinal County, Electrical District No. 7 of Maricopa County, Electrical District No. 8 of Maricopa County, Gila River Indian Community Utility Authority, Harquahala Valley Power District, Maricopa County Municipal Water Conservation District 1, McMullen Valley Water Conservation & Drainage District, Navajo Tribal Utility Authority, Ocotillo Water Conservation District, Roosevelt Irrigation District, Tonopah Irrigation District, Town of Thatcher, and Town of Wickenburg (the SPPA Members). Additionally, the City of Williams and Tohono O’odham Utility Authority are in the process of becoming members and will likely do so in 2021. 

SPPA was formed to give its members a mechanism to jointly manage and dispatch their power resources and pursue more affordable power supply opportunities for the customers they serve. SPPA manages a formal pool of many of its members’ power resources and facilitates the supply of additional energy needed to meet their customers’ loads. The SPPA Members collectively deliver electricity to approximately 880 MW of retail load over an area of 2,100 square miles, mostly in rural Arizona. Many of the SPPA Members are embedded in the service territory of Arizona Public Service Company (APS) and take network transmission service from APS, an EIM entity. SPPA also manages the loads of some members located within the service territories of Salt River Project (an EIM Entity) and Tucson Electric Power and Public Service Company of New Mexico (both of which have announced their intention of becoming EIM Entities). 

As an example of the issues SPPA faces, SPPA’s APS members are wholesale entities that interconnect with APS at distribution levels. These entities are intermixed with APS retail customers in rural areas, frequently on the same distribution circuits. SPPA’s APS members have metering comparable to that of APS’s intermingled retail customers. The extant metering satisfies the requirements of the transmission agreements between SPPA and APS, but it likely will not satisfy the metering and telemetry requirements of CAISO Tariff § 29.10, which applies to EIM Entities and is being proposed in this stakeholder proceeding to apply to SESCs. Due to the nature of the metering and the nature of the interconnections, APS allocates many charges—including EIM imbalance charges—to the interspersed retail and wholesale loads on an after-the-fact basis (SPPA understands that this arrangement is similar to that of California Community Choice Aggregators, in the sense that the transmission provider must allocate certain costs among customers of different utility providers). 

SPPA’s APS members also take certain scheduling services from APS’s merchant affiliate. Those services have allowed SPPA’s APS members to satisfy their obligations under the relevant transmission agreements and tariffs, including Attachment Q (Energy Imbalance Service) under APS’s OATT. APS has declined to continue providing those scheduling services when the current contract expires, so SPPA will assume those responsibilities on January 1, 2021. SPPA nevertheless expects that APS will continue to allocate charges—including EIM charges—to the interspersed loads of APS’ retail customers and SPPA member wholesale customers in the same way it has always done, without need for expensive metering upgrades that are not required by APS’s transmission agreements with SPPA.

While SPPA has focused on APS as an example, SPPA’s Salt River Project members have a similar situation with loads dispersed within SRP’s territory. SPPA’s PNM and TEP loads will face their own challenges. It will take time for SPPA to be ready to assume an SESC role for its diverse membership, and it may not make sense for some areas to adapt to that framework any time soon. Nevertheless, SPPA expects that it will be in the position of assisting its members in a variety of different system configurations and circumstances. The SESC role, when appropriate, must be flexible enough to accommodate a variety of existing practices that may not always be susceptible to immediate change.

SPPA urges CAISO to clarify, consistent with the general principle that EIM participation is voluntary, that load serving entities have the option of whether to take on the SESC role.  The entity that would become an SESC—not the CAISO or the EIM Entity—must have the option.

SPPA also urges CAISO to clarify that this initiative will not expand the EIM metering and telemetry requirements to any entities other than SESCs. If an entity elects not to become an SESC, and where a transmission provider’s tariff and relevant service agreements do not require the same metering and telemetry required by CAISO Tariff § 29.10, then a transmission customer should have no obligation to upgrade its meters. This is especially true for small, local entities that have historically served intermixed loads and been allocated costs without such metering and telemetry, and where it is and likely will remain cost-prohibitive to install more sophisticated real-time metering and telemetry.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

See comments above.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

No comments at this time.

4. Provide your organization’s comments on the settlements proposal for this initiative.

See comments above. 

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

No comments at this time. 

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

No comments at this time.  

7. Provide your organization’s comments on the outage management proposal for this initiative.

No comments at this time.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments at this time.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

See comments above.  

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

No comments at this time.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments at this time.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

General
a. UAMPS proposes that any structures or considerations in this straw proposal for sub-entities be
consistent and considered with the current Extended Day Ahead Market (EDAM) framework.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

Roles and Responsibilities
a. Will behind the meter resources will be treated differently at a sub-entity level, or be required to
register and integrate into the full network model?

3. Provide your organization’s comments on the forecasting proposal for this initiative.

4. Provide your organization’s comments on the settlements proposal for this initiative.

Meter Data, Settlements and Invoicing
a. If settlements will occur at the EIM sub-entity scheduling coordinator level as well as the EIM
entity level, how will the CAISO handle any contradicting settlement disputes on the same data?
b. Will the sub-entity have to use the same meter as the EIM entity and/or another EIM sub-entity
for settlements on a jointly owned unit?
c. Currently EIM entity transmission customers do not receive settlement data until after the
CAISO dispute windows so we imagine sub-entities will receive settlement data on the same
timelines as the EIM entity?

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

7. Provide your organization’s comments on the outage management proposal for this initiative.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

3. Provide your organization’s comments on the forecasting proposal for this initiative.

4. Provide your organization’s comments on the settlements proposal for this initiative.

5. Provide your organization’s comments on the system access proposal for the EIM Sub-Entity cheduling Coordinator Role initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

6. Provide your organization’s comments on the energy transfers proposal for this initiative.

7. Provide your organization’s comments on the outage management proposal for this initiative.

8. Please provide your organization's comments on the new pro forma agreements that are being proposed in the EIM Sub-Entity Scheduling Coordinator Role initiative.

9. Provide your organization’s comments on the system access proposal for this initiative.

For EIM entities and their subsequent sub-entity scheduling coordinators that are EIM members but not RC West participants, please provide comments on if your organization has interest in utilizing the CAISO webOMS to perform outage coordination.

11. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

12. Provide any additional comments on the issue paper/straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.