Bonneville Power Administration
Submitted 01/10/2022, 03:46 pm
1.
Please share your organization’s overall position on the revised draft final proposal:
Support with caveats
The Bonneville Power Administration (Bonneville)[1] appreciates the opportunity to submit comments on CAISO’s EIM Resource Sufficiency Evaluation (RSE) Enhancements Revised Draft Final Proposal dated December 16, 2021. While we do not believe the revised draft final proposal achieves the objectives of Phase 1 of this initiative – transparency and accuracy of the RSE – we acknowledge that the proposed changes likely reflect a reasonable estimate of what CAISO can accomplish at this time. There are significant inaccuracies of the EIM RSE that remain and thus, our support for the revised draft final proposal is contingent upon the CAISO expediting the remaining areas that still need to be addressed in a Phase 1b immediately after Board approval of this proposal in February 2022.
Out of the four key remaining areas that Bonneville requested be addressed in our previous comments[2] on the draft final proposal, there was one area that was addressed as a stop gap measure in the revised draft final proposal - the disabling of intertie uncertainty. Bonneville thanks the CAISO for this change. However, there are at least three significant areas that have been identified as part of this initiative that remain unresolved and still need to be addressed to improve the accuracy of the EIM RSE:
- Intertemporal Constraints: Bonneville continues to disagree with CAISO’s approach to include resources bid into the Short-term Unit Commitment (STUC) run but that are not available during the time period evaluated for the EIM RSE. We maintain that the capacity test should only count resources that are truly available for the operating interval(s) being evaluated by the EIM RSE. The CAISO has stated it will provide additional analysis to clarify the impact of incorporating intertemporal constraints using the STUC horizon.
- Accuracy of the uncertainty requirement: The EIM RSE was structured to ensure an EIM Entity and the CAISO is able to meet their demand with a 95% level of confidence. The current calculations of historical net load uncertainty and intertie deviations have been determined to not provide accurate indicators of future expected uncertainty. The CAISO plans to implement a new methodology (quantile regression) for calculating net load uncertainty in fall 2022. And the CAISO has stated it plans to work on a new methodology for calculating intertie uncertainty in Phase 2, along with offering the opportunity to consider both intertie and net load uncertainty holistically in Phase 2. The CAISO has planned to not begin until July 2022 at the earliest.
- Systemic Load Conformance: The CAISO has highlighted that the issue of its use of significant and systemic load conformance for the CAISO BAA is complex and multi-faceted and requires additional analysis and discussion to determine the best approach for its incorporation into the EIM RSE.
Given the foundational nature of the EIM RSE and its importance in EIM Entities’ ability to have trust and confidence that the EIM, as a voluntary market, is producing reliable and equitable results, we urge the CAISO to prioritize addressing these remaining items in a Phase 1b and not delay work until July 2022.
[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 around 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] BPA Comments on EIM RSE Draft Final Proposal
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
Bonneville supports CAISO’s proposal to suspend the intertie deviation uncertainty adder in the capacity test until a more accurate calculation is developed. However, Bonneville emphasizes that getting to an accurate calculation and reinstating the intertie deviation uncertainty requirement to the capacity test should be prioritized. We urge the CAISO to examine the methodology for calculating intertie uncertainty as part of Phase 1b, to begin immediately after approval of the EIM RSE Enhancements proposal in February 2022.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
Bonneville supports CAISO’s proposal to suspend the net-uncertainty adder in the capacity test until a more accurate calculation is implemented. Bonneville understands that the CAISO will implement a quantile regression approach to calculating historical net load uncertainty in fall 2022. As the CAISO anticipates implementation of this new approach, Bonneville requests that the CAISO:
- Allow time and dedicate CAISO staff to assist EIM Entities with replicating the quantile regression uncertainty calculation in order to build confidence in its accuracy and identify any improvements that may be needed before it is implemented.
- Consider running the quantile regression and existing histogram methodology in parallel for a period of time to compare the results of the two different methodologies.
- Consider separating the uncertainty calculation for the capacity test and the flexible ramping sufficiency test from that of the flexible ramping product as recommended by DMM[1].
Bonneville emphasizes again that getting to an accurate calculation and reinstating the net-uncertainty adder to the capacity test should be a priority.
[1] See Section 6 (p. 24) of DMM’s EIM RSE Metrics Report covering November 2021
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
Bonneville has no further comments beyond what was provided by the EIM Entities regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
Bonneville continues to oppose the CAISO’s proposal to utilize resource bids in the STUC[1] to count towards meeting the capacity test as we believe this will include supply that is not actually available in real-time. We maintain that the appropriate time horizon to determine capacity that is operationally available in real-time is the RTUC[2] as it aligns with the timing of the EIM RSE. Bonneville reiterates the request made by the EIM Entities that the CAISO (or DMM) provide stakeholders with a counterfactual analysis using HE 17-22 of the 5 highest load days of Summer 2021 to clearly show:
- Capacity counted in the existing capacity test
- Capacity that was not actually operationally available in real-time
- Capacity that would have been counted using the STUC time horizon (i.e. 4.5 hours)
- Capacity that would have been counted using the RTUC time horizon (i.e. 2 hours)
We also ask that the DMM provide this type of information more routinely as part of its reporting on the EIM RSE.
Bonneville appreciates the CAISO’s proposal to make configurable the amount of capacity that will be counted in the capacity test for resources that are unavailable due to prior market decisions. However, this change does not enhance the accuracy of the EIM RSE as CAISO proposes to continue to count the maximum bid-in capacity of the resource, which does not reflect the actual capacity that resource could have provided within the operating hour.
[1] The STUC commits and de-commits resources 4.5 hours ahead of the operating hour.
[2] The RTUC commits and de-commits resources 2 hours ahead of the operating hour.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
Bonneville agrees with the concept that EIM Entities and the CAISO should auto-fail the EIM RSE when in emergency conditions. However, we do not support CAISO’s approach to determining emergency conditions based on operator actions. EIM Entity operators each take different actions when in emergency conditions depending on the circumstance and it is not feasible for the CAISO to define each operator action that may be taken or to have visibility into those actions outside of its own BAA.
Bonneville maintains that the appropriate trigger to limit the real-time market’s dispatch of additional energy transfers into a BAA when a BAA is in emergency conditions is to use the NERC Energy Emergency Alerts (EEAs) and their equivalence. These are public notices visible to all EIM Entities. In our comments[1] on the draft final proposal, Bonneville provided the definitions of the circumstances around EEAs and the crosswalk between the NERC EEAs and the CAISO AWE levels.
Additionally, Bonneville believes it is critical for the CAISO and DMM to continue to report on how the EIM RSE would perform during these emergency conditions if it didn’t auto-fail. This kind of reporting will provide a helpful indicator on the accuracy of the EIM RSE and what further enhancements may be needed.
[1] See response to Question 11 in BPA's comments on the EIM RSE Enhancements Draft Final Proposal
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
Bonneville has no comments on the proposal to expand the interchange reliability accounting to account for both imports and exports.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
As stated previously, Bonneville urges the CAISO to proceed with a phase 1b to begin immediately after the approval of this proposal. Phase 1b should be focused on analysis and enhancements needed to enhance transparency and ensure that the EIM RSE is accurately evaluating the operating capability and obligations of each BAA being tested for the period being tested. This should include:
- Analysis of counting capacity made available in the STUC that was not actually available in real-time
- Method for calculating intertie uncertainty
- Testing of the quantile regression approach to calculating net load uncertainty, including working with EIM Entities to be able to re-create the test.
- A holistic examination of the uncertainty calculation that includes intertie and net load uncertainty
- Appropriate incorporation of significant and systemic adjustments made to a BAA’s load forecast, including load conformance used by the real-time market, into the EIM RSE.
Phase 2 should be focused on the effectiveness of the EIM RSE at achieving its objective, which is to prevent or strongly discourage leaning. The scope should appropriately be focused on EIM RSE failure consequences. However, Bonneville reiterates that appropriate failure consequences can only be effective if the EIM RSE produces accurate results in the first place.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
Bonneville appreciates the depth of discussion and breadth of analysis provided by the CAISO and DMM on the EIM RSE. We have found all of the additional analysis and discussion throughout this initiative especially helpful in understanding the complexities of the EIM RSE and identifying targeted areas of improvement. We ask that the CAISO and DMM continue the good work that was started in this initiative on an expedited schedule and trust that we can get to an EIM RSE that is accurate, effective, and equitably applied to all EIM Entities and the CAISO BAA.
California Community Choice Association
Submitted 01/10/2022, 02:31 pm
1.
Please share your organization’s overall position on the revised draft final proposal:
Support
The California Community Choice Association (CalCCA) appreciates the opportunity to submit comments on the Revised Draft Final Proposal (Draft Proposal) in the Energy Imbalance Market (EIM) Resource Sufficiency Evaluation (RSE) Enhancements Initiative.[1] CalCCA is supportive of the efforts of the California Independent System Operator (CAISO) to adopt enhancements to the RSE to ensure that the RSE is administered accurately and applied equitably. CalCCA supports the proposed two-phased approach of implementing enhancements developed with stakeholder input in Phase 1 on an expedited basis, and then evaluating the success of such enhancements in an upcoming Phase 2.
In particular, CalCCA supports the delay of any consideration of RSE failure consequences to Phase 2 -- after the implementation of the enhancements. As CalCCA has stated in its prior comments in this initiative, CalCCA opposes financial or additional operational consequences (beyond the current capping of incremental upward EIM transfers) for failing the RSE, as such consequences will have adverse impacts on the EIM, a voluntary market, by hindering EIM participation beyond what is necessary to avoid leaning.
EIM entities can voluntarily elect to participate in and make supply available to the EIM through the base scheduling process. EIM participants already face existing penalties for non-compliance with responsibilities in the Balancing Area Authority. In addition, the CAISO’s market process clears supply with forecasted demand. To do this, resource adequacy resources have a must offer obligation to ensure sufficient offers are made available to the market to meet forecasted demand. Any financial consequences for failure of the RSE could dissuade entities from fully participating in the EIM to avoid the risk of incurring financial penalties.
In addition, operational consequences beyond the current capping of incremental upward EIM transfers to prevent leaning should not be considered. Any such operational consequences could exacerbate reliability challenges if a decrease in the transfer limit occurs when an entity is already experiencing reliability challenges.
[1] EIM Resource Sufficiency Evaluation Enhancements Phase 1, Revised Draft Final Proposal, Dec. 16, 2021 (Draft Proposal).
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
No comments at this time.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
No comments at this time.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
CalCCA supports further analysis (in Phase 2) of how to incorporate demand response into the RSE. The removal of any proposed enhancements to classify expected demand response participation through forecast adjustments, which could trigger the automatic application of the under-scheduling tests, is appropriate. CalCCA agrees with the CAISO that any consequences for potential misuse of demand response must only be developed after stakeholder input and further CAISO analysis. In general, CalCCA opposes any financial penalties or additional operational consequences outside of the current capping of incremental EIM transfers.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
No comments at this time.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
No comments at this time.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
No comments at this time.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
No comments at this time.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
No comments at this time.
California Public Utilities Commission - Energy Division
Submitted 01/11/2022, 10:18 am
1.
Please share your organization’s overall position on the revised draft final proposal:
Based on information discussed at the last few CAISO stakeholder meetings, and at the Market Surveillance Committee meeting on November 19th, CPUC staff is concerned that, as noted by CAISO, the Resource Sufficiency Evaluation (RSE) test as currently constructed “significantly disadvantages the CAISO in passing the RSE”[1] (and, as a result, California customers). This is because EIM advisory transfers are not included in the RSE test, but exports, enabled by advisory EIM transfers, are included in the test. As noted by CAISO,
The CAISO has shown through analysis that the HASP process has the potential to award block hourly exports from the CAISO based the assumed availability of EIM transfers; to the extent this occurs this adds to the CAISO’s capacity test obligations while not adding to its available supply.[2] (Footnote omitted, emphasis added.)
Not only does this seem unjust and unreasonable, as it could lead to CAISO failing the RSE since the advisory EIM imports themselves are not included in the RSE test itself, but it could pose serious reliability issues to the extent that the advisory EIM imports fail to materialize, forcing CAISO to support the exports with internal resources that were likely procured – and may be needed – to provide reliability services to CAISO load. We believe that this issue should be addressed expeditiously, preferably before this summer, as it is a critically important and concerning reliability issue.
In addition, CPUC staff does not support CAISO’s proposal “to discount any interchange awards that have not submitted a transmission profile e-Tag equal to the hour ahead scheduling process award by the forty minutes prior to the operating hour (T-40) deadline.”[3] Given the issue identified above, CPUC staff is concerned that under stressed system conditions, this proposal, if adopted, will make an already bad situation even worse.
Using an example to illustrate our concern with this, if EIM advisory imports supporting exports are 2,000 MW and those imports do not flow (say, due to a transmission derate like the one that occurred on July 9th), and thus CAISO finds itself 2,000 MW short in the RSE, this proposal would make that unjust and unreasonable shortfall even worse. Further, it is arbitrary and capricious because other EIM entities have failures in interchange awards that CAISO has not proposed to include in this iteration of its proposal so this is clearly asymmetric treatment of CAISO vs non-CAISO entities. We are also concerned that adding a new element that is not sufficiently vetted for this upcoming summer could lead to unintended results and consequences. In this regard, we would note that CAISO added new elements to the capacity test last summer, only to agree at this point that they should remove them for further study (e.g., the net load uncertainty and intertie uncertainty calculations). Likewise, CPUC staff believe that the larger issues regarding HASP and the RSE should be further explored, studied and resolved before adding ever more stringent requirements to CAISO alone.
[1] Revised Draft Final Proposal, p. 15, available at http://www.caiso.com/InitiativeDocuments/RevisedDraftFinalProposal-EIMResourceSufficiencyEvaluationEnhancements.pdf
[2] Id at 14.
[3] Id at 28.
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
CPUC staff supports this proposal, especially in light of the fact that the current RSE test, as configured, “significantly disadvantages the CAISO in passing the RSE.”
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
CPUC staff supports this proposal, especially in light of the fact that the current RSE test, as configured, “significantly disadvantages the CAISO in passing the RSE.”
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
CPUC staff does not take a position on this proposal at this time.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
CPUC staff does not take a position on this proposal at this time.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
CPUC staff does not take a position on this proposal at this time.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
CPUC staff opposes this proposal for the reasons discussed in response to Section 1, above.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
CPUC staff urges CAISO to address the issues of advisory imports (and non-firm imports) supporting exports. CPUC staff believes that this issue should be addressed expeditiously, preferably before this summer, as it is a critically important and concerning reliability issue for the reasons discussed in response to Section 1, above.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
NV Energy
Submitted 01/10/2022, 10:39 am
1.
Please share your organization’s overall position on the revised draft final proposal:
Support with caveats
As explained in the comments below, NV Energy supports the CAISO’s proposals to suspend the intertie deviation adder and the net-uncertainty adder. NV Energy also supports the decision to remove any penalties associated with incorporation of the EIM Entities demand-response programs into the load forecasts used for the market and the Resource Sufficiency Evaluation (RSE).
The CAISO’s proposal to add a new element to the RSE related to emergency conditions, highlights the need for an immediate, expedited stakeholder process to come up with an interim, simplified approach that could be in place for the Summers of 2022 and 2023 to enable EIM Entities in to receive additional transfers, if there is available supply in the EIM. The market rules should not prohibit the transfer of available energy through the EIM, even after an RSE failure, to meet events such as the Bootleg Fire in 2021 that derated critical transmission facilities and challenge system reliability.
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
NV Energy supports the proposal to suspend the intertie deviation uncertainty adder.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
NV Energy supports the proposal to suspend the net-uncertainty adder in the capacity test.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
NV Energy strongly supports the CAISO’s proposal first to better account for the EIM Entities’ demand response programs that are not explicitly modeled in the real-time market in the resource sufficiency evaluation, and second to remove any proposed penalties targeted toward the demand response functionality. NV Energy agrees that it is far better as an initial step to observe incorporation of the EIM Entities demand-side management programs before taking any precipitous action to impose penalties.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
No additional comments.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
NV Energy has significant concerns with the potential impacts of the RSE on EIM Entities who find themselves in an emergency situation. While NV Energy understands the purpose of this proposal is to prevent leaning by entities during emergency situations, the CAISO must ensure that the implementation of this is additional criteria is carefully thought out to ensure EIM Entities are not unduly harmed and reliability impaired. The latest language is concerning as it ties emergency actions to the RSE which could unintentionally and unfairly limit incremental transfers when it is not appropriate to do so. Due to the timing of the RSE, it could be possible for an EIM Entity to be in an emergency situation and automatically fail the RSE for the upcoming hour. However, the EIM Entity could have procured additional resources for the following hour and may not expect to continue to be in an emergency situation. This would result in an EIM Entity being unable to receive incremental transfers despite not being in an emergency situation. Mechanisms would also have to be built around strictly defining the appropriate emergency conditions. NVE believes it would be far better not to tie emergency situations to the RSE. Nevertheless, if the proposal moves forward, individual FMM intervals should be selected and any transfer limitations should be limited to those specific intervals. Mechanisms would need to be built in order for EIM Entities to communicate this type of information. In addition, there is currently no specific language tied to the details of what the incremental transfer limit would be based off of. The limits should be frozen based on the last interval directly preceding an emergency situation and not at a lower base transfer amount that may exist earlier in the hour. Without this, it would be possible for an entity to be harmed even further as transfers are not only frozen, but potentially reduced from levels before entering an emergency.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
No additional comments.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
The discussion of a new criteria for emergencies highlights a significant flaw in the implementation of the current RSE – freezing the upward incremental EIM Transfers may unnecessarily harm reliability if there is available, voluntarily-offered supply in the EIM. If there is insufficient EIM bids to supply imbalances, then limitations on imports to deficient EIM Entities is appropriate. If, however, supply is available, then it should be used to address the reliability need of the EIM Entity at an appropriate price. Simply stated a market rule should not contribute to physical withholding to prevent or respond to an emergency.
The CAISO “reiterates the voluntary nature of participation that the existing EIM design allows” and states “[t]he consequences of resource sufficiency evaluation failures should not cause operational or reliability issues.” It is important to recognize that an emergency situation does not mean a participant has a deficient resource adequacy program. During the summer of 2021, the Bootleg Fire caused a derate of the Pacific AC Intertie from 4,800 MW to 428 MW, severely straining system conditions for several EIM Entities including NV Energy. NV Energy submits that there is no more important aspect of any initiative than the RSE failure consequences and how it needs to be modified to improve reliability. This need is increased as the expansion of the EIM may further limit bilateral intra-day and intra-hour trading opportunities.
If the CAISO and stakeholders are supporting 12 hours a week of stakeholder meetings on a potential EDAM market design, surely there is the bandwidth the address current market conditions on an expedited basis so improvements could be in place by the summer of 2022 or 2023 at the latest. Confidence in the reliable operation of the EIM design is a foundational element of any market expansion. Even prior to full consideration of the issue of failure consequences as part of Phase 2 of this initiative or the separate initiative on price formation, the CAISO should develop an expedited, simplified rough-justice pricing approach to enable increased transfers to help alleviate emergency conditions.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
No additional comments.
Pacific Gas & Electric
Submitted 01/10/2022, 04:58 pm
1.
Please share your organization’s overall position on the revised draft final proposal:
PG&E appreciates the CAISO’s efforts in Phase 1 of this initiative to make improvements to the accuracy and transparency of the Energy Imbalance Market (EIM) Resource Sufficiency Evaluation (RSE). The Revised Draft Final Proposal makes several changes to build stakeholder support from the diverse community of EIM participants. PG&E supports some of the proposed changes and opposes others, as outlined in our subsequent comments.
The equitable application of RSE requirements and counting rules to all EIM entities continues to be a concern for PG&E. The Revised Draft Final Proposal recognizes that the “CAISO balancing authority area is differently situated and has different practices than EIM entity balancing authority areas operating under an OATT framework.” PG&E appreciates the CAISO’s effort to account for these differences in the application of the RSE, but believes further work is needed to demonstrate the equitable application and design of the RSE.
In our comments, PG&E discusses our concerns with proposals or current rules that do not appear to apply the RSE consistently and equitably in all EIM areas:
- The proposed counting of battery storage capacity in the EIM areas outside of the CAISO BAA;
- The proposed emergency operator actions that correspond with resource insufficiency; and
- The counting of HASP exports based on advisory EIM transfers toward the CAISO BAA’s RSE requirements.
On the final bullet point, the CAISO has recognized that “the interaction between HASP and the RSE during stressed system condition already significantly disadvantages the CAISO in passing the RSE.”[1] Correcting the RSE counting rules to address this issue should be a high priority for the CAISO. The impact of leaving this issue unresolved in Phase 1 is magnified by the potentially large impact of the proposal to reduce the CAISO BAA’s RSE credits for import deviations at T-40, which the CAISO has recognized will lead to a “sizeable discount in import awards credited to the CAISO, specifically during peak conditions.”[2] Taken together, these counting rules for CAISO BAA exports and imports appear to result in higher and more stringent RSE requirements for the CAISO BAA than other EIM areas. We urge the CAISO to perform additional analysis on the interaction between HASP and the RSE and take steps to address this RSE design flaw as soon as possible to ensure that CAISO does not continue to be unfairly disadvantaged.
[1] EIM Resource Sufficiency Evaluation Enhancements Phase 1. Revised Draft Final Proposal. December 16, 2021. Pg. 15 at http://www.caiso.com/InitiativeDocuments/RevisedDraftFinalProposal-EIMResourceSufficiencyEvaluationEnhancements.pdf
[2] “Resource Sufficiency Evaluation Enhancements - Draft Final Proposal Stakeholder Meeting.” CAISO Market Infrastructure Policy. October 12, 2021. Pg. 21 at http://www.caiso.com/InitiativeDocuments/Presentation-ResourceSufficiencyEvaluationEnhancements-Oct12-2021.pdf
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
PG&E supports suspending the intertie uncertainty adder and welcomes holistic review of the RSE uncertainty adders in Phase 2
PG&E supports the proposal to suspend the intertie uncertainty adder from the capacity test calculation until a more accurate measurement of intertie uncertainty can be developed. Suspending the intertie uncertainty adder is an appropriate response to stakeholder comments, and the CAISO’s own analysis[1], showing that the current methodology using a 95% confidence interval is not an accurate predictor of uncertainty and has significantly increased capacity test failure rates in many EIM BAAs.
PG&E also supports CAISO’s plan to perform a holistic review in Phase 2 of the intertie deviation and net load uncertainty requirements and analyze the combined impact of using 95% confidence intervals for both adders.
[1] “Analysis of the Intertie Deviation Adder Used in the Capacity Test.” October 6, 2021. Prepared by CAISO Market Analysis and Forecasting. See pg. 6 at http://www.caiso.com/InitiativeDocuments/Analysis-IntertieDeviationAdderUsed-CapacityTest.pdf
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
PG&E supports suspending the net load uncertainty adder and welcomes holistic review of the uncertainty adders in Phase 2
PG&E supports the proposal to suspend the net load uncertainty requirement. PG&E believes stakeholders and the MSC[1] have raised legitimate concerns that the current histogram methodology for calculating net load uncertainty has the potential to overstate the actual net load uncertainty and significantly increase RSE failures.
PG&E welcomes discussion in Phase 2 of alternative methodologies to measure net load uncertainty, including approaches tailored specifically to meet the goals of the RSE and that take into account actual system conditions near the time of the RSE tests.
As noted in our comments in question 2, PG&E agrees with CAISO’s proposed approach to holistically review the combined impact of the intertie deviation and net load uncertainty requirements to ensure that coincident adders at the 95% confidence intervals do not overcount total uncertainty.
[1] “Opinion on Market Enhancements for Summer 2021 Readiness.” Market Surveillance Committee of the California ISO. March 8, 2021. See pg. 11 at http://www.caiso.com/Documents/MSCOpiniononMarketEnhancementsfor2021SummerReadiness-Mar8_2021.pdf
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
CAISO should perform regular monitoring of demand response accounting in the RSE
PG&E supports removing the previously proposed penalties associated with using the demand response functionality in the RSE. However, ongoing monitoring and reporting on the use and impact of the demand response functionality will be necessary to ensure transparency, accuracy and confidence in this new input in the RSE calculation. PG&E agrees with the CAISO’s intent to revisit this issue in Phase 2 of this initiative if further steps are needed to prevent misuse of the new demand response functionality.
While the CAISO has no control over EIM entities’ current demand response programs, the CAISO’s monitoring of the performance of demand response programs could be leveraged to promote best practices and improve regional coordination of the demand response resources that will be accounted for in the RSE.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
PG&E supports the proposal to create flexibility for CAISO to adjust the capacity credited to offline resources in the future, subject to further reporting, analysis, and stakeholder discussion
PG&E believes CAISO is taking a reasonable approach to determine how the RSE counts the capacity of resources that are offline due to economic displacement but would otherwise be available to the real-time market. For offline resources, CAISO proposes that the capacity test will consider 1) the resource’s start-up time, (2) the hours for which bids for the resource were submitted, and (3) the number of daily start or upward state transitions available to the resource, to determine whether the real-time market is capable of starting the resource.
For offline capacity that meets the 3 criteria listed above (with some exceptions), the CAISO proposes to initially count the capacity at the resource’s maximum bid-in output. However, the CAISO also proposes to make this a configurable parameter through a Business Practice Manual change to ensure it retains the ability to adjust these counting practices, if reporting shows that the maximum is significantly over-representing the capacity available to the real time market for use because ramping constraints are not considered.
In concept, PG&E does not oppose the proposal to make the capacity credited to offline resources configurable in the future. However, PG&E requests that any future decisions to adjust the counting practices should be transparent, supported by sufficient market data and analysis, and informed by stakeholder input.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
PG&E opposes the CAISO’s proposal to expand the list of operator actions triggering automatic RSE failures. CAISO should consider deferring this proposal to the comprehensive review of failure consequences that is in scope for Phase 2.
PG&E cannot support the proposal to trigger an automatic failure of the RSE when operators direct voltage reductions for the purpose of reducing power consumption because the CAISO has not sufficiently explained the rationale for this proposal. More information about the timing and conditions associated with this specific operator action is needed to understand the basis for and implications of this proposal.
The CAISO’s approach to triggering automatic RSE failures during obvious emergency conditions seems to favor identifying a list of unique operator actions that serve as a proxy for resource insufficiency. PG&E is concerned that this approach could add to the existing asymmetries in the application of the RSE and establish different RSE standards and treatment among the diverse set of EIM entities. Stakeholders have suggested that automatic RSE failures could be based on common measurements of emergency conditions, such as NERC definitions of Energy Emergency Alert Stages.[1] PG&E would support further discussion of such an alternative approach that aligns with this initiative‘s goal to improve the equitable administration of the RSE.
Lastly, PG&E reiterates its concern that the current RSE failure consequence to lock the levels of EIM transfers could exacerbate reliability challenges during emergencies. EIM BAAs may enter emergency conditions for a range of reasons beyond their control – such as transmission outages or extreme weather -- that may not be reflective of a BAA’s failure to procure sufficient capacity. While recognizing the need to address excessive and intentional “leaning,” PG&E questions whether automatically reducing access to EIM transfers during emergencies is in the best interest of EIM market efficiency or reliability for participating EIM entities. Because this change relates to RSE failure consequences, it should be considered as part of the comprehensive failure consequences review scheduled for Phase 2 of this initiative.
[1] Bonneville Power Administration. Comments on Draft Final Proposal, EIM resource sufficiency evaluation enhancements initiative. 10/22/2021. https://stakeholdercenter.caiso.com/Comments/AllComments/57d5daa4-1c8a-47e3-8f9b-cb3127ea3a51#org-e1bd3945-f89c-4560-8d31-4fc732d13307
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
PG&E supports the proposal to clarify that T-40 transmission profile requirement applies to all interchange awards
PG&E supports expanding the proposed interchange accounting rules for energy awards that do not submit an e-tag with a valid transmission profile by T-40 to apply to exports as well as imports. Creating parallel treatment for imports and exports aligns with current market rules and ensures that the CAISO BAA is not disadvantaged in the RSE calculations.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
The CAISO BAA should not be disadvantaged by inflated RSE requirements due to CAISO hourly exports supported by advisory EIM transfers
PG&E urges CAISO to devote attention to the impact of CAISO exports cleared by HASP based on access to advisory EIM transfers on the CAISO BAA’s RSE requirements. PG&E understands from the CAISO Market Policy and Performance presentation (see slides below)[1] on December 8, 2021 that the CAISO BAA’s RSE requirement may be inappropriately inflated based on HASP-cleared exports supported by advisory EIM transfers.
The Revised Draft Final Proposal acknowledges that the “HASP process has the potential to award block hourly exports from the CAISO based the assumed availability of EIM transfers; to the extent this occurs this adds to the CAISO’s capacity test obligations while not adding to its available supply.”[2] The interaction between HASP and the RSE raises significant concern about the equitable application of the RSE. The CAISO should treat this problem as a high priority to ensure the CAISO BAA is not subject to a RSE design flaw that affects only the CAISO BAA and makes the CAISO BAA more likely to fail the RSE than other EIM areas.
[1] “Resource Sufficiency Evaluation (RSE) Enhancements initiative – RSE Analysis Discussion Continuation.” CAISO Market Policy and Performance. December 8, 2021. Slides 4-6 at http://www.caiso.com/InitiativeDocuments/Presentation-EIMResourceSufficiencyEvaluationEnhancements-Dec8-2021.pdf
[2] EIM Resource Sufficiency Evaluation Enhancements Phase 1. Revised Draft Final Proposal. December 16, 2021. Pg. 14 at http://www.caiso.com/InitiativeDocuments/RevisedDraftFinalProposal-EIMResourceSufficiencyEvaluationEnhancements.pdf
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
PG&E opposes the current proposal to count battery storage capacity in the EIM areas because the details of the proposal have not been defined sufficiently to be implemented this year.
PG&E is concerned with the CAISO’s proposal to credit battery storage capacity in the EIM areas based on the state of charge (SOC) because it appears to require development of a new SOC model. If a model has been made available to EIM participants enabling SOC management in real time only, PG&E requests details of that model. Assuming that EIM participants do not currently provide (or at any rate are not required to provide by tariff) SOC telemetry for their NGR resources, the proposal would require developing a real time SOC managed resource NGR model and telemetry requirements simply to enable RSE counting. Because of the inconsistencies with the more familiar CAISO SOC managed NGR model, PG&E believes this proposal would require development and validation that are unlikely to be completed on the short timeline of this initiative.
Public Generating Pool
Submitted 01/10/2022, 12:40 pm
1.
Please share your organization’s overall position on the revised draft final proposal:
Support with caveats
The Public Generating Pool (PGP ) appreciates the opportunity to comment on the EIM RSE Enhancements Issue Paper and Workshop. PGP takes great interest in this initiative as there are PGP members who are (or will be) EIM participants that will be directly impacted by the outcome of this initiative.
There have been ongoing questions associated with the EIM Resource Sufficiency Evaluation (RSE) going back several years. These questions include:
• Are the RSE tests accurate?
• Should there be stronger consequences for RSE failure?
• Are the RSE tests applied as equitably as possible to all market participants?
While these questions have been discussed in a variety of forums, the events of August 14th & 15th 2020 clearly demonstrated that improvements to the RSE tests were necessary. On these days, CAISO passed the RSE tests while in an Energy Emergency Alert (EEA), which is a NERC-defined condition when a balancing authority does not have enough resources to meet their obligations. After stakeholder discussions, CAISO agreed that improvements were necessary and identified the following enhancements that were implemented as part of the Summer 2021 Readiness initiative:
• Correctly accounting for resource de-rates and outages
• Correcting the inclusion of mirror resources for CAISO
• Including net load uncertainty to the capacity test
CAISO also identified that there was an issue with the inclusion of resources with a lengthy start-up time, but could not develop a solution in time for Summer 2021. CAISO committed to initiating a EIM RSE Enhancement initiative to develop additional RSE improvements and to consider changes to RSE failure consequences.
CAISO posted a 2-Phase Straw Proposal for this EIM RSE Enhancements initiative in August 2021 and identified the following improvements that would be addressed in Phase 1:
• Exclude resources that have a longer start-up time than the Short-Term Unit Commitment (STUC) time horizon (~4.5 hours) in the capacity test
• Account for any quantity of power balance relaxation in the flexible ramping test
• Broadening inclusion of demand response in the RSE tests
• Requiring that import schedules have a tagged transmission profile at T-40 to ensure deliverability
• Limit EIM transfers while arming load for reserves
• Commitment for DMM to develop routine reporting on RSE accuracy
• Commitment for CAISO to provide additional data to market participants for validation and for spot-checking their own RSE status
CAISO indicated that Phase 2 would deal with failure consequences and, potentially, issues related to load conformance. PGP supported these enhancements, but noted concerns with applicability of the balancing test to all market participants, usage of the STUC time horizon, the uncertainty methodology, and the deferral of issues related to load conformance to Phase 2.
CAISO posted a Draft Final Proposal for Phase 1 in October 2021 that provided additional detail and clarification, but did not fundamentally change its proposal from what was described in the Straw Proposal. Regarding the applicability of the balancing test to CAISO and the usage of the STUC time horizon, PGP requested routine reporting from DMM that will allow stakeholders to determine whether the frequency and magnitude of these issues warrants consideration as EIM RSE enhancements. PGP, as well as other stakeholders, also repeated comments on the Straw Proposal expressing concerns with the uncertainty methodology and the deferral of issues related in load conformance to Phase 2.
In response to stakeholder comments on the Draft Final Proposal, CAISO performed additional analysis on the use of load conformance and reconsidered the application of uncertainty in the RSE tests. The result was the posting of a Revised Draft Final Proposal in December 2021 that includes the following:
• Acknowledgement that there could be instances when EIM transfers are enabled by the use of load conformance, but the impact is not 1-to-1 and this is only an issue under tight system conditions. CAISO indicated that this issue cannot be addressed for Summer 2022 since it requires greater study that would begin after the completion of Phase 1.
• Remove net load uncertainty and intertie uncertainty adders to the capacity test until the methodology is improved in Phase 2.
• Add operator instructed voltage reductions as an additional emergency action that would limit EIM transfers.
• Remove any unique penalties associated with demand response, but reassess in Phase 2.
PGP supports the Phase 1 RSE enhancements that are currently included in the Revised Draft Final proposal. However, there are outstanding issues, especially those related to uncertainty and load conformance, that cannot be implemented in time for Summer 2022. PGP believes that it is important to address these issues sooner rather than later and is pleased that CAISO has agreed to continue developing and sharing analysis related to these topics soon after the completion of Phase 1. However, CAISO has indicated through its Draft Policy Initiatives Roadmap that Phase 2 will commence in June 2022, and PGP believes that this initiative will have a higher likelihood of success if the additional analysis on load conformance and uncertainty is shared as part of an open stakeholder process. As such, PGP suggests that CAISO commence Phase 2 immediately after the completion of Phase 1.
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
It is PGP’s understanding that CAISO’s proposal to suspend the intertie deviation uncertainty adder was driven by wildfire-caused transmission outages that resulted in market participants carrying a significant amount of additional uncertainty. In lieu of a straightforward process to exclude outlier data, PGP supports the suspension of this adder until improvements are made in Phase 2.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
In response to stakeholder comments after the events of August 2020, CAISO included a net load uncertainty adder in the capacity test as part of the Summer 2021 Readiness initiative. CAISO also included a provision in its tariff that would allow removal of this adder if it was not functioning as intended. As reported by DMM, the inclusion of this adder has resulted in additional RSE failures of nearly all market participants. However, these additional failures occur on a small percentage of intervals (generally < 1%). PGP believes that a small increase in failures should have been expected as a result of the inclusion of the net load uncertainty adder.
PGP has commented on both the Straw and Draft Final proposals that the methodologies used for both net load and intertie uncertainty rely on a very limited data set that produce unstable and inaccurate results and is pleased that CAISO plans to address the uncertainty methodology in Phase 2. However, PGP is concerned that removing the net load uncertainty adder in Phase 1 may result in a less accurate RSE for Summer 2022 and encourages CAISO and the EIM Entities to collaborate to see if there is a simple improvement that could be implemented for Summer 2022. For example, each market participant could use a commonly used error metric (such as Mean Absolute Percent Error) for each balancing area’s net load to compute the adder.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
PGP supports removing penalties associated with demand response as an interim measure with the understanding that this will be monitored and reassessed in Phase 2.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
PGP supports making the amount of capacity configurable for resources who are unavailable as a result of prior market decisions. PGP also requests that DMM regularly report the frequency and magnitude of these capacity adjustments.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
PGP supports the expansion of operator actions that would indicate resource insufficiency. However, it is important that notifying CAISO of these operator actions does not result in market participants having to develop cumbersome manual processes. PGP encourages CAISO to automate this notification process as much as possible.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
PGP supports applying the requirement to submit a transmission profile at T-40 to both imports and exports.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
CAISO has identified in Section 6 of the Revised Draft Final proposal that failure consequences, load conformance and demand response monitoring are in scope for Phase 2 of this initiative. CAISO also mentions in the Revised Draft Final that both the intertie and net load uncertainty methodologies will be revised in Phase 2, yet this is not listed in Section 6. PGP requests that CAISO specifically reference revising the uncertainty methodologies as being in scope for Phase 2 in Section 6.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
- PGP is pleased with the prompt effort undertaken by DMM to develop routine reporting of EIM performance.
- PGP appreciates the efforts CAISO has taken to educate stakeholders on the reasons for and the impacts of load conformance. PGP agrees that this is a complex issue that cannot be resolved in time for Summer 2022 and is pleased that CAISO has indicated its intent to continue analysis and stakeholder engagement soon after the completion of Phase 1. PGP believes that additional analysis on load conformance and uncertainty should be shared as part of an open and organized stakeholder process and suggests that CAISO commence Phase 2 immediately after the completion of Phase 1.
- PGP and other stakeholders have requested additional information on the amount of generation that would be counted in the STUC time horizon that was actually available for dispatch. PGP would like DMM to consider including this information in their routine reporting of RSE performance.
- PGP encourages CAISO and stakeholders to prioritize work on issues that could reduce the need for CAISO operators to use load conformance. CAISO has already indicated that improvements to the Flexible Ramping Product and the creation of an Imbalance Reserve Product would reduce the need for load conformance, but other approaches to reduce CAISO operators’ need to use load conformance should be explored as well.
- In the presentation at the September 9th Market Performance and Planning Forum (MPPF), CAISO shared the following graph, which leaves the impression that renewable generation is over-forecasted in the day-ahead on every hour. While renewable curtailment potentially explains the difference between day-ahead forecast and actuals, it seems unlikely that there would be curtailments over peak net load hours during summer months. Persistent over-forecast of renewable generation in the day-ahead, if it exists, could result in CAISO not acquiring enough supply in the day-ahead which may result in an operator using load conformance to attract additional supply in the HASP and FMM timeframes. In order to determine whether or not there is persistent over-forecast of renewable generation in the day-ahead, PGP requests that CAISO supply additional data and analysis that is much more granular than that supplied at the MPPF.
.png)
Salt River Project
Submitted 01/10/2022, 12:09 pm
1.
Please share your organization’s overall position on the revised draft final proposal:
Support with caveats
Salt River Project Agricultural Improvement and Power District (SRP) supports, with caveats, the CAISO’s efforts to improve the accuracy and transparency of the EIM Resource Sufficiency Evaluation (RSE) and appreciates the incorporation of stakeholder input in the Revised Draft Final Proposal.
SRP understands the proposed enhancements will be an improvement but is concerned that accuracy challenges remain unresolved. SRP encourages the CAISO to initiate a Phase 1B of this initiative immediately following the completion of the current phase, as explained in more detail under item 9.
In addition to these comments, SRP supports the EIM Entities joint comments.
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
SRP supports the CAISO’s proposal to suspend the intertie deviation uncertainty adder until an improved methodology can be developed.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
SRP supports the CAISO’s proposal to suspend the net-uncertainty adder in the capacity test until the accuracy of the calculation can be more thoroughly evaluated or a new approach is implemented.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
SRP supports the proposal to remove penalties associated with using demand response contribution in the balancing test.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
SRP supports the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources that may be unavailable due to prior market decisions. SRP continues to request that the CAISO perform analysis to understand how this capacity would have been accounted for in July 2021 scenarios with Short-Term Unit Commitment (STUC) and Real-Time Unit Commitment.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
SRP generally supports the concept of expanding actions that correspond to resource insufficiency; however, SRP opposes the CAISO’s proposal that all EIM participants sign an attestation obligating them to notify the CAISO should they perform these emergency actions. Consistent with the EIM Entities joint comments, SRP prefers that any Balancing Authority that declares a NERC-defined Energy Emergency Alert 2 (or equivalent) or greater be automatically deemed resource insufficient.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
SRP supports the CAISO’s proposal to not count CAISO intertie schedules (imports and exports) for which an e-tag with at least a transmission profile is not submitted by 40 minutes prior to the operating hour.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
The identified scope for phase 2 is robust and will require a significant time commitment from CAISO staff and stakeholders. SRP suggests that the CAISO focus on items identified for phase 2 to implement improvements in a timely manner. If necessary, additional changes can be made through future enhancements.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
SRP understands that phase 2 is scheduled to begin in July 2022. SRP is concerned that resource sufficiency inaccuracies that remain unresolved by this proposal will continue into summer 2022. SRP encourages the CAISO to initiate a Phase 1B of this initiative immediately following the completion of the current phase. SRP requests that Phase 1B include:
- Further analysis of the impact of CAISO operator-induced load conformance
- Resolution of interactions between the Hour-Ahead Scheduling Process and EIM RSE resulting in the CAISO Balancing Authority Area becoming over-extended with exports it cannot support without relying on EIM import supply
- Developing and implementing an accurate measure of net load uncertainty
- Further evaluation of the STUC horizon proposal
- Detailed review of solar performance relative to forecasts used in the RSE
Six Cities
Submitted 01/10/2022, 04:29 pm
Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
1.
Please share your organization’s overall position on the revised draft final proposal:
Support
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
The Six Cities do not oppose suspension of the intertie deviation uncertainty adder.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
The Six Cities do not oppose CAISO’s proposal to suspend the currently effective net uncertainty adder in the capacity test and support consideration of an alternative methodology that would be expected to provide a more accurate measure of uncertainty.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
At this time, the Six Cities do not oppose deferred consideration of penalties intended to prevent misuse of the demand response functionality. However, the CAISO should identify and track instances when demand response counted as available in the capacity test fails to perform and act promptly to address any pattern of relying on demand response for RSE purposes that does not perform when needed.
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
The Six Cities do not oppose this element of the Revised Draft Final Proposal.
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
The Six Cities support the CAISO’s proposal to expand the operator actions that are considered as indicating resource insufficiency. In addition to the specific proposal to include system wide reductions in operating voltages outside of nominal parameters as indicating resource insufficiency, the CAISO should remain open to identifying other system conditions that indicate resource insufficiency.
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
The Six Cities support application of a T-40 deadline for submitting a transmission profile e-Tag for both imports and exports considered for RSE purposes.
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
The Six Cities generally support inclusion of the topics described in the Revised Draft Final Proposal in Phase 2 of this initiative.
The Six Cities suggest two additional topics for further consideration In Phase 2:
- Consistent with the discussion in Item 6 above, Phase 2 should include identification and consideration of any additional operator actions and/or system conditions that may be deemed to indicate resource insufficiency.
- Phase 2 should include comprehensive evaluation of the interplay between cleared imports and exports for RSE purposes, including concerns raised by the CPUC Energy Division during the December 21, 2021 web conference.
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
Throughout Phase 2 of this initiative, evaluation of potential modifications to the RSE must take into account in an unbiased manner differences in market structure and risk exposure among EIM participants, including the CAISO. Participation in the EIM and the scope of participation in the EIM are voluntary for EIM entities, but the CAISO and LSEs within the CAISO are unable to withdraw from or minimize participation in the CAISO’s markets. EIM entities expect that EIM rules will accommodate and respect the market structures within which they operate and the operating practices they have developed within those contexts. The CAISO’s market rules and operating practices are equally entitled to respect and accommodation, if not more so in light of the voluntary/involuntary dichotomy noted above. RSE modifications should not create advantages or disadvantages for, or impose unreasonable burdens on, any subset of EIM participants, including the CAISO.
Southern California Edison
Submitted 01/10/2022, 10:21 am
1.
Please share your organization’s overall position on the revised draft final proposal:
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
Western Power Trading Forum
Submitted 01/11/2022, 07:22 am
1.
Please share your organization’s overall position on the revised draft final proposal:
Support
WPTF appreciates the opportunity to submit these comments on the CAISO’s Revised Draft Final Proposal for its Resource Sufficiency Evaluation Enhancements initiative discussed with stakeholders during the Dec 21, 2021 meeting. Generally speaking, WPTF supports the direction of this initiative, especially given the CAISO’s consideration for interim measures. We ask that the CAISO capitalize on the momentum gained in this phase of the initiative and immediately engage with stakeholders on the Phase 2 elements such that improved calculations for the RSE tests can be developed and implemented sooner rather than later. WPTF asks that the CAISO confirm Phase 2 will include (1) consideration of load conformance, (2) net load uncertainty methodology, potentially based on the FRP quantile regression approach, and (3) intertie deviation uncertainty adder.
2.
Please share your organization’s perspective regarding the proposal to suspend the intertie deviation uncertainty adder:
WPTF appreciates the CAISO’s responsiveness to consider interim measures for Phase 1 of this initiative as it relates to the intertie deviation uncertainty adder. As the CAISO notes in the proposal, while it remains unclear if eliminating the adder all together is the appropriate interim step, it at least eliminates the known inaccuracy of the results and unintended outcomes. We are looking forward to engaging with the CAISO and stakeholders on an improved methodology for capturing the impact of intertie deviations on resource sufficiency.
3.
Please share your organization’s perspective regarding the proposal to use its FERC authority to suspend the net-uncertainty adder in the capacity test:
Similar to our response to #2 above, we appreciate the CAISO considering an interim solution to observed issues with including net-load uncertainty adder in the capacity test. We agree that the CAISO should defer including this element at this time. Once the quantile regression approach is implemented, and after some gained experience, that could be a potential solution. That being said, we ask that the CAISO provide analysis of the quantile regression approach and its estimated impact on the RSE tests prior to proposing that as the preferred methodology. It would be unfortunate for the CAISO to immediately include the net-load uncertainty adder based on the quantile regression approach to find out that approach is resulting in unintended outcome as well. it will also be important to keep an open mind and consider other methodologies as well and not necessarily solely focus on the quantile regression approach.
4.
Please share your organization’s perspective regarding the proposal to remove any penalties intended to prevent misuse of the demand response functionality:
5.
Please share your organization’s perspective regarding the proposal to make configurable the amount of capacity that will be counted in the capacity test for resources who unavailable due to prior market decisions:
6.
Please share your organization’s perspective on its proposal to expand the operator actions that correspond to resource insufficiency:
7.
Please share your organization’s perspective regarding the proposal to expand the interchange reliability accounting, to account for both import and exports:
8.
Please provide your organization’s perspective on additional scope items, not already identified in the paper, that the ISO should include in phase 2 of the RSEE initiative:
9.
Please provide any additional comments on the EIM RSE Enhancements initiative that have not previously been addressed:
