Comments on Comments on Extended Day-Ahead Market Tariff Clarification Matrix

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

CDWR-SWP appreciates the opportunity to provide input to the EDAM Tariff Clarification Matrix.

CDWR-SWP has a few clarification questions, as shown below.

2. Please provide any additional questions you may have

1. Section 11.2.1.9: CDWR-SWP asks for clarification on whether Imbalance Reserve cost allocations related to ETC/TOR will apply to the annual process allocation (Tiers 1,2,3). As the text is currently written, Imbalance Reserve cost allocations are applied only to Tier 1 and Tier 2, implying that Imbalance Reserve cost allocations are applied only to the monthly allocation process.
2. Section 40.6.5.3:
   1. Is RAAIM calculated separately for the DAM shown RA resource and the reassigned resource?
   2. Can a system resource reassign RA obligation to another system resource? Is it only in DAM? Can the physical resource accepting reassignment have the same SC as for the system resource?
3. Section 40.6.8: Is exemption applicable to a system resource from a WEIM BAA?

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

Portland General Electric Company (PGE) appreciates the opportunity to comment on the CAISO’s November 4, 2025 proposed tariff amendments related to the Extended Day-Ahead Market (EDAM) and Day-Ahead Market Enhancements (DAME). PGE supports the majority of the CAISO’s proposed amendments. These revisions improve tariff clarity, strengthen EDAM settlement structures, and provide needed transparency and certainty to EDAM Entities and market participants.

PGE offers the following supportive comments.

1. Clarifying Imbalance Reserve (IRU/IRD) Settlement Provisions: PGE supports CAISO’s revisions to Sections 11.2.1.8.1, 11.2.1.8.2, and 11.2.1.9, which provide clearer definitions for unavailable imbalance reserve awards and provide accurate and transparent settlement rules are essential for EDAM’s success.
2. CRR Settlement Clarification for EDAM (Section 11.2.4.1.2):  PGE supports the clarification that Hourly CRR Congestion Funds are calculated only for CAISO BAA constraints and that congestion on EDAM BAA constraints is settled exclusively at the EDAM Entity level. This approach ensures that congestion revenues on EDAM BAA facilities must remain with the EDAM Entity and should not be used to fund CAISO CRRs. The clarification prevents cross-subsidization between CAISO CRR holders and EDAM Entities, reinforces the separation between CAISO’s CRR framework and EDAM congestion revenue allocation, and improves transparency in congestion accounting for EDAM BAAs. PGE views this as an essential correction to ensure that EDAM congestion revenue flows are well-defined and equitable.
3. Corrections to Reliability Capacity Settlement (RUC/RCU/RCD):  PGE supports the revisions in Section 11.8.6.5.3 and related provisions, which correct inadvertent references to imbalance reserves and ensure settlement provisions apply accurately to Reliability Capacity. These clarifications provide accurate bidding and settlement expectations for RMR and RA resources, maintain consistency with day-ahead RUC design, and reduce the risk of settlement misallocations. PGE supports CAISO’s efforts to ensure that Reliability Capacity settlement rules are internally consistent as EDAM begins operation.
4. Support for Clarifications to EDAM Transmission Rights and Legacy Contract Treatment:  PGE supports CAISO’s proposed amendments to Sections 33.16, 33.17, and 33.23, which define the treatment of EDAM transmission ownership rights, legacy contract rights, and transmission service requirements for EDAM Resources. EDAM participation should not override OATT frameworks or pre-existing commercial arrangements. The amendments preserve the role of EDAM Transmission Ownership Rights holders and clarify how revenues and charges flow between CAISO, EDAM Entities, and rights holders. PGE supports CAISO’s approach, which respects regional tariff structures and maintains clear boundaries between EDAM participation and OATT service.
5. Improvements to EDAM Market Transparency and Operational Coordination:  PGE supports CAISO’s proposals to allow CAISO to share operationally relevant information with EDAM Entities (Section 33.6.6), establish a transitional approach to pricing and infeasibility management for new EDAM Entities (Section 33.27.1), and extend pricing correction timelines when coordination with external BAAs is required (Section 35.3.2). These changes reflect PGE’s view that EDAM implementation must prioritize operational stability, especially during onboarding of new EDAM Entities.
6. Enhancements to E-Tag Validation and Intertie Scheduling (Section 11.32):  PGE supports the proposed clarifications to HASP reversal, E-Tag timelines, and intertie schedule validation. Accurate tagging and alignment between physical operations and market outcomes are essential for reliability and for preventing inappropriate cost shifts between BAAs.

PGE supports the CAISO’s proposed EDAM and DAME tariff amendments. PGE appreciates CAISO’s continued engagement with EDAM Entities and stakeholders and looks forward to ongoing collaboration to address issues and questions raised throughout implementation and stabilization of EDAM.

2. Please provide any additional questions you may have

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

• Sections 40.6.5.2.1, .2, .3, .4 - Resource Adequacy Bulk Changes. SCE has concerns with the proposed tariff clarifications. SCE believes that requiring RA Import resources to ‘reassign’ to either specific resources for EDAM and WEIM footprint resources or specific DGAPs for non-WEIM resources by the RTM is not necessarily a clarification, but rather a potential significant change in market design and policy. These concerns were echoed by multiple stakeholders in the recent mid-November CAISO EDAM workshops. Since then, CAISO has acknowledged concerns from stakeholders and has announced that the GGAP based changes would be delayed until the beginning of 2027, at earliest. SCE supports this delay. Given this delay, can the CAISO please clarify whether these proposed changes would be included in this contemplated near-term tariff clarification filing?  These tariff changes would appear to cause new burdens on market participants and SCE requests that the CAISO provide further explanation of how the changes are consistent with approved policy and existing tariff authority.  Instead, SCE believes that these or similar changes be subject to further stakeholder process and board approval.

• Section - 33.23 Transmission Service Requirements for EDAM Resources. SCE notes the following insertions (highlighted in yellow):

An EDAM Resource Scheduling Coordinator must obtain transmission service from an EDAM Transmission Service Provider, which may be satisfied through the following options:

(a) The EDAM Resource is a designated network resource under the terms of an EDAM Transmission Service Provider tariff;

(b) The EDAM Resource reserves firm point-to-point transmission service of any duration under the terms of an EDAM Transmission Service Provider tariff, or

(c) The EDAM Resource is associated with an EDAM Legacy Contract or an EDAM Transmission Ownership Right.

If options (a), (b), or (c) above are not satisfied, the CAISO will inform the EDAM Entity associated with the EDAM Transmission Service Provider so that the EDAM Transmission Service Provider may assess a transmission charge based on the transmission rate for the lowest duration of firm transmission service offered under its tariff, which may be a daily firm or hourly firm transmission service.  Where a response is unable to satisfy options (a), (b), or (c) above, the EDAM Transmission Service Provider tariff may provide for an adjustment of the firm transmission service charge as appropriate.

SCE has a contracted VER located in the Pacificorp BAA and has communicated general concern about potentially being assessed concurrent transmission charges for both market awards that would be assessed an hourly firm transmission rate plus the cost of having to procure PTP transmission for the same volume output from the resource. SCE would appreciate the opportunity to have continued discussion with both CAISO and Pacificorp on how to resolve this issue through a potential ‘adjustment of the firm transmission service charge as appropriate’.

2. Please provide any additional questions you may have

In the proposed revisions to Sections 11.2.1.8.1 and 11.2.1.8.2, the tariff has been clarified to cap the unavailable IR quantities by the difference between the IR award and the Five-Minute Imbalance Reserve Quantity. The Five-Minute Imbalance Reserve Quantity is defined as “For a resource with an Imbalance Reserves Award, the five-minute ramp capable portion of the award measured as the MW quantity of the resource’s ramp capability above the Day-Ahead hourly Energy schedule, in the case of IRU, or below that schedule, in the case of IRD. The ramp capability is determined based on the Master File-registered ramp rate used to optimize the day-ahead market.” Please explain why the unavailable IR quantity is being reduced by the Five-Minute Imbalance Quantity. This seems to imply that fast ramping resources (e.g. batteries) could have a zero or even negative unavailable IRU quantity, which does not seem consistent with the intent.

• The proposed revision in Section 30.5.2.8 clarifies that RUC Availability Bids cannot exceed the economically bid portion of the energy curve and that resources offering economic energy must submit RCU bids for the entire economic bid range. The language in Section 31.5.1.2 still refers to RUC Availability Bids and “Energy Bids”, instead of specifying Economic Energy Bids. Also, it states that “A Scheduling Coordinator representing an Eligible Intermittent Resource must submit RUC Availability Bids for RCU at a quantity equal to their forecasted output based on the forecast referenced in Section 34.1.6.” Does this also apply to Eligible Intermittent Resources(EIRs) that only submit self-schedules? Or, like in Section 30.5.2.8, does it only apply to EIRs that submit economic bids? Please clarify the tariff language further.
• Is the proposed revision in Section 40.6.1 (4) supposed to refer to the economic bid range of the Energy Bid Curve, consistent with the changes proposed in 30.5.2.8?
• Section 40.6.8 (f) says “.  For RA Resources that fail to submit any RUC Availability Bid for either RCU or RCD, the Generated Bid is for the required quantity at the Default Availability Bid.” But there is no must offer obligation for RCD. Please clarify the intent of RCD in this section.
• In addition to the proposed clarifications provided, there are some other areas where I would like to seek further clarification or edits:
  • Section 8.4.1.1 (g) states: “In the Real-Time Market, where a storage resource using the Non-Generator Resource model will not have sufficient State of Charge to meet its Ancillary Services Schedule, Imbalance Reserves Award, or RUC Award, the CAISO will dispatch the storage resource to have sufficient State of Charge to meet its Ancillary Services Schedule, Imbalance Reserves Award, or RUC Award.” If a storage resource has ancillary service awards and imbalance reserves and/or RUC awards in a given interval, is the resource only dispatched to have sufficient SOC for the most binding of the awards? Please clarify.
  • Section 30.5.8.2 incorrectly states that Demand Bids and Virtual Bids can be submitted to the real time market.
  • Section 30.1.1 does not include IR and RC bids

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

The Six Cities have the following comments and questions regarding the indicated sections of the Extended Day-Ahead Market Tariff Clarification Matrix posted on November 4th:

Sec. 11.2.4.1.2              Please provide an expanded explanation for the proposed changes to this section.  If the Hourly CRR Congestion Fund is only determined for Transmission Constraints in the CAISO BAA (that are congested in the IFM in a settlement period), why do EDAM Entities need to have an Hourly CRR Congestion Fund set at $0?  Do these entities need to have this fund at all? 

Sec. 33.23                      3^rd paragraph, line 7 - - change “response” to “resource”

                                                                line 8 - - change “options” to “option”

                                                                line 24 - - insert “daily or” before “hourly”

Sec. 33.30.8.3               Will CAISO provide any notice to a Scheduling Coordinator within the CAISO BAA that does not provide an E-Tag for an import from non-resource-specific forward supply contracts within three hours following publication of the Day-Ahead Market results?  If so, add appropriate language so stating.  If CAISO does not plan to provide such notification, please explain why not.

Sec. 34.2.1                     Please explain the effect of the proposed change on low-priority export schedules cleared in the HASP.

App. C, Part A.8            Although the matrix explanation states that “[t]his revision . . . also adds language to clarify the CAISO will calculate LMPs at pricing nodes within the Market Area,” there is no added language shown in redline on the matrix, and there do not appear to be any differences from the language filed in FERC Docket No. ER23-2686.  Please clarify.

App. C, Part A.8.1.2     It appears that the duplicate language is included at an additional location (i.e., in the immediately preceding paragraph) in Part A.8.1.2 as included in the filing in Docket No. ER23-2686.  In addition, the sentence beginning with “Further” is incomplete in its current form; it appears the sentence could be corrected by deleting “that” after “self-schedules.”

Bulk Update revisions              The Bulk Update revisions shown at pages 26 – 35 of the matrix appear to relate to provisions that CAISO has stated it plans to defer for a transition period of at least one year.  Please clarify whether that is correct and, if so, when CAISO plans to submit these revisions for CAISO Board and FERC approval.  These revisions appear to involve substantive changes in practices rather than clarifications of existing policy.  They do not seem appropriate for a tariff clarifications filing, particularly given that they seem to remain under discussion in implementation workshops.

2. Please provide any additional questions you may have

The Six Cities have no additional questions at this time.

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

November 18, 2025

CAISO EDAM Tariff Clarifications Matrix

The Energy Authority (TEA) Comments

TEA supports the clarifications made through page 25 of the draft EDAM Tariff Clarifications published on November 4, 2025, but does not support the intertie scheduling and associated RA-related changes on pages 26 and following.

TEA appreciates the format used and the detailed rationale provided for each proposed change in the first 25 pages. TEA notes, however, that detailed rationales were not provided for the proposed intertie scheduling changes and to an extent did not adequately connect the dots to the conforming RA-related changes on page 26.

TEA strongly supports the Tariff clarification proposed for Section 33.23, Transmission Service Requirements for EDAM Resources (p. 16). PacifiCorp, in its TSP role, is unable to offer Firm transmission service in many areas within each of its BAAs and therefore it is not possible for certain EDAM SCs to acquire the Firm PTP or Network rights required by the current EDAM Tariff. This exposes these entities to additional costs and absent changes would cause them in some instances to be charged twice for transmission in EDAM. It also would expose them in some circumstances to unauthorized use penalties on top of the double-charge for transmission service. It is important to note though that CAISO making this change is only the first step to fixing these and associated problems – the EDAM Entity TSP must also update their Tariffs and Business Practices to ensure their customers are not harmed by the existing policy embedded in the EDAM Entity Tariffs. And further, the CAISO and the EDAM Entities need to build on this allowance to assess how this identified lack of Firm transmission impacts EDAM SCs’ ability to attain a Tier One congestion hedge in EDAM. This connects also to management of Designated Network Resources in EDAM, which today compel entities to rely on non-firm Network transmission to support spot-market firm-energy transactions. The EDAM RSE necessitates pre-market firm-energy transactions between gen and load SCs and this DNR issue combined with the congestion hedge rules is a significant impediment to EDAM LSEs’ ability to self-cure their RSE positions through interchange and intrachange transactions.  

TEA does not support CAISO’s implementation plans regarding intertie scheduling for the CAISO BAA and non-CAISO EDAM BAAs as discussed to date and due to the interaction between intertie scheduling and RA also does not support those related changes. TEA outlined its concerns during the recent CAISO meetings on these topics and in its recently-submitted comments[1]^,[2].

With just over five months until EDAM go-live, TEA believes CAISO needs to move to a triage approach to implementation planning, specifically regarding its policies and practices that impact scheduling interchange between the WEIM BAAs, the CAISO EDAM BAA, and the non-CAISO EDAM BAAs. CAISO should look for solutions that fit within its existing Tariff to the extent possible while also being minimally-disruptive to the markets its members engage with – such as the western bilateral trading-hub markets, markets for import RA, transmission markets, and forward financial markets.

TEA also supports the CAISO beginning to scope a first round of “EDAM Enhancements” for future tariff changes that run through an expediated stakeholder initiative, which could include assessing a transition to a GAP-Tie methodology and finding ways to make the dispatch of RA resources sited in a WEIM or EDAM BAA more efficient and more tightly integrated with in-market solutions.

TEA is currently drafting additional comments, scenarios, and suggested next steps for an interim intertie and Import RA scheduling policy to support EDAM go-live on May 1, 2026, and looks forward to discussing those ideas with CAISO at the earliest opportunity.

Following the December 3 meeting, CAISO should file the Tariff Clarifications included in the first 25 pages to ensure they can be timely approved and that EDAM TSPs have an opportunity to make conforming changes to their OATT(s). However, until additional stakeholder discussions can be worked through and an interim policy arrived at, CAISO should not act on the remaining proposed changes on page 26 and following.

[1] https://stakeholdercenter.caiso.com/Comments/AllComments/47dc2bc6-758f-4753-8041-9362ed524ab9#org-5c7f2c45-ac78-484c-bab0-e0662947d95d

[2] https://stakeholdercenter.caiso.com/Comments/AllComments/47dc2bc6-758f-4753-8041-9362ed524ab9#org-09fb7c59-d55f-40db-a9b7-667a12b3a788

2. Please provide any additional questions you may have

N/A

1. Please provide your organization’s feedback regarding the Extended Day-Ahead Market Tariff Clarification Matrix, which was posted on Nov 4th

Please see attached document.

2. Please provide any additional questions you may have

During the meetings on 11/5, 11/6, and 11/14 the CAISO noted that for non-resource specific imports that are coming from non-EDAM BAAs the import bid can only be at a CAISO BAA scheduling point if the source BAA is adjacent to the CAISO BAA, otherwise it must be imported at the most adjacent BAA and then transfered into the CAISO rather than direclty imported. The Tariff Clarifications provided do not seem to include language around that bidding rule.