Comments on Draft Tariff Language

FERC Order 831 - Import bidding and market parameters

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Comment period
Sep 15, 08:00 am - Sep 24, 05:00 pm
Submitting organizations
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Joint Commenters
Submitted 09/24/2020, 12:12 pm

Submitted on behalf of
PacifiCorp; NV Energy, Puget Sound Energy, Portland General Electric, Idaho Power

1. Provide a summary of your organization’s comments on the draft tariff language (optional):

PacifiCorp, NV Energy, Puget Sound Energy, Portland General Electric and Idaho Power, (collectively, the "Joint Commenters") appreciate the opportunity to submit comments on the California ISO ("CAISO") FERC Order 831 final proposal and draft tariff language.

In light of the Federal Energy Regulatory Commission (“FERC”) order in Docket No. ER19-2757 issued September 21, 2020, the Joint Commenters request that the CAISO synchronize the effective date of this penalty parameter tariff filing with the March 21, 2021, effective date directed by FERC in its September 21 order.  Aligning the effective dates is critical to achieving the intent of this initiative.

2. Provide your organization’s comments on section 6.5.2.3.7 Constraint Relaxation Threshold:
3. Provide your organization’s comments on section 27.1.2 Ancillary Service Prices and all relevant subsections:
4. Provide your organization’s comments on section 27.4.3 CAISO Markets Scheduling and Pricing Parameters and all relevant subsections:
5. Provide your organization’s comments on section 30.5.2.4 Supply Bids for System Resources:
6. Provide your organization’s comments on section 30.6.2.1.2 Real-Time Dispatch Options and all relevant subsections:
7. Provide your organization’s comments on section 30.7.12 Validation of Bids in Excess of Soft Energy Bid Cap, Hard Energy Bid Cap, or Minimum Load Cost Hard Cap and all relevant subsections:
8. Provide your organization’s comments on section 30.11 Adjustments to Reference Levels Prior to CAISO Market Process and all relevant subsections:
9. Provide your organization’s comments on section 30.12 After-CAISO Market Process Cost Recovery and all relevant subsections:
10. Provide your organization’s comments on section 31.3.1 Market Clearing and Price Determination and all relevant subsections:
11. Provide your organization’s comments on section 34.10 Dispatch of Energy from Ancillary Services and all relevant subsections:
12. Provide your organization’s comments on section 39.6.1 Maximum Bid Prices and all relevant subsections:
13. Provide your organization's comments on Appendix A – Definitions:
14. Additional comments on the FERC Order 831 – Import Bidding and Market Parameters draft tariff language:

Southern California Edison
Submitted 09/24/2020, 04:27 pm

1. Provide a summary of your organization’s comments on the draft tariff language (optional):

Please see attached. Thanks.

2. Provide your organization’s comments on section 6.5.2.3.7 Constraint Relaxation Threshold:
3. Provide your organization’s comments on section 27.1.2 Ancillary Service Prices and all relevant subsections:
4. Provide your organization’s comments on section 27.4.3 CAISO Markets Scheduling and Pricing Parameters and all relevant subsections:
5. Provide your organization’s comments on section 30.5.2.4 Supply Bids for System Resources:
6. Provide your organization’s comments on section 30.6.2.1.2 Real-Time Dispatch Options and all relevant subsections:
7. Provide your organization’s comments on section 30.7.12 Validation of Bids in Excess of Soft Energy Bid Cap, Hard Energy Bid Cap, or Minimum Load Cost Hard Cap and all relevant subsections:
8. Provide your organization’s comments on section 30.11 Adjustments to Reference Levels Prior to CAISO Market Process and all relevant subsections:
9. Provide your organization’s comments on section 30.12 After-CAISO Market Process Cost Recovery and all relevant subsections:
10. Provide your organization’s comments on section 31.3.1 Market Clearing and Price Determination and all relevant subsections:
11. Provide your organization’s comments on section 34.10 Dispatch of Energy from Ancillary Services and all relevant subsections:
12. Provide your organization’s comments on section 39.6.1 Maximum Bid Prices and all relevant subsections:
13. Provide your organization's comments on Appendix A – Definitions:
14. Additional comments on the FERC Order 831 – Import Bidding and Market Parameters draft tariff language:
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