ACP-California
Submitted 08/25/2021, 04:10 pm
Submitted on behalf of
ACP-California
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
ACP-California appreciates CAISO’s ongoing efforts to improve the MIC process. Given California’s new and growing need for a diverse set of clean resources, MIC is becoming increasingly important. We applaud CAISO’s efforts in the Revised Straw Proposal to look at new methods for expanding MIC through the newly proposed “MIC expansion request” process.
In these comments, we suggest that the methods for expanding MIC be broadened to include another, separate option to expand MIC through an “expression of interest” (and subsequent subscription) process. Under an “expression of interest” process, interested parties (LSEs, generators and potentially others) could indicate to CAISO an interest in expanded MIC at individual branch groups, without having to meet pre-defined requirements (such as having an existing RA contract). If sufficient interest is identified through the expression of interest, CAISO could study MIC expansion options and either approve those expansions as economic/in the interest of ratepayers or offer interested parties an opportunity to pay for a subscription to the expanded MIC at the applicable branch group.
Additionally, we encourage CAISO to allow not only LSEs, but also developers, to acquire MIC through the expression of interest and subscription process proposed in these comments. This would provide an avenue through which resources that can deliver to CAISO branch groups could obtain (and retain) MIC and may improve and streamline contracting with CAISO LSEs for imported RA resources. We appreciate CAISO’s efforts to continue to explore improvements to the MIC process and look forward to continuing to participate in this initiative.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
Improved transparency will be important for imported RA resources and LSEs going forward. Making data on owners of MIC allocations at the branch group level publicly available will be beneficial to various market participants.
CAISO should ensure that, whatever this data is available to be publicly posted, it is broadly available and easy to access. Providing access to information through CAISO applications (such as CIRA) may inhibit access by some parties and/or add difficulty and time to the process of acquiring information on MIC. All data that can be publicly posted should be easily accessible (e.g., on the CAISO website) and should not require interested parties to utilize CAISO applications.
Additionally, ACP-California supports the suggestion of Joint Parties for CAISO to augment the information it posts on MIC to include a summary of the branch groups that were over requested in steps 4a, 4b, 9, 11, and 13. The information provided by CAISO should also include information on how many MWs in particular branch groups were over requested by to improve overall MIC transparency.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
ACP-CA appreciates that CAISO has included this topic in the Revised Straw Proposal. Considering new and improved methods for expanding MIC is an important undertaking which can support LSEs ability to meet RA obligations with a broader set of diverse, clean imported resources which may be delivered on new transmission. ACP-California, therefore, supports the proposed “expansion request” process CAISO has outlined to provide a new avenue to expand MIC, whereby entities meeting certain criteria can request MIC expansions.
In addition to the more formal MIC expansion request process CAISO has proposed in the Revised Straw Proposal, which includes certain criteria of “legitimate need” in order to limit queued requests to increase MIC, ACP-California suggests that CAISO should also develop a process by which an indication of interest for expanded MIC can be considered without a stringent demonstration of “legitimate need.” Thus, we suggest the addition of another, separate process by which MIC may be able to be expanded. This additional process will be referred to as the “expression of interest” and subscription process.
At a high-level, an “expression of interest” process would allow interested parties (including LSEs and developers) to indicate their interest in expanded MIC at a particular branch group. This would provide CAISO an indication of the commercial interest in expanding MIC at particular locations. CAISO would utilize these expressions of interest to determine the locations where there is the most interest in MIC expansion. CAISO could then study upgrade opportunities to expand MIC at the locations where there is the most interest. Similar to CAISO’s MIC expansion request proposal, if the identified upgrades from the “expression of interest and subscription” process are shown to be economic or in the best interest of ISO ratepayers, then the MIC expansion could be paid for by ISO ratepayers and allocated to LSEs using the applicable allocation methodology. But, if the expansion is not found to be economic or in the best interest of ratepayers, interested parties could be given an opportunity to subscribe to increased MIC at the location, via paying for their share of the associated upgrade costs. This type of a process could facilitate expansions to MIC based on commercial interest and, in doing so, and could help improve CAISO’s access to a diverse set of clean resources. The opportunity to indicate an interest in expanding MIC, and to subscribe to MIC, should be afforded not only to LSEs, but also to developers of generation/transmission which may seek to provide imported RA resources to CAISO LSEs.
ACP-California suggests that CAISO augment its proposal related to increasing MIC to also include a process to indicate commercial interest in expanding MIC and to develop a subscription model where expanded MIC could be allocated or purchased at locations with the highest level of interest. Importantly, for the MIC expansion request process proposed by CAISO and for the “expression of interest and subscription” process proposed in these comments, we urge CAISO to include options for generation/transmission developers to, themselves, acquire and retain expanded MIC. Such a process would help streamline and provide certainty to contracting for imported RA resources.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
ACP-California does not oppose giving LSEs with RA contracts priority during the step 13 of the allocation process and agrees with Six Cities that it would be reasonable to assign MW in proportion to the size of each requestor’s RA contract rather than on first come-first serve basis.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
California Community Choice Association
Submitted 08/25/2021, 01:52 pm
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
The California Community Choice Association (CalCCA) appreciates the opportunity to submit comments on the Maximum import capability (MIC) Enhancements Revised Straw Proposal. CalCCA generally supports the California Independent System Operator (CAISO’s) proposal, specifically the proposal to enhance transparency to facilitate trades more easily and increase the usage of available MIC. CalCCA also requests the CAISO monitor and report out on the amount of MIC being locked in for long-term use. These changes, coupled with the proposals contemplated in the Resource Adequacy Enhancements initiative that would replace substitution requirements and Resource Adequacy Availability Incentive Mechanism (RAAIM), will result in the efficient allocation and use of MIC.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
CalCCA supports the CAISO’s proposal to improve transparency. The CAISO proposes to make data publicly available through a web interface identifying most up-to-date owners of MIC allocations at the branch group level including megawatt (MW) quantity, contact, and MWs available for trade and aggregate usage by branch group level after Resource Adequacy (RA) showings are submitted. Improvements to transparency will allow for load-serving entities (LSEs) to trade MIC more easily by identifying potential entities with MIC available to trade at different locations.
The Revised Straw Proposal asks whether the CAISO should aggregate of MIC usage by the California Public Utilities Commission (Commission) versus Non-Commission jurisdictional LSEs or provide a single aggregated number for all LSEs. CalCCA recommends the CAISO split the aggregation by Commission versus non-Commission jurisdictional LSEs so that if unused MIC is primarily attributable to LSEs under one group or the other, the appropriate local regulatory authority(ies) can investigate the primary causes of unused MIC for their LSEs.
In addition to providing the data proposed in the Revised Straw Proposal, the CAISO should also monitor and report out on the amount of multi-year MIC locked in by LSEs on specific branch groups. CalCCA does not take issue with the opportunity for LSEs to lock in longer-term MIC for multiple years as adopted in the MIC Stabilization and Multi-Year Allocation initiative but requests the CAISO monitor and report out on how much MIC is being locked in for multiple years to ensure adequate short-term MIC is also available. If in the future significant portions of MIC are locked in many years forward (including evergreen contracts), it could create challenges for LSEs year-long import contracts looking to secure MIC. The CAISO should monitor and report out on the amount multi-year MIC so stakeholders are aware of the amount of MIC that is locked in for future years.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
No comments at this time.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
No comments at this time.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
No comments at this time.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
No comments at this time.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
In the Revised Straw Proposal, the CAISO lists several issues that the CAISO does not plan to move forward with or that require further exploration before moving forward with a proposal. These issues include developing an auction mechanism for allocating MIC, conducting deliverability studies after RA showings, releasing unused MIC, and changing the methodology for calculating MIC to include liquidity. CalCCA generally supports the CAISO’s decision not to move forward with these changes at this time, given the current allocation process generally works well by allocating MIC to LSEs responsible for paying the costs of the transmission system and meeting RA obligations. A method that continues to allocate MIC to LSEs based on its load ratio share, coupled with improvements to transparency proposed in this initiative and the removal of substitution requirements and RAAIM contemplated in the RA Enhancements initiative, should result in efficient allocation and use of MIC.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
CalCCA continues to support the Energy Imbalance Market (EIM) Governing Body classification for this initiative.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
No additional comments at this time.
California Department of Water Resources
Submitted 08/25/2021, 02:01 pm
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
CDWR continues to support CAISO efforts on potential improvements (in the areas of MIC calculation, allocation, and usage provisions) that maintain the fundamental principle of the MIC framework that existing ownership rights, existing transmission contracts, and pre-existing RA commitments should be recognized and respected. CDWR acknowledges that CAISO does not plan to move forward with three scope items: 1) conducting deliverability studies at the end of RA showings process, 2) incorporation of auction or market-based assignment process, and 3) recapture and release of unused MIC allocations.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
CAISO considers making MIC data publicly available (potentially in CIRA) identifying owners of all MIC allocations at the branch group level including MW, contact person, MWs available for trade etc. The exact information that will be posted in CIRA should be identified in this proposal.
If CAISO updates the unused MIC daily, it will provide further clarity and opportunity for a bilateral transaction for recapture of unused MIC until the plans are locked at T-30. CAISO should also consider if unused MIC (after T-30) can be utilized for forced outage or planned outage substitution by an import resource after the RA showing, by the original owner of the MIC allocation, and by another entity who wants to trade the unused MIC for substitution using an import resource.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
No comment.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
CDWR is supportive of CAISO’s proposal that stakeholders with the following legitimate reasons be allowed to make requests for MIC expansions under a new process: 1) Existing RA import contract (internal LSEs) not already used as Pre-RA Import Commitment or New Use Import Commitment. 2) Owners of new transmission connecting to the CAISO grid from an external Balancing Authority Area (BAA) if not already covered under the policy-driven MIC expansion option.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
The CAISO in the proposal specifies that if two or more LSEs have RA contracts that exceed the amount left after step 12 on any given branch groups, then the assignment will go to the request received first (earliest) and so on until all MWs have been assigned. CDWR prefers that the allocation be prorated than the first come first serve basis; there should be a fixed deadline when requests are submitted and after the deadline, total available import capability should be prorated to the aggregated request for allocation after step 12 so all the entities in need of MIC can benefit from such allocation.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
CDWR supports the CAISO intent to update Tariff and Reliability Requirements BPM language to be consistent with current approved practice of using two decimal places in transactions, and showings; the proposal specifies the need to make a change in the section 40.4.6.2.2.2 to two decimal numbers.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
MIC calculation based on shown RA may not be appropriate because some contracts that are dependent on hydrology (such as hydro resource) may have inherent uncertainty associated with the availability of resource and if an LSE’s load is hydrology dependent, there could be wild swings in LSE’s RA showing quantity utilizing the MIC.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
No comment.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
CDWR agrees that deliverability study at the end of RA showings could leave LSEs with stranded assets and has a possibly significant ramification on Capacity Procurement Mechanism (CPM) backstop costs allocations.
Northern California Power Agency
Submitted 08/27/2021, 09:43 am
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
Please see item four (4) below:
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
No comments at this time.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
No comments at this time.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
NCPA is concerned about CAISO’s proposed solution to “collect [contractual] data and to make it available to the CPUC for preparation of the main portfolio.” This is seemingly in response to an issue identified by the Six Cities in their Straw Proposal comments; that CAISO incorrectly assumes that the “CPUC portfolio accounts for all loads including non-CPUC jurisdictional entities” and therefore “does not attempt to obtain information from non-CPUC jurisdictional LSEs regarding the external resource procurement plans” in policy-driven MIC expansion studies. NCPA is in agreement with Six Cities that CAISO should take the contracts of non-CPUC jurisdictional utilities into account in the TPP or the MIC process, assuming that the data required is narrowly tailored and appropriately safeguarded if commercially sensitive. However, NCPA does not understand CAISO’s rationale for providing the data to the CPUC.[1] CAISO is responsible for assuring that the total portfolio it considers is appropriate for the analyses it conducts, rather than delegating the function to the CPUC. The proposal also lacks clarity on what the CPUC would do with the data.
NCPA concurs that CAISO should address the issue identified by the Six Cities, but the proposal to do so is lacking in important details and should be reconsidered.
[1] NCPA notes that it is not clear that the CPUC even has a need for the data or that it intends to include the data in its portfolio.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
No comments at this time.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
No comments at this time.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
No comments at this time.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
No comments at this time.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
No comments at this time.
Pacific Gas & Electric
Submitted 08/25/2021, 04:32 pm
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
PG&E supports the implementation of the following items proposed in the revised straw proposal:
- Additional transparency during the allocation and trading process and especially to the ownership and usage (after the allocation process ends).
- Proposed improvements to step 13 of the allocation process.
- Clarifications and clean-up of language in the Tariff and Business Practice Manual regarding standard use of two decimal places.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
PG&E welcomes CAISO’s proposal to improve transparency of ownership and usage during the allocation and trading process. PG&E supports CAISO’s proposal to make the following data publicly available through a web interface (or publishing):
- Identify the most up-to-date owners of all MIC allocations at the branch group level – including MW quantity, contact person and “MWs available for trade”.
- Aggregate usage by branch group level after validation of each month ahead and year ahead RA showing.
PG&E would welcome more transparency on the CAISO’s MIC assignment process by providing more explanation on the amount of assigned MIC to LSEs based on their individual request (Step 5 to 12). We recognize that the information could be confidential and do not request that non-essential details on the allocation calculation be made public. However, the CAISO could provide a descriptive note to each LSE explaining the amount of MIC assigned compared to the MIC requested.
The CAISO requests stakeholder opinion on how the aggregation should be done either for all LSEs or for CPUC jurisdictional LSEs versus non CPUC jurisdictional LSEs. PG&E has no preference at this stage. However, PG&E would welcome any clarifications that the CAISO could share explaining if there would be useful insights by separating the import rights out by CPUC vs non-CPUC jurisdictional LSEs.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
PG&E appreciates the clarifications the CAISO provided on the deliverability studies for internal resources as well as imports (assumptions, studies, existing transmission constraints, deliverability protection etc.) in the previous proposal. PG&E has further questions raised in the below section.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
On the inclusion of contractual data from non-CPUC jurisdictional LSEs into the main portfolio, PG&E supports the proposal to have the ISO collect such data and to make it available to the CPUC for the preparation of the main portfolio.
On the proposed new way for MIC expansion, the CAISO should clarify what aspects of the MIC expansion consists of an increased MIC availability due to existing transmission capacity instead of a request to increase MIC capability with new grid upgrades.
PG&E has initial questions on the legitimate reasons for MIC expansion requests that the CAISO has proposed:
- What type of existing import contract will the CAISO consider a legitimate reason? Could the Western Systems Power Pool (WSPP) Schedule C (or contractually equivalent) firm energy contract be a legitimate reason?
- On the second reason – why would the new transmission not automatically generate a MIC availability expansion?
As pointed out by the ISO, PG&E believes this requires further discussion and should be addressed in a broader context of existing initiatives or a new initiative.
PG&E also believes the CAISO could consider a process similar to the Distributed Generation Deliverability (DGD) study for import. As expressed by some stakeholders in their comments to the straw proposal (i.e. Six Cities, and Southwestern Power Group (SWPG), Pattern Energy and Valley Electric Association), the CAISO could consider adding a planned import resources study process. This new study could also help address the asymmetry of data quality between CPUC versus non-CPU jurisdictional LSEs. This process could leverage some of the components of the existing DGD process that allocates available deliverability to LSEs to allocate based on meeting eligibility requirements. Additionally, a MIC expansion process could be created similar to the existing GIDAP that outlines a clear path for resources to obtain deliverability either through the TPP approved upgrades or self-funding upgrades.
On the other ways for MIC expansion, the CAISO recaps in the MIC expansion section that starting this year the LSEs have an opportunity to obtain multi-year reservation of their MIC allocations at certain branch groups based on their new contracts. In the MIC stabilization and multi-year allocation the CAISO conducted last year, the CAISO was proposing a phased approach on the type of new contracts that could lock MIC on a multi-year basis. The phase one currently in place limits eligible contracts to count for New Use Import Commitment to pseudo-tie or dynamic scheduled resources. PG&E wonders if the CAISO considers updating the types of resources that could be eligible to count for New Use Import Commitment.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
PG&E does not oppose the revision of step 13 of the MIC allocation process to give priority to existing contract. The CAISO requests stakeholder to specify if the ratio of MW requested vs MW available is preferred over first come first served, PG&E does not have any preference.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
PG&E supports the CAISO’s proposal to revise the current tariff language that limits bilateral MIC transfers to MW increments to better align with the Reliability Requirements BPM requiring that all RA requirements, transactions, and showings are done to two decimal places.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
PG&E supports the CAISO’s decision to not move forward with the proposals of 1. Conduct deliverability studies at the end of the RA showings process; 2. Incorporate an auction or other market-based mechanism into the assignment process; and 3. Recapture and then release the unused MIC allocations.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
No comments.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
No comments.
Salt River Project
Submitted 08/25/2021, 02:32 pm
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to provide comments on the MIC Enhancements revised straw proposal. SRP strongly supports the CAISO’s decision to address the broader topic of wheeling and transaction prioritization through the External Load Forward Scheduling Rights Process (ELFSRP) initiative. This change is a positive example of the CAISO responding to stakeholder feedback.
SRP encourages the CAISO to maintain close coordination between the MIC Enhancements and ELFSRP initiatives and to remain alert for potential coordination concerns that may result from splitting these two initiatives. As the MIC Enhancements initiative evolves a phased approach may be prudent, specifically for those elements of the MIC Enhancements initiative that may have a direct or indirect influence on the ELFSRP initiative. SRP encourages such an approach and asks the CAISO to identify those elements of the MIC Enhancements initiative that may influence the ELFSRP initiative to make this stakeholder process transparent.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
SRP supports the CAISO’s proposal to improve transparency by making data more accessible through a web interface.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
SRP supports the CAISO’s proposal to provide additional insight into the deliverability process and the interaction between internal resources and imports.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
SRP supports the CAISO’s proposal to address the framework and process to submit requests for customer-paid transmission upgrades outside of this initiative.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
No comments at this time.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
SRP supports the CAISO’s proposal to update the Tariff and Reliability Requirements Business Practice Manual to be consistent with FERC approved practice.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
No comments at this time.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
SRP is concerned about the timing of this initiative creating challenges for effective coordination with the ELFSRP initiative. The CAISO has ensured stakeholders that it will coordinate between MIC Enhancements and ELFSRP; however, the timing of the initiatives may make that coordination difficult. SRP suggests the CAISO consider phasing the MIC Enhancements as described below and in answer 1 above.
The schedule for the MIC Enhancements initiative includes the final proposal in October and CAISO Board of Governors (Board) consideration in November 2021 – the plan does not include any phases. Under the current schedule, the CAISO would implement MIC enhancements in spring 2022 for Resource Adequacy (RA) compliance year 2023.
The ELFSRP initiative currently includes two phases:
- Phase 1 for near-term enhancements that would be finalized for Board consideration in March 2022 and implementation in summer 2022
- Phase 2 for a long-term framework that would be finalized for Board consideration in May 2022 and implementation in January 2024
SRP is concerned about the timing differences in these initiative plans because the MIC Enhancements initiative is moving to completion much sooner than even Phase 1 of the ELFSRP initiative. SRP requests that the CAISO consider the following phased approach for the MIC Enhancements Initiative:
- Phase 1 for near-term changes included in the MIC Enhancements straw proposal that do not need to be closely coordinated with the ELFSRP initiative. Phase 1 could include:
- Improved MIC transparency
- Updating Step 13 of the MIC process
- MIC and deliverability process education
- Phase 2 that better aligns with the ELFSRP Initiative timing to ensure that work in the MIC Enhancements does not need to be redone or superseded by policies developed in the broader ELFSRP proposals. Phase 2 could include new options for MIC expansion:
- Ratepayer funded option presented in the MIC Enhancements revised straw proposal
- Participant-funded/Third-party funded MIC expansion project also described in the revised straw proposal – as the CAISO indicated, any potential framework, process, and rights to use of the customer-paid transmission upgrades will all need to be considered in the larger context of other current initiatives or potentially a new stakeholder initiative and will not be developed through this MIC Enhancements initiative.
SRP respectfully asks the CAISO to identify those elements of the MIC Enhancements initiative that may directly or indirectly influence the ELFSRP initiative to make this stakeholder process transparent, and to consider the phasing in of those MIC elements so they align with the ELFSRP initiative timeline.
Because the CAISO removed elements of this initiative associated with reservation of import capability and transmission for wheel-through transactions, SRP agrees that this initiative will not require a briefing of the EIM Governing Body. If the scope of this initiative evolves to include changes to rules governing the use of CAISO transmission or otherwise affect participation in EIM, SRP requests that the CAISO reconsider the EIM Governing Body role.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
No additional comments at this time.
Silicon Valley Power
Submitted 08/25/2021, 04:58 pm
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
No comment at this time.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
SVP continues to believe improving transparency regarding ownership of MIC allocations and their use and availability will increase trading of import capability. Making the data available through a web interface by identifying the owners of all MIC allocations at the branch group level, including MW quantity available for trade along with the contact person would assist and improve the trading of import capability. Updating CIRA to facilitate the trading process would be beneficial to all users.
The data that is published should be the balance of each branch group level after validation of each month ahead and year ahead RA showing. If the remaining unused import capability is published along with the contact information of the MIC allocation owner, participants will be able to easily identify possible trading opportunities.
In response to the CAISO question, “Should the aggregation be by CPUC vs Non-CPUC jurisdictional LSEs or just a single aggregated number for all LSEs?” SVP believes there is no value in providing the disaggregated information by CPUC vs. Non-CPUC jurisdictional LSEs.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
No comment at this time.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
While SVP is supportive of providing data to improve modeling efforts and the efficiency of the MIC process, we are concerned about the additional administrative burden introduced along with the use of another entity to bypass limitations of jurisdiction. In this case, CPUC would be obtaining data for its purpose through the introduction of new requirements by the CAISO. What’s not clear is
- what new level of reporting will become mandatory
- what type of contract data will be collected
- will the data be aggregated or LSE-specific
- what protections will be provided to safeguard commercially sensitive data
This proposal doesn’t achieve any significant additional benefits and only serves as substituting the current procedure of “ISO changing or augmenting of the CPUC main portfolio since the ISO does not have visibility on what part of the main portfolio needs to be subtracted to make room for the actual non-CPUC jurisdictional contracts.” For these reasons and concerns, SVP does not support including contractual data from non-CPUC jurisdictional LSE’s.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
SVP is concerned with the first come first serve approach to allocating RIC due to the potential advantage it gives to larger staffed and financially incentivized organizations. The lack of resources/authority to follow through on contract continuity or performance to justify ownership of the MIC rights also opens up gaming opportunities. A deadline based, pro-rata approach may be more reasonable.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
No comment at this time.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
Many of these issues still need to be explored in future MIC enhancements.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
No comment at this time.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
No comment at this time.
Six Cities
Submitted 08/25/2021, 06:11 pm
Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
The Maximum Import Capability (“MIC”) Enhancements Revised Straw Proposal includes several incremental enhancements to the MIC framework that the Six Cities hope will result in some increase in the availability of MIC for additional Resource Adequacy (“RA”) Imports. In particular, the Six Cities very much appreciate the CAISO’s willingness to modify Step 13 of the MIC allocation process to provide a priority for existing RA contracts in that step of the process. In addition, the Six Cities support elements of the Revised Straw Proposal (a) seeking to improve transparency in the allocation and use of MIC and to enhance opportunities for trading of MIC and (b) outlining on a preliminary basis a process for considering stakeholder requests to expand MIC at specific branch groups. However, as described in greater detail in Item 4 below, the Six Cities are disappointed that the CAISO has not responded to previous suggestions by the Six Cities that availability of MIC be expanded on an interim basis to reflect temporarily unused deliverability reserved for resources internal to the CAISO Balancing Authority Area (“BAA”) that are not in operation.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
The Six Cities support the measures to enhance transparency with respect to the allocation and usage of MIC allowances as proposed in section 4.1 of the Revised Straw Proposal. In terms of the CAISO’s request for stakeholder input on whether aggregated usage data should distinguish between aggregated usage by CPUC jurisdictional LSEs and non-CPUC jurisdictional LSEs or provide single aggregated numbers (by branch group) for all LSEs, the Six Cities do not necessarily object to reporting usage information on a bifurcated basis as between CPUC and non-CPUC jurisdictional LSEs. However, the Six Cities do not necessarily perceive a benefit to such bifurcated reporting. The Six Cities therefore support reporting based on a single, aggregated number for each branch group.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
The Six Cities have no comments on educational topics at this time.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
The Six Cities support consideration of contractual data from non-California Public Utilities Commission (“CPUC”) jurisdictional load-serving entities (“LSEs”) in the formulation of the resource portfolio that the CAISO evaluates as part of the Transmission Planning Process (“TPP”) to determine whether sufficient import capability exists to deliver new projected import contracts in furtherance of state policy goals. However, the Six Cities have concerns with the CAISO’s proposal, as described in section 4.3, sub-section 1 at page 15 of the Revised Straw Proposal, simply to collect data from non-CPUC-jurisdictional LSEs and turn it over to the CPUC. For example, it is not clear to the Six Cities why consideration of import contracts anticipated by non-CPUC-jurisdictional LSEs would require “subtractions” from the CPUC main portfolio to “make room for the actual non-CPUC jurisdictional contracts” if the CPUC main portfolio does not include such non-CPUC-jurisdictional contracts in the first place. More importantly, it is the CAISO’s responsibility to ensure that its TPP addresses the needs of all LSEs that rely upon the CAISO Controlled Grid, not just those that are subject to the jurisdiction of the CPUC. Simply collecting data from non-CPUC-jurisdictional LSEs and turning it over to the CPUC does not fulfill that responsibility.
With respect to future “state” and/or “renewable area” totals versus branch group split of actual RA import contracts as discussed in sub-section 2 of section 4.3 of the Revised Straw Proposal, the CAISO’s assumption that the problem of some branch groups being oversubscribed and others being undersubscribed will self-correct as a result of the opportunity to secure multi-year reservations of MIC allocations appears unsupported and in any event fails to address the needs of non-CPUC-jurisdictional LSEs to the extent they are not considered in the portfolios studied in the TPP.
The Six Cities very much appreciate the CAISO’s recognition in sub-section 3 of section 4.3 of the Revised Straw Proposal that there is “a need to provide an avenue” for stakeholder requests to expand MIC at specific branch groups. As the Six Cities understand the broad outline for such a process as set forth in sub-section 3, the first step would consist of a deliverability analysis to evaluate whether existing facilities could support MIC expansion to accommodate a specific request, similar to the assessments that are made with respect to ability to accommodate anticipated imports from a resource area included in a resource portfolio, but focused at the branch group level. If the deliverability analysis indicates that existing facilities could not support the requested expansion of MIC, subsequent steps would include the ability to request (and initially pay for) a facility study to identify upgrades that could support the requested expansion of MIC. At this time, important details regarding the CAISO’s conceptual proposal for addressing MIC expansion requests are lacking, and the Six Cities do not necessarily agree with all of the elements of the CAISO’s process that are outlined in sub-section 3. In particular, certain criteria, including how the CAISO will evaluate whether stakeholders have “legitimate reasons” for seeking an expansion in MIC or when it is in “the best interest of the ISO ratepayers” for a MIC expansion project to advance, require additional stakeholder discussion. The Six Cities look forward to working with the CAISO and other stakeholders to develop further the process for addressing MIC expansion requests. Relatedly, the Six Cities request that the CAISO clarify the portions of this topic that the CAISO believes require further stakeholdering in a future initiative – is it the CAISO’s intent that the entire concept and process for requesting MIC expansions be subject to a further or separate stakeholder process, or is the CAISO’s position that only the details of customer-funded MIC expansions require further stakeholdering in a separate stakeholder process? In either case, the Six Cities urge the CAISO to move forward on development of the details of these proposals so that they can be implemented as expeditiously as possible.
As noted in the summary section above, Six Cities are disappointed that the CAISO has not responded to previous suggestions by the Six Cities that availability of MIC be expanded on an interim basis where reservations of deliverability for resources internal to the CAISO BAA that are not in operation permit. The Six Cities’ previous comments in this initiative included the recommendation that the CAISO allow “Interim MIC” or “Short-Term MIC” up to the quantities of new internal resources shown as deliverable in the most recent deliverability analysis that are not yet in service. Such “Interim MIC” expansions also could include deliverability that is being preserved for resources that have ceased operation but are planning to repower or return to operation after upgrades. Reservations of deliverability for non-operational resources appear to persist for multiple years, and allowing interim use of such deliverability could accommodate additional RA imports that would contribute to reliability during the span of the reserved but unused deliverability. The CAISO has received FERC approval in Docket No. ER21-1536-000 for changes adopted through the Market Enhancements for Summer 2021 Readiness initiative to permit temporary grants of deliverability status to new internal resources under what appears to be an approach that also could apply to MIC. Such a process for granting Interim MIC allowances also could be included as an element of addressing specific MIC expansion requests.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
The Six Cities appreciate the CAISO’s inclusion of the Six Cities’ proposed modification to Step 13 of the allocation process and support its inclusion in the Revised Straw Proposal.
With respect to the CAISO’s proposal that allocations at this step be based on a “first come, first served” principle, the Six Cities request that the CAISO reconsider this approach. Instead, if two or more LSEs have RA contracts that exceed the amount left after Step 12 on any branch group, then the Six Cities propose that each LSE making “same day priority” requests based on existing RA contracts receive an allocation that is proportional to the RA contract quantities supporting their respective requests. For example, if there is 100 MWs of MIC remaining, and two LSEs – one with an 80 MW existing RA contract and one with a 60 MW existing RA contract – each request MIC at this step, each LSE would receive an allocation, with the first LSE receiving 57 MW and the second LSE receiving 43 MW.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
The CAISO’s proposal to align provisions of the Tariff and BPMs to consistently show numerical amounts to two decimal places seems reasonable.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
With respect to the discussion in the Revised Straw Proposal (at page 18) regarding evaluation of possible changes in the methodology for calculating MIC, it appears that the CAISO is either unwilling or unable to propose approaches that, short of specific MIC expansion requests as discussed above, will increase overall quantities of available MIC. There seems to be a disconnect between the CAISO’s perception of MIC availability and usage versus some LSEs’ perceptions of MIC availability and usage, particularly with respect to smaller LSEs that may receive shares of MIC that are commercially challenging to use.
The Six Cities urge the CAISO to consider studying MIC expansions at branch groups that tend to be fully subscribed, potentially as a sensitivity in the TPP. This study could entail an increase in MIC by a certain percentage or certain quantity of MWs and would culminate in an assessment of the cost of needed upgrades to accomplish the MIC expansion at the relevant groups. This would enable stakeholders – particularly the CAISO LSEs that are responsible for funding the upgrades – to weigh in on whether expanding the MIC is a worthwhile use of ratepayer funds and/or could be accomplished economically.
This proposal for an annual study (or a study at another required interval, such as every other year) of potential MIC expansion as part of the TPP would help mitigate the current situation, where the CAISO effectively (and on a basis that generally appears to be permanent) caps the amount of available MIC at historic usage levels. It would also provide stakeholders with an idea of what MIC expansion may cost relative to the cost of internal RA resource procurement.
If the CAISO believes that periodically studying potential MIC expansions would be infeasible, the Six Cities request that the CAISO explain its reasons. To be clear, the Six Cities do not believe that the need to develop criteria, assumptions, or parameters for these studies should constitute a reason not to conduct the studies.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
The Six Cities support the CAISO’s conclusion regarding the role of the EIM Governing Body. With respect to scheduling, the Six Cities continue to urge the CAISO to move forward expeditiously with this initiative to enable modifications to the MIC methodology and allocation process to be implemented as soon as feasible.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
The Six Cities have no additional comments at this time.
Southern California Edison
Submitted 08/25/2021, 09:06 am
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
SWPG/Pattern/VEA Joint Parties
Submitted 08/25/2021, 04:35 pm
Submitted on behalf of
Southwestern Power Group (SWPG), Pattern Energy, and Valley Electric Association (VEA)
1.
Provide a summary of your organization’s comments on the Maximum Import Capability (MIC) Enhancements revised straw proposal:
Southwestern Power Group (“SWPG”), Pattern Energy (“Pattern”), and Valley Electric Association, Inc. (“VEA”) (the “Joint Parties”) appreciate the opportunity to comment on the CAISO’s Revised Straw Proposal in the Maximum Import Capability Enhancements stakeholder process.
2.
Provide your organization’s comments on the improve transparency topic, as described in section 4.1:
The Joint Parties agree with the CAISO’s proposal to increase transparency by providing the MIC ownership and usage data as described on p. 14 of the Revised Straw Proposal, and for the usage data we would support the breakdown by CPUC and non-CPUC jurisdictional LSEs. The CAISO should provide transparency for all entities holding MIC allocations, including those entities who are located outside the CAISO BAA.
In addition, the Joint Parties propose that the CAISO disclose which branch groups are “over requested” during the 13-step process and by how many MWs. For example in steps 4a, 4b, 9, 11, and 13 there is the potential for branch groups to be over requested and for LSEs to receive less than their desired amount. In these cases it would be helpful for stakeholders to know which branch groups are over requested and by how many MWs so they can plan accordingly.
The Joint Parties are concerned that transparency alone will not produce liquidity in the MIC market. Today, the LSEs who hold MIC allocations are generally known, but it is difficult, if not impossible, to purchase MIC in certain months. Please refer to question #7 for further suggestions to alleviate these problems.
3.
Provide your organization's comments on the education regarding deliverability of imports and internal resources topic, as described in section 4.2:
The Joint Parties have no comments on this section.
4.
Provide your organization’s comments on the MIC Capability expansion topic, as described in section 4.3:
The Joint Parties thank the CAISO for acknowledging the need for additional MIC expansion opportunities as expressed by multiple stakeholders and for proposing solutions. Our comments are organized by sub-section of section 4.3.
First as a general observation under “Policy driven MIC expansion” the following is stated on p. 14 regarding any new policy-driven transmission upgrades needed: (emphasis added)
“If deliverability is not available then new transmission projects are proposed and approved in order for the MIC expansion to take place. In this case the expansion of MIC has to wait until after the transmission projects are in-service.”
The Joint Parties simply emphasize the need for advance planning for MIC expansion whether occurring through the current policy-driven process or the new proposed request process. Due to the potential delays in granting MIC expansion, it is important that requests be considered and studies conducted well in advance of the year needed rather than only in the year immediately prior.
- Inclusion of contractual data from non-CPUC jurisdictional LSEs
The Joint Parties appreciate the CAISO addressing this concern which was raised by multiple stakeholders. We agree with the CAISO’s proposal for it to collect contractual data from the non-jurisdictional LSEs and combine with similar data received in the CPUC portfolio. The Joint Parties would also advocate giving the non-CPUC jurisdictional LSEs the opportunity (but not necessarily the obligation) to provide future planned import resource data to the CAISO for resources anticipated but not yet under contract, since as mentioned any MIC expansion triggered by such resources may require long lead-times to implement. Since the CAISO would receive such future planned import data in the CPUC portfolios for the CPUC-jurisdictional LSEs, it should also have access to similar data from the non-CPUC LSEs to plan accordingly for their import resource needs. Given the long lead times to develop new projects which will increase available MIC, the CAISO should create a mechanism to allow development of new resource portfolios that include non-CPUC jurisdictional LSEs’ RA resources as soon as possible. While the CAISO and CPUC have indicated an intention to do so, the Joint Parties have no basis to believe that all LSEs’ resource portfolios have been included in the portfolios recently proposed by the CPUC to be used in the CAISO’s next TPP.
- Future “state” and/or “renewable area” totals vs branch group split of actual RA import contracts
In this sub-section, the CAISO describes the process for an LSE to secure the RIC needed for an RA contract at a given branch group when the branch group is different from that indicated by the CPUC portfolio for the respective “state” or “renewable area”. The main point here is that in order for the LSE to secure the unlocked RIC as described here, there would need to be sufficient RIC MW available at the desired branch group to meet the anticipated RA contract need, which only reinforces the need for additional MIC expansion opportunities (see following sub-section).
- LSE requests to increase import capability at specific branch groups
In this sub-section, the CAISO proposes to allow requests for MIC expansion from stakeholders with legitimate reasons or meeting certain criteria. The Joint Parties propose the following as criteria for stakeholders to make such requests:
- LSEs with existing RA import contracts;
- LSEs with expiring pre-RA import allocations (in situations where MIC at a particular branch group would otherwise be reduced);
- Owners of new transmission facilities connecting to the ISO grid from an external BAA; or
- Owners of new transmission facilities or import generation with firm point-to-point transmission service to the ISO grid from an external BAA.
The Joint Parties also propose that the following provisions be incorporated in the new MIC expansion request and study process:
- Due to the potential long lead-time required to grant a MIC increase, stakeholders should be able to submit requests several years ahead of the year in which the MIC increase is needed. For example, a stakeholder could submit a request in 2022 for a MIC increase at a given branch group starting in 2025.
- On p. 16 CAISO states: “After studies are complete these requests can result in an increase in MIC if and when deliverability is available.” In the event that deliverability is available but for less than the amount requested and/or at a later date than requested, the Joint Parties propose that CAISO fulfill the request partially. For example, if a stakeholder requests a 300MW increase at a given branch group starting in 2023, and CAISO determines that there is deliverability available to increase by 200MW starting in 2024, then CAISO should grant the partial increase and specify a date when the full increase can be granted, or allow the stakeholder to pay for a facility study for the amount that could not be granted.
- Similar to b), if CAISO conducts a facility study and determines that part of the MIC increase can be granted through upgrades that CAISO considers “economic or in the best interest of the ISO ratepayers”, then CAISO should grant the partial increase.
- The criteria for which upgrades will be considered “economic or in the best interest of the ISO ratepayers” should be made transparent before the new process is implemented and preferably during this stakeholder process itself.
- The CAISO should implement an aggressive timeline for implementing the MIC expansion program, given the fact that additional MIC is needed now.
5.
Provide your organization’s comments on the Step 13 - give priority to existing RA contracts topic, as described in section 4.4:
The Joint Parties agree with the proposed change to give LSEs with existing RA contracts priority for obtaining unallocated RIC during step 13, but with two modifications.
As stated by CAISO in the Revised Straw Proposal and the August 11 stakeholder call if two or more LSEs have RA contracts that exceed the amount left after step 12 on any branch group, then CAISO proposes that the assignment go to the request received first (earliest) and so on until all MWs have been assigned. This approach seems arbitrary in that one LSE could grab all the MWs for its RA contract by simply having faster mouse-clicking speed than another. Instead, we would advocate for the MWs to be assigned in proportion to the size of each requestor’s RA contract using the method proposed by Six Cities in their comments since this approach seems more objective and equitable.
The CAISO should also consider giving priority to RA contracts with longer terms (i.e. greater than or equal to X years) over contracts with shorter terms. By encouraging longer term contracts, the CAISO will ensure a stable supply of imported RA resources.
6.
Provide your organization’s comments on the Tariff and Reliability Requirements BPM alignment of terms topic, as described in section 4.5:
The Joint Parties agree with this proposed change.
7.
Provide your organization’s comments on other issues that require further exploration, as described in section 4.6:
The Joint Parties have comments on the following issues listed in this section:
Change in methodology for calculating MIC
Since CAISO is already proposing to reveal data on MIC ownership and usage, this information combined with the data on over-requested interties as mentioned in question #2 could help determine “liquidity” at branch groups and improve the MIC calculations per branch group going forward. For example, if branch group A has 100MW of MIC that is held but not used in RA showings but branch group B is over-requested by 100MW, then CAISO could take this information into account in future MIC calculations at these respective branch groups.
Incorporate an auction or other market based mechanism into the assignment process
As mentioned previously the Joint Parties are concerned that transparency alone will not produce liquidity in the MIC market, as the identity of many current MIC holders is already known but yet it is difficult and often impossible to purchase MIC in certain months. Therefore, the CAISO should consider developing incentives to selling (or disincentives from holding) unused MIC.
Recapture and then release the unused MIC allocations
The Joint Parties support the comments of the CAISO Department of Market Monitoring (DMM) that are being filed in this round of comments. DMM points out that external RA resources have not been used for resource substitution in the past three (3) years, and the CAISO has confirmed that external capacity can only be used for RA substitution for forced outages of external capacity. Therefore, it does not appear that resource substitution is the reason that unused MIC has been withheld from the market.
DMM has observed that MIC on some branch groups has gone unused between 2019 and September 2021 to support import RA and in other branch groups less than 50 percent of MIC has been used to support import RA in this same period (refer to DMM’s comments for specific data). Since this MIC was not used to support RA imports and was not traded bilaterally, it provided no value towards meeting LSE RA requirements. Thefore, the Joint Parties strongly encourage the CAISO to develop a process by which LSEs with excess MIC are required to release unused MIC at a specified price so that other entities seeking MIC can have access to the excess capacity on the system.
8.
Provide your organization’s comments on the proposed initiative schedule and EIM Governing Body role, as described in section 5:
The Joint Parties support the proposed initiative schedule and EIM Governing Body role, with the goal of presenting proposed changes to the CAISO Board of Governors in November 2021. Also, the CAISO should propose a timeline and proposed schedule for implementing the MIC expansion program, including any additional stakeholder process as indicated in Section 4.3.
9.
Additional comments on the Maximum Import Capability Enhancements revised straw proposal:
The Joint Parties have no further comments on the Revised Straw Proposal and look forward to collaborating with the CAISO staff and other stakeholders on this important initiative.
