Comments on Issue Paper

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

APS appreciates the ability to comment on the External Load Forward Scheduling Rights Process. APS understands that with the sunset of the current priorities on May 31, 2021, additional changes will need to be implemented for Summer of 2022. However, the Phase 1 content fails to clearly state the priorities that will be in place for market participants once the current priorities sunset. The Phase 1 focus is on transparency and minor changes to the Summer 2021 framework, but the proposed changes fail to address the underlying priority levels established for different schedules looking to utilize CAISO transmission under Open Access principles. This lack of clarity is detrimental to forward procurement and reliability.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

APS requests that CAISO add the ability to notify Sink BA’s when schedules are e-tagged, but do not have a corresponding residual unit commitment (RUC) award. This transparency will allow Sink BA’s to assess the risk of export curtailments to their respective BA’s when they are not the scheduling coordinator on the transactions. A Sink BA is not made aware that a schedule importing to their BA has not been awarded in RUC and that if not awarded in the hour ahead scheduling process (HASP) is subject to curtailment. This lack of awareness can lead to reliability related problems that could be mitigated if known earlier.

APS would also request that CAISO consider making any changes in Phase 1 that bring together market and OATT related seams issues. These could be the review of the 45-day requirement for wheeling entities to procure firm energy and transmission to the CAISO scheduling point. The ability for transmission to be released on a forward basis and procured by wheeling entities seeking high priority service on the CAISO system without having to meet a 45-day advance notice.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

APS is disappointed that solutions and corrections in the external load forward scheduling rights process could not be made available for the summer of 2022. During the Summer 2021 Summer Enhancements Stakeholder process, CAISO repeatedly assured APS and others that the changes made for 2021 would be temporary. Additionally, CAISO stated that their intention was to implement permanent solutions for the summer of 2022.  We understand that current circumstances make that impractical however, we would like some assurance that Phase 2 implementation will not slip beyond the Summer of 2024 and every effort to execute prior to summer of 2023 will be made.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

APS re-iterates the principles provided at the July 13^th, 2021, workshop for consideration in development of the long-term framework for establishing scheduling priorities in the market.

1. Transmission priorities should be consistent with timing and purpose of transaction for internal and external load.
2. All LSEs, internal and external to the CAISO, should have the right to substitute energy and capacity for forward contracts.
3. The CAISO should establish consistent requirements for internal and external load to establish forward priorities.
4. The CAISO should provide full transparency on any load forecast differences between Integrated Forward Market (IFM) and RUC prior to IFM run.
5. External LSEs seek equitable rights based on open access principles.

APS requests the CAISO to recognize the interaction between this issue and resource adequacy rules in California and for the CAISO to advocate for any resource adequacy changes that allow for them to account for resources utilizing the transmission system for native load and make available any available transmission capacity to other balancing authority areas that would like to procure transmission service on a forward basis. 

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

APS believes these working groups are appropriate in nature and subject matter to work towards the long-term framework.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

APS agrees with the advisory classification for this initiative.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Please see DMM's comments in attached PDF file.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

Please see DMM's comments in attached PDF file.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

Please see DMM's comments in attached PDF file.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

Please see DMM's comments in attached PDF file.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

Please see DMM's comments in attached PDF file.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

Please see DMM's comments in attached PDF file.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

Please see DMM's comments in attached PDF file.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

CPUC staff believes that the scope of this initiative should be expanded to include additional elements, as discussed further in response to Question 2, below. 

Transparency elements.  In its issue paper, CAISO proposes to include in its scope additional transparency enhancements, including 1) consolidation of terms and BPM requirements, 2) curtailment data and information, 3) data on transactions at time points, and 4) RUC load forecast adjustment data.  CPUC staff agrees that additional transparency could be helpful and support these elements, with the possible exception of data on RA imports at tie points, especially if this data is provided prior to the compliance filings.  In particular, CPUC staff is concerned that this could lead to the scheduling of additional wheeling transactions for purposes of economic arbitrage rather than for reliability needs, which could jeopardize reliability for California customers.  CPUC staff look forward to discussing this element further during the stakeholder process. Likewise, CPUC staff would like further information on whether comparable information is available from other balancing authorities, in particular information regarding the level of contracting at various tie-points. CPUC staff believe that there should be symmetry across balancing authorities so that internal CAISO load serving entities are not disadvantaged with regarding to their procurement and transmission certainty.

Substantive enhancements.  In its issue paper, CAISO proposes to consider more substantive enhancements, including: 1) high priority export status when the sum of schedules exceeds the non-RA capacity, 2) mitigating impacts of underproduction of resources supporting PT exports, and 3) minimizing unnecessary curtailment.  With regard to this last element, stakeholders have suggested that entities should have valid e-tags in order to be given priority with respect to curtailments in the post-HASP allocation process.  The CPUC does not oppose addressing the first two elements, but opposes the requirement to have valid day-ahead e-tags be considered in the curtailment and post-HASP allocation process. Because parties need source to sink transmission to obtain day-ahead e-tags, CPUC staff believes that this proposal is simply another way to effectuate using transmission external to the CAISO system to control who may use the transmission system internal to the CAISO system. CPUC staff opposes this approach for all of the reasons contained in its previous comments at CAISO and in its filings at FERC.

Regarding the timeline, CAISO has proposed that it will issue a straw proposal on October 25^th, a draft final proposal on December 22^nd, a final proposal on February 10^th, and bring the final proposal to the EIM Governing Body on March 10^th and to the ISO Board on March 23 – 24^th, with implementation in June 2022. Given that the existing tariff expires on May 31, 2022, CPUC staff is concerned that this process may not allow sufficient time for a revised proposal to be in place on June 1, 2022, which would require a CAISO filing by at least April 1^st, at the latest. It would be helpful for CAISO to clarify how it will ensure that its new proposal be adopted by FERC and implemented by June 1, 2022, or that alternatively the currently effective rules included in the existing tariff that expires on May 31, 2022, are extended in the event that the new proposals is not adopted by FERC, in order to ensure that CAISO does not revert to its previous tariff provisions, which could jeopardize the reliability of the grid.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

While CPUC staff supports extension of the current tariff provisions as a default, if changes are made, CPUC staff recommends that the scope of Phase 1 be expanded to include consideration of the following:

• Consideration/inclusion of a cap on the magnitude of the wheeling transactions. It is CPUC staff’s understanding that allowing wheeling transactions to be prioritized equal to load was premised on the fact that external load serving entities were relying on wheeling transactions to serve load, similar to internal entities relying on resource adequacy imports. However, there were no wheeling transactions in 2020 (other than existing long-term transmission contracts, TORs and ETCs). In addition, wheeling transactions this past July totaled only ~800 MW (see figure below), suggesting that, to date, external entities are not relying in wheeling transactions to serve load in a manner similar to California customers.  Further, wheeling transactions thus far have been relatively limited, but if wheeling transactions increase substantially, this could seriously jeopardize the reliability of the grid for California customers, especially if California is unable to import power (due to wheeling transactions) or is unable to move power from the north to the south across Path 26 during reliability events (see table below).

Further, as noted previously by CAISO, California has historically used its maximum import allocations at the major inter-ties and, thus, allowing wheeling could potentially crowd out RA import transactions (see figure below).[2]

Accordingly, CPUC recommend that CAISO consider limits on wheeling transactions to ensure both reliability and to ensure that Californians have access to the transmission grid during stressed system conditions, for which they pay $2.7 billion per year.

• Consideration/inclusion of a default option in CAISO’s FERC filing to extend the current framework, should FERC reject any proposed changes.  As previously noted, CPUC staff is concerned that should FERC reject or delay consideration of any proposed changes or should changes not be filed at FERC in time, that the current tariff expires on May 31, 2022. Therefore, CPUC staff recommends that CAISO consider inclusion of a default option in its filing at FERC that would extend the current framework as an alternative.
• Consideration/inclusion of CPM and RMR designations in the post-HASP allocation process.  CPUC staff recommends that CAISO consider RMR and CPM designations in the post-HASP allocation process, particularly when considering internal transmission constraints. Broadly, CAISO will consider RA transactions in the north and wheeling transactions and allocate internal transmission, pro rata, when there are infeasibilities. However, RMR and CPM are procured and paid for by California customers, are subject to Resource Adequacy Availability incentives and in all other ways are, effectively, RA resources. In some cases, these resources are even under an RA contract, but are unable to be uploaded on supply plans because that deadline closes at T-30, apparently with no exception, even for new or emergency reliability resources.  Therefore, CPUC staff recommends that these resources be included in the post-HASP adjustment process.

[1] Available at https://efiling.energy.ca.gov/GetDocument.aspx?tn=236297-1&DocumentContentId=69272;

2021:  https://efiling.energy.ca.gov/GetDocument.aspx?tn=231551&DocumentContentId=63367

[2]CAISO, “Maximum Import Capability Enhancements: Straw Proposal,” May 6, 2021, available at http://www.caiso.com/InitiativeDocuments/StrawProposal-MaximumImportCapabilityEnhancements.pdf.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

CPUC staff supports the scope of the phase 2 initiative. Regarding the timing, CAISO has indicated that it will post a straw proposal on December 22^nd, a revised straw proposal on February 24^th, a second revised straw proposal in late April, and a 3^rd revised straw proposal in mid- to late-June at the same time it reconsiders its timeline.  This would be followed by an EIM Governing Boards and ISO Board meetings in March of 2023 and implementation in 2024. CPUC staff is concerned that if CAISO goes to its governing boards in March 2023, that it is not likely that there will be an implementable solution for 2024, given that a FERC filing and approval would be required and the final structure might involve changes to the CRR and TPP processes.  This means that the short-term solution currently being considered by CAISO could be in place in 2022, 2023, and 2024, raising the issue that the short-term solution needs to be durable and fair, and address any potential reliability concerns.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

CPUC generally supports the guiding principles and, in particular, appreciates that CAISO has included as one of those principles that any durable solution should recognize native load priority.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

CPUC staff is interested in participating in the working groups and looks forward to the upcoming discussions.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

CPUC staff agrees with the decisional classification, with the CAISO Board having primary authority and the EIM Governing Body having an advisory role.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

It would be helpful to understand how CAISO prioritizes LPT exports and load in the day-ahead and day-of time frame.  In particular, it would be helpful if CAISO could explain why LPT exports were not curtailed on July 9^th, despite being cut in the RUC process and being not feasible in the real-time market due to loss of a substantial imports due to transmission outages on Malin and NOB (see figures below).

In addition, it would also be helpful to understand when CAISO will cut wheeling transactions, when the import and the export leg are not paired.  This question/concern arises from market results from July 9^th, when CAISO’s portion of Malin intertie was derated from ~3,000 MW to ~300 MW because of the Bootleg fire and NOB was derated as well.  Despite these derations, it does not appear that any wheeling transactions were cut, as shown in the figure below, with the day-ahead (DA) wheels and real-time (RT) wheels in green.[3]

It would be helpful to understand under what conditions wheels are cut if the import and the export leg are not paired, and whether this occurred on July 9^th and why or why not.

[3] CAISO, “Summer Market Performance Report – July 2021,” September 7, 2021, p. 19, available at http://www.caiso.com/Documents/Presentation-July2021SummerMarketPerformanceReport-Call-Sept7-2021.pdf#search=summer%20market%20performance%20presentation%20July.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Remove Day-Ahead E-Tag Proposal from Scope: The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) does not support the proposal to require that all high priority wheel transactions and resource adequacy imports submit a valid day-ahead e-tag.[1]   Cal Advocates agrees with the CAISO and other California stakeholders that this proposal does not align with California’s existing resource adequacy program. The California Public Utilities Commission resource adequacy (RA) rules for non-resource-specific RA imports attempt to balance resource flexibility with reliability. [2]   Requiring bidders to submit e-tags in the Day-Ahead market instead of 40 minutes before the CAISO market run,[3] could increase the costs of imports to California ratepayers without providing equal or greater reliability value.

Keep the Under Supported Priority Export Proposal in Scope: Cal Advocates supports the Joint Load Serving Entities’ (LSE) suggestion that the CAISO consider enhancements to: (1) ensure that a Priority (PT) Export is actually deliverable to its indicated export intertie and (2) curtail resources that are under-performing and significantly deviating from their export schedules. 

Cal Advocates agrees with this proposal because when a resource that supports a PT export is under-performing, it can adversely affect the CAISO’s ability to manage the grid reliably.  As the CAISO explains, “in stressed system conditions, to the extent the supporting resource is significantly underperforming compared to a PT export schedule, the CAISO needs to make up that capacity to support the export potentially exacerbating already delicate system conditions.”[4]

Phase 1 Timeline

Extend the Existing Load, Export, and Wheeling Prioritization Policy until CAISO implements the Phase 2 long-term prioritization framework.

The proposed Phase 1 timeline creates the risk that the CAISO could operate without a policy in place to prioritize energy delivery activity on the California transmission system during tight system capacity events.  The recently approved CAISO tariff changes that established load, export, and wheeling priorities during extreme events will expire June 1, 2022.  CAISO’s proposed schedule for the implementation of the External Load Forward Scheduling Rights Process Phase 1 short-term enhancements is summer 2022.  CAISO proposed implementation of the Phase 2 long-term prioritization framework starts in 2024. 

Given this schedule, the CAISO should ensure that there is no gap and that a scheduling prioritization policy is in place for extreme events until CAISO implements the Phase 2 framework. 

Prioritize Serving Native Load

The CAISO tariff now gives wheel through transactions that have confirmed priority status the same treatment as native load during tight system conditions.[5]  Cal Advocates supports this temporary change. 

For the long-term prioritization policy, the External Load Forward Scheduling Rights Issue Paper is not clear on whether or not the CAISO intends to prioritize native load and address concerns that California’s grid may not have excess transmission capacity to serve wheel through transactions during all months of the year.  California stakeholders, as well as the CAISO Department of Market Monitoring (DMM) have stated that it may be the case that “there is no excess transmission capacity beyond that needed to meet the needs of CAISO load.” [6]^{, [7]}

For these reasons, Cal Advocates recommends that the CAISO conduct a transmission capacity study to determine the capacity needed to serve native load in 2021 prior to implementing the other activities mentioned in the Issue Paper.

[1] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 19.

[2] 2022 Filing Guide for System, Local and Flexible Resource Adequacy (RA) Compliance Filings, September 24, 2021, pp. 41-45.

[3] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 20.

[4] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 19.

[5] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 7.

[6] Comments of Pacific Gas and Electric Company Before the Federal Energy Regulatory Commission, Doc No. ER21-1790, May 19, 2021, p. 4.

[7] Motion to Intervene and Comments of the Department of Market Monitoring of the California Independent System Operator Corporation, Docket No. ER 21-1790, May 19, 2021, p. 10.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

As recommended in the response to question one, Cal Advocates requests that CAISO commence an expedited study on native load transmission needs to be completed before all other activities proposed in this initiative, especially the proposed working group activities focused on developing forward transmission rights. 

The results from the study on native load transmission needs should identify the amount of excess transmission capacity the CAISO has to accommodate wheel through transactions.  The study results should also be used to determine how much reliable transmission capacity must be reserved to serve native load during peak load conditions.

The CAISO’s Issue Paper confirms that other Regional Transmission Operators (RTO) in the United States,[1] set aside/reserve transmission capacity for their respective native load/network load as an existing transmission commitment within their Available Transmission Capacity methodology.[2]  

[1]  The CAISO provided information on scheduling priority policies in PJM Interconnection (PJM), Midcontinent Independent System Operator (MISO) and Southwest Power Pool (SPP),

[2] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 31.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

The CAISO’s Phase 2 Scope of Work is as follows:

1. Develop a forward transmission reservation process for establishing scheduling priorities in the market.
2. Establish stakeholder working groups to evaluate forward transmission reservation process components for compatibility with the CAISO market structure and consistency with the guiding principles for this initiative.[1]

This proposed scope of work for Phase 2 does not prioritize determining the available transmission capacity to support wheeling activity and the transmission capacity needed to serve native load.  The CAISO states that its firm transmission reservation process framework will include consideration of the transmission capacity needs to serve native load in Phase 2 of the External Load Forward Scheduling Rights Process.  However, this discussion happens concurrently with discussions on the forward transmission reservations process.  Cal Advocates recommends that the CAISO prioritize its determination of the transmission capacity needed to serve native load before consideration of the forward transmission reservation process.  This will ensure that the reservation process excludes the system capacity necessary for the CAISO to reliable serve native load.  Accordingly, Cal Advocates requests that the CAISO’s proposed Working Group 1 [2] start immediately.  Once this working group has confirmed the preferred method for calculating native load needs in California, the CAISO should use this method to determine the amount of transmission capacity that must be reserved to serve native load in California.  This will also confirm the available transmission capacity to serve wheeling activity.

[1] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 22.

[2] The full title for Working Group 1 is Working Group 1 - Calculating Native Load & Available Transfer Capability (ATC). CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 4.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

Cal Advocates is supportive of having guiding principles for a scheduling priority framework.  Cal Advocates supports three of the six proposed guiding principles for the scheduling priority framework in the Issue Paper with some suggested edits. The three principles we support with recommended revisions are provided below with edits:

1. “Ensure CAISO’s ability to reliably serve native load needs while, and ability to provide ing available non-discriminatory access to the transmission system consistent with open access principles;
2. Ensure CAISO has the tools and processes necessary to manage the grid reliably; and
3. Maintain the efficiencies of the CAISO markets in dispatching resources to serve and meet market needs.”[1]

The other guiding principles provided in the Issue Paper need more discussion to ensure they will not conflict with the above principles.  As such, Cal Advocates recommends eliminating the following proposed principles or deferring discussion on these principles for later in the initiative:

1. “Minimizing seams issues between the CAISO organized market and the OATT framework prevalent across the west;
2. Supporting reliable load service in the CAISO and across western balancing authority areas; and
3. Not deter or inhibit competitive trades.” [2]

[1] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 9.

[2] CAISO External Load Forward Schedule Rights Initiative Issue Paper, August 31, 2021, p. 9.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

Cal Advocates recommends:

1. The CAISO should avoid scheduling working group meetings that conflict with other CAISO initiatives concerning California transmission, such as the CAISO transmission planning process, so that stakeholders are able to actively participate in both initiatives that may have overlapping issues.
2. The tasks under Working Group 1 should start and conclude before the other proposed working groups start as explained in the response to question 3.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

At this time, Cal Advocates has no comment on this issue. 

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

At this time, Cal Advocates has no other comments on this initiative or Issue Paper.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

The Joint California LSEs ("Joint CA LSEs") are disappointed by the CAISO’s decision to reject our proposed interim framework. The current scheduling parameters do not appropriately prioritize CAISO BAA reliability, and we do not support the CAISO’s proposed timeline, which will leave this interim solution in place until 2024. We believe that any near-term enhancements proposed within Phase 1 should improve CAISO BAA reliability beyond the current scheduling parameters and be implementable by June 1, 2022.

It is essential that the CAISO set realistic expectations for implementation and ensure that the current tariff provisions remain in place after the May 31, 2022 sunset date. Our understanding is that the near-term enhancements will build off those provisions; however, we are concerned that some items that the CAISO has identified as in scope for this initiative, such as changes in curtailment deadlines and changes in market systems related to high priority (“PT”) exports, may pose significant implementation challenges. Our concern is that the failure to develop and implement at least some elements of these Phase 1 items could lead to a scenario where the previously-applicable penalty parameters are re-implemented temporarily, leading to significantly decreased reliability for a portion of next summer. This result is unacceptable to the Joint CA LSEs. As such, the CAISO must consider its timeline carefully and evaluate options for tariff filings to ensure that the current penalty parameters remain in effect until replacement provisions are implemented.

The Joint CA LSEs support the CAISO’s inclusion of a solution to mitigate impacts of underproduction of resources supporting PT exports. We look forward to working collaboratively with the CAISO to find a viable solution.

The Joint CA LSEs are concerned that a Day-Ahead E-Tag requirement could lead to market power concerns related to the availability of transmission on external systems as well as create a new seams issue. It appears that the majority of the transmission rights leading to COB and NOB are held by a limited group of entities that may have the ability to exert market power if parties were required to procure transmission in the Day-Ahead timeframe. Also, a Day-Ahead E-Tag requirement would be inconsistent with current NERC requirements across the West, thereby creating an additional seams issue. For these reasons, we do not currently support a Day-Ahead E-Tag requirement. The suggestion to move the pro rata curtailment allocation to after the T-20 deadline, as outlined in comments submitted by Shell Energy North America (US), L.P. (“Shell”), could have some merit, but the Joint CA LSEs are reserving any substantive comments on the Shell approach until after a more detailed proposal is available.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

The Joint CA LSEs encourage the CAISO to consider changes to the tariff to better define what should be treated as Resource Adequacy capacity. Specifically, we ask the CAISO to address the comments made by the CPUC Energy Division regarding the fact that RMR and CPM resources are not currently treated as RA capacity in the post-HASP allocation. For the purpose of Phase 1 scoping, we ask that the CAISO consider if these resources should be treated as RA capacity in the allocation. At this time, the Joint CA LSEs believe that the comments offered by the CPUC Energy Division have merit. There appears to be no valid reason not to treat these resources comparably to RA capacity in the post-HASP allocation process; indeed, these resources share many of the same performance obligations as RA capacity, and LSEs within the CAISO are funding the performance of these resources’ CPM and RMR obligations. As such, RMR and CPM resources should be prepared to participate fully in all of the CAISO’s market processes, to be subject to comparable offer and participation obligations, and to provide all of their reliability attributes to the CAISO in exchange for the capacity payments that they recoup pursuant to the RMR and CPM programs. It is equally important that the CAISO ensure deliverability of these resources at the same level of priority as RA resources.   

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

The Joint CA LSEs support the CAISO’s plan to pursue a forward transmission reservation process that will allow for reasonable native load protection and respect existing CAISO market frameworks. The key components of the process that the CAISO has thus far identified seem reasonable and consistent with our understanding of the common practices of other BAAs and RTOs/ISOs.

The Joint CA LSEs ask the CAISO to provide more detail regarding the processes that overlap with this initiative (e.g. Transmission Planning Process and Congestion Revenue Rights Auction and Allocation Process) and their respective timelines. Acknowledging that at this early stage the exact scope of the proposal is not known, it would be helpful to understand when changes to these overlapping processes would be required in order to operationalize the Phase 2 proposal.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

The Joint CA LSEs would like to underscore the importance of reserving adequate capacity to meet native load requirements. We again emphasize that, similar to every other BAA and as prescribed by FERC policy[1], BAAs can reserve transmission capacity in order to reliably serve their native load. Only after a BAA is confident that it is able to serve its native load is it required to provide broader access to its system. Ensuring that the CAISO BAA can reliably serve native load will be paramount in fostering participation in the potential expansion of the CAISO market across the West.

The Joint CA LSEs would also like to point out that, while minimizing seams issues between the CAISO market and OATT BAAs may be desirable, eliminating seams issues will not be possible, nor should it be the goal of this initiative. The basic framework proposed by the CAISO should reduce some of the most significant seams issues. The Joint CA LSEs ask that the CAISO, however, work toward solutions that are in alignment with the CAISO market structure instead of reverting to the OATT model. Rather, the Joint CA LSEs urge the CAISO to work cooperatively with neighbors to evaluate ways in which their market participation may advance beyond the OATT model.

[1] “We conclude that the native load priority established in Order No. 888 continues to strike the appropriate balance between the transmission provider’s need to meet its native load obligations and the need of other entities to obtain service from the transmission provider to meet their own obligations.” FERC Order 890 P. 107.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

In these workshops, the CAISO should determine its own processes, consistent with open access principles, and bearing in mind its core obligation of ensuring reliability to the load within its Balancing Authority Area. The Joint CA LSEs are concerned by the currently-proposed structure of the working groups, which appears to provide external entities with a potentially outsized influence on topics that affect the CAISO BAA. While we certainly see the value in learning from the practices of other BAAs, we do not believe that neighboring BAA processes or these stakeholders should dictate the outcomes of this stakeholder proceeding, which addresses terms and conditions for access to and scheduling rights over the CAISO-controlled transmission system, including assets owned by Participating Transmission Owners in the CAISO (which include nine of the Joint CA LSEs). In particular, when determining how much capacity on the CAISO transmission system is necessary to serve CAISO native load, we urge the CAISO to ensure the conversation is appropriately balanced and focused on the needs of CAISO BAA stakeholders. It is these stakeholders for which the CAISO transmission system has been planned, and it is these stakeholders that have paid for the costs of the CAISO transmission system. Most importantly, it is these stakeholders that depend on the CAISO transmission system to meet the needs of their customers in every hour of every day. In attempting to perform outreach for the purpose of accommodating the emerging desires of neighboring systems to procure external power supply and wheel it across the CAISO based on scheduling priorities that could very well impair reliability to CAISO native load, the Joint CA LSEs strongly urge the CAISO to appropriately weigh the views and perspectives of entities within the CAISO BAA.   

To provide transparency and allow for a robust discussion, the Joint CA LSEs support the CAISO opening the working groups up to a public audience. We believe that external BAAs should have no significant concerns about describing their processes and terms for transmission access on their systems in detail within a public workshop. These rules should be set forth in their own public tariffs and related business practice documents such that there should be no concerns regarding confidentiality. 

One topic that does not appear to be within the scope of any of the identified workshops is the development of the appropriate rates and charges for forward reservation of scheduling priorities. The CAISO should further detail how it will address this topic within the scope of the three proposed working groups. If this is not adequately addressed in the scope of the proposed working groups, the Joint CA LSEs recommend that this topic form the subject of a separate workshop scheduled to occur following the development of the long-term framework for establishing scheduling priorities.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

The Joint CA LSEs agree that this initiative is out of the scope of Joint Authority and that the EIM Governing Body has an advisory role on this initiative.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

No additional comments.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

MRP supports the CAISO’s proposal to provide additional information, including a running total of registered PT wheels by tie point and resource adequacy imports by tie point.  MRP appreciates that the CAISO is already publishing hourly operator adjustments to the RUC demand forecast as part of the new Day-Ahead Summer Report (e.g., http://www.caiso.com/Documents/Day-Ahead-Summer-Report-Sep-28-2021.html).

MRP also supports (1) creating in CIRA a dedicated field that automatically calculates non-RA capacity available to support PT exports and (2) in the situation in which a scheduling coordinator submits an retaining PT export self-schedule for an amount greater than the supporting resource’s ability to support that PT schedule, retaining PT status for the amount of the supporting resource’s non-RA capability and giving any remaining part of the self-scheduled export LPT priority instead of reverting the entire self-schedule to LPT priority. 

With regards to the issue of mitigating the risk of underproduction of resources supporting PT exports, MRP understands from the CAISO’s response to a question MRP posed on the September 9 conference call that the CAISO is focused on variable energy resources serving as supporting resources, not on other types of resources serving as supporting resources.   MRP supports this focus.  MRP was concerned that the CAISO might require supporting resources to generate an amount of energy at least equal to the PT export self-schedule.  MRP now understands and appreciates that this is not the CAISO’s intent.  

MRP also supports the CAISO’s proposal to defer consideration of requiring that supporting resources be deliverable to the relevant intertie scheduling point as part of Phase 2 of this initiative. 

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

MRP has no other specific enhancement to propose now.  MRP appreciates the CAISO’s prior and ongoing efforts to clarify and enhance the process for allowing generators within the CAISO balancing authority area to serve as supporting resources.   

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

MRP has no comment on this topic.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

One issue important to MRP is that, as the CAISO determines native load needs as part of the proposal to allocate a portion of the CAISO network's capability to wheel-throughs and exports, the CAISO should continue to prioritize the deliverability of generators within the CAISO’s footprint.  While MRP does not object to the CAISO’s proposal for “carving out” part of its network transmission capability to allocate on a forward basis for purposes other than serving native load (i.e., wheel-throughs and exports), MRP would be greatly concerned if that process negatively affected the deliverability of generators within the CAISO footprint.  MRP also looks forward to the discussion of if and how the CAISO will assess and allocate transmission service associated with export schedules on a forward basis, similar to what it proposed for wheel-throughs.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

MRP has no comment on this topic.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

MRP supports the proposed classification.  

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

MRP has no comment on this topic.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

NV Energy is very concerned about the timing of Phase 1. As proposed by the CAISO, the changes would not be presented to the CAISO Board until March 2022. That means the FERC filing would occur in April 2022 with a decision in June 2022. By that time the hot weather is already well underway. Moreover, NV Energy and its transmission customers are already engaged in procurement for the Summer of 2022. Simply stated, we need certainty as to the rules we will be operating under as soon as possible. Accordingly, NV Energy strongly recommends that the CAISO divide Phase 1 into 2 parts.  In Phase 1A, the CAISO would file immediately to extend the current priority wheel structure approved by FERC for the summer of 2021 at least for the summer of 2022 and 2023. Phase 1B would be the additional data transparency and process enhancements that comprise the current Phase 1 proposal. Consideration of these enhancements could continue on the schedule proposed by the CAISO, with a decision by the Board in March 2022.

Currently, the tariff provisions expire on May 31, 2022. Moving ahead with the continuation of the priority wheeling approach with a FERC filing immediately would give EIM Entities, especially those in the Desert Southwest certainty as to the rules governing the qualifications for obtaining priority wheeling status as soon as possible. NV Energy notes that the CAISO’s Phase 1 proposal does not discuss how EIM Entities can obtain priority wheel through for the Summer of 2022. Rather the proposal identifies additional data transparency and process enhancements that appear to build upon the previously approved design. While NV Energy supports many of these transparency and process proposals, these can be discussed in the manner and schedule identified on page 35 of the Issue Paper.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

The Issue Paper identifies both transparency and process enhancements. The transparency improvements include:

• review and consolidation of terms across the tariff, BPMs, and system guide documents to ensure consistent terminology when referring to priority wheels;
• additional data and information regarding curtailment events affecting priority wheels and exports;
• additional data on transactions at tie points into the CAISO as a way to help inform future priority wheel registrations and to evaluate as a factor in the potential risk of curtailment, whether high or low scheduling priority; and
• publication of operator adjustments to the day-ahead forecast.

NV Energy supports the inclusion of these items as they will provide useful data both for current operations and consideration of a long-term approach. 

Process enhancements identified by CAISO in the Issue Paper include:

• In cases of self-scheduled PT exports where the sum of the PT export bid exceeds the total non-RA capacity the CAISO could explore retaining PT export status for at least a portion of the schedule, and reverting the remaining amount to LPT export status; and
• the risk of over-curtailment should be minimized by considering only high priority transactions (PT wheels, RA imports) with valid e-tags.

NV Energy supports consideration of these issues in Phase 1B.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

The CAISO envisions that a forward transmission reservation process will provide a pathway for external parties to secure high scheduling priority, equal to load, for transactions across different increments in time. The market would continue to re-optimize all physically available transmission capacity, as it does today, to ensure the most efficient and effective market solution. If the market cannot solve, those transactions with forward reserved transmission would have the benefit of establishing priority equal to load and obtaining the higher certainty.

NV Energy supports the approach and objectives for Phase 2. We agree that as the stakeholder process progresses, additional key issues are likely to be identified that we will need to work through collaboratively.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

On page 9 of the issue paper, the CAISO identifies six guiding principles for the initiative:

• Ensure CAISO’s ability to reliably serve native load needs while, providing non-discriminatory access to the transmission system consistent with open access principles;
• Minimize seams issues between the CAISO organized market and the OATT framework prevalent across the west;
• Support reliable load service in the CAISO and across western balancing authority areas;
• Not deter or inhibit competitive trades;
• Ensure CAISO has the tools and processes necessary to manage the grid reliably; and
• Maintain the efficiencies of the CAISO markets in dispatching resources to serve load and meet market needs.

NV Energy supports these principles. While the first principle recognizes the need to provide non-discriminatory access and to adhere to FERC’s longstanding open access principles, NV Energy recommends greater specificity. We would add a seventh principle:

• Identify and make available for wheeling transactions on long and short-term basis, available transfer capability (ATC) not reserved by CAISO LSEs in their resource adequacy showing.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

NV Energy sees value in a working group structure in which participants could discuss issues and potential solutions and bring those back to the larger stakeholder group. Due to transparency concerns expressed by several stakeholders during the last meeting; however, it may be better for the CAISO staff to conduct open meetings on specific topics as a way of proceeding.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

NV Energy agrees that based on the EIM Governing Body would have an advisory role

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

PacifiCorp appreciates the opportunity to comment on the CAISO’s issue paper for the external load forward scheduling rights process. PacifiCorp proposes an additional enhancement for CAISO to consider for the scope of Phase 1 during this stakeholder initiative.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

PacifiCorp proposes that Phase 1 also enhance the CAISO’s e-tag approval process.  Currently, CAISO approves all e-Tags that are made prior to T-20.  PacifiCorp proposes that CAISO change its e-tag approval process to only approve e-Tags that are backed by binding market awards or that CAISO has identified as being resource specific.  The current practice creates a potential reliability risk to sink balancing authority areas when e-Tags sourced from CAISO are initially approved and incorporated into the balancing authority area resource plan only to be curtailed at T-20. The current practice has been harmful to neighboring EIM Entities. Late CAISO curtailments result in impacts to EIM Entity bid range capacity test which sometimes result in bid range capacity test failures.  Additionally, these curtailments harm the EIM Entities further because these curtailments are captured in the histogram resulting in a larger bid range capacity test requirement for 30 days.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

The proposed solutions need to be fostered in the spirit of collaboration and transparency.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

No comment.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

No comment.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

No comment.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

No comment.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

Please see Powerex's comments at powerex.com/sites/default/files/2021-09/2021-09-30%20LT%20Sched%20Rights%20Issue%20Paper.pdf

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

PGP supports CAISO’s proposed Phase 1 scope items and timeline and is encouraged by CAISO including in scope nearly all of the suggested near-term enhancements requested by stakeholders. PGP believes the proposed transparency enhancements and PT wheel and PT export process enhancements will improve external LSEs’ ability to proactively manage their systems and reliably serve load. 

With respect to transparency enhancements, PGP supports comments made by stakeholders at the most recent workshop who requested that CAISO publish a guide summarizing where different data is located, given the numerous different reports, webpages, etc. the data is spread across.

PGP also encourages CAISO to provide more information responding to the stakeholder recommendation to require valid E-tags for import RA and PT wheels prior to initiating curtailments. PGP believes this proposal has merit as it could help avoid the risk of inefficiently over-curtailing real import RA and PT wheel schedules. PGP requests that the CAISO provide more information and detail on any barriers to adopting this recommendation.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

 No comments at this time.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

PGP supports CAISO’s proposed scope for the Phase 2 initiative which is to develop a forward transmission reservation process under which parties can reserve transmission service in advance, over a variety of different time frames, and secure a scheduling priority for wheeling through and export transactions equal to internal load. 

PGP appreciates the CAISO moving forward with an approach to the long-term framework that strives to balance the needs of the CAISO to ensure reliable service to load, while also providing open access to the transmission system, across different increments of time, consistent with open access principles. We believe this approach has the best chance of addressing seams issues between the CAISO market and the OATT.

PGP also commends CAISO for the detailed summary it developed comparing transmission scheduling practices in other RTOs/ISOs. This information is very helpful in considering policy options in this initiative. Given that the majority of ISOs/RTOs use a transmission reservation system framework akin to an OATT, this certainly provides support for CAISO’s approach to developing a long-term framework transmission reservation process. PGP encourages the CAISO to consider and refer to the approaches of other RTOs/ISOs as it builds its straw proposal and throughout the policy development of this initiative.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

PGP generally supports the guiding principles proposed by CAISO, as these match very closely with the principles recommended by PGP. PGP believes one clarification could be helpful to the following principle:

• Ensure CAISO’s ability to reliably serve native load needs while providing non-discriminatory access to the transmission system to external entities over a variety of different timeframes consistent with open access principles

PGP’s understanding is that CAISO intends to develop a forward transmission reservation process that will provide opportunities for external entities to secure transmission service over a variety of different time frames (long-term, down to daily and/or hourly) however, this detail is currently missing from the principle and should be included.

PGP further believes it would be helpful for CAISO to address in more detail how these principles be used and how the policy that is developed will be measured against the principles as this initiative proceeds. Principles can provide a helpful guide for policy development, but it also important to ensure there is a process to cross walk proposals against principles along the way to ensure they serve a meaningful role.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

In concept, PGP generally supports the approach of developing smaller working groups to tackle different topics, given the breadth and complexity of the work that will be involved to set up a forward transmission reservation process. However, stakeholders have raised transparency concerns with respect to any closed meetings used to develop policy and PGP believes CAISO should be responsive to these concerns. 

PGP suggests CAISO move forward with the structure of the small groups approach recommended, however, CAISO should provide public notice of the small group meetings and allow all stakeholders to attend the meetings of these groups. To the extent any entity participating in a small group might be reticent to share information about its processes publicly, CAISO could engage with entities and their subject matter experts individually to gather information/learn about processes and then bring back general observations/lessons learned to the working group for discussion. This would avoid an entity having to share publicly information about processes that may be sensitive in nature, while still allowing CAISO and stakeholders to gain valuable education and information that could be used to inform policy development.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

PGP agrees with CAISO that the EIM Governing Body has advisory authority with respect to this initiative. As CAISO describes, both Phase I and Phase II of this initiative would adjust the tariff rules that govern whether and to what extent schedules to wheel through or export from the CAISO balancing authority area would receive priority. None of the currently contemplated tariff changes would be “applicable to EIM Entity balancing authority areas, EIM Entities, or other market participants within EIM Entity balancing authority areas, in their capacity as participants in EIM.” Instead, the proposed tariff rules would be applicable “only to the CAISO balancing authority area or o the CAISO-controlled grid.” Therefore, these proposals fall outside the scope of joint authority and would fall under the EIM Governing Body’s advisory authority. 

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

PGP continues to believe it would be helpful for CAISO to provide an overview of its MIC allocation process and transmission planning process for stakeholders and explain how they will be impacted, if at all, in developing the long-term framework in Phase 2. 

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

The Public Power Council[1] (PPC) supports CASIO’s proposed Phase 1 scope items and timeline.  PPC appreciates the CAISO’s receptiveness to stakeholder’s suggestions for near term enhancements as well as additional reporting and transparency enhancements.  The substantive Phase 1 enhancements outlined in the issue paper have merit as potential improvements to the status quo.  In particular, PPC is supportive of the CAISO pursuing an approach to minimize over-curtailment by requiring valid e-tags for high priority self-scheduled transactions.  PPC looks forward to additional discussion on the timing of when a valid e-tag should be required.

PPC also supports CAISO’s planned transparency enhancements.  The additional data and reports CAISO has already made available at this time have been valuable to PPC.  PPC believes the additional data items will similarly benefit CAISO market participants and stakeholders. 

[1] PPC members are statutory preference customers of the Bonneville Power Administration (BPA) and represent over 90 percent of BPA’s Tier 1 sales.  Overall, Northwest public power is the largest purchaser of BPA’s power products and services and is among the largest purchasers of BPA’s transmission products and services, funding nearly 70 percent of the agency’s total power and transmission costs.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

 No comments at this time.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

PPC supports CAISO’s Phase 2 scope of developing a framework for forward transmission reservations.  As demonstrated by the significant attention this topic has received in this stakeholder initiative and during the Summer 2021 Readiness initiative, the ability to secure and confidently rely upon transmission on external transmission providers’ systems is a key element of western energy markets.  The ability to reserve and reliably utilize transmission to wheel power across multiple transmission providers creates benefits for suppliers and purchasers across WECC, including the CAISO.  Transmission reservations on external systems also provide stable cost recovery to transmission providers and supports the expansion of transmission systems which in turn creates benefits across the west through alleviating congestion and allowing more efficient dispatch of resources. 

PPC believes the success of this initiative depends on the CAISO developing a transmission reservation framework that allows external parties to access the CAISO transmission grid in a manner similar to how other transmission providers facilitate access.  To that end, PPC supports CAISO’s plans to develop working groups comprised of different transmission providers to evaluate different components of a forward transmission reservation process consistent with the guiding principles.  PPC offers additional considerations for these working groups below. 

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

PPC generally supports CAISO’s modifications to the guiding principles for the development of a long-term framework for the forward reservation of transmission.  PPC appreciates CAISO’s inclusion of additional principles suggested by stakeholders such as minimizing market seams between the CAISO market and the OATT framework and supporting reliable load service in CAISO and across the west.  As described in PPC’s previous comments, CAISO’s market rules and processes can create adverse impacts on other transmission providers' systems.  PPC believes it is essential that any framework that is developed needs to minimize potential adverse impacts to other regions and transmission providers.

Ultimately, building broad regional support for a CAISO forward transmission reservation process will require a framework that meets and balances the potentially conflicting principles identified by the CAISO.  As described above, PPC believes CAISO developing a framework that is similar to the non-discriminatory and open-access transmission other transmission providers in the west provide has the best chance of resulting in a durable solution that is broadly supported.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

PPC recognizes the potential advantages of limiting participation in the proposed working groups.  However, PPC encourages CAISO to provide as much transparency into these discussions as possible because the discussions and work products of the proposed working groups will likely inform significant portions of the Phase 2 proposal. 

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

No comments at this time.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

PPC appreciates the opportunity to comment on the External Load Forward Scheduling Rights Process Issue Paper.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Salt River Project Agricultural Improvement and Power District (SRP) appreciates the opportunity to comment on the External Load Forward Scheduling Rights Process Issue Paper. 

SRP requests that the CAISO maintain focus and priority on External Load Forward Scheduling Rights Process implementation, especially given the potential for a parallel Extended Day Ahead Market process.  External Load Forward Scheduling Rights Process initiative should remain the top priority.

SRP supports the CAISO’s proposed Phase 1 scope items and timeline as described in the Issue Paper.  SRP understands that Phase 1 will focus on near-term enhancements to the existing scheduling priorities framework that the CAISO can implement no later than June 2022.  These enhancements will work towards improving transparency and priority (PT) wheel and PT export process enhancements.  

SRP noted the CAISO’s Issue Paper focuses on transparency enhancements but does not propose an approach to address interim tariff requirements. SRP requests that the CAISO document and specify its intentions to revise or request extension of tariff provisions approved by FERC in late June 2021. SRP requests this clarification as soon as practical to provide increased certainty to entities throughout the region because resource planning efforts for Summer 2022 are well under way.

As Phase 1 and 2 progress, SRP requests that the CAISO provide frequent information on testing and Market Simulation timelines given the recent implementation delays with the Summer 2021 readiness enhancements.  SRP has concerns that both phases of implementation could be delayed due to software issues if the CAISO does not allow enough time for iterative testing by the CAISO and market participants.  SRP requests that the CAISO remain committed and adhere to a Phase 1 implementation date by June 2022 and a Phase 2 implementation date by no later January 2024, with adequate testing time built in.  It is imperative that this initiative move forward in a timely manner because of the potential impact on load serving entities (LSEs) to maintain reliability.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

To improve transparency, SRP requests that the CAISO provide notifications to sink Scheduling Coordinators as well as sink Balancing Authorities (BAs) when a Scheduling Coordinator within the sink BA is awarded energy not backed up by Residual Unit Commitment (RUC) awards.  While this will likely require e-Tag information to implement and communicate effectively, efforts should address concerns raised by Powerex and Shell with respect to unsupported awarded energy. 

Additionally, SRP requests that Phase 1 include consideration of potential changes to PT export priority, particularly for non-resource specific Residual Unit Commitment (RUC) awards that are now a lower priority in the Real Time Market (RTM).  For potential scenarios where non-resource specific RUC awards are supported in the RTM, the CAISO should clarify whether these awards that are “rebid” in the RTM carry just RTM priority or if they have relevant priority between RUC supported awards and RTM awards.

Finally, SRP remains concerned over the timeline deployed for the Summer 2021 Enhancements related to wheel-through transactions, and that sufficient time was not provided to thoroughly test the software upgrades and enhancements necessary to implement the tariff changes.  SRP requests that any subsequent enhancements and/or software upgrades related to Phase 1 provide sufficient time to ensure a robust testing and verification process prior to implementation.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

While SRP would prefer a quicker timeline for Phase 2 implementation, we can support a timeline to fully implement an equitable long-term, durable Phase 2 solution no later than January 2024 as stated in the Issue Paper provided that meaningful progress can be measured and demonstrated to stakeholders as this initiative progresses towards implementation.

SRP supports the stated scope of Phase 2 development of an equitable forward transmission reservation process.

SRP remains hopeful that a comprehensive, workable, and transparent near-term and long-term durable solution can be identified in a timely manner.  We expect that the CAISO will implement the solution in a manner where transmission access and costs are allocated equitably and commensurate with the benefits received, including the firmness of transmission as well as any financial rights.  If CAISO load will continue to carry firmness priority over exports and wheel-throughs, this should be considered as part of the pricing and suite of transmission products the CAISO ultimately elects to offer.

As stated in previous comments submitted to the CAISO on August 3, 2021, SRP remains concerned that it will be challenging for the CAISO to develop an equitable long-term framework that meets the needs of the CAISO’s internal LSEs as well as the needs of external LSEs. It will be important for all stakeholders to work together and identify opportunities for possible compromise while maintaining focus on reliability, predictability, and similar treatment for similar transactions.

Finally, SRP remains concerned over the timeline deployed for the Summer 2021 Enhancements related to wheel-through transactions, and that sufficient time was not provided to thoroughly test the software upgrades and enhancements necessary to implement the tariff changes.  SRP would request that any subsequent enhancements and/or software upgrades related to Phase 2 provide sufficient time to ensure a robust testing and verification process prior to implementation.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

As SRP discussed at the July 13, 2021, workshop, the use of wheel throughs has been a common and necessary approach across the West, especially for net import regions, such as California and the Desert Southwest.  SRP remains committed to the principles we put forth at the July workshop to be implemented as part of the long-term durable solution: 

• Transmission priorities should be consistent with both the timing and purpose of transactions for internal and external load.
• All LSEs, internal and external to the CAISO, should have the right to substitute energy and capacity for forward contracts.
• The CAISO should establish consistent requirements for internal and external load to establish forward priorities.
• The CAISO should provide full transparency on any load forecast differences between Integrated Forward Market (IFM) and RUC prior to IFM run.
• External LSEs should have equitable rights based on open access principles.

SRP appreciates the CAISO’s statement made in the Issue Paper that “the [CAISO’s guiding] principles also recognize there are inherent differences between CAISO’s organized market paradigm and the OATT [Open Access Transmission Tariff] paradigm that must be bridged to support competitive markets and provide increased dependability to transactions that rely on the CAISO transmission system”.  SRP appreciates CAISO’s recognition that the CAISO’s transmission system is utilized to reliably serve load across the region through wheel-through as many other transmission systems (including SRP’s) must serve the same purpose for both internal load as well as consideration to energy wheels through their systems.  SRP supports the CAISO’s guiding principles because they are based on reliably serving load across western balancing authority areas.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

SRP supports the CAISO standing up three working groups as described in the Issue Paper:

• Working Group 1 - Calculating Native Load Needs & Available Transfer Capability
• Working Group 2 - Transmission products and reserving transmission service
  • SRP agrees with the CAISO that some overlap between Working Group 1 and 2 participants would be valuable.
• Working Group 3 - Studying requests for long-term service and identifying upgrades

SRP requests representation in each of these three working groups and commits to making resources available to participate.

SRP agrees with the CAISO that participation from entities within and outside of the CAISO balancing authority area footprint will be essential for these working groups. Geographic diversity should be a key principle in staffing these three working groups.  The working groups should have representation from internal CAISO participants, Desert Southwest participants and Pacific Northwest participants. CAISO should also seek a balance of transmission providers, transmission customers, and entities that are both providers and customers in these working groups.

With respect to process, SRP encourages the CAISO to consider leveraging these working groups to develop straw proposals before conducting stakeholder workshops for these topics.  Open and candid conversation amongst working group participants will result in a deeper understanding of the issues and allow for more effective sharing of processes, concerns, limitations, and challenges as the CAISO develops straw proposals.  While SRP strongly supports an open and transparent process, each working group needs time to candidly share and analyze information to enable straw proposal development.  The public can then review and discuss the straw proposal(s) in a public stakeholder workshop.  SRP suggests this approach to balance the need for candid conversation with the CAISO’s obligation and need to have open and transparent stakeholder processes. 

Additionally, SRP requests that each working group meeting have an agenda that is shared at least 5 business days in advance in order for all of the participating entities to have time to adequately prepare in order to engage effectively.  This will also require the CAISO to identify ahead of time what data participants will be asked to share or discuss at each working group meeting.  SRP is committed to this process and believes these simple project management procedures will allow for effective participation.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

SRP supports the current proposed advisory role for the EIM Governing Body. 

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

As this initiative moves forward, it will be important to affirm that real-time transactions, both bilateral and through the IFM, largely serve the same purpose of maintaining reliability for both internal and external loads.  Real-time and day-ahead transactions on high energy demand days are primarily driven by the need to support loss of generation, system events, or changes in forecasted load.

As stated in comments submitted to the CAISO on August 3, 2021, SRP is seeking equitable rights based on Open Access principles. SRP remains committed to the principle that this initiative will focus on reliability rather than efficient market design.  It is clearly stated that this initiative’s main principle is to “reliably serve load, dispatching resources on a least cost basis when reliability can be met.” While the efficient dispatch of generation is a component of this effort, the outcome of this process is clearly focused first and foremost on reliability.  FERC Order 888 and OATT processes need to be a foundational element in this initiative. FERC Order 888 clearly states that access to a public utility’s transmission system is to be on a comparable basis to native load as this is a cornerstone of FERC’s open access policies.  Hence, the comparability standard should be included as a principle.  For example, “an open access tariff that is not unduly discriminatory or anticompetitive should offer third parties access on the same or comparable basis, and under the same or comparable terms and conditions, as the transmission provider's uses of its system.”[1]  Thus, comparability requires that external LSEs be able to access the CAISO transmission system on a basis comparable to California native load.[2]  

SRP appreciates the CAISO’s recognition that wheel throughs and exports are important to the entire Western Interconnection and the CAISO’s acknowledgement that the interim solution approved for summer 2021 is not a durable long-term framework.  Thus, the External Load Forward Scheduling Rights Process initiative should remain the top priority.

[1]  Inquiry Concerning the Commission's Pricing Policy for Transmission Services Provided by Public Utilities Under the Federal Power Act, Policy Statement, 69 FERC ¶ 61,086 (1994).

[2]  See Transmission Access Policy Study Group v. FERC, 225 F.3d 667, 681 (D.C. Cir. 2000) (“Open access is the essence of Orders 888 and 889. Under these orders, utilities must now provide access to their transmission lines to anyone purchasing or selling electricity in the interstate market on the same terms and conditions as they use them own lines.”).

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Please see attached comments.  

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

Please see attached comments. 

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

Please see attached comments. 

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

Please see attached comments. 

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

Please see attached comments. 

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

Please see attached comments. 

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

Please see attached comments. 

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

Vistra appreciates the challenge before the CAISO weighing whether it should focus on long-term durable solutions (Phase 2 scope), or changes needed to make market participants more comfortable that the current framework is workable going into next summer. We find it a reasonable approach to separate the phases into two tracks and allow to progress in parallel as opposed to sequentially. In our view this is a new stakeholder approach to sticky issues on scope and timing that we are optimistic will pay dividends.

The Phase 1 scope items appear to be geared to building market confidence in the current functionality through transparency and quality enhancements that can be implemented by next summer. Vistra supports this approach. Given that these transparency and market quality enhancements are needed by the sunset date of the wheel through Tariff provisions to mitigate market uncertainty, we find the CAISO timeline prudent to bring Phase 1 to its governing bodies in March 2022. On a substantive note, Vistra requests the CAISO make available all of the proposed data transparency items on a near real-time basis through OASIS.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

None currently.

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

Vistra finds it a reasonable approach to separate the phases into two tracks and allow to progress in parallel as opposed to sequentially. We strongly support the CAISO transitioning to this long-term durable solution of a forward transmission reservation process. Vistra is committed to engaging collaboratively with the CAISO staff and market participants in this Phase 2 to help develop a framework that will enhance the function and efficiency of the market. Considering the complexity of the issues in scope for a market design effort of this nature, the CAISO proposed timeline for an effective date through an independent release in early 2024 seems reasonable. Vistra wants to acknowledge that an early 2024 implementation date implies to us the seriousness that CAISO is approaching this initiative by contemplating implementation before the standard fall release. We recognize and appreciate this commitment and look forward to working with the CAISO towards improving its market design to include a forward transmission reservation process.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

Vistra provided robust comments[1] on the CAISO July workshop including a set of requests and providing a proposed framework that the CAISO could explore. In our review of the CAISO scope of its proposed priorities and workshop scope, we believe the CAISO vision is conceptually aligned with ours. Vistra recommends the following principles including the CAISO’s and Vistra’s (bold font):

• Ensure CAISO’s ability to reliably serve native load needs while, providing nondiscriminatory access to the transmission system consistent with open access principles
• Ensure priority given to native load is consistent with open access principles[2]
• Ensure priority given to point-to-point transmission customers is consistent with open access principles[3]
• Ensure transmission customers appropriately schedule their transmission reservations to affirm their priority treatment in the markets consistent with open access principles[4]
• Ensure CAISO’s curtailment priorities respect the equivalent of the open access requirements when enacting curtailments or service interruptions[5]
• Minimize seams issues between the CAISO organized market and the OATT framework prevalent across the west
• Support reliable load service in the CAISO and across western balancing authority areas
• Not deter or inhibit competitive trades
• Ensure CAISO has the tools and processes necessary to manage the grid reliably
• Maintain the efficiencies of the CAISO markets in dispatching resources to serve load and meet market needs

[1] https://stakeholdercenter.caiso.com/Comments/AllComments/134505f1-b137-4fb9-a58d-1222af70e4e2#org-6b980f09-d5ba-4de4-a13c-36fe059e76b7

[2] See Vistra comments on July workshop, “Ensuring priority to native load is consistent with open access requirements”, Page 1-3 and “reservation priorities”, Page 3-5.

[3] See Vistra comments on July workshop, “reservation priorities”, Page 3-5.

[4] See Vistra comments on July workshop, “scheduling priorities”, Page 6.

[5] See Vistra comments on July workshop, “curtailment priorities”, Page 6-9.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

Vistra conceptually agrees with the structure if we have the flexibility to refine it within the working group. For example, discussing native load and available transmission capacity are two concepts within the broader discussion of establishing robust, open access reservation process and priority access. Similarly, discussing the types of products and reservation process are also concepts needed to be explored within the broader reservation process and priority access discussion. However, the workshops need to include the scheduling priorities and curtailment priorities that would be associated with those transmission reservations. This topic is not clearly in a workshop group at this point. We believe these elements are pivotal to the success of building a long-term framework so should be clearly within scope of one of these groups. In our opinion, it would be most appropriate within Group 2 as a second phase once the types of reservation services are refined. Vistra requests the CAISO specifically include this in a group to ensure these critical rules are scheduled for development.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

This initiative should be classified under the joint authority role of the EIM Governing Body. Per the approved guidelines, joint authority should apply to CAISO consideration of an “element of a proposed policy change that would change or establish tariff rules applicable to the EIM entity balancing authority areas, EIM entities, or other market participants within the EIM entity balancing authority areas, in their capacity as participants in EIM”. Respectfully, Vistra views this initiative as impacting the EIM entity balancing authority areas, EIM entities, or other market participants in the EIM areas. We have this view because these are some of the same entities and participants that will also participate in the forward transmission reservation process. For the EIM entities, these entities may participate in the forward transmission reservation process to secure transmission service to support their base schedules, an important element of the EIM. Further, EIM entities may be impacted by these policy changes because the amount of transmission reserved could result in reducing the EIM transfers available within the EIM entities. For example, if the transmission system is oversubscribed this could reduce the amount of EIM transfers accessible to the EIM entities in real-time, which is a meaningful impact to them and could impact their ability to derive benefits from EIM participation.

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative:

None currently.

1. Please provide your organization’s perspective on the proposed Phase 1 scope items and timeline described in the issue paper:

WPTF appreciates the opportunity to submit comments on the Issue Paper discussed during the September 7 stakeholder call. We believe transparency is a key element to a well-functioning market and are supportive of the CAISO including several elements within Phase 1 that will improve market transparency and reporting. We ask that as the CAISO starts to shape how the data will be presented, accessed, and updated, that there is an opportunity for stakeholders to provide feedback. For example, if the data is posted in an excel file or on OASIS, in hourly vs daily granularity, etc. Having an end-user perspective will likely result in the data being more useful and valuable to the market participants. 

WPTF appreciates the CAISO’s proposed phased approach for the overall policy effort. As such, the timeline of phase 1 seems reasonable though we ask that to the extent issues within phase 1 require additional time that the CAISO does not sacrifice needed discussion to adhere to a pre-determined timeline. Rather we ask the CAISO to consider, if needed, either (1) moving the element to phase 2 or (2) extending the timeline of phase 1.

2. Provide your organization’s suggestions on any additional near-term enhancements that should be considered as part of the initiative Phase 1 scope:

3. Provide your organization’s perspective on Phase 2 scope of the initiative and timeline - the development of a forward transmission reservation process for establishing scheduling priorities in the market:

WPTF supports the proposed scope of Phase 2, especially the choice to pursue the phases in parallel rather than delaying phase 2. In phase 2, we ask that the CAISO consider including elements that require additional time included in phase 1 scope and, to the extent needed, new elements that come up in discussions of the phase 1 efforts. Additionally, WPTF would like to confirm that the phase 2 scope of developing a forward transmission reservation system is not restricted to internal and external Load Serving Entities but is a process for a new reservation system open to all Transmission Customers.

4. Provide your organization’s perspective on the guiding principles for the development of a long-term, holistic, framework for establishing scheduling priorities in the market:

WPTF believes that one of the guiding principles of this effort should be to ensure a market design that provides for open access to the CAISO transmission system pursuant to FERC open access requirements. A second guiding principle is that the forward transmission reservation system is in alignment with the CAISO’s Maximum Import Capability, which is needed for capacity outside the CAISO to provide RA supply across the interties to serve internal load.

5. Provide your organization’s perspective on the structure of the suggested stakeholder working groups proposed to further vet aspects of the forward transmission reservation process:

WPTF is supportive of the structure the CAISO has suggested for moving phase 2 of this stakeholder effort forward in parallel to phase 1. We often find working groups extremely useful and productive, especially when held at the beginning of a stakeholder process. To that end, there is also merit in having smaller more effective working groups while at the same time ensuring they remain open to the public. We appreciate the CAISO recognizing the importance of having discussions with the general stakeholder committee and thus no longer considering keeping the working groups private. While not explicitly listed in the working group scopes, WPTF requests the CAISO include discussion of scheduling and curtailment priorities applicable to each transmission product that will be developed.

Additionally, as WPTF has stated in other initiative comments, we believe all stakeholder processes would benefit from first having a clearly defined problem statement developed up front. Without a clearly defined problem statement the policy outcome may end up not fully addressing the underlying concern or issue in the most effective and efficient way.

6. Provide your organization’s perspective on the EIM decisional classification for the initiative:

7. Provide your organization’s perspective on any other aspects of the issue paper and initiative: