Stakeholder center

Comments on Comments due on draft final proposal posting

Penalty enhancements - demand response, investigation, and tolling

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Comment period
Jul 20, 08:00 am - Aug 08, 05:00 pm
Submitting organizations
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California Efficiency + Demand Management Council, Renew Home
Submitted 08/09/2024, 10:12 am

Submitted on behalf of
California Efficiency + Demand Management Council, Renew Home

Contact

Luke Tougas (l.tougas@cleanenergyregresearch.com)

1. Please provide a summary of your organization’s general comments on the PEDRIT draft final proposal and presentation:

The California Efficiency + Demand Management Council (Council) and Renew Home support the PEDRIT draft final proposal.  It strikes a good balance between ensuring clarity and accountability while recognizing that a certain degree of margin for error is inevitable.

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the draft final proposal:

The Council and Renew Home appreciate the following clarifications provided in the Draft Final Proposal: 1) there are no penalties for on-time inaccurate submissions of DR monitoring data with corrections after the submission deadline; 2) the submission deadline for DR monitoring data is based on the applicable trade date; and 3) the calculation methodology for meter data inaccuracy.  We support all of these clarifications and would like to thanks the CAISO for its willingness to adopt a courtesy notice at T+44B for missing DR monitoring data. 

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the draft final proposal:

N/A

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the draft final proposal:

N/A

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the draft final proposal:

The Council and Renew Home support the inaccurate meter data penalty materiality threshold as proposed in the Draft Final Proposal.

6. Please provide your organization’s comments on the proposed removal of the ISO reporting requirement for federal entity Rules of Conduct violations.

N/A

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the draft final proposal

The Council and Renew Home support the PEDRIT initiative falling under joint authority for the simple reason that it will impact WEIM entities.

8. Please provide additional comments on the PEDRIT draft final proposal or presentation not mentioned above:

N/A

California ISO - Department of Market Monitoring
Submitted 08/08/2024, 09:02 am

Contact

Aprille Girardot (agirardot@caiso.com)

1. Please provide a summary of your organization’s general comments on the PEDRIT draft final proposal and presentation:

Please see the attached Comments from the Department of Market Monitoring.

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the draft final proposal:

Please see the attached Comments from the Department of Market Monitoring.

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the draft final proposal:

Please see the attached Comments from the Department of Market Monitoring.

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the draft final proposal:

Please see the attached Comments from the Department of Market Monitoring.

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the draft final proposal:

Please see the attached Comments from the Department of Market Monitoring.

6. Please provide your organization’s comments on the proposed removal of the ISO reporting requirement for federal entity Rules of Conduct violations.

Please see the attached Comments from the Department of Market Monitoring.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the draft final proposal

Please see the attached Comments from the Department of Market Monitoring.

8. Please provide additional comments on the PEDRIT draft final proposal or presentation not mentioned above:

Please see the attached Comments from the Department of Market Monitoring.

Attachments

Idaho Power Company
Submitted 08/07/2024, 01:35 pm

Contact

Lisa O'Hara (lo'hara@idahopower.com)

1. Please provide a summary of your organization’s general comments on the PEDRIT draft final proposal and presentation:

 Idaho Power greatly appreciates the CAISO’s efforts in revising and updating the Rules of Conduct and related penalty structure to ensure any penalties assessed are proportionate to any harm caused by the error or violation. 

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the draft final proposal:

No comments.

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the draft final proposal:

 Idaho Power is supportive of streamlining the investigative process and appreciates the CAISO adopting the suggestion that only one CIDI ticket be utilized during the investigative process and remain open until either CAISO issues a final notice with no penalty, or if there is a penalty, until the CAISO receives payment or issues a refund.  Idaho Power believes this will make the investigative process easier to follow and more efficient.

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the draft final proposal:

Idaho Power is supportive of the proposed penalty tolling process and appreciates the clarity of the process.

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the draft final proposal:

Idaho Power greatly appreciates CAISO’s proposal for a materiality threshold and believes the 3% or 3 MW threshold strikes the proper balance for ensuring that minor errors or inaccuracies do not result in a penalty while still encouraging compliance with reporting accurate meter data. 

6. Please provide your organization’s comments on the proposed removal of the ISO reporting requirement for federal entity Rules of Conduct violations.

No comments.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the draft final proposal

No comments.

8. Please provide additional comments on the PEDRIT draft final proposal or presentation not mentioned above:

No comments.

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