Comments on Draft Final Proposal

1. Provide position of your organization and a summary of comments on the draft final proposal.

The Bonneville Power Administration (Bonneville) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) Draft Final Proposal dated October 30, 2020 and the subsequent workshop held on November 6, 2020.  Bonneville is particularly pleased that the CAISO is following through on its commitment memorialized in the Bonneville-CAISO Implementation Agreement to propose changing the T-40 base schedule submission deadline to T-30. 

Bonneville is a federal power marketing administration within the U.S. Department of Energy that markets electric power from 31 federal hydroelectric projects and some non-federal projects in the Pacific Northwest with a nameplate capacity of 22,500 megawatts. Bonneville currently supplies 30% of the power consumed in the Northwest. Bonneville also operates 15,000 miles of high voltage transmission that interconnects most of the other transmission systems in the Northwest with Canada and California. Bonneville is obligated by statute to serve Northwest municipalities, public utility districts, cooperatives and other regional entities prior to selling power out of the region.

Bonneville continues to support the proposal, as has been stated in previously submitted comments, and commends the CAISO’s responsiveness to the concerns raised by some EIM Entities.  To that end, Bonneville is supportive of the CAISO’s proposal to include an advisory T-40 Resource Sufficiency test to help mitigate potential reliability risks that some EIM Entities have raised. Bonneville also supports the proposal to include a resource’s startup energy in its hourly resource plan.  Further, the CAISO’s willingness to investigate the potential of moving the T-55 timelines is greatly appreciated.

Moving the T-40 base schedule submission deadline to T-30 will allow Energy Imbalance Market (EIM) Entities to submit more accurate base schedules which will have a positive impact on market operations.  Likewise, allowing entities to submit base schedules below a resource’s minimum load will allow more accurate base schedules which, in turn, will create a more efficient and economic market.

Bonneville continues to encourage evaluation of refining other hourly timelines to provide similar benefits. For example, moving the T-55 base schedule submission deadline for market participants forward to T-45 would allow EIM Entities to work with resources and loads within the EIM Entities’ Balancing Authority Areas to submit more accurate schedules closer to the operating hour. 

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

See Bonneville’s previously submitted comments.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

See Bonneville’s previously submitted comments.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

See Bonneville’s previously submitted comments.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

See Bonneville’s previously submitted comments.

1. Provide position of your organization and a summary of comments on the draft final proposal.

Please see our full set of comments at the link below.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

Please see our full set of comments at the link below.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

Please see our full set of comments at the link below.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

Please see our full set of comments at the link below.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

DMM provides its full set of comments on the Draft Final Proposal at the following link:

DMM Comments on Western EIM Base Schedule Submission Deadline Draft Final Proposal

1. Provide position of your organization and a summary of comments on the draft final proposal.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

Idaho Power generally supports the proposals in the draft final proposal.  As CAISO develops the implementation schedule, CAISO should ensure that EIM entities and their vendors have sufficient time to make necessary changes to their own software.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide position of your organization and a summary of comments on the draft final proposal.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

PG&E appreciates that CAISO’s efforts to balance the benefits of the proposed change with the concerns with stakeholders.  In response to stakeholder concerns on the submission deadline, CAISO’s draft final proposal makes two changes:

1. CAISO is proposing to retain the T-40 RSE as an advisory run
2. CAISO is proposing to implement this change concurrent with FRP but delay activation in production until testing shows no performance concerns

PG&E supports these changes but would like CAISO to be more specific on the second.  Could CAISO please provide the results of the performance testing as well as details regarding the acceptable performance threshold.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

PG&E appreciates that CAISO’s efforts to balance the benefits of the proposed change with the concerns with stakeholders.  In response to stakeholder concerns on the start-up energy, CAISO’s draft final proposal includes ex post monitoring. PG&E supports this approach and would encourage the CAISO to work with the DMM to ensure adequate monitoring.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

The draft final proposal includes CAISO’s commitments for the implementation phase for both the start-up energy and submission deadline change.

Submission deadline change: implement this change concurrent with FRP but delay activation in production until testing shows no performance concerns.

Start-up energy: “The CAISO is concerned this functionality has the potential to be abused to pass the RSE. Any type of validation or automated monitoring would require coordination between BSAP, Settlements and webOMS. This would be difficult to automate and implement prior to Spring 2021.”

PG&E respectfully requests careful coordination between the policy and implementation teams to make sure that the nuances of these implementation commitments are followed.

1. Provide position of your organization and a summary of comments on the draft final proposal.

PacifiCorp submits the following comments to the California Independent System Operator Corporation (“CAISO”) on the Western EIM Base Schedule Submission Deadline draft final proposal published October 30, 2020, (“Draft Final Proposal”). PacifiCorp supports the proposal and appreciates the opportunity to provide the following comments for the CAISO’s consideration. 

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

PacifiCorp is pleased that the CAISO has proposed to run an additional resource sufficiency evaluation (“RSE”) at T-40 that uses the real-time pre-dispatch (“RTPD”) interval initiated at T-52.5 and its initial resource schedules as an input, while still moving the final RSE to T-30, also using the same initial conditions. PacifiCorp agrees that this change will provide EIM entities with an opportunity to take manual actions to pass the RSE, and enough time to resolve the potential imbalance prior to the start of the operating hour.

Further, PacifiCorp supports the CAISO’s commitment to ensure that this initiative does not degrade existing market performance or impact the implementation of the flexible ramping product (“FRP”), and its plans to implement the currently proposed functionality concurrently with implementation of the FRP enhancements.

PacifiCorp notes that it appears the CAISO did not address PacifiCorp’s previously submitted comments regarding modification of the deviation histogram. PacifiCorp reiterates its recommendation that the CAISO modify the deviation histogram to align with the proposed T-30 financially binding deadline, wherein the histogram would use the deviation between T-30 and the T-20 tagging deadline instead of the deviation between T-40 and the T-20 tagging deadline.

PacifiCorp understands that the CAISO is not prepared to expand the scope of the current initiative to include moving the T-55 RSE (and customer generation base schedule submission deadline) to T-50, as doing so would involve shortening the solution time for the RTPD interval and adjusting the load and variable energy resource (“VER”) forecasting used for the T-55 RSE.  PacifiCorp appreciates the CAISO’s commitment to examine the impact of running a shortened RTPD during implementation of this initiative and consider moving the T-55 deadline to T-50 in a future initiative based on the results of the testing.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

PacifiCorp supports the CAISO’s proposal to allow resources’ start-up energy to be included in EIM entities’ hourly resource plans.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

PacifiCorp supports the CAISO’s proposed EIM Governing Body’s primary approval authority classification.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

No comments. 

1. Provide position of your organization and a summary of comments on the draft final proposal.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

PGE is generally supportive of the CAISO’s overall proposal but would like to re-emphasize the importance of ensuring that the RSE test results for the advisory T-40 RSE are published as soon as possible.   As PGE noted during the November 6, 2020 stakeholder meeting, if the T-40 RSE test results are published too late, this will compromise the ability for entities to secure any bilateral transactions and for entities to turn on a resource for the upcoming hour.  Traders will require at least five minutes to create a tag and finish a deal.  Additionally, sufficient time is needed to ensure that an entity’s system has obtained the necessary data and that that data is successfully transferred to the CAISO system. 

CAISO has acknowledged the importance of ensuring that entities are afforded enough time to complete these critical tasks and indicated during the stakeholder meeting that such results should be available within one or two minutes.  While this should be sufficient time for most entities, such assurances fall short of a guarantee.  As such, PGE would encourage CAISO to include a re-evaluation of this proposal should performance of the advisory test not result in the improved flexibility and reliability that the proposal was intended to address.  Such a re-evaluation would be included in the future stakeholder process that CAISO referenced in the Draft Final Process and is expected to explore additional changes to T-55 RSE and subsequent RTPD intervals. 

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide position of your organization and a summary of comments on the draft final proposal.

Please see Powerex's comments at https://powerex.com/sites/default/files/2020-11/2020-10-13%20EIM%20Base%20Schedule%20Comments%20-%20Final%20Proposal.pdf

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

Please see Powerex's comments at https://powerex.com/sites/default/files/2020-11/2020-10-13%20EIM%20Base%20Schedule%20Comments%20-%20Final%20Proposal.pdf

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

Please see Powerex's comments at https://powerex.com/sites/default/files/2020-11/2020-10-13%20EIM%20Base%20Schedule%20Comments%20-%20Final%20Proposal.pdf

1. Provide position of your organization and a summary of comments on the draft final proposal.

The Sacramento Municipal Utility District (SMUD) appreciates the opportunity to provide comments and input on the CAISO’s Western EIM Base Schedule Submission Deadline Draft Final Proposal, dated October 30, 2020 (Proposal).  SMUD is an active market participant in the Western EIM through the Balancing Authority of Northern California (BANC) Balancing Authority (BA).  Accordingly, we have a direct interest in this initiative.The Sacramento Municipal Utility District (SMUD) appreciates the opportunity to provide comments and input on the CAISO’s Western EIM Base Schedule Submission Deadline Draft Final Proposal, dated October 30, 2020 (Proposal).  SMUD is an active market participant in the Western EIM through the Balancing Authority of Northern California (BANC) Balancing Authority (BA).  Accordingly, we have a direct interest in this initiative.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

SMUD continues to support the move from a T-40 to T-30 deadline.  The changes in the Proposal, including an additional resource sufficiency evaluation (RSE) at T-40, appear to address reliability and operational issues raised by EIM Entities.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

SMUD supports the changes in this latest Proposal; however, SMUD requests clarification on whether the EIM Base Schedule Energy Below Minimum Load functionality also applies to configuration transition (e.g., 1X1 to 2X1) of a Multi-State Generator (MSG)?

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

SMUD reiterates that it considers this initiative within the primary approval authority of the EIM Governing Body.

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide position of your organization and a summary of comments on the draft final proposal.

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

Salt River Project Agricultural Improvement and Power District (SRP) appreciates CAISO listening to reliability concerns we outlined in our comments on the Straw Proposal. CAISO’s inclusion of an additional resource sufficiency evaluation forty minutes prior to the operating hour (T-40) addresses these concerns.

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

SRP appreciated the opportunity to participate in the draft proposal stakeholder meeting.  During this meeting, SRP received clarification on the following items and requests CAISO to explicitly confirm this understanding:

1. Base schedule submission below minimum load (Pmin) is intended to be used for startup energy only.  CAISO understands that some startups may also be categorized as testing and therefore exceed normal startup times or characteristics.  These base schedules below Pmin would be considered acceptable with appropriate documentation such as logs.  However, the use of base schedule submissions below Pmin should not be used for general testing purposes, other than during startup.
2. Scheduling infrastructure business rules (SIBR) will not prohibit the submission of bids above Pmin for the resource/configuration with corresponding base schedules below Pmin for startup energy. However, bid curves may not extend below the Pmin, which is consistent with SIBR today.
3. Base schedules may be submitted below Pmin for startup energy for all resources, including participating, non-participating, multi-stage generator, and non-multi-stage generator resources.
4. Base schedule submissions below Pmin will be allowed in cases where there is also a Pmin uprate/re-rate due to ambient, plant trouble, or other conditions.
5. Base schedule optimizer results may be used as documentation to support base schedule submissions that deviate from the after-the-fact monitoring rules for justifiable reasons.

SRP looks forward to working with CAISO to further define types of evidence that CAISO will consider acceptable for documenting deviations from the monitoring criteria.

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

SRP supports CAISO’s proposal for the EIM Governing Body to have primary approval authority for this initiative.   

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide position of your organization and a summary of comments on the draft final proposal.

SCE is supportive of the changes within this initiative but wishes the CAISO to test these changes to ensure that feasible AC schedules can be provided within the timeframe necessary for running the RTPD software and publish the market schedules. 

2. 2. Provide your organization’s comments on changes included in the draft final proposal regarding moving the financially binding base schedule submission deadline from T-40 prior to the operating hour to T-30 prior to the operating hour.

CE supports the proposed change to the submission deadline for EIM base schedules provided the change from T-40 to T-30 produces feasible AC schedules for the real-time market within the necessary time required to run the market software in RTPD and the change facilitates the timely publication of schedules. 

3. 3. Provide your organization’s comments on changes included in the draft final proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

?SCE recommends the CAISO  must ensure that the modification is not abused by market participants during resource audits and market operation despite the convenience of including startup energy within all EIM entities’ hourly resource plans. 

4. 4. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

SCE supports the determination of primary authority in favor of the EIM Governing Body since base scheduling of resources is a process specific to the EIM balancing authority areas. 

5. 5. Provide any additional comments on the draft final proposal for the Western EIM Base Schedule Submission Deadline initiative.

None.