Comments on Draft tariff language

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

The California Community Choice Association (CalCCA) provides redline edits and an embedded comment to section 11.2.6.1 (see attachment). These edits would allow resources and load serving entities (LSE) to complete the Day-Ahead Market Enhancements (DAME) Transitional Measures election process at any time during the three-year DAME Transition Period, with 30 days’ notice to the California Independent System Operator Corporation, to reflect the fact that LSEs and resources may enter into Resource Adequacy contracts on a monthly basis. CalCCA’s changes are consistent with the policy in the Revised Final Proposal, which did not communicate a one-time election process.[1] 

[1]             Day-Ahead Market Enhancements Revised Final Proposal at 50: http://www.caiso.com/InitiativeDocuments/RevisedFinalProposal-Day-AheadMarketEnhancements.pdf.

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

CDWR appreciates an opportunity to submit comments on the DAME Draft Tariff Language CAISO published on June 2, 2023.

CDWR proposes the following tariff change in order to align with what is proposed in the Revised Final Proposal (Page 30).

39.7.4  Default Availability Bid for Imbalance Reserves and Reliability Capacity

The CAISO applies separate IRU Default Availability Bids and RCU Default Availability Bids. 

A resource’s IRU Default Availability Bid is the higher of: (a) $55/MWh; or (b) the IRU competitive locational marginal price Negotiated Availability Bid.

A resource’s RCU Default Availability Bid is the higher of: (a) $55/MWh; or (b) the RCU competitive locational marginal price Negotiated Availability Bid.

A Scheduling Coordinator may choose to pursue both an IRU Negotiated Availability Bid and an RCU Negotiated Availability Bid at a future date to be communicated in the CAISO’s Business Practice Manuals.

CDWR also has the following comments regarding the proposed Notional CRR Value definition.  In Appendix A, it states:

- Notional CRR Value

For a given CRR in a Settlement Period, the sum of: (1) the product of: (a) the MCC of Energy at the CRR Sink minus the MCC of Energy at the CRR Source and (b) the MW quantity for that Settlement Period; (2) the product of (a) the MCC of Locational IRU Price at the CRR Sink minus the MCC of Locational IRU Price at the CRR Source and (b) the MW quantity for that Settlement Period; and (3) the product of (a) the MCC of Locational IRD Price at the CRR Sink minus the MCC of Locational IRD Price at the CRR Source and (b) the MW quantity for that Settlement Period. The Notional CRR Value for a CRR Obligation can be a non-positive value for a Settlement Period but cannot be less than zero (0) for a CRR Option.

CDWR is concerned of possible escalation of the CRR Auction Efficiency when the IRU and IRD MCC settlements are added to the DA CRR Settlements via the DAME proposal presented in the above paragraph.  As mentioned in our CRR comments submitted to previous phases of the DAME Stakeholder process, CDWR recommended that, prior to implementing the DAME CRR design, CAISO initiate stakeholder process to identify the root cause of the shortages in the DA CRR Auction Efficiency.  As part of this stakeholder process, CAISO needs to investigate why the Track 1B could not continue to provide the desired protection to the load demand as it did in the first three quarters following the implementation of the Track 1B proposal in January 2019

Until the DA CRR Auction Efficiency is fixed CDWR does not support the implementation of DAME CRR for the following reasons:

1. Prior to the introduction of the DA CRR product to the market participants in April 2009, CAISO had performed seven years of DA LMP pricing studies (1, 1A, 2, 2A, 2B, 2C, 3 etc.), and the market participants could have an idea on how the DA CRR settlement mechanism works and the market participants could decide to participate or not in the CAISO’s DA CRR market.  CDWR is not aware that CAISO had performed any of the IRU and IRD Locational Marginal Pricing studies that would tell market participants what range is expected from such settlements if IRU and IRD settlements will be added to the DA energy LMP settlement.  CDWR strongly believes that market participants cannot accept the addition of the IRU and IRD MCC settlements to the DA CRR energy settlements as mentioned in the CAISO DAME CRR proposal without CAISO performing the IRU and IRD LMP pricing studies.  If CAISO cannot provide any IRU and IRD locational pricing studies, it would be of great help if CAISO could provide a range the IRU and IRD LMP might have in the DAME CRR Settlements.
2. CDWR, as any other participant to the CAISO’s CRR market is legally bound by the CAISO’s Officer Certification Form to comply with CAISO CRR design rules such as: a) CRR Credit Requirements and b) Market Participant’s (MP) proof that the MP has in place, a sound CRR Strategy that allows the MP to cope with negative CRR.  CDWR CRR Strategy strongly relies in estimating the DA congestion rents, estimating the DA CRR revenues, and without an IRU and IRD LMP pricing in place CDWR cannot any longer estimate the value of its nominated CRR.

For the reasons specified at #2 above, CDWR strongly believes that CDWR and other market participants cannot accept the DAME CRR tariff language until CAISO performs, posts, and discusses with market participants via the stakeholder processes the IRU and IRD LMP studies.

CDWR proposes the following definition.

- Notional CRR Value

For a given CRR in a Settlement Period, the product of: (a) the MCC of Energy at the CRR Sink minus the MCC of Energy at the CRR Source and (b) the MW quantity for that Settlement Period.

The proposed Tariff Language above would maintain the status quo until the DA CRR Auction Efficiency is solved and CAISO runs IRU and IRD LMP studies.

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Please see attched files.  Thanks for the opportunity to comment.

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Please see NCPA's redlines and comments for the following sections:

11.2.1.9.5

11.8.6.5.3.1

11.8.6.5.3.2

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

PG&E provides comments to the draft tariff language around three areas (1) the concerns about the details which are not included in the Revised Final Proposal of Day-Ahead Market Enhancements (DAME RFP); (2) clarifying questions of the languages, which has ambiguities, and (3) inconsistencies of languages among sections.

1. PG&E is concerned about the following points, which have details not included in the Revised Final Proposal of Day-Ahead Market Enhancements (DAME RFP). PG&E requests further discussions from the CAISO of those issues:

• [11.2.6.1] DAME transition period/ measure. PG&E is concerned that “30 days after the effective date of (the Tariff Language)” is not sufficient. Most clarifications of existing contract language will require significant discussion between counterparties to RA agreements. These discussions may lead to disputes. The CAISO should assume in its transition period that contract disputes will occur and accommodate the dispute resolution timeline that is common to most RA agreements. As a result, PG&E requests a period of 180 days for LSEs and resource owners to resolve their differences in interpretation of existing contract language. PG&E suspects that many of its contracts will resolve much quicker than 180 days but does not believe it is appropriate to restrict sharing to only those contracts that are resolved quickly. PG&E does not believe that the CAISO or other entities will be disadvantaged by a longer timeline for entities to reach agreement on the transition period.
•  [11.2.6.3.1] Opportunity cost. The RA resource may or may NOT be entitled to receive the opportunity cost of energy due to offering Imbalance Reserves dependent on specific contracts. PG&E recommends two alternatives of “allocates the opportunity cost component of that revenue… to the Scheduling Coordinator for the resource.”
  • ALT 1: the CAISO calculates the opportunity cost and provides the information to the LSE and contracted RA resource without allocating the cost, while allocating the rest of the IBR payment as stated in the transition solution.
  •  ALT 2: the CAISO calculates the opportunity cost and provides the option for the LSEs in the beginning of opt-in to elect whether or not having this amount allocated to the Schedule Coordinator for the resource.
•  [40.6.8, 30.5.1(bb), 30.7.3.1 Step 3] Bid insertion for RA. PG&E finds the language that “For RA Resources that fail to submit any RUC Availability Bid for either RCU or RCD, the Generated Bid is for the required quantity with $0 (zero) price component” is misaligned with the policy defined in DAME RFP, which allows RA to submit bids above $0. PG&E is concerned that inserting bids for RA at $0 could result in California RA capacity be dispatched to meet other BAA’s Imbalance Reserve requirements in the Extended Day-Ahead Market (E-DAM). PG&E recommends two options to address this issue:
  • OPT1: CAISO should modify availability bid and its insertion value consistent with section 39.7.4,
  • OPT2: CAISO should include modifying this provision as part of EDAM policy paper.
• [30.7.3.1 Step 3] Bid insertion for Reliability Capacity. The language implies that a zero price RCU bid will be inserted, if the quantity of the RCU bid associated with a renewable was below its forecast. PG&E is concerned that a $0 value should not be inserted for a capacity bid, which is submitted at a non-zero price. PG&E recommends that in the case that the bid quantity is less than forecast, the CAISO should extend to forecast value rather and keep the bid price as submitted. This would be consistent with how AS bids are extended in real time.

2. PG&E requests the CAISO to provide clarifications to the following points:

• [27.4.3.5] Effectiveness threshold. PG&E requests the CAISO to clarify the meaning of the language that “The CAISO sets this threshold at two-tenths of a percent (.2%) divided by any applicable Deployment Factor” with an example.
• [30.5.1] DAM award publication time. PG&E asks the CAISO to explain why the 1pm deadline for DAM award publication was removed.
•  [31.3.4] E-tag requirements from IR awards. PG&E would like the CAISO to clarify System Resource’s IR awards, if any, should the incoming transmission line or path be derated such that the participant cannot tag to the appropriate or expected quantities.
• [31.3.1.5.2]15-min Dispatchable. PG&E recommends the CAISO add a new definition for “15-minute dispatchable” that describes the existing master file flag so that it can be used as a defined term when describing IR resource eligibility.
• [31.5.7, 31.5.8] Undispatchable capacity. PG&E recommends that the term “undispatchable” only be used through the defined term “Undispatchable Capacity”, as is the case in the current CAISO tariff.
• [31.5.7] RUC capacity. PG&E requests the CAISO to clarify whether “RUC capacity” means the Reliability Capacity procured in RUC. If so, PG&E recommends the CAISO to eliminate the term “RUC Capacity” and replace it with “Reliability Capacity” to prevent potential confusions.
• [31.5.8] RTM bidding obligation from RUC awards. PG&E finds the language confusing that “Resources receiving a RUC Availability Award for RCU that has submitted an Energy Bid in the Day-Ahead Market to export outside the EDAM Area must provide a decremental Energy Bid to dispatch down the export schedule in the FMM if needed.” This language implies that the resource has the obligation to submit a dec bid for energy in real-time. However, PG&E requests the CAISO to clarify that it should be the export, instead of the resource, to have such an obligation.
• [11.2.1.1] IFM Payments for Supply of Energy and Imbalance Reserves. PG&E requests the CAISO clarify draft language that Non-Generator Resources (NGRs) are eligible to provide Imbalance Reserves. The current draft language is unclear in multiple sections, e.g., “For each Settlement Period for which the CAISO clears Imbalance Reserves transactions in the IFM, the CAISO pays Scheduling Coordinators representing Generating Units, Participating Loads, Proxy Demand Resources, Reliability Demand Response Resources, Distributed Energy Resource Aggregations and System Resources […].”
• [11.2.1.8.1, 11.2.1.8.2] Charges for Unavailable IRU and IRD Awards. PG&E requests CAISO update Appendix A to include definitions for Upper Economic Limit and Lower Economic Limit.
• [11.25.2.1.1] Deviation settlement for Imbalance Reserves. The stated deviation settlement does not appear to be the same as the description in the Revised Final Proposal of Day-Ahead Market Enhancements (Section 4.2), which includes two components: forecasted movement and uncertainty awards. PG&E requests the CAISO to clarify the intend and the meaning of “FMM Uncertainty Award.” 
• [30.5.2.5, 31.5.3.1.3] Supply Bids for Metered Subsystems & MSS Adjustments. The CAISO proposed deleting Tariff language related to Metered Subsystems (MSS) that does not appear related to DAME. Would the CAISO clarify why the following MSS language was deleted? For example, this sentence: “Scheduling Coordinators that represent MSS Operators that have opted out of RUC participation pursuant to Section 31.5 must Self-Schedule one hundred percent (100%) of the Demand Forecast for the MSS.”
• [30.7.3.5] Bid insertion for MSG resources. PG&E requests the CAISO to define the bid insertion scenarios for MSG when a resource is awarded RCD and its reliability dispatch is in a lower configuration than its energy award in the IFM.
• [31.2.2.3.2] Mitigation of Bids for IRU. PG&E requests the CAISO define “Competitive LMP Parameter” in Appendix A.
• [31.5.3.1] CAISO Operator Review & Adjustment. The CAISO currently publishes CAISO BAA RUC operator adjustment details in Day Ahead Summer Reports. The draft Tariff language changes “CAISO Forecast of CAISO Demand” to “CAISO Forecast of BAA Demand.” Will the CAISO publish RUC operator adjustment details for all BAAs in future Day Ahead Summer Reports?
• [40.10.6.1(d)] Bidding obligation for Reliability Capacity. The only reference to bidding obligation for RC is in - a section that relates to flexible RA capacity. It is not clear whether CAISO intents to have the bidding obligation for RC be based on flexible RA capacity. PG&E suggests that it should be based on generic RA capacity.

3. PG&E requests the CAISO to address the following inconsistencies identified in the draft tariff language of DAME:

• [4.5.4.4(a)(iv)] Termination of Scheduling Coordinator Agreement and Suspension of Certification. PG&E believes the CAISO inadvertently used an “and” instead of an “or” at end of this draft language: “if the Scheduling Coordinator does not participate in the CAISO’s markets for Energy, Imbalance Reserves, Reliability Capacity, and Ancillary Services for a period of twelve (12) consecutive months […]”
• [31.3.4/31.3.1.5.1] System Resource. The reference to “a System Resource” in Section 31.3.4 should be followed by “with a Resource ID defined in the CAISO Master File", so that it is consistent with the IR eligibility described in Section 31.3.1.5.1.
• [30.5.2.9/31.3.1.6.2] Bidding range for Imbalance Reserves. PG&E questions the setting of “The value for the $/MW per hour component of the Bid must be between 0 and 247” stated in Section 30.5.2.9. Given that “the upper bound of the procurement curve for both IRU and IRD is $55 per MW,” IBR bids above $55 is unlikely to be dispatched or set the price. PG&E is concerned that allowing bids above $55 lends possibility of intentional and unintentional withholding and could reduce the available IBR capacity in the market.
• [40.6.1(5)/40.6.1(1)(a)] Self-schedule bids. Inconsistency between Section 40.6.1(5) and 40.6.1(1)(a) relating. PG&E recommends that 40.6.1(5) be clarified that only resources with flexible RA capacity be required to submit IR bids.
• [40.6.1(5)/40.10.6.1(a)] Bidding obligation for Imbalance Reserves. Inconsistency between Section 40.6.1(5) and 40.10.6.1(a) - is the bidding obligation for IR based on generic RA capacity or flexible RA capacity? PG&E recommends that the bidding obligation for IR be based only on the flexible RA capacity.

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

PacifiCorp appreciates the opportunity to comment on and make any changes to the Day-Ahead Market Enhancements draft tariff language. Please see the attached document for PacifiCorp's comments. 

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Please see the attached redline.  

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

see attached

1. Please provide any redline changes and embedded comments your organization may have on the Day-Ahead Market Enhancements draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Comments of The Energy Authority on the CAISO Day-Ahead Market Enhancements Draft Tariff Language published June 2, 2023.

The Energy Authority (TEA) is a public power-owned, nonprofit corporation that as a national energy marketing company, evaluates challenges, manages risks, and executes solutions to help its clients maximize the value of their assets and respond competitively in the changing energy markets. TEA partners with over 60 public power clients, managing approximately 30,000 MW of peak load and 24,000 MW of generation in North America’s organized and bilateral wholesale energy markets. TEA’s Western Interconnect partners both inside California and in the rest of the western-markets footprint are directly engaged in and impacted by the CAISO’s existing and evolving day-ahead and real-time energy markets.

TEA generally supports the CAISO’s initial Day-Ahead Market Enhancements (DAME) Draft Tariff Language (DTL), appreciates the CAISO’s publication of a DAME DTL matrix that maps the changes proposed, and supports the recent adjustments the CAISO has made to the remainder of the joint Extended Day-Ahead Market (EDAM) and DAME tariff language development process and the targeted filing timelines.

TEA seeks clarification and further discussion in two areas:

• Regarding the offer ranges stated for Reliability Capacity (RC) and Imbalance Reserves (IR) in Sections 30.5.2.8 and 30.5.2.9, TEA requests the CAISO explain why the $250/MWh and $247/MWh effective caps for these products as well as the IR Procurement Curve outlined in Section 31.3.1.6.2 do not scale to the Hard Energy Bid Cap when such is in place. TEA notes that the Real-Time (RT) Flexible Ramping Product (FRP) against which these RC/IR products settle is opportunity-cost based and therefore is sensitive to the offer cap and questions whether not scaling the DAME products during high-priced tight system conditions may create unintended consequences.
• Regarding the description of the Residual Unit Commitment (RUC) process, setting of targets and operator adjustments, and description of RUC Zones in Section 8.3.1, 31.5.3.1, and 31.5.3.2, TEA requests the CAISO:
  • Clarify any differences in roles and responsibilities that may exist between RC-procurement and RUC-related actions the CAISO may take as the CAISO Balancing Authority Area (BAA) Operator versus those it may take as the EDAM Market Operator and those that other EDAM BAA Operators may take;
  • Further explain the impact that the procurement of IR is expected to have on the CAISO RUC Net Short process, which TEA understands is largely driven today by Variable Energy Resource (VER) Integrated Forward Market (IFM) bidding behavior relative to the CAISO’s forecast of such resources’ real-time production; and
  • Clarify and explain the relationship between nodal procurement expectations for the IR and RC products with the RUC Zones concept.

TEA appreciates the CAISO’s attention to these items and looks forward to continuing dialogue with the CAISO and other stakeholders to promote positive outcomes for this important initiative.