Greg Rybka (firstname.lastname@example.org)
PG&E has provided its redlines and comments in the attached file of "Draft Tariff Language Track 2 Transmission Service Market Scheduling Priorities Phase 2 Section 23 and Section 36 Appendix A.
Teresa Silva (email@example.com)
SDG&E appreciates the opportunity to submit comments on the Transmission Service and Market Scheduling Priorities (TSMSP). Please see our comments below:
23.2.3 Termination or Modification of a Firm Power Supply Agreement Underlying a Monthly or Daily Wheeling Through Priority and Other Releases of Awarded Wheeling Through Priorities Back to the CAISO
Priorities Back to the CAISO
If the firm power supply contract supporting the Wheeling Through Priority is terminated for any reason or is modified such that the MW quantity, hours of service, import point, or export point changes, the Scheduling Coordinator with a monthly or daily Wheeling Through Priority must notify the CAISO within one (1) Business Day.
"Hours of service" referenced here makes no
mention to number of days, we suggest adding those units of time to the language.
If the Scheduling Coordinator seeks a priority for MW quantity
greater than the MW quantity in the original contract, or either the import or export Scheduling Point in the replacement contract is different than the import or export point in the original contract supporting the Wheeling Through Priority, the Scheduling Coordinator must re-apply for a Wheeling Through Priority in a subsequent request window.
The case where there is a greater
number of hours is missing, suggest adding this case and consequence of having a greater number of hours.
23.3.1 Historical Contract
Information Regarding Non-Resource Adequacy Resource Import Supply
The import supply contracts that can be reported under this
Section 23.3.1 must be longer-term firm contracts that include the applicable month, monthly contracts, or a portfolio of shorter-term contracts for the month. They cannot be contracts to replace other external capacity that becomes unavailable.
The definitions of "longer term" and "shorter term" contracts
are not defined, and we suggest adding time metrics to these terms.
If termination of the supporting firm power supply contract occurs before the date on which the Scheduling Coordinator with the Wheeling Through Priority can first schedule a Priority Wheeling Through transaction using its Wheeling Through Priority, the Wheeling Through Priority will terminate unless the Scheduling Coordinator can demonstrate an equivalent replacement power supply contract
Section 23.2.3 states that the wheeling through priority will terminate when the firm power supply contract does yet section 23.7.1 states that a wheeling through priority reseller cannot resell or reassign priority to avoid a firm power supply contact. If 23.7.1 is true, then it seems the ability to resell is still available even when losing the supply contract. Specifying cases when priority can and cannot be resold with respect to terminating contracts will help clarify this section.
23.7.1 Procedures for Reselling a Monthly Wheeling Through Priority
A Wheeling Through Priority Reseller will remain responsible for complying with all requirements of this Section 23. Resales of a Wheeling Through Priority only allow the transfer of a Wheeling Through Priority and do not convey to the assignee any other rights, and the assignee is not responsible to the CAISO for the Wheeling Through Priority Reseller’s financial obligation to the CAISO for ultimate payment of the original Wheeling Through Priority, which obligation remains with the Wheeling Through Priority Reseller. A Wheeling Through Priority Reseller cannot resell or assign a Wheeling Through Priority for the purpose of enabling avoidance of the firm power supply contract requirement of Section 23.2.1.
Submitted on behalf of Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
Margaret McNaul (firstname.lastname@example.org)
Please refer to the attached redlines.
Stephen Keehn (email@example.com)
SCE is concerned that under the proposed tariff it seems that external entities may be able to lock up transmission capacity without having to fund any transmission upgrades and without having to show a contract for supply supporting the request, as is required for short-term wheeling priority requests. This seems possible if a long-term wheeling priority request is determined to not require any upgrades or new transmission. SCE reminds the CAISO that the existing transmission was paid for by CAISO load and should not be assigned to non-CAISO entities unless studies demonstrate that local load will have no need for the capacity for a significant period, likely a minimum of 20 years. If external entities pay for the construction of new transmission or for upgrades to the current system SCE agrees that they should be able to receive wheeling priority for these expenditures, but even in these cases, the CAISO should ensure the request does not encumber existing capacity that may be needed in the future to serve CAISO load.
SCE also seeks clarification as to why the CAISO has specifically called out for assessment congestion across Path 26, and not across any other internal paths. Should the specific path assessment include other potential congested paths, such as Path 15? Alternatively, do the general studies consider congestion on all possible paths? Currently, the main congestion point associated with wheeling transaction is Path 26, but it is possible that in the future this will change. The tariff should be written to consider all potential sources of internal congestion, not just those we currently see.
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