Comments on Intertie Schedule Modeling Enhancements (6/15)

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

Comments on the Intertie Schedule Modeling Evolution Stakeholder

Workshop - June 15, 2026

Department of Market Monitoring

June 29, 2026

Summary

DMM appreciates the opportunity to comment on the June 15, 2026 Intertie Schedule Modeling Enhancements Stakeholder Workshop.[1] Given DMM’s understanding of the issue based on materials presented in the stakeholder workshop, DMM is concerned that the proposed solution to non-optimal tagging on CAISO ITC rights—the enhanced scheduling limit constraints—has the potential to unnecessarily limit imports and exports. DMM asks the ISO to provide additional details on the issue and clarify why it could not instead be solved with a post-market procedure that ensures optimal tagging. 

Comments

Potential for the “enhanced scheduling limit constraints” to limit the available import supply

As DMM understands the proposal, the current ITCs—which are the sum of the scheduling path limits— would be replaced with “enhanced scheduling limit constraints” for each ‘point-to-point’ limit along the scheduling path. As an example, consider Figure 1 from page 33 of the presentation:

Figure 1. ITCs and scheduling paths

In this example, import bids at SP1 would currently be constrained by ITC1 with a limit of 250 MW (100 MW from path SP1 to SP2, plus 150 MW from path SP1 to SP3). Imports would also be constrained by ITCs 5, 6, and 7. But under the new approach, imports could choose to bid at one of two paths to get from SP1 to CISO:

1. SP1-SP3-CISO, which would be subject to limits SP1-SP3 of 150 MW, and SP3-CISO of 300 MW; or
2. SP1-SP2-SP4-CISO which would be subject to limits of 100, 150, and 500 MW.

If 400 MW of imports are offered at SP1, a total of 250 MW could be supported by the scheduling rights. But under the new approach, importers would have to choose one of the paths to offer on before the market runs. If the imports all chose the SP1-SP3-CISO path, then they will be limited by the 150 MW SP1-SP3 constraint, and only 150 MW of imports will clear when the scheduling rights could support up to 250 MW.

DMM asks the ISO to confirm this understanding of how the new modeling would work. If so, it appears this could unnecessarily limit the supply of imports based on which scheduling paths the importers guess they should be submitting offers on.[2] This splitting of offers at ITCs into different paths could also create situations where higher cost imports clear on one path while lower cost imports remain uncleared on the other path.

What is causing the imports to not be optimally tagged over ISO scheduling rights?

As the ISO states, the total amount of imports cleared under current ITC limits can be supported by the ISO’s scheduling rights if the schedules are optimally tagged. But the ISO states that the assumption of optimal tagging does not always hold. DMM asks the ISO to clarify why this does not always hold. Why are the tags not created to conform to the scheduling rights available when it is feasible to tag within the available rights? Who is creating these tags for ISO scheduling rights: the ISO or market participants?

For example, assume one bid clears all 250 MW of the ITC1 limit at SP1. If the import is all tagged along the SP1-SP3-CISO path it would violate the 150 MW SP1-SP3 limit, causing the problem the ISO described. But why would the import be tagged this way? Why can’t the import be tagged as 150 MW taking the SP1-SP3-CISO path and 100 MW taking the SP1-SP2-SP4-CISO path? 

DMM asks the ISO to explain why this problem cannot be solved with a post-market tagging procedure that does not violate any path scheduling limits (i.e., that ensures optimal tagging) rather than changing how imports bid into the market—which might unintentionally limit imports and exports or lead to inefficient clearing of intertie transactions.

[1]  Intertie Schedule Modeling Enhancements - Stakeholder Workshop, June 15, 2026: https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation-Intertie-Schedule-Modeling-Enhancements-Jun-15-2026.pdf

[2] The opposite might also be true. The ability to export from CISO could also potentially be unnecessarily limited.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

No comment.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

PG&E supports increasing day-ahead market accuracy and effectiveness. 

In order to move forward with GAP-Tie designs, the CAISO must be able to show the GAP-Tie design will not break current systems (i.e. contracting, acquiring transmission rights, reassignment, bidding, tagging, timing, settlements). PG&E needs to see more details to understand how the process will work in order to be comfortable with the design. For example, entities must retain the ability to contract for RA imports, both specified and unspecified. These changes touch on many important processes and PG&E needs CAISO’s help to fully vet this proposal. For example, PG&E has the following questions:

• How does this work for ETCs and TORs?
• If an RA import is reassigned to an EDAM BA’s resource, does that change which party bids the import? Does it change who gets paid? Could this impact long-term contracts for any non-pseudo-tie/dynamic-tie resources?
• Will the GAP-Tie design alter the congestion risk on either side of the ISO boundary?
• How will tagging work? Which entity bears the risk if the import fails to tag?

Additionally, PG&E requests a bid-to-bill walkthrough of the process to understand how the changes that CAISO is proposing will work, as this could help think through and reveal concerns that stakeholders had not considered.

The GAP-Tie design represents the potential to improve the modeling and scheduling accuracy of the day-ahead market, improve congestion pricing in the day-ahead market, and reduce the need for real-time redispatch. These are goals that PG&E supports, but would like CAISO’s help to verify that the new process will work.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

The GAP-Tie model should improve the accuracy of the DA solution over the current Scheduling Point-Tie (SP-Tie) design. The current design models injections at the ISO boundary as a fictional generator stationed at the other end of a tie, which can lead to inaccurate DA schedules and inaccurate congestion pricing that the real-time market must then redispatch. The GAP-Tie design should improve the DA solution by modeling non-source-specific imports at a Default Generation Aggregation Point (DGAP), which can represent anticipated power flows more accurately. This appears to be a small, but sensible improvement over the current SP-Tie design. PG&E supports the goal of improving the day-ahead market’s accuracy, but needs to see more details to understand how the process will work.

Previously, CAISO had proposed multiple import prices at a tie point using the Custom Generation Aggregation Point (CGAP) model, but some stakeholders raised concerns with gaming. PG&E supports removing the CGAP proposal and its associated opportunities for gaming.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

No comment.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

PG&E supports the goal of clearing DA imports more accurately and efficiently. As a next step for the ESLC, PG&E would appreciate an example that is a bit more clear about the problem. What is the magnitude of the problem? Does CAISO anticipate this getting worse in the future? Also it would be helpful to see a more detailed example showing which schedules are flowing where and which transmission constraint is binding. The example provided on slides 37 and 38 are a bit tough to follow.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

No comment.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

PacifiCorp thanks the CAISO for the presentation at the June 15th stakeholder call that gave stakeholders a recap of the proposed GAP-Tie design. To date, the CAISO has provided examples demonstrating that the GAP-Tie modeling may better align with real-time power flow, resulting in improved congestion management and price formation. While the CAISO has previously indicated a desire to move forward with the GAP-Tie construct prior to Portland General Electric’s activation in the Extended Day-Ahead Market, it is apparent that stakeholders still need time to understand nuances and edge cases to refine business and hedging practices. A broad understanding of the implications to stakeholders transacting in the CAISO’s day-ahead and real-time market to support contractual obligations is necessary and so additional workshops will be prudent as the CAISO continues through this initiative.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

PacifiCorp recognizes that the CAISO’s examples are designed to be agnostic to specific Balancing Authority Areas (BAAs), however, given the material changes introduced by GAP-Ties, discussions of real-world scenarios at intertie locations frequently transacted at (i.e., Four Corners, Mona, Malin, Palo Verde, etc.) and associated price formation is warranted. The CAISO presented GAP-Tie pricing data now available on OASIS. PacifiCorp recommends revisiting the data available and providing crosswalk examples on specific interties comparing the SP-Tie and GAP-Tie modeling, including the resulting DGAP pricing. This will enable stakeholders to clearly evaluate the differences in congestion price formation under each approach. 

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

PacifiCorp agrees with stakeholders that creating multiple prices at an intertie point could lead to inefficiencies for those who frequently transact at CAISO interties and appreciates the CAISO assuaging concerns from stakeholders by establishing a single price per intertie. During the June 15th stakeholder call, it was apparent the CAISO exhibited a defined position for which adjacent BAA price would be used at which intertie. PacifiCorp requests the CAISO to publish a reference document for intertie locations and BAA DGAP’s associated with those specific intertie locations. For example, it was stated that Malin would use Bonneville Power Administration's (BPA) DGAP and Palo Verde would utilize Salt River Project’s DGAP during the call. This request is to ensure explicit communication and transparency as stakeholders continue in the discussion at future workshops.   

The CAISO discussed that to achieve the single price, the market optimization would mirror schedules at the adjacent balancing authority, simplifying the GAP-Tie design. The examples provided in prior meetings did not go into the mechanics of bridging schedules to the adjacent balancing authority to achieve the single price and appear to trade one set of the assumptions for another. In future workshops, it’d be beneficial to stakeholders to understand how this is an improvement over using the SP-Tie design already established.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

No comment.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

PacifiCorp appreciates the high-level overview given on the Enhanced Scheduling Limit Constraint (ESLC) and agrees this initiative is the appropriate forum for intertie scheduling discussions. PacifiCorp requests the CAISO to revisit the ESLC in a future stakeholder call to better understand the scope of the effort such as specific scheduling paths that are causing the need for the ESLC in addition to how multiple prices discussed in the meeting. Based on the presentation, CAISO appears to be requesting stakeholders that all scheduling paths are registered in the Masterfile and then modeled as composite interties. Any deviation from the new composite interties will be rejected in the day-ahead timeframe unless communicated after-the-fact use of an alternate scheduling path. Although this is perceived flexibility offered by the CAISO, it does introduce operational limitations and increased coordination with the CAISO.  

PacifiCorp requests that the CAISO clearly articulate the proposed process and associated impacts across stakeholder groups, specifically calling out the lift for EDAM Entities and Scheduling Coordinators. From an EDAM Entity lens, the ESLC appears to entail additional complexity, reduce operational flexibility, and impose significant workload on EDAM Entities to implement without a clear understanding, or assessment of the overall benefit. 

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

No comment.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

At this time, the Six Cities have not yet developed a definitive position regarding implementation of the GAP-Tie modeling design, but they do not oppose further analysis and consideration of GAP-Tie modeling.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

The Six Cities appreciate the CAISO posting informational data on intertie prices that would have occurred if GAP-Tie modeling had been in place.  It would be very helpful if the CAISO could analyze the available data and summarize the anticipated impacts of adopting GAP-Tie modeling on intertie prices and other market outcomes (e.g., volumes of imports and exports, impacts on CRRs).  To the extent that the data appear to indicate differences or inconsistencies in impacts among different interties, the Six Cities request that the CAISO share its analysis of the reasons for such differences.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

At this time and on a preliminary basis, the Six Cities support development of a single price at each intertie, subject to consideration of additional data or analyses that may become available.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

The Six Cities have no comments on this topic at this time. 

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

Based on the Six Cities’ understanding of the CAISO’s Enhanced Scheduling Limit Constraint (“ESLC”) proposal, and on a preliminary basis, it appears conceptually appropriate to align constraints reflected in the market optimization with available transmission rights.  It will be critical, however, for the implementation process to include active coordination and full transparency among all affected transmission owners and transmission rights holders, especially with regard to the classification and quantification of transmission rights reflected in specific Scheduling Limit Constraints.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

The Six Cities have no additional comments at this time.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

SCE requires more information as discussed below before determining our position on GAP-Tie design. SCE understands the efficiency gains that the CAISO anticipates when moving to GAP-Tie design but requires additional information to assess the potential cost impacts due to commercial changes required to adapt to a GAP-Tie market design.  

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

CAISO needs to provide stakeholders with an analysis comparing SP-Tie price at each node with the DGAP prices at the same nodes and clearly identify which DGAP would be the default, adjacent BAA DGAP that would be reported as the single price for the intertie. CAISO should also provide analysis showing how many CAISO interties will have multiple DGAPs at the intertie, and what percentage of imports are sourced through these interties, and for each intertie how much of the imports are sourced through the various DGAPs.

As SCE understands, it is no longer possible to fully price hedge a transaction from a generator in an EDAM BAA to load in the CAISO. The hedging entity can purchase OATT transmission from the generator to the intertie in the EDAM BAA, and a CRR in the CAISO from the intertie to the load aggregation point. However, the potential difference in the Marginal Energy Cost (MEC) between the two EDAM BAAs (the Transfer System Revenue) is split evenly between the two BAAs, and the CAISO BAA portion will not be allocated to the importer or the CRR holder but will be allocated to load on a load weighted basis. Because of this, SCE requests that the CAISO provide an analysis of how often it should be expected that the MECs will differ and what those differences are expected to be. There are now almost two months of EDAM data to be used, and it may be possible to use WEIM data to determine how often congestion between the BAAs is expected to arise.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

SCE has several questions about the single price per intertie location:

• SCE would like to understand exactly which adjacent DGAP maps to each intertie (or at least for COB, NOB, PV, Mead, and Mona). A 1-to-1 mapping table would be ideal. Additionally, SCE has requested in Question 2 data and analysis on the DGAPs at each intertie.
• Slide 13 in the presentation states “All intertie schedules will use by default the adjacent balancing area DGAP for a given intertie location.” Will all transactions at the intertie be priced at the single price, or will the single price be the reported price, but individual transactions will, or may, settle at the specific DGAP where the power is coming from? Is the single price to be used only for non-resource specific import energy?
• A few slides later, on slide 17 in the presentation, it indicates that CRRs will be able to use all DGAPs as source/sinks. This seems to imply that these prices will be available and be used for settlement purposes. Will CRRs be available at the single price and be applicable to all potential DGAPs at that intertie? This is why the analysis requested in Question 2 is important.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

SCE continues to have concerns about RA Import Reassignments and reiterates its request to CAISO to have a bid-to-bill walkthrough of this process. The example should include discussions of settlement, scheduling, CRRs, tagging, CARB Cap-and-Invest GHG compliance obligations, MIC, MOO and bidding requirements, and RAAIM implications so that entities can see the full scope of operational and commercial impacts of the new mechanism.

SCE is concerned that the RA import scheduling and processes will impact the current commercial structures for bilateral energy import and RA contracts and there could be potential negative effects on the availability of these products to CAISO LSEs. CAISO providing a complete bid-to-bill example covering all aspects will help stakeholders understand and anticipate potential issues. Such an understanding will be critical in negotiating new RA contracts and determining how existing RA contracts will need to be treated. 

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

SCE’s initial impression is that the ESLC mechanism will be an improvement, but we are still analyzing the examples. It would be helpful to SCE to have a repeat presentation in which stakeholders can ask questions after having digested the initial presentation.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

No comments.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

The well-functioning, efficient, and reliable intertie markets the West has relied on for many years are critical to maintain as the West transitions to operating under centralized day-ahead markets. They are the key link between forward capacity and energy markets used to manage risk and meet compliance and planning obligations and the physical spot-markets where generation is dispatched to serve real-time demand. They are also the pathway for market participants to solve market seams issues bilaterally while formal market-to-market solutions are developed long-term at the market operator level. Any changes made to policies impacting intertie markets must target improving their efficiency without undermining their ability to continue providing reliability and economic value to market participants and ratepayers.

Unfortunately, while it is questionable whether the changes proposed to date in the Intertie Schedule Modeling (ISM) initiative would improve the efficiency of CAISO's intertie markets – or even meaningfully improve modeling accuracy – it is certain they would both disrupt aspects of its day-ahead and hour-ahead intertie markets in multiple areas and fail to address the liquidity and price-formation issues that have emerged with the implementation of EDAM.  

For these reasons, The Energy Authority (TEA) does not support the current scope and proposal.

TEA does, however, support CAISO continuing the ISM initiative – we simply believe the effort should restart with CAISO and stakeholders working together to develop a clear problem statement, while also identifying risks to avoid and benefits to target.

TEA sees the following issues as discussion topics that could help define a problem statement for the ISM initiative and more broadly for addressing intertie market inefficiencies, and would be willing to unpack each in a stakeholder panel or presentation at a future meeting:

• Price formation and reliability impacts of the self-scheduling requirements for imports and exports at non-CAISO EDAM External Interfaces.
• RA Import viability and loss of access to marginal inter-regional supply during tight system conditions as existing CAISO interties transition to EDAM interties in 2027 and 2028.
• Impacts of changes to forward contracting at existing trading hubs and physical delivery of traded products as Western index-based markets adapt to EDAM, Markets+, and RTOE seams, RA Programs, and price formation in 2027 and 2028.
• Impacts of policy changes developed in either/both the Congestion Revenue Rights Enhancements Phase 2 initiative and the EDAM Congestion Revenue Allocation

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

Before CAISO performs analysis, on modeling, price formation, and economic efficiency impacts of moving from the current SP-Tie model to a GAP-Tie model, the apparent gap in understanding between CAISO, California-centric stakeholders, and entities transacting in the broader West around how forward financial and physical bilateral markets operate, the value they provide, and the foundations they rely on needs to be addressed. TEA is willing to participate in a panel discussion or provide an overview of its experience and examples of transactions that would be impacted by a modeling change but believes multiple entities need to bring their perspectives to this process for it to be successful.

Further, it would be helpful for CAISO to discuss its existing approach to using its Full Network Model (FNM) to approximate regional dispatch and powerflow impacts on CAISO constraints when doing any of the following: transmission and interconnection planning, MIC allocation, annual and monthly CRR allocations and auctions, and multi-day reliability and market planning look-aheads. CAISO should also review outcomes from its c.2013-14 FNM initiative, including powerflow accuracy studies that were performed following implementation as these may provide valuable context for considering issues and potential solutions in the current market.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

This question highlights why some stakeholders, including TEA, consider moving to a GAP-Tie model for CAISO’s BAA and maintaining a GAP-Tie model for the non-CAISO EDAM BAAs that relies on DGAPs to approximate powerflow impacts and inform price formation as problematic. Each Western market beyond CAISO’s border still depends on contract-path transmission that has significant locational value to effect transactions – and only the SP-Tie model with its individual prices at individual interties respects that reality.

For example, resources in the BPA BAA wishing to sink to CAISO have the choice to compete to acquire transmission on the Pacific AC Intertie, the Pacific DC Intertie, or to wheel through multiple systems to reach one of multiple CAISO interties, each of which today often have significant differences in their pricing. Is it just and reasonable to adopt a policy that means the entities invested in transmission rights to one intertie scheduling point will no longer receive the locational price benefits of accessing that intertie?

The West is not operating as a single RTO and extending RTO-to-RTO seams management concepts to an OATT-to-RTO seam requires significant work and negotiation to get to a reasonable solution. This is not only an issue for marketers selling economy energy – it very much impacts RA Import markets, both for price formation reasons and because of how import allocation rights are managed at individual interties by CAISO. These issues need to be discussed before discussing how intertie locations could be priced if a GAP-Tie model was used for CAISO’s non-EDAM interfaces. 

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

Contracting for capacity that meets RA program qualifications has never been more complex as suppliers and purchasers are having to contend with multiple policy changes, new markets, and increased competition. Adding EDAM ISM changes that would increase both the complexity and price-risk of managing RA import/export contracts within the current contracting window (e.g., 2027-28 compliance years/seasons) would only serve to increase contracting risk, which ultimately is an inefficiency that harms ratepayers. TEA therefore recommends CAISO consider Import RA contract facilitation when defining the problem statement for the ISM initiative and work with stakeholders to understand what they need as suppliers and purchasers from an import scheduling and process perspective to reduce risk and increase the efficiency of RA transactions.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

TEA supports the request the Western Power Trading Forum (WPTF) made during the meeting for CAISO to provide a narrative description of their proposal. TEA requests that cover the problem CAISO sees, the timeline it must be addressed on, and the proposed solution. Following that, CAISO should work with stakeholders to identify any trade-offs or carry-on impacts for entities transacting capacity, energy, or CRR products in the areas the policy would apply.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

Please see TEA's note above regarding being part of a potential panel on existing Western forward markets and the touchpoints with intertie market policy and modeling.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

TransAlta Energy Marketing U.S. (TEMUS) appreciates the willingness of the CAISO to help stakeholders better understand the implications of the CAISO’s proposed Generation Aggregation Point (GAP) tie design after stakeholders first raised concerns about the design in November 2025.

TEMUS understands that the CAISO wants to apply the GAP-Tie design in the Extended Day-ahead Market (EDAM) because:

1. FERC approved the continued use of the Scheduling Point pricing as “transitional”;
2. GAP-Tie pricing is currently utilized in the real-time Energy Imbalance Market (EIM), and;
3. The GAP-Tie design is expected to improve power flow modeling.

However, this is insufficient to justify the use of GAP-Tie pricing in EDAM if it does not address the root cause of the issue in the first place.  Essentially, the CAISO is proposing to better measure the problem of phantom congestion instead of fixing it.

The GAP-Tie design may create much more harm to the electricity market than it solves: the potential to create multiple prices at the same interface restricts market efficiency by complicating price transparency. Market liquidity flourishes under stable markets with predictable outcomes, while the GAP-Tie design creates an environment in which specific GAP-Tie pricing creates a significant risk of energy transactions. TEMUS remains concerned with the GAP-Tie design because its impacts are much greater in EDAM than in EIM, where the volume of transactions and range of possible outcomes is much lower.

The GAP-Tie design is a solution to an engineering problem without consideration of the impact on market design and outcomes. Instead, the problem of phantom congestion would be better addressed by enabling economic intertie bidding at all EDAM interfaces. This would create a clear signal for both market participants and to the CAISO as the market optimizer.

The argument that intertie bidding would harm reliability is a non sequitur because the EDAM design includes numerous safeguards, including balancing area transfer constraints, the Resource Sufficiency Evaluation (RSE) and penalties, and the ability to self-schedule, in addition to OATT contract limits and commercial consequences.

Therefore, TEMUS urges the CAISO to:

1. Modify the EDAM tariff to enable economic bidding at all interties and for a wider range of transfers, and;
2. Maintain the current SP-Tie pricing design.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

TEMUS agrees that the Department of Market Monitoring’s (DMM) previous suggestion of a simplified design has merit and is worth exploring in future workshops. A simplified GAP design where only one generic GAP is used per tie instead of multiple potential GAPs would help reduce complexity and may improve the loop flow issues raised by the CAISO.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

See above comments regarding multiple prices at the same intertie.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

No comment.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

TEMUS is concerned that the CAISO’s Enhanced Scheduling Limit Constraint (ESLC) proposal creates less transparency and adds another limit on transfers that is not visible to Market Participants when they submit their final schedules in the day-ahead. In addition, the ESLC further erodes the value of purchasing firm transmission from EDAM Entities, because increased uncertainty reduces the effectiveness of transmission rights as a hedging instrument. This could, in turn, jeopardize revenue collected from the OATT-based service, eventually increasing retail rates.

During the June 15 workshop the ESLC concept was briefly introduced, but the cost-benefit of implementation on market efficiency was not explained. It is also unclear how the ESLC would impact Congestion Revenue Rights valuation, auction funding, and Congestion Revenue Allocation. Again, this appears to be an engineering solution applied with little consideration to the impact on the electricity market.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

TEMUS recommends that the CAISO address the long-standing issues regarding loop-flow modeling in the Integrated Forward Market (IFM) and specifically address why either loop-flows or flows from Existing Transmission Contract (TOR) and Transmission Ownership Rights (ETC) on some constraints, by themselves, appear to exceed the transmission limit.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

At this stage, Vistra is not prepared to support a transition to GAP-Tie modeling unless the CAISO provides significantly more clarity on how common commercial transactions of resources located within the CAISO BAA will be bid, scheduled, prioritized, tagged, settled, and curtailed under the future design. The June 15 presentation explains the modeling rationale, but it does not yet provide a complete transaction path for a California resource located inside the CAISO BAA that seeks to sell power outside the CAISO BAA, nor does it sufficiently clarify the transaction path differences depending on the final sink location.

A resource selling power at its Point of Interconnection (“POI”) within the CAISO BAA with the intent to support sale to an external BAA has more complex transaction paths post-EDAM. Below is a non-exhaustive list of the trading scenarios that we would like a transaction path mapped from any contract reference number, forward transmission reservations, bidding, and scheduling.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

In prior discussions, CAISO has explained that an intertie offer under GAP-tie modeling of $5/MWh would be evaluated against the Default GAP of $10/MWh to represent in the model a willingness to import at the GAP-tie at $15/MWh or higher. Today, an intertie offer at $5/MWh implies willingness to inject if intertie clearing price is at $5/MWh or higher. If the market participant wants to make the same offer as today, Vistra has understood from discussions a basis offer of $-5/MWh is needed so the model sees the economic value at $5/MWh after assessing the intertie basis offer against the GAP price. These are two different types of bidding: physical basis under GAP-tie and fixed price under SP-tie.

We are concerned that there is lack of detail and clarity on how the bid is to be treated in the DAM, HASP, and RTM under GAP-tie to inform changes in bidding behavior. Vistra still has questions regarding the bid types for intertie transactions in DAM versus RTM and whether they are still shifting from fixed price to physical basis, and as such the change to bidding behavior is still uncertain. A more robust discussion about what fixed price versus physical basis means commercially, and which type of offer is needed into DAM versus RTM for intertie offers is needed to avoid bidding that interferes with the desired market outcomes from confusion.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

Vistra generally supports the objective of establishing a single price per intertie location, but we do not see how a single price per intertie is feasible under the GAP-tie model. For Vistra, single intertie pricing necessitates maintaining the SP-tie model that models injections or withdrawals at the BAA boundary. A single intertie GAP-tie price seems as if it will sometimes be correct but may also often be incorrect if the resource is not sourcing and flowing from the assumed GAP location causing further confusion regarding price outcomes. Additional clarity on that concern would be appreciated.

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

Vistra is interested in whether there are any changes for CAISO internal resource selling power outside the CAISO BAA to continue to be eligible to meet the sink BAAs Resource Sufficiency Evaluation in DAM or RTM due to GAP-tie.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

Vistra is not opposed to modeling improvements; however, we seek an implementation approach that minimizes complexity and pricing outcomes for different transactions designed to result in a similar market dispatch outcome. Currently, the pricing results presented regarding ESLC modeling appear to produce many market price scenarios. Vistra seeks a better understanding of whether there is a way to streamline the outcomes, and encourages the CAISO to refine the modeling approach to minimize confusion and produce rational price outcomes.

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

None at this time.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

Western Area Power Administration (WAPA) is a federal agency responsible for marketing hydropower generated by the federal Central Valley Project (CVP) to meet its statutory responsibilities to serve project-use energy pumping requirements and market available hydropower generation under its Power Marketing Plan to preference power customers.  In Northern California, WAPA serves load in both the Balancing Authority of Northern California and the CAISO.  WAPA delivers its generation from many large and small hydro facilities of the CVP to its loads.  WAPA owns, operates and maintains an extensive high voltage transmission network extending to the load center of Northern California.

WAPA appreciates the opportunity to provide comments on the CAISO’s presentation on intertie schedule modeling enhancement. WAPA will be affected by how the intertie schedule modeling changes the existing commercial arrangements for transmission and energy outside CAISO’s market. CVP generators will participate in the Extended Day-Ahead Market (EDAM) after Balancing Authority of Northern California (BANC) joins EDAM in October 2027. CVP generators will have to support generic Resource Adequacy (RA) imports to its power customers in the CAISO Balancing Authority Area. The intertie schedule modeling will also affect how CVP generators will participate in EDAM.

WAPA supports CAISO’s efforts to enhance the accuracy of the power flow model as the means to enhance system reliability, market efficiency and price accuracy. In developing such enhancements, CAISO must not impede market efficiency, including bilateral markets, mute price signals or misalign the LMP and the true value of the energy in bilateral markets, force market participants to engage in additional business processes to transact in bilateral markets, and consequently diminish the efficiency of bilateral markets.

CAISO’s presentations so far focused on the modeling accuracy from a power flow perspective. CAISO argued that modeling the power flow on the intertie by a single injection would not be as accurate as by a group of generators in the neighboring BAA. While WAPA does not oppose such a general idea, WAPA is concerned with the current GAP-Tie design and particularly the implementation details. WAPA is concerned that CAISO’s intertie modeling implementation, including the GAP-Tie design and the Transfer System Resource settlement implementation has adverse effects on:

• WAPA’s transmission assets and transmission ownership rights,
• WAPA’s ability to procure replacement power through bilateral trades over interties for WAPA’s sub-balancing authority area,
• WAPA’s ability to market CVP power efficiently

WAPA recommends that CAISO allow sufficient time for the market participants to understand the details of the GAP-tie design and propose improvement instead of rushing to implement the current version of the GAP-tie design by October 2027.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

WAPA requests that CAISO release the latest problem formulation details to allow market participants to understand the price formation and the ramifications. CAISO can update the Extended Day-Ahead Market Draft Technical Description released on September 11, 2024 or release the Appendix of the latest EDAM BRS that describes the final formulation details. 

A small but non-trivial linear programming (pricing run) example to illustrate the interactions among balancing constraints, transmission/transfer constraints, GAP-tie definition and price formation for GAP-tie, SP-tie and TSR will be very helpful. 

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

WAPA needs more information to provide comments on single/multiple prices associated with DGAP.?See information requests in item 2. 

In general, multiple prices at the same transaction point can create energy valuation uncertainties and settlement complications. For example, the current TSR pricing creates two prices on each side of the intertie after DAME. Although such a pricing design is not a direct consequence of GAP-tie but a settlement design detail, it has had adverse effects on liquidity and valuation of bilateral transactions over interties between two EDAM BAAs.  

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

The current RA import scheduling design requires reassignment from the intertie resources that shows RA to individual generation resources per MIC (maximum import capability) entitlement. The total number of generator self-schedules = number of generators * number of MIC entitlements * number of intertie resources. This is a very large number! Moreover, since intertie schedules must be e-tagged, all these self-schedules must be integers. The integerization creates under and over provision relative to the original RA showing. Moreover, the individual generators in the group of generators may experience derate while the group of generators supporting the interchange can still provide the same amount of RA capacity. By requiring the RA import to be linked to individual generation resources, the CAISO has just created significant but unnecessary burden for the market participants to perform generator substitution frequently. This is not intrinsically a GAP-tie problem; it is a small implementation detail associated with the GAP-tie design that creates a big implementation complexity for market participants. 

Because an RA obligation provided by a firm import schedule that is e-Tagged must be honored by the originating BAA, WAPA believes it is not necessary to reassign intertie RA obligation to individual generators. WAPA encourages CAISO to explore simplifications for market participants to enhance market efficiency. WAPA is committed to work with the CAISO to explore alternative solutions.  

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

WAPA does not have comments on this subject at this time. 

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.

1. Please provide your organization’s feedback regarding the evolving CAISO balancing area intertie schedule modeling to GAP-Tie design as described in the June 15, 2026 presentation.

To the extent possible at this stage, please share your organization’s perspective on whether you may support or oppose evolving to the GAP-Tie design for modeling intertie schedules and associated rationale.

WPTF appreciates the opportunity to submit these comments. Based on the information presented to date, WPTF is not persuaded that the proposed transition to a GAP-Tie design has been demonstrated to produce materially more accurate market outcomes than the current framework, especially when factoring in the market economic and efficiency impacts.

CAISO's primary rationale for moving to GAP-Tie modeling is that modeling imports as injections at the intertie location may not accurately reflect the actual source of energy and therefore may contribute to inaccurate congestion management and price formation. While WPTF acknowledges that the current SP-Tie approach necessarily relies on simplifying assumptions, the proposed GAP-Tie design appears to replace one set of assumptions with another rather than eliminating the underlying uncertainty.

This concern is particularly acute for imports that originate outside EDAM or WEIM areas or for transactions where the ultimate source of supply is not known at the time of market clearing. In such circumstances, assigning imports to an adjacent balancing area DGAP may be no more representative of actual power flows than modeling the transaction at the intertie location itself. CAISO has asserted that the GAP-Tie approach more closely reflects physical generation sources, but has not yet provided sufficient empirical evidence demonstrating that the resulting market solutions are materially more accurate or efficient.

Before adopting a significant redesign of intertie modeling, CAISO should provide quantitative analysis comparing the current SP-Tie framework and the proposed GAP-Tie framework across a range of historical market conditions. Such analysis should evaluate impacts on congestion management, LMP formation, congestion revenue allocation, uplift, dispatch efficiency, and overall production costs. Without such evidence, it remains unclear whether the benefits of the proposed redesign justify the additional complexity and implementation costs.

We also have significant concerns that the impact on market economics and efficiencies have not been adequately discussed or considered. We discuss this concern in more detail in response to #2 below.

2. Please provide your organization’s feedback regarding additional information that may be helpful in comparing the current SP-Tie design and the potential future GAP-tie design for modeling intertie schedules and any associated tradeoffs (i.e., additional examples, data, analysis or other information).

As stated in previous comments, WPTF believes CAISO should devote significantly more attention to evaluating the market efficiency and economic tradeoffs associated with the proposed design changes.

The June 15 presentation focuses heavily on potential improvements to congestion modeling and price formation, but provides little discussion of the potential adverse impacts on economic dispatch and market efficiencies. Specifically, WPTF is concerned that the proposed framework would increase self-scheduling and adversely impact price formation and thus ability to achieve the most efficient outcome.

Increased reliance on self-schedules generally reduces the amount of capacity available for economic optimization. When resources are self-scheduled rather than economically bid, market prices become less reflective of marginal production costs and the market's ability to identify and dispatch the least-cost resources is diminished. As a result, consumers may face higher overall costs even when lower-cost resources are available and willing to serve load because the market has no visibility into the marginal costs of all resources, just those that economically offer; in other words, this proposal will force self-scheduling of potentially higher cost resources than otherwise would be used but for this proposal and diminish the potential overall benefits of participating in an organized market.

Similarly, the proposal may reduce operational flexibility available to the market for congestion management. Economic dispatch relies on the ability of the market to efficiently re-dispatch resources in response to changing system conditions. To the extent the proposal increases self-scheduling, it may actually reduce the flexibility available to manage congestion efficiently.

To facilitate a meaningful evaluation of these tradeoffs, CAISO should engage in more robust discussion of the economic impacts and provide additional analysis focused on the market economics associated with the proposed changes, including impacts on economic dispatch, production costs, congestion management, and overall market efficiency. In particular, CAISO should evaluate how increased incentives for self-scheduling may degrade price formation, rendering prices less reflective of true marginal costs, which in turn diminishes the market’s ability to efficiently commit least-cost resources and manage congestion due to weakened and less accurate price signals.

Absent this information, stakeholders cannot adequately assess whether the proposed changes improve or diminish market performance.

3. Please provide your organization’s feedback regarding the establishment of a single price per intertie location associated with the DGAP of the adjacent balancing area.

WPTF believes that a single price should exist for a given product at a given intertie location. Market transparency, efficient trading, and effective price signals are best supported when market participants can rely on a single transparent locational price. Having multiple prices for the same product at the same location was one of the main concerns raised by stakeholders when the CAISO initially introduced their plan for intertie scheduling and modeling prior to EDAM go-live.

Creating multiple prices for effectively the same import or export opportunity at the same intertie location risks introducing unnecessary complexity, reducing price transparency, and creating opportunities for inefficient arbitrage behavior. Multiple prices may also create challenges for hedging, bilateral contracting, and market participation by introducing uncertainty regarding which price ultimately applies to a transaction.

Accordingly, WPTF supports maintaining a single pricing construct at each intertie location. However, this does not diminish our concern that the proposed intertie modeling simply swaps out one potentially inaccurate assumption (injection at intertie point) versus another (assuming it comes from within the adjacent BAA).

4. Please provide your organization’s feedback regarding RA import scheduling and processes presented during the June 15th meeting under the GAP-Tie design.

Please include any additional information that may be helpful to introduce in future workshops to help improve understanding or evaluation of the design.

No additional comments at this time; please see previously submitted comments.

5. Please provide your organization’s feedback regarding the Enhanced Scheduling Limit Constraint (ESLC) presentation and establishing the scheduling limits on certain multi-segment interties on the system to manage transmission rights violations, schedule curtailments and operational impacts on these paths.

WPTF has significant concerns regarding the proposed ESLC framework.

Although CAISO presents ESLC as a means of more accurately enforcing transmission rights on specific transmission segments, the proposal appears to introduce substantial additional complexity into both market participation and risk management. Market participants would effectively be required to identify and commit to specific scheduling paths in advance despite the fact that actual system conditions, transmission availability, and commercial opportunities may change significantly between the time scheduling decisions are made and the time energy ultimately flows.

The proposal therefore risks creating unnecessary friction and reducing the flexibility that currently exists for participants to adapt to changing market conditions. Market participants may be forced to make path-specific decisions based on incomplete information, potentially resulting in less efficient scheduling outcomes.

Additionally, it is our understanding that this proposal will create multiple prices for the same product at the same location. The difference in prices is dependent on the path chosen when offering the energy as an import. As noted in previous meetings throughout this entire effort, WPTF does not support having multiple prices for the same product at the same location.

WPTF is also concerned about the implications for the CRR market. The proposed framework appears to require market participants to forecast not only congestion risk but also the specific scheduling path that will ultimately be relevant for future transactions. This introduces additional uncertainty into CRR decisions and may reduce the effectiveness of CRRs as a hedging instrument.

Moreover, it remains unclear how CAISO will determine the amount of transmission capability to make available on each path within the CRR process and how those assumptions will remain aligned with the day-ahead market. Stakeholders have spent considerable effort over the years attempting to reduce discrepancies between the CRR model and the day-ahead market because such differences contribute to underfunding, inefficient hedging outcomes, and reduced confidence in the CRR framework. WPTF is concerned that ESLC may create another source of divergence between the CRR and day-ahead market models unless carefully designed and validated.

At this stage, WPTF does not believe CAISO has demonstrated that the benefits of ESLC outweigh the additional complexity and market risks introduced by the proposal

6. Please provide your organization’s feedback on any other aspects of the presentation and initiative.

To the extent that a stakeholder is interested in presenting at a future workshop, please send an email to ISOstakeholderaffairs@caiso.com.