Comments on August 7, 2024 Configurable Parameters Implementation Working Group

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) August 7, 2024, Day-Ahead Market Enhancements (DAME) configurable parameters implementation working group. The CAISO’s proposed testing approach for the configurable parameters preserves most of the time for their own process, leaving little time for market participant review and feedback. The CAISO should revise the schedule and milestones to allow for more stakeholder engagement necessary to determine the values used for the configurable parameters.

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

The timeline indicates that following the August 7, 2024, stakeholder working group, the CAISO will not reengage stakeholders on the configurable parameters until the first quarter of 2026, at which point the CAISO will host one stakeholder meeting per month between January and March prior to a May 2026 implementation date. This schedule does not allow time for the CAISO to present its analysis and use that analysis to inform a methodology for identifying the proper values to use for the configurable parameters.

The timeline shows that CAISO will conduct its analysis from June through December 2025 but will not reengage with stakeholders during this time. The CAISO should revise this timeline to engage with stakeholders earlier in the process to inform them of the results of the analysis as they become available on each configurable parameter, rather than waiting until the entire analysis is complete. As its analysis becomes available, the CAISO should also engage with stakeholders on how the analysis will inform the methodology for selecting the values used in the configurable parameters. Waiting until 2026 to present the entire analysis and set the configurable parameter values does not give enough opportunity for stakeholders to weigh in on the results and values before DAME go-live.

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

CalCCA supports including the five configurable parameters in the scope of the implementation working group, but as described in Section 2, the CAISO should alter the working group schedule to allow more time to assess and potentially modify the values that will be used.

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

CalCCA agrees with the CAISO that the five configurable parameters will have interactions with each other and, therefore, supports the CAISO’s proposed approach of first testing individual parameters and their sensitivities and then assessing the performance of all parameters in place to identify any needed calibration or unintended interplays.

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

CalCCA has no comments on the imbalance reserve mosaic quantile regression parameters at this time.

6. Provide any additional comments:

CalCCA has no additional comments at this time. 

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

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

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

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

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

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

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

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

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

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

6. Provide any additional comments:

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

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

NV Energy appreciates and generally supports CAISO’s effort to undergo a stakeholder process to receive stakeholder comments and feedback for the imbalance reserve product configurable parameters. During the August 7, 2024, working group meeting CAISO described the testing schedule, defined the tunable parameters, and explained the testing methodology. This was all very helpful to gain a better understanding of the scope for this implementation working group; however it was not clear how the data will be provided to stakeholders and what data stakeholders would be able to see in order to provide meaningful feedback. As an example, it would be helpful if CAISO provided the results and impacts broken out by each individual Balancing Authority Area so that stakeholders have the ability to view the overall impact each parameter has on their respective area.

Additionally, it was unclear whether these parameters will be stated in a Business Practice Manual at the conclusion of this process or if these parameters will not be clearly stated in any documentation. NV Energy recommends that the final tunable parameters be stated clearly in a Business Practice Manual or tariff following the conclusion of this process in order to preserve the stakeholder process if changes are necessary in the future.

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

 No comment.

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

NV Energy is surprised that parameters 4) imbalance reserve demand curve cap and 5) default availability bid prices for imbalance reserves up and reliability capacity up mitigation are within the scope as tunable parameters. These specific items were a part of the Day Ahead Market Enhancements initiative and were approved and included within the tariff changes.  Therefore, NV Energy recommends that these items be brought back to the stakeholder process if CAISO determines that these parameters need to be tuned to a different cap or price. 

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

NV Energy generally supports CAISO’s proposed testing approaches; however, CAISO has not been clear about the testing footprint that would be used.  NV Energy believes the footprint will be just as important to the overall test as other controls that will be applied while testing.  For instance, the test may indicate a certain value is needed for the parameters for an EDAM footprint that only includes PacifiCorp and the CAISO Balancing Authority Areas and may indicate very different values when a larger footprint is included with more connectivity with a different resource mix. It would be helpful for stakeholders to understand the footprint that was used during testing when reviewing the results.  Additionally, NV Energy would like to know whether CAISO plans to change the parameters when the EDAM footprint changes and includes a larger footprint.

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

No comment.

6. Provide any additional comments:

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

PG&E appreciates CAISO hosted the DAME configurable parameters implementation working group discussion and provide the opportunity for questions and comments.  

PG&E has been a committed partner in the development of the Extended Day-Ahead Market and the Day-Ahead Market Enhancements.  We want to see a successful and on-time launch of EDAM and the testing and tuning of these parameters are a crucial part of the preparation.  

The 8/7 initial plan is a good start. PG&E finds that the testing plan presented on August 7th is a good start but is concerned of its incompleteness.  For this process, PG&E has two key expectations:  

1. That the entire testing and tuning process will be a collaboration between CAISO and stakeholders. Tuning of the parameters is too important to have gaps in the communication between CAISO and stakeholders. PG&E would suggest the CAISO hold additional working group sessions between now to Jan 2026. We’re committed to helping develop and provide feedback throughout the entire process. 

        2. The level of detail shared needs to be sufficient to assess the testing, test results and tuning methods. The initial plan is a good start but needs to be more complete.  The tunning of these policy-driven parameters is different than implementation testing.  It may require different methods and metrics. We’ve provided specific questions and comments on item #3, and we expect more detailed plans, methods, metrics will be provided in future meetings.  

  With the goal of a successful 2026 launch of DAME and EDAM, it is critical that stakeholders are not surprised by the results presented to them in January 2026. Having frequent and broad communication of this testing and tuning process should mitigate the risk of a 2026 surprise and help launch DAME and EDAM on time. 

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

Market Sim and Parallel Operations

On this plan, we would like to see a final market simulation test plan that includes tests for parameter interactions and a final set of tests at the ‘optimal’ parameter values (from the fine-tuning results) and the interaction between them. This item is critical to the implementation success. We are committed to helping at every stage.

       DAME Config Parameters Tuning

The testing of these policy-driven parameters is different than implementation testing.  It may require different methods and metrics; further it will require more regular and active updates to stakeholders. Additionally, we have concerns about the level of detail shared isn’t sufficient to assess the testing methods (see our response to question 4).  Therefore, we suggest the CAISO hold additional working group sessions between now and Jan 2026.

Imbalance Reserve Requirements

For this stage we have only a few clarifying questions:

1. It is our understanding that this portion will be built out the Imbalance Reserve product functionality. Can CAISO confirm this understanding?
2. What is the scope of the Imbalance Reserve Requirements testing?
3. Are those milestones for CAISO internal teams?
4. There are some stakeholder meetings shown on the schedule, can CAISO elaborate this line item a little more?

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

PG&E appreciates the amount of thought and effort that has gone into constructing this testing plan. We do have a few comments and questions regarding the choice of included parameters:

1. In the policy phase, there was some consideration of treating imbalance reserve down differently than imbalance reserve up. To that end, is CAISO considering having different tunable parameters for the upward and downward products?
2. Should the process include parameters that activate/deactivate the RUC-Market Power Mitigation (MPM) process?  Our understanding from the business requirements and specifications for DAME is that RUC-MPM may not be performed initially, and CAISO specifies a parameter for activation of MPM (DAME BRS BRQ 05020). PG&E is curious whether the parameter will be set based on market conditions. If so, we believe that it should be tunable and beneficial from discussion in this working group.  
3. Should an additional tunable parameter be defined to constrain the effect of energy limits on imbalance reserve awards, analogous to the envelope constraints defined for batteries. If IRU counts toward 100% of a hydro resource’s daily energy limit implies its day ahead energy awards may be highly variable unless the resource bids to avoid imbalance reserve awards (i.e., bids zero quantity or $55/MW).
4. PG&E is confused by the inclusion of the imbalance reserve demand curve cap (parameter #4) and the default availability bid prices for imbalance reserve (parameter #5).  PG&E appreciates more clarities on (a) how CAISO plans to tune these parameters without real bids, and (b) are curious why these should be considered for tuning given these are tariff defined values, (c) if CAISO plans to change the demand curve cap value, this needs to go through a stakeholder process.  

1. 1. Functionality verses Tuning. We understand that CAISO can test the functionality of a demand curve cap or default bid prices; what is confusing is how CAISO plans to “tune” these values with limited understanding of how these products will be bid. These are completely new products. Stakeholders and the Market Surveillance Committee Members expressed doubt as to what actual bids for these products will be. Without actual bids, it is unclear how one can assess whether a cap is of an appropriate value.

1. 2. Tariff Defined parameters.  The demand curve cap is defined to be $55/MWh, as specified by the pending tariff section §31.3.1.6.2.  This was set to that value after significant stakeholder debate.

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

As the CAISO is going to introduce these new products into the market, we commend the CAISO for outlining what is going to be a thorough testing plan.  We offer these comments and questions in the hopes that we can help create a successful DAME and EDAM launch in 2026. 

PG&E would appreciate it if the CAISO could clarify what it is meant by “performance analysis” for those parameters? Is it software performance (i.e., computational time), or are there other metrics measuring market responses, such as price changes and expected levels of unrealized congestion from Imbalance Reserve awards?  PG&E finds the latter were typically not included in conventional market-sim procedures but believes they are critical for the CAISO and stakeholders to understand how the values of the parameters should be set with the addition of new products in DAME.   

1. Set of transmission constraints enforced in the deployment scenarios during market simulation.
   • What range will be used for initial testing (e.g., [0-1] or [0.1-0.9])?
   • How is the constraint being identified and selected for the testing?  i.e., is it a static set or is it a static method for selecting a dynamic set of constraints?
   • What is meant by “performance analysis” for this parameter?

2. Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios.
   • What is meant by “performance analysis” for this parameter?

3. Energy storage “envelope constraint” multipliers – no questions

4. Imbalance reserve demand curve cap & 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation.
   • As noted in the previous response, we understand that CAISO can test the functionality of a demand curve cap or default imbalance reserve bid; what is confusing is how CAISO plans to “tune” these values with limited understanding of how these products will be bid. These are completely new products. Stakeholders and the Market Surveillance Committee Members expressed doubt as to what actual bids for these products will be. Without actual bids, it’s unclear how one can assess whether a cap is of an appropriate value?  
   • PG&E believes it is important to assess the market outcomes including:
     1. Impact on LMPs for energy or ancillary services.
     2. Frequency of occurrences where the IFM does not clear for the full amount of imbalance reserves.  

         These metrics of market outcomes will depend on the assumed imbalance reserve bids.

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

There was not any testing approach presented in the 8/7 meeting; therefore, we suggest that CAISO provide the testing approach and another opportunity for stakeholders to comment.  

6. Provide any additional comments:

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

PacifiCorp appreciates the CAISO providing an update to stakeholders on their plans for tuning the DAME configurable parameters. PacifiCorp believes that the proposed timeline may not be long enough with the expectation that there will be robust discussion in the stakeholder meetings on what the parameter values should be set to. Based on the August 7 meeting, it appears as though stakeholders will want to thoroughly discuss how the configurable parameters should be set. PacifiCorp agrees with the parameters that will be tested and how those parameters will be tested. PacifiCorp also appreciates the CAISO conducting a separate process for the imbalance reserve requirement estimations.

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

PacifiCorp is wary of the current schedule as it seems to only provide a short window for stakeholders and the CAISO to discuss and enact changes from the stakeholder meetings before EDAM go-live. During the policy phase, stakeholders were under the impression that there would be more discussion on how the parameters should be set. PacifiCorp expects that stakeholders will want to make changes from the initial values, which may require further testing from the CAISO. If the CAISO is confident with their proposed schedule, PacifiCorp recommends that the CAISO release their analysis on the tunable parameters well before the first stakeholder meeting so that all stakeholders have time to prepare.

It would also be helpful if the CAISO clarifies what the expectations are for the stakeholder meetings. In particular:

• What analysis does the CAISO plan on showing in the stakeholder meetings?
• What performance indicators from testing may suggest to the CAISO that the configurable parameters should be changed from their initial values?
• If stakeholders and the CAISO decide to make parameter changes in the March stakeholder meeting, how will that impact parallel operations?

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

PacifiCorp agrees with the list of configurable parameters that will be tested by the CAISO and discussed for implementation.

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

PacifiCorp agrees with the proposed testing approach.

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

PacifiCorp appreciates that the CAISO has separated the efforts to evaluate the mosaic quantile regression parameters from the meetings on the other configurable parameters. PacifiCorp is looking forward to seeing the CAISO’s analysis and working towards making improvements, if needed, to the quantile regression parameters before EDAM go-live.

6. Provide any additional comments:

PacifiCorp asks that the CAISO explain what the EDAM footprint will be for the parameter testing in MAP-Stage because the footprint will likely have an impact on how the tunable parameters perform. Also, PacifiCorp would like to know if the CAISO will be sharing analysis in the stakeholder meetings that is specific to the CAISO or if the analysis will include information about PacifiCorp. If the analysis will contain PacifiCorp information, the company would like to know beforehand in case there is information that may be deemed sensitive to the company.

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

N/A 

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

SDG&E appreciates that CAISO’s modeling activities will be complex and time consuming, and notes that this effort would benefit from stakeholder participation throughout the process, and in particular prior to the Q1 2026 proposed stakeholder meetings for the configurable parameters. During the workshop, CAISO staff indicated openness to earlier discussions, and SDG&E strongly encourages revision of the current timeline to allow for more participation upfront and throughout the proposed schedule. DAME will have far-reaching impacts for CAISO’s as well as SDG&E’s operational systems, and it would be beneficial if updates and opportunities for stakeholder involvement were available with each modeling iteration as this would provide transparency and facilitate feedback to support CAISO’s work.

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

N/A 

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

N/A 

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

N/A 

6. Provide any additional comments:

N/A 

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

SCE's comments will primarily focus on the timing and involvement of stakeholders in the implementation working group plan.  The proposed plan waits too long to involve stakeholders in the implementation process.  There should be at least one stakeholder meeting concerning the tunable parameters prior to market sim with monthly or bi-monthly updates through the commencement of parallel operations.  This will do two things:  (1) refresh stakeholders understanding of the effort including setting expectations and provding updates during market sim; (2) with that refreshed understanding, ensure that stakeholders will be up-to-speed and fully engaged during the fine-tuning that will occure in a compressed timeframe during parallel operations.

Because DAME and EDAM represent such a significant evolution of CAISO markets, it must be anticipated that there will be various hiccups along the path to implementation that will further compress already short timelines.  To mitigate the risk of further compression, it will behoove CAISO to involve stakeholders earlier in the implementation process with stakeholder meetings beginning before market sim rather than beginning before parallel operations.

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

See above for comments on the commencement and cadence of stakeholder meetings.

The project milestones appear okay but CAISO should ensure that some contingency has been built in the market sim and parallel operations schedules.

Additionally, is there an overall master schedule that shows the implementation steps for both DAME and EDAM?  If not, does it make sense to create one so that stakeholders can get an overall sense of the work to be accomplished by Q2/Q3 2026?

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

No comment at this time

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

The proposed testing approaches appear to be sound.  There should be some consideration of how CAISO will deal with unexpected outcomes, either in market sim or parallel operations.  For example, if any one or more of the parameters requires siginficant deviation from their respective initial values in order for the optimization to acheive sound results, CAISO should involve stakeholders in a more robust review of the parameter(s).

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

No comment.

6. Provide any additional comments:

No additional comments.

1. Provide a summary of your organization’s comments on the Aug 07, 2024 DAME configurable parameters implementation working group discussion:

WPTF appreciates the CAISO for providing stakeholders with an update and overview of their plan for the implementation working groups on configurable parameters. However, we are disappointed by the lack of early stakeholder engagement in the process for the configurable parameters. WPTF is concerned that there may not be enough time to fully involve stakeholders and integrate their feedback as envisioned by the implementation working groups during the policy process. Additionally, the testing process must ensure that the parameters being evaluated not only address market performance but also address the outstanding policy questions that initially prompted these working groups. 

2. Provide your organization’s comments on the current implementation working group schedule and milestones:

WPTF appreciates the schedule and milestones set for the imbalance reserve requirement process. Engaging early with stakeholders and holding staggered meetings throughout the analysis phase allows for meaningful feedback and gives CAISO sufficient time to incorporate this input and make necessary adjustments.

However, we are extremely disappointed with the proposed schedule and milestones for the configurable parameters. Stakeholders should be involved earlier in the process. While we understand the need for initial analysis time, scheduling three stakeholder meetings in the last three months is inadequate. This approach does not provide enough time for meaningful engagement, feedback, or integration of that feedback into the analysis and testing. Additionally, it leaves insufficient time to present updated results, make necessary changes to the market design before go-live, and address any required Tariff amendments.

We respectfully request that the CAISO (1) include stakeholder meetings during the Map stage testing, (2) start the parallel operations testing and scheduled stakeholder meetings earlier such that feedback can be incorporated into ongoing testing, and (3) ensure the overall schedule allows for sufficient time to make market design changes, including potential FERC filings, if needed before go-live.

3. Provide your organization’s comments on the five configurable parameters included in the scope of the implementation working group:

The parameters include: 1) Set of transmission constraints enforced in the deployment scenarios during market simulation; 2) Tunable parameter for proportion of imbalance reserves that are “deployed” in deployment scenarios during market simulation; 3) Energy storage “envelope constraint” multipliers; 4) Imbalance reserve demand curve cap; and 5) Default availability bid prices for Imbalance reserves Up and Reliability Capacity Up mitigation. More information on these parameters can be found in the DAME Business Requirements Specification (BRS): https://www.caiso.com/documents/businessrequirementsspecification-day-aheadmarketenhancement.pdf

No comment.

4. Provide your organization’s comments on the proposed testing approaches for each of the configurable parameters:

WPTF believes it’s important that the testing approaches reflect the essence of the policy discussions that led to these implementation working groups. Specifically, there was considerable debate about whether the imbalance reserve design should be fully nodal, more like a zonal framework, or somewhere in between. Additionally, there was also lively debate on the value of the imbalance reserve demand curve bid cap, especially in light of the fact it was changed at the end of the policy discussion to $55/MW. Thus, the testing approaches included in this stakeholder engagement should aim to quantify the costs and benefits of the range of potential frameworks and impact of the imbalance reserve demand curve cap. 

The proposed parameter values to initiate testing and conduct sensitives around seem to focus primarily on a nodal framework and $55/MW demand curve cap. Thus, we ask CAISO to test the following parameter values which will help quantify the pros and cons of frameworks along the zonal to nodal spectrum and impact of the unjustifiably low demand curve cap:

• Transmission constraints: Set of major interfaces like Path 15, Path 16, and other known constraints that routinely contribute to the inability to move energy from one larger area to another
• Deployment: 0%
• Imbalance Reserve Demand Curve Cap: $247/MW

Additionally, the analysis presented to stakeholders should evaluate the impact on price formation, alignment between congestion in the IFM and real-time markets, the correlation between the amount of imbalance reserves procured and the imbalance reserve demand curve cap, and market process time. These were significant policy questions discussed before the Board meeting, which led to the establishment of these working groups. The goal was to continue policy discussions using market results from these working groups to assess the pros and cons of designs ranging from zonal to fully nodal.

5. Provide your organization’s comments on the proposed testing approach to evaluate the Imbalance Reserve mosaic quantile regression parameters:

No comment.

6. Provide any additional comments: