Comments on Revised straw proposal

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

The California Efficiency + Demand Management Council (Council) thanks the CAISO for the improvements made in the Revised Straw Proposal, especially the clarifications to how the DR monitoring data penalties would be applied.  The Settlement Quality Meter Data (SQMD) materiality threshold is a positive step but additional clarity is needed of exactly how the thresholds will be calculated.  Additionally, the Council recommends that the materiality threshold be expanded to DR monitoring data.  The Council fully supports the reduced minimum number of days of historical DR monitoring data from 90 to 45, while still allowing the CAISO to collect older data if needed for baseline determinations.   

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

The Council appreciates the CAISO providing additional examples to illustrate how the DR monitoring data penalties would be applied, and supports the proposed penalties.  However, in light of the newly added meter data materiality threshold for Settlement Quality Meter data (SQMD), the Council recommends that the same threshold be applied to DR monitoring data.  Prompt and accurate SQMD are arguably of greater importance to CAISO operations so it would be fair to expand the materiality threshold to DR monitoring data as well.

The Council also thanks the CAISO for reducing the minimum days of historical DR monitoring data from 90 days to 45 days, with exceptions when additional data are needed for specific baseline methodologies. This will reduce the burden on DR providers while ensuring the CAISO continues to have the data it needs to perform its operations.

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

The Council reserves comment. 

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

The Council reserves comment.

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

The Council strongly supports the proposed materiality threshold because it would avoid penalties over comparatively immaterial data gaps. However, it is not clear exactly how the CAISO would determine whether the material threshold has been exceeded.  More specifically, the Revised Straw Proposal states that “self-reported inaccuracies below 3% of 3 MW of the day’s actual data will not be considered a tariff violation and therefore will not be subject to penalties.” This presents the question of exactly how the percentage of the day’s data is determined. For instance, is it based on the number of time intervals? A similar question applies to how the MW magnitude of the shortfall is calculated, especially if MW schedules vary during a trading day.

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

The Council has no objections to the Joint Authority classification of this initiative.

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

N/A

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

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

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

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

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

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

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

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

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

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

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

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

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

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

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

 Idaho Power appreciates the opportunity to comment on the CAISO’s Revised Straw Proposal for its Penalty Enhancements: Demand Response, Investigation, and Tolling stakeholder initiative (Revised Straw Proposal).  Idaho Power appreciates CAISO’s continuous effort to work with stakeholders on the Rules of Conduct section of the ISO tariff and believes these proposed changes are a step toward ensuring penalties are just and reasonable.

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

No comments.

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

No comments.

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

Idaho Power appreciates the CAISO addressing its comments regarding the clarity of the tolling process and CAISO’s efforts toward enhancing the CIDI ticket process to keep all communication in one CIDI case for ease of tracking.

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

 Idaho Power appreciates the CAISO’s consideration of its suggestion to include an inaccurate meter data penalty materiality threshold.   Idaho Power believes that this proposed materiality threshold achieves a balance of ensuring that accurate and timely meter data is submitted while also ensuring that entities are not penalized for meter data errors that have a de minimis impact on the market. 

Idaho Power does request one clarification from the revised straw proposal.  The revised straw proposal describes the Current Rule as “the penalty for inaccurate meter data is assessed at either the lower of $1,000 or 30% of the value of the error.”  The Proposed Rule is that “self-reported errors below 3% or 3MW of the day’s actual data will not be assessed penalty.”  Idaho Power requests clarification that the Current Rule would stay in effect in the event that the materiality threshold was not met, and that the Proposed Rule would be in addition to the Current approved penalty for inaccurate meter data.

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

No comments.

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

No comments.

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

 NV Energy appreciates CAISO’s continuous effort to work with stakeholders on the Rules of Conduct section of the ISO tariff.  NV Energy supports CAISO’s initial proposal to update the investigation process and offers the following options for consideration to update the investigation process:

1. Option 1 - The CIDI ticket that reports the meter data error should remain open until the CAISO’s final findings and penalty notice, if applicable, is issued.
2. Option 2 - The CIDI ticket that reports the meter data error should remain open until either CAISO issues a final notice with no penalty, or if there is a penalty, until the CAISO receives final payment or issues a refund.

Currently, CAISO closes CIDI tickets prior to the conclusion of the entire investigative process which results in multiple CIDI tickets which makes communication between the Scheduling Coordinator and CAISO difficult and results in a confusing process. Prematurely closing CIDI tickets leads the Scheduling Coordinator to think that the CAISO’s investigation is closed and there will be no penalty.  Also, when the CIDI ticket is prematurely closed, the Scheduling Coordinator cannot reply to CAISO utilizing the relevant CIDI ticket number for ease of tracking.   NV Energy believes that the process would be simpler and more efficient to have one CIDI ticket associated with a single issue. 

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

NV Energy supports the CAISO’s proposed penalty tolling process to have the Scheduling Coordinator pay a penalty after a FERC decision is issued determining that the penalty is appropriate.

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

NV Energy supports the CAISO’s proposed meter data penalty materiality threshold of less than 3% or 3 MW of the day’s actual value.

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

Olivine appreciates CAISO’s PEDRIT proposal. With a few clarifications, we believe that it would strike a good balance of flexibility for market participants and give CAISO better reliability in meter data submissions

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

Olivine appreciates CAISO reducing the minimum historical data from 90 days to 45 days. This can be helpful, especially for getting new resources and new customers online more quickly. We also appreciate CAISO’s clarification on late meter data not resulting in compounding penalties if there are multiple days missing that are related to the same event. 

CAISO should set the submission deadlines for monitoring data based on the trade date it is applicable for. Under the new requirements, registration load data (CBL) will be required for 45 days prior to each event. Given that the deadline for performance data is based on a trade date of T+52B, underlying load data for the 45 days preceding the trade date could change near the 52B deadline for the trade date, affecting baseline and performance calculations. What is the deadline for CBL data? If the monitoring data deadline is 52 business days after the date of the meter data itself, an SC could be subject to late data changepenalty for the monitoring data even if there is no penalty for the same trade date for performance data. This could incentivize DRPs not to re-submit monitoring data if there are last-minute changes.

As an example, suppose we are looking at 6/13/2024. The 52B deadline is 8/26/2024. However, the 52B for the first set of CBL data could be as early as 7/11/2024 (the 52B date for 4/30/2024). It would be helpful if the deadline for this data remained 8/26. Otherwise, CBL data would be out of sync with BASE data.

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

Olivine supports the materiality threshold for inaccurate meter data submission. CAISO should clarify the units for the materiality threshold. Is the 3 MW referring to average dispatch throughout the day, dispatch across any interval, or something else? It would be more clear if it were stated in terms of metered energy in MWh.

CAISO should implement the materiality threshold for DR monitoring data. This data is not used directly for market settlement, and it could be costly if there is a financial penalty on resubmission for monitoring data even if the performance data submission itself is not subject to penalty. At minimum, it should be the same materiality threshold as for meter data (both for baseline and performance data). We understand that it would not be appropriate for an SC to submit 0 MWh meter and/or baseline data by 52B only to correct it several months later. However, there can be metering issues that persist beyond 52B that necessitate smaller changes. These should be permissible as long as they meet the 10%/3 MW threshold as described. Applying the materiality threshold to monitoring data would also alleviate some concerns expressed earlier regarding monitoring data deadlines.

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

1. Please provide a summary of your organization’s general comments on the PEDRIT revised straw proposal and presentation:

SCE appreciates CAISO’s improvements to the proposed two-letter process in replacement of the current three-letter process. CAISO has stated that moving to a two-letter process is not intended to reduce the time available to the Scheduling Coordinator (SC) and/or the listed generator to respond to the notice of violation, and the process flowchart on page 17 of the presentation deck helps clarify the intent of CAISO’s proposed two-letter investigation process.  SCE will support the proposal only if CAISO includes the flowchart or equivalent in the BPM and CAISO commits to having open dialogue between CAISO and the SC/listed generator when trying to resolve a potential Rules of Conduct (ROC) violation. SCE also expects that CAISO will not prematurely issue the second and final Results of Review letter so long as there is continued effort put forth by the SC/listed generator. 

For the new proposed process to be successful, it is crucial that CAISO enhance its communications and collaboration with SCs and Market Participants (MP) during the contested violation period. CAISO must maintain close communication with SCs and MPs to ensure an aligned understanding of the evidence.  When a result of a contested violation is determined, CAISO must clearly explain the results and the rationale behind its decision. SCE recommends that this process be detailed extensively in the relevant Business Practice Manual. This will ensure that all parties involved have a clear understanding of the process and its implications. In addition, CAISO should ensure that both the SC and the listed generator receive the initial notice of violation. Furthermore, CAISO should implement a process for confirmation of receipt by the SC and the listed generator to ensure that they have been notified and given the appropriate time to respond to the notice.

2. Please provide your organization’s comments on the proposed definition of submission requirements and penalty structure for DR monitoring data, as described in the revised straw proposal:

SCE does not have any additional comments.  

3. Please provide your organization’s comments on the proposed streamlining of the Rules of Conduct investigative process, as described in the revised straw proposal:

SCE does not have any additional comments.  

4. Please provide your organization’s comments on the proposed update to the penalty tolling process, as described in the revised straw proposal:

SCE does not have any additional comments.  

5. Please provide your organization’s comments on the proposed establishment of an inaccurate meter data penalty materiality threshold, as described in the revised straw proposal:

SCE does not have any additional comments.  

6. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the revised straw proposal:

SCE does not have any additional comments.  

7. Please provide additional comments on the PEDRIT revised straw proposal or presentation not mentioned above:

SCE does not have any additional comments.