Comments on draft tariff language

1. Please provide your organization’s overall feedback regarding the EDAM Congestion Revenue Allocation Draft Tariff language.

PG&E has three comments and suggestions: 

1) Section 33.11.1.2.1 needs to be more clear.  E.g., the first sentence describes a "difference" and it takes way too much brain power to understand what two things are being compared. 

2) In section 33.11.1.2.1, why do the EDAM participating transmission service providers get to determine which types of firm service qualify?  We understand that the CAISO tariff cannot overrule the EDAM participant OATT, where the suballocation will finally happen. But the CAISO tariff can put a minimum standard that qualifies for this CRA treatment; i.e., CAISO will only allocate the EDAM entity the parallel flow on contracts with a term of one month or longer.  This is what the policy says and the CAISO tariff should help ensure that the policy is followed even if we can't determine how the EDAM OATT suballocation happens. 

3)  These redlines reference sections that are not in the current conformed tariff, but are pending.  Even though those sections are not being edited, it would be really helpful to include those sections for reference.  At a minimum, any references to pending sections should be labeled as pending and let us know in which of the pending amendments the section is in. 

1. Please provide your organization’s overall feedback regarding the EDAM Congestion Revenue Allocation Draft Tariff language.

PacifiCorp appreciates the opportunity to participate in the CAISO’s expedited stakeholder process and comment on the proposed EDAM Congestion Revenue Allocation Draft Tariff language (“Draft Tariff Language”). PacifiCorp understands the Draft Tariff language seeks to address concerns regarding parallel flow congestion cost allocation that were raised in PacifiCorp’s proceeding before the Federal Energy Regulatory Commission (“FERC”) to revise its Open Access Transmission Tariff (“OATT”) to implement the EDAM in its Balancing Authority Areas. PacifiCorp also understands that the Draft Tariff Language is proposed as a transitional solution to address these concerns ahead of other near- and long-term EDAM enhancements to address congestion cost issues, which will be addressed after EDAM go-live.

PacifiCorp maintains that the congestion allocation approach proposed in the Company’s pending EDAM implementation proposal is just and reasonable and appropriately suballocates the total pool of congestion revenue that would be allocated from CAISO. Nonetheless, PacifiCorp recognizes that several stakeholders have expressed concern over parallel flow congestion exposure stemming from the EDAM design itself, even if such concerns may be overstated. Accordingly, PacifiCorp supported CAISO launching this expedited stakeholder process to assess this EDAM design issue.

Following extensive engagement with CAISO and other stakeholders on this issue, PacifiCorp believes that the resulting Draft Tariff Language, as modified per below, will address stakeholders’ parallel flow concerns. In particular, the proposed language directs CAISO to allocate a portion of day-ahead parallel flow congestion revenues to the EDAM balancing area where market participants have paid prices that include those congestion costs.  The EDAM balancing area receiving the parallel flow congestion revenue can thereafter use it to manage the cost of congestion for those transmission customers exercising their eligible firm transmission rights.  This updated approach is in contrast with the current CAISO tariff language that would otherwise solely allocate congestion revenue based on where the constraint occurs. 

PacifiCorp supports the Draft Tariff Language as a means to achieve this transitional congestion change ahead of EDAM implementation, and suggests the following edit to proposed CAISO Tariff Section 33.11.1.2.1.  The redline change below is suggested to avoid unnecessarily restricting the type of firm transmission products that an EDAM Entity may make eligible for congestion cost allocation treatment under such EDAM Entity’s OATT.

33.11.1.2.1      EDAM Entity Balancing Authority Area Contribution Adjustment

For each Settlement Period of the DAM, the CAISO will determine the Congestion difference within the EDAM Area from the contribution of qualified and balanced Day-Ahead Self-Schedules registered by the EDAM Entity in each EDAM Entity Balancing Authority Area to the Marginal Cost of Congestion at each resource location and intertie in the EDAM Area and allocate this Congestion difference to the EDAM Entity Balancing Authority Area where the qualified and balanced Day-Ahead Self-Schedule is associated. Qualification for this adjustment will be afforded to transmission service identified in the EDAM Transmission Service Provider tariff as a firm service of sufficient duration, such as firm long-term and monthly point-to-point and network transmission service rights under FERC’s pro forma open access transmission tariff, including conditional firm transmission service. Registration of qualified transmission service rights will occur through the procedures described in Section 33.18.3 and result in a CRN to facilitate this adjustment. A Day-Ahead Self Schedule will be considered balanced for purposes of this adjustment in accordance with the provisions of Section 33.16 application to the determination of whether an EDAM Legacy Contract is balanced in the DAM.

1. Please provide your organization’s overall feedback regarding the EDAM Congestion Revenue Allocation Draft Tariff language.

PGE appreciates the CAISO’s thorough and timely revisions to the tariff language to better align congestion revenue allocation with the broader EDAM design. The draft language affirms key principles including recognition of firm transmission service under the EDAM OATT, proportional allocation of surplus based on measured demand, and the clear separation of CRR and EDAM congestion revenues. 

PGE believes this tariff revision supports EDAM go-live and the associated customer benefits it is expected to deliver. By expanding access to regional diversity, improving day-ahead market efficiency, and ensuring fair and transparent congestion revenue allocation, EDAM is expected to lower costs and enhance reliability, all of which will directly benefit PGE customers. 

PGE supports the draft tariff language and encourages the CAISO to move forward with implementation.

1. Please provide your organization’s overall feedback regarding the EDAM Congestion Revenue Allocation Draft Tariff language.

In the proposed Tariff language, CAISO creates a new section 33.11.1.2.1 (below) which includes a provision that attempts to articulate which transmission service will be afforded the adjustment. WPTF is concerned that this language is suggesting what types of service may lead to qualification (rather than leaving that to the individual EDAM entities to put in their tariffs). We do not believe the CAISO is seeking this authority, nor were those specifics laid out in the policy process. While in the long-term, we would like to see the CAISO take more ownership over market rules and drive consistency (such as defining eligible transmission rights), for the time being including this language in the CAISO tariff, while officially leaving the definition of eligibility to EDAM Entity tariffs, may lead to confusion and create the potential for conflicts. For now, CAISO should leave the definition of eligibility to EDAM Entity tariff.  As the EDAM evolves, however, CAISO should seek to implement these definitions on a consistent basis within the Market Operator tariff.

WPTF recommends the CAISO strike the proposed language that is redlined below.

33.11.1.2.1 EDAM Entity Balancing Authority Area Contribution Adjustment

For each Settlement Period of the DAM, the CAISO will determine the Congestion difference within the EDAM Area from the contribution of qualified and balanced Day Ahead Self-Schedules registered by the EDAM Entity in each EDAM Entity Balancing Authority Area to the Marginal Cost of Congestion at each resource location and intertie in the EDAM Area and allocate this Congestion difference to the EDAM Entity Balancing Authority Area where the qualified and balanced Day-Ahead Self-Schedule is associated. Qualification for this adjustment will be afforded to transmission service identified in the EDAM Transmission Service Provider tariff as a firm service of sufficient duration, such as firm long-term and monthly point-to-point and network transmission service rights under FERC’s pro forma open access transmission tariff, including conditional firm transmission service.  Registration of qualified transmission service rights will occur through the procedures described in Section 33.18.3 and result in a CRN to facilitate this adjustment.  A Day-Ahead Self Schedule will be considered balanced for purposes of this adjustment in accordance with the provisions of Section 33.16 applicable to the determination of whether an EDAM Legacy Contract is balanced in the DAM.