1.
Please provide your organization’s perspective on the draft tariff language, Section 24:
Southwestern Power Group (“SWPG”), Pattern Energy (“Pattern”), and Valley Electric Association, Inc. (“VEA”) (the “Joint Parties”) have no comments on the draft tariff language, Section 24.
2.
Please provide your organization’s perspective the draft tariff language, Section 40:
The Joint Parties offered the following suggested changes to the draft Tariff language, Section 40. Note strike-through for deleted text and underlining for added text.
CAISO TARIFF
40.4.6.2 Deliverability of Imports
40.4.6.2.1 Available Import Capability Assignment Process
Step 13: Requests for Balance of Year Unassigned Available Import Capability: To the extent total Available Import Capability remains unassigned as disclosed by Step 12, Scheduling Coordinators for Load Serving Entities, Participating Generators, or System Resources may notify the CAISO of a request for unassigned Available Import Capability on a specific Intertie on a per MW basis. Step 12 must be completed before a Scheduling Coordinator may submit a request under this step for any remaining unassigned Import Capability. Any requests received prior to the time stated in the Market Notice issued at the completion of Step 12 will not be honored by the CAISO. Each request must include the identity of Load Serving Entity, Participating Generator, or System Resource on whose behalf the request is made. The CAISO will accept only two (2) requests per calendar week from any Scheduling Coordinator on behalf of a single Load Serving Entity, Participating Generator, or System Resource.
Load Serving Entities with existing Resource Adequacy contracts will receive priority over other requests received on the same day. The load serving entity may only receive this priority on the branch group where the existing Resource Adequacy contract is scheduled. To receive priority, the Resource Adequacy contract cannot be fully utilized as a Pre-RA Commitment or a New Use Import Commitment. A Load Serving Entity may use a Pre-RA Import Commitment or New Use Import Commitment if it did not receive a “full allocation” under those terms and it may use it only for the part (MWs) that was denied the Pre-RA Import Commitment or New Use Import Commitment status. If the Resource Adequacy contract is not fully utilized as a Pre-RA Commitment or a New Use Import Commitment, then the portion of the Resource Adequacy contract that is not utilized as a Pre-RA Commitment or a New Use Import Commitment shall receive priority. If two or more Load Serving Entities have RA contracts that exceed the amount left after step 12 on any given branch group, the assignment will be split among the Load Serving Entities with applicable contracts based on (Total MWs available at the branch group divided by the Sum of MWs from all applicable contracts or eligible portions of contracts receiving priority) multiplied by each Load Serving Entities applicable contract amount.
After addressing any priority for requests associated with Resource Adequacy contracts, the CAISO will honor timely requests in priority of the time requests from Scheduling Coordinators were received until the Intertie is fully assigned and without regard to any Load Serving Entity’s Load Share Quantity. Any honored request shall be for the remainder of the Resource Adequacy Compliance Year.
3.
Please provide your organization’s perspective on the draft business practice manual language for Transmission Planning Requirements:
The Joint Parties offered the following suggested changes to the draft BPM for Transmission Planning Requirements, Sections 3.2.2.3 and 3.2.6. Note strike-through for deleted text and underlining for added text.
For Section 3.2.6 the Joint Parties recommend deleting the sub-bullets a), b), and c) and referring back to the Tariff to avoid confusion and inconsistency.
Business Practice Manual for Transmission Planning Process
3.2.2.3. Maximum Import Capability Expansion Requests
Requests to perform deliverability studies in order to expand the maximum import capability must also be submitted to the CAISO within 2 weeks after the first stakeholder meeting at the same not later than the time that the study plan comments are due. The maximum import capability expansion requests must identify the intertie(s) (branch group(s)) that require expansion. For an LSE tThe request must include information about existing resource adequacy contracts or power purchase agreements. (either resource adequacy or transmission) For new transmission owners or other market participants the request must include information on contractual arrangements or other evidence of financial commitments the requestor has already made in order to serve load or meet resource adequacy requirements within the CAISO balancing authority area. The quality of the data must be sufficient for the CAISO to make a determination about the validity of such request as available in the Tariff pursuant to Section 3.2.6 below. The CAISO will maintain confidentiality of data provided except for the requestor name, intertie (branch group) and the MW quantity of the expansion request.
3.2.6. Requests for Maximum Import Capability Expansion
The CAISO will evaluate each maximum import capability expansion request in order to establish if the submitting entity had legitimate reasons and has made financial commitments towards serving ISO internal load meets the criteria listed in the Tariff Section 24.3.5. The following are the legitimate reasons to submit a MIC expansion request:
a) Existing RA import contract (internal LSEs), not already fully accounted for as Pre-RA import Commitment or New Use Import Commitment.
b) Owners of new transmission connecting to the ISO grid from an external Balancing Authority Area (BAA) or connecting into the neighboring BAA immediately adjacent to the ISO grid.
c) Other stakeholders that can contractually demonstrate financial commitments towards serving ISO internal load.
The ISO will coordinate combine the legitimate valid MIC expansion requests with the policy driven MIC expansion and the total of the two will affect be used to identify all branch groups that do not have enough sufficient Remaining Import Capability to cover both the legitimate valid MIC expansion requests and the policy driven MIC expansion.
The exact calculation of the target expanded MIC can be found in Reliability Requirements BPM section 6.1.3.5 “Deliverability of Imports”.
The interrelation between the target expanded MIC and the generation interconnection process can be found in Reliability Requirements section 6.1.3.6 “Modeling Expended MIC Values in GIP”.
