Comments on Draft Tariff Language

1. Provide a summary of your organization’s comments on both sets of draft tariff language (optional):

Please see DMM's comments at the following link: 

http://www.caiso.com/Documents/DMMCommentsonVariableOperationsandMaintenanceCostReview-DraftTariffLanguage-Nov172020.pdf

2. Provide your organization’s comments on section 30.4.5.4.2 CAISO Process of the transition period draft tariff language:

Please see section 1 for a link to DMM's comments.

3. Provide your organization’s comments on section 11.8.2.1 IFM Bid Cost Calculation:

Please see section 1 for a link to DMM's comments.

4. Provide your organization’s comments on section 11.8.3.1 RUC Bid Cost Calculation:

Please see section 1 for a link to DMM's comments.

5. Provide your organization’s comments on section 11.8.4.1 RTM Bid Cost Calculation:

Please see section 1 for a link to DMM's comments.

6. Provide your organization’s comments on section 30.4.5 Proxy Cost Methodology and all relevant subsections:

Please see section 1 for a link to DMM's comments.

7. Provide your organization’s comments on section 39.6.1.6 Maximum Start-Up Cost and Maximum Load Cost Registered Cost Values:

Please see section 1 for a link to DMM's comments.

8. Provide your organization’s comments on section 39.6.1.6.3 Variable Operations and Maintenance Adder Components:

Please see section 1 for a link to DMM's comments.

9. Provide your organization’s comments on section 39.7.1.1 Variable Cost Option and all relevant subsections:

Please see section 1 for a link to DMM's comments.

10. Provide your organization’s comments on section 39.7.1.3.2 Negotiated Values and Informational Filings:

Please see section 1 for a link to DMM's comments.

11. Provide your organization's comments on Appendix A – Master Definitions Supplement:

Please see section 1 for a link to DMM's comments.

12. Additional comments on the Variable Operations and Maintenance Cost Review draft tariff language(s):

Please see section 1 for a link to DMM's comments.

1. Provide a summary of your organization’s comments on both sets of draft tariff language (optional):

Please see attached.

2. Provide your organization’s comments on section 30.4.5.4.2 CAISO Process of the transition period draft tariff language:

3. Provide your organization’s comments on section 11.8.2.1 IFM Bid Cost Calculation:

4. Provide your organization’s comments on section 11.8.3.1 RUC Bid Cost Calculation:

5. Provide your organization’s comments on section 11.8.4.1 RTM Bid Cost Calculation:

6. Provide your organization’s comments on section 30.4.5 Proxy Cost Methodology and all relevant subsections:

7. Provide your organization’s comments on section 39.6.1.6 Maximum Start-Up Cost and Maximum Load Cost Registered Cost Values:

8. Provide your organization’s comments on section 39.6.1.6.3 Variable Operations and Maintenance Adder Components:

9. Provide your organization’s comments on section 39.7.1.1 Variable Cost Option and all relevant subsections:

10. Provide your organization’s comments on section 39.7.1.3.2 Negotiated Values and Informational Filings:

11. Provide your organization's comments on Appendix A – Master Definitions Supplement:

12. Additional comments on the Variable Operations and Maintenance Cost Review draft tariff language(s):

1. Provide a summary of your organization’s comments on both sets of draft tariff language (optional):

Vistra is generally supportive of the proposed draft tariff language with a few modest revision requests or clarification requests. In addition, Vistra notes the effective dates in the draft Tariff language are confusing compared to the Final Proposal’s implementation plan proposed. We request additional clarity on how the CAISO’s implementation plan has changed since the Final Proposal herein.

2. Provide your organization’s comments on section 30.4.5.4.2 CAISO Process of the transition period draft tariff language:

Vistra seeks additional clarity on the effective dates included in the draft tariff. The new Tariff Section 30.4.5.4.2 includes the text, “Effective January 1, 2022, default adders established pursuant to this Section 30.4.5.4.2 will supersede and replace any then-existing default adders previously established for resources with the same fuel source or technology.” The Final Proposal proposed a phased approach to the implementation on Page 33 stating, “The CAISO expects the explicit principles to be effective on 5/1/2021; this will allow the CAISO and market participants the time to process negotiated O&M Adder values before the next key date. The next key date is 10/1/2021, when the CAISO proposes to implement the new default O&M Adder values.”[1] We additionally note the comments that CAISO provided on its redline in Section 30.5.4.3.2 referring to an April 1, 2022 effective date for the CAISO process. Based on the Final Proposal, Vistra anticipated the effective date for this section would be October 1, 2021. We request additional context on why the CAISO process language is proposed to be implemented later than the remaining language since this appears to govern an internal process not subject to technology implementation constraints. Vistra respectfully asks the CAISO to clarify whether their implementation plans have changed since the Final Proposal was released and if so how.

[1] Variable Operations and Maintenance Cost Review Final Proposal, October 22, 2020, Page 33, http://www.caiso.com/InitiativeDocuments/FinalProposal-VariableOperations-MaintenanceCostReview.pdf.

3. Provide your organization’s comments on section 11.8.2.1 IFM Bid Cost Calculation:

None at this time.

4. Provide your organization’s comments on section 11.8.3.1 RUC Bid Cost Calculation:

None at this time.

5. Provide your organization’s comments on section 11.8.4.1 RTM Bid Cost Calculation:

None at this time.

6. Provide your organization’s comments on section 30.4.5 Proxy Cost Methodology and all relevant subsections:

Vistra seeks clarifications on the principles for negotiated Variable Operations & Maintenance Adders, new Tariff Section 30.5.4.3.1:

• Clarify Start-Up/Shut-Down includes cycling in 30.5.4.3.1(a): We respectfully request the CAISO clarify that in the language “Any operations costs proposed for inclusion in the Variable Operations and Maintenance Adders must be variable operations costs, meaning the costs of consumables and other costs that vary directly with electrical production (i.e., Start-Up/Shut-Down, run-hours, or electricity output) of a resource” the Start-Up/Shut-Down includes cycling for storage resources.
• Request CAISO identify major components excluded pursuant to 30.5.4.3.1(v) in its Business Practice Manuals (“BPM”): We respectfully request the CAISO identify in its BPM the major components by resource type that are not eligible to be included in negotiated values. We recognize that these may not be identifiable until the CAISO has completed future negotiations for some resource types such as storage. We request the CAISO commit to updating its BPM to maintain a list of major components by resource type on a recurring basis.

Additionally, Vistra requests the CAISO combine new Tariff Section 30.4.5.4.4 with existing Tariff Section 39.7.1.3.2.1 and new Tariff Section 30.4.5.4.5 with existing Tariff Section 39.7.1.3.2.2. Our view is that for the Tariff to include two separate sections for this detail that describes the renegotiation or FERC informational filings will in our view make the revised tariff language more confusing. Vistra respectfully prefers the current structure that includes all negotiated values in the Tariff Section 39.7.1.3.2.1, and Renegotiation of Values, and Tariff Section 39.7.1.3.2.2, Informational Filings with FERC. We believe this is a superior construct and urge the CAISO maintain it by merging the new proposed sections for negotiated O&M adders into the existing sections.

7. Provide your organization’s comments on section 39.6.1.6 Maximum Start-Up Cost and Maximum Load Cost Registered Cost Values:

None at this time.

8. Provide your organization’s comments on section 39.6.1.6.3 Variable Operations and Maintenance Adder Components:

None at this time.

9. Provide your organization’s comments on section 39.7.1.1 Variable Cost Option and all relevant subsections:

None at this time.

10. Provide your organization’s comments on section 39.7.1.3.2 Negotiated Values and Informational Filings:

Please see our above comment under Section 30.4.5. We reiterate our request that the CAISO combine new Tariff Section 30.4.5.4.4 with existing Tariff Section 39.7.1.3.2.1 and new Tariff Section 30.4.5.4.5 with existing Tariff Section 39.7.1.3.2.2. Our view is that for the Tariff to include two separate sections for this detail that describes the renegotiation or FERC informational filings will in our view make the revised tariff language more confusing. Vistra respectfully prefers the current structure that includes all negotiated values in the Tariff Section 39.7.1.3.2.1, and Renegotiation of Values, and Tariff Section 39.7.1.3.2.2, Informational Filings with FERC. We believe this is a superior construct and urge the CAISO maintain it by merging the new proposed sections for negotiated O&M adders into the existing sections.

11. Provide your organization's comments on Appendix A – Master Definitions Supplement:

None at this time.

12. Additional comments on the Variable Operations and Maintenance Cost Review draft tariff language(s):

None at this time.