Comments on Track 1 revised draft tariff language

1. Please provide any redline changes and embedded comments your organization may have on the Transmission Service and Market Scheduling Priorities Phase 2 track 1 revised draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Please see DMM comments in Section 23.2.3 of the attached PDF.  

1. Please provide any redline changes and embedded comments your organization may have on the Transmission Service and Market Scheduling Priorities Phase 2 track 1 revised draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

NV Energy appreciates the opportunity to comment on the revised tariff language. As the CAISO has set the comment date three days before the call to review the revised tariff language, stakeholders do not know the basis for why comments were accepted or rejected. In the comments below, NV Energy reiterates certain of our prior comments as well as providing limited comments on the new provisions.

• 23.2.1 and 23.2.4 - in (4) the draft proposal states, “all eligibility requirements to support a monthly or daily Wheeling Through priority have been met”. The specific requirements should be identified in the tariff. It is unclear what the “all eligibility requirements” would be other than those already delineated in 23.2.1. (1), (2), and (3).

• 23.2.1 – there is a typo in the start of the second paragraph “CASO” should be “CAISO”.

• 23.2.3 – Notice within one business day is an unrealistic standard as there may be ongoing issues related to the underlying contract. Suggest a minimum of 5 business days.

• 23.3.2 - there is a typo in the second paragraph “include” should be “including”.

• 23.3.3 – One of the purposes of allowing CAISO LSEs’  non-resource adequacy resources to reserve ATC was because the MIC was too restrictive and that it was important for CAISO LSE’s to contract for additional supply, especially if an external resource adequacy resource became unavailable.  In a May 25, 2023, proposed decision in R.21-10-002, the CPUC, however, proposed to allow external resources without MIC to qualify as a resource adequacy resource at Malin and NOB:

One way to address this is to limit the ability to acquire additional import capability through the ATC process to the two import locations most used by LSEs to pair with import RA: California-Oregon Border (COB)/Malin and Nevada-Oregon Border (NOB). By limiting the additional acquisition of ATC to these two interties, this would effectively ensure that there is no violation of the simultaneous import limit, nor any associated reliability risk. For this reason, we find this modification to Energy Division’s proposal to be reasonable, and adopt it here. We also direct Energy Division Staff to work with CAISO on concerns that CAISO’s penalty parameters do not sufficiently prioritize RA imports and that MIC does not reserve internal transmission for RA imports.

Accordingly, if a Commission-jurisdictional LSE procures ATC or acquires ATC through the resale process at either COB/Malin or NOB, the LSE is permitted to pair the ATC with RA imports to meet its RA requirements.

If this order becomes final, it would undermine the rational for permitting non-resource adequacy contracts to reserve ATC and these agreements should be removed from the ATC process.

• 23.3.3 and 23.3.4 - The CAISO added provisions related to TORs. However, there are no comparable provisions with respect to ETCs. As stated in NV Energy’s prior comments, the CAISO must provide a specified means in the tariff that holders of ETC import rights can utilize, assign, or sell all or a portion of those rights to support Priority Wheeling Through transactions. In the January 18, 2023, Final Proposal, the CAISO stated:

It is important to highlight as well that if the resulting ATC calculated by the ISO is limited, entities seeking to wheel through the ISO can also consider alternate approaches to wheeling through the ISO, such as working with entities that have existing transmission contracts (legacy) and potentially contract for their import capability that they may have at individual interties.

There is no provision in the draft tariff language that specifies how an entity in the Desert Southwest can work with an entity that has import rights at Malin to obtain a Priority Wheeling Through transaction utilizing these ETC rights. It is vital that this linkage be specified in the CAISO Tariff as the proposed definition of “Priority Wheeling Through” in Appendix A is “A Wheeling Through Self-Schedule that has obtained a priority under Section 23”. Thus, the means of accessing these ETC and TOR rights to obtain Priority Wheeling Through transaction status also must be included in Section 23.

1. Please provide any redline changes and embedded comments your organization may have on the Transmission Service and Market Scheduling Priorities Phase 2 track 1 revised draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

PG&E appreciates the generally helpful clean up of the draff tariff along with the incorporation of several of PG&E’s requests in its prior comments.

Several concerns remain for PG&E:

• The TRM can still be allocated in full in earlier time horizons, leaving no TRM at later ones.
• Missing sections on long-term wheeling reservations and on compensation
• Examples could still be clearer.

More specific comments on sections are shown below and are included in the attachment.

1. Please provide any redline changes and embedded comments your organization may have on the Transmission Service and Market Scheduling Priorities Phase 2 track 1 revised draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Powerex submits the following comments on the CAISO’s June 14, 2023, Transmission Service and Market Scheduling Priorities Phase 2 Revised Draft Tariff Language (“Revised Draft Tariff”). Powerex is seeking clarity regarding how existing transmission contracts can be used to establish Wheeling Through Priority across the CAISO system, particularly with respect to TORs that are released to the CAISO in exchange for option congestion revenue rights (CRRs).

The Final Proposal describes that one option for market participants to establish a Wheeling Through Priority is “…to seek to contract with holders of legacy transmission contracts to support wheel through transactions across the ISO system given there is 1200 MW of capacity tied up under legacy agreements that must be respected.”[1]

Powerex owns long-term firm PacifiCorp OATT rights from Malin to Round Mountain that are considered Transmission Ownership Rights (TORs). As TORs, these rights are treated as Existing Transmission Contracts (ETCs) that are deducted from the available ATC to support CAISO imports at the Malin intertie. However, as part of a FERC-approved settlement agreement, PacifiCorp customers with rights from Malin to Round Mountain can elect to release their TOR capacity to the CAISO in exchange for receiving option CRRs. Such an election supports increased market efficiency by allowing the CAISO to increase the ATC at the Malin intertie for market use, while providing the customer that releases those rights with congestion revenues across that path.  

Powerex requests that the CAISO confirm and clarify in the Revised Draft Tariff the approach to ensure that TOR rights that are released to the CAISO in exchange for option CRRs can be used to support a Wheeling Through Priority. Specifically, Powerex seeks to confirm that:

1.         A market participant that holds TORs from a CAISO intertie (e.g., Malin) can request a Wheeling Through Priority directly from that CAISO intertie to any CAISO Export Scheduling Point.

2.         CAISO will credit the TOR capacity at the relevant CAISO intertie (e.g., Malin) towards the Wheeling Through Priority request (hence reducing the import ATC that must be reserved to support the Wheeling Through Priority request by the quantity of supporting TORs).

3.         The market participant that requests a Wheeling Through Priority directly from the CAISO intertie (e.g., Malin) using its TOR capacity will also release those rights to the CAISO in exchange for receiving option congestion revenue rights (like today).

4.         Provided that the market participant releases its TOR capacity supporting the Wheeling Through Priority request, it can register and schedule its Priority Wheel Resource ID directly from the CAISO intertie (e.g., Malin) to the requested CAISO Export Scheduling Point.

Powerex's comments are also available at CAISO Transmission Service & Market Scheduling Priorities Phase 2 Comments.pdf (powerex.com)

[1] Final Proposal at 26.

1. Please provide any redline changes and embedded comments your organization may have on the Transmission Service and Market Scheduling Priorities Phase 2 track 1 revised draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below:

When providing additional comments in the text box below, please specify the section(s) or subsection(s) your comments refer to.

Please see the Six Cities' redline.  Copy and paste the following link into your web browser to access: 

https://www.caiso.com/InitiativeDocuments/SixCitiesComments-TransmissionService-MarketSchedulingPrioritiesPhase2-RevisedDraftTariffLanguage.docx

Six Cities' proposed text revisions are highlighted in green.