Include redlined comments in word version of the tariff language posted on the initiative webpage and attach below.
Throughout the stakeholder process for this initiative, Salt River Project Agricultural Improvement and Power District (SRP) understood base schedules below minimum load (Pmin) to be optional. For instance, the Draft Final Proposal provides the following: “The submission of the startup energy within a base schedule is at the discretion of the EIM entity base schedule coordinator.” CAISO consistently described the proposed inclusion of startup energy as something it would “allow” rather than use language like require. However, the proposed tariff language implies base schedules below Pmin are required. SRP requests clarification and offers edits to section 29.34(e)(4) to better capture the discretionary intent of allowing startup energy within a base schedule.
§29.34(e)(4) Contents of EIM Base Schedules. EIM Base Schedules of EIM Entities must include hourly-level Demand Forecasts for EIM Demand, hourly-level schedules for resources,
including hourly-level schedules below PMin, and hourly-level scheduled Interchanges. EIM Entities have the option to include hourly-level schedules below PMin in EIM Base Schedules.
Early in the stakeholder process for this initiative, SRP commented that moving the market closing timeline for financially binding base schedules from 40 minutes before the operating hour (T-40) to 30 minutes before the operating hour (T-30) would adversely affect system reliability. CAISO’s inclusion of a T-40 resource sufficiency evaluation in the Draft Final Proposal addressed this concern. The T-40 resource sufficiency evaluation is important for SRP’s system reliability; therefore, SRP requests that CAISO clearly document the T-40 resource sufficiency evaluation in its tariff.
§29.34(f)(1)(C) Additional Revisions. EIM Entity Scheduling Coordinators may continue to revise hourly Real-Time EIM Base Schedules, or, with regard to non-participating resources, revise EIM Base Schedule information submitted pursuant to Section 29.34(f)(4), at or before 40 minutes before the start of the Operating Hour. The CAISO will perform a resource sufficiency evaluation at 40 minutes before the start of the Operating Hour.
The proposed revisions to §29.34(f)(2) are confusing as currently written. As revised, the clause “which the CAISO will make available to the EIM Entity without price information” follows “provided that an EIM Participating Resource Scheduling Coordinator may also include Energy below PMin in an EIM Base Schedule,” and it is unclear what it means to have the clause reference the additional language. It may be clearer to move the clause to the end of the paragraph. SRP’s suggested clarification is as follows:
§29.34(f)(2) EIM Base Schedule for EIM Participating Resources. The EIM Base Schedule for each EIM Participating Resource must be within the Economic Bid range of the submitted Energy Bids for each Operating Hour for EIM Resources,
provided that an EIM Participating Resource Scheduling Coordinator may also include Energy below PMin in an EIM Base Schedule, which the CAISO will make available to the EIM Entity without price information, provided that an EIM Participating Resource Scheduling Coordinator may also include Energy below PMin in an EIM Base Schedule.
 Draft Final Proposal at p. 9: http://www.caiso.com/InitiativeDocuments/DraftFinalProposal-WesternEIMBaseScheduleSubmissionDeadline.pdf.
 Id. at p. 3, 5, 8.