Comments on Revised draft tariff language

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language.

Bonneville has reviewed the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language. Bonneville is concerned about the impact of the change to E-tagging to using the firm-provisional tag. This will have an impact on the ability of Bonneville and any sub-entities in its BAA to participate in CAISO’s day ahead and hourly markets. See question 4 below for further details.

2. Please upload a copy of your organization’s edits and comments to the draft tariff language, in redline and showing suggested strikethrough or associated comment, to implement WEIM Resource Sufficiency Evaluation Enhancements Phase 2.

No comment

3. Indicate your organization’s support for the proposed changes in draft section 29.11(t), the proposed implementation of the Settlements and Billing for the assistance Energy transfer product:

No comment

4. Indicate your organization’s support for the proposed changes in draft sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4, the proposed implementation of the exclusion of certain LPT exports:

Bonneville has concerns regarding the impact of requiring that the Scheduling Coordinator for any export schedule other than an export backed by Generation from non-Resource Adequacy Capacity must submit an E-Tag with the designation of firm provisional energy (G-FP). The Bonneville BAA does not currently allow energy with an E-tag other than Firm (G-F) to sink in the Bonneville BAA. If imports are E-tagged as G-FP, Bonneville would need to determine treatment of reserves for this product, and establish appropriate business practices to support that treatment. At this time, the Bonneville BAA does not have the business practices, policies and rate structures in place to provide reserves or to ensure that entities self-supply reserves for G-FP energy sourced from the CAISO or any neighboring BAA, and as a consequence, LPT imports tagged as G-FP energy from the CAISO will not be permitted to sink in the Bonneville BAA.  

Bonneville encourages CAISO to consider alternative approaches to noting prioritization of exports.

In Section 34.12.4, the first paragraph states that “CAISO may…apply the market scheduling run priorities…before the CAISO Balancing Authority Area is in an energy emergency alert.” Bonneville notes that the RSE Second Revised Final Proposal states that curtailment would happen “even before the CAISO BAA is in an energy emergency alert (EEA) 3.” BPA seeks clarity on the correct language and encourages CAISO to maintain the original statement regarding EEA 3.

5. Indicate your organization’s support for the proposed changes in draft section 29.34(n)(3), the proposed implementation of the assistance Energy transfer product:

No comment. 

6. Provide your organization’s comments on Appendix A:

No comment.

7. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language:

No additional comment.

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language.

CPUC Energy Division Staff (hereinafter “ED Staff”) appreciates the opportunity to submit comments on CAISO’s “Revised Draft Tariff Language – WEIM Resource Sufficiency Evaluation Enhancements Phase 2.”  ED Staff has the following comments:

• ED staff supports CAISO’s proposed changes to Section 29.34 (l)(3)(B) that exclude the real-time hourly block exports which cleared the HASP from the CAISO’s resource sufficiency test  by not counting these exports  in the calculation of CAISO’s demand obligation.  However, ED staff encourages CAISO to specifically delineate the HASP exports that will not be included in the RSE (i.e., (a) Real-Time economic hourly block export schedules that cleared HASP, and (b) Real-Time Self-Schedule hourly block export schedules not backed by Generation from non-Resource Adequacy Capacity and cleared HASP).  In addition, ED staff requests that CAISO clarify that real-time hourly block exports which do not clear the HASP (but may have e-tagged nonetheless) are also excluded from the demand obligation.
• ED staff does not support CAISO’s proposal in Section 29.34(n)(3) to allow the CAISO itself to accept the assistance energy through a market notice process. 
• ED staff strongly supports CAISO’s proposed addition of Section 34.12.4 clarifying that it may curtail lower priority HASP hourly block exports before it is in an energy emergency alert and that it will curtail lower priority HASP hourly block exports in an EEA3 to prevent the need to arm load to meet its operating reserve obligations.
• As the purpose of the language is not clear, ED staff requests that CAISO delete the language in Section 34.12.4 that reads,  “and protected self-schedules” in section C (“Day-Ahead hourly block export schedules not backed by Generation from non-Resource Adequacy Capacity that also cleared HASP and are protected Self-Schedules,” emphasis added).

2. Please upload a copy of your organization’s edits and comments to the draft tariff language, in redline and showing suggested strikethrough or associated comment, to implement WEIM Resource Sufficiency Evaluation Enhancements Phase 2.

Please see comments in response to Question 1.

3. Indicate your organization’s support for the proposed changes in draft section 29.11(t), the proposed implementation of the Settlements and Billing for the assistance Energy transfer product:

Please see comments in response to Question 1.

4. Indicate your organization’s support for the proposed changes in draft sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4, the proposed implementation of the exclusion of certain LPT exports:

Please see comments in response to Question 1.

5. Indicate your organization’s support for the proposed changes in draft section 29.34(n)(3), the proposed implementation of the assistance Energy transfer product:

Please see comments in response to Question 1.

6. Provide your organization’s comments on Appendix A:

Please see comments in response to Question 1.

7. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language:

Please see comments in response to Question 1.

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language.

PG&E appreciates the opportunity to comment on the revised draft tariff language for the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 initiative.  PG&E requests clarifications and further explanation on several elements of the revised draft tariff language.  Please see the attached document for PG&E’s comments.    

2. Please upload a copy of your organization’s edits and comments to the draft tariff language, in redline and showing suggested strikethrough or associated comment, to implement WEIM Resource Sufficiency Evaluation Enhancements Phase 2.

Please see the attached document.   

3. Indicate your organization’s support for the proposed changes in draft section 29.11(t), the proposed implementation of the Settlements and Billing for the assistance Energy transfer product:

Please see the attached document.   

4. Indicate your organization’s support for the proposed changes in draft sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4, the proposed implementation of the exclusion of certain LPT exports:

Please see the attached document.   

5. Indicate your organization’s support for the proposed changes in draft section 29.34(n)(3), the proposed implementation of the assistance Energy transfer product:

Please see the attached document.   

6. Provide your organization’s comments on Appendix A:

Please see the attached document.   

7. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language:

Please see the attached document.   

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language.

PacifiCorp appreciates the opportunity to provide comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 initiative (“initiative”) revised draft tariff language. Overall, the changes in the draft tariff language accurately reflect the design outlined in the (second) revised final proposal. PacifiCorp supports additional clarity in the defined rules for the Energy Assistance program and treatment of low-priority transfers (“LPT”). PacifiCorp supports the elements proposed throughout this initiative and looks forward to seeing the market evolve with the needs of its participants.  

2. Please upload a copy of your organization’s edits and comments to the draft tariff language, in redline and showing suggested strikethrough or associated comment, to implement WEIM Resource Sufficiency Evaluation Enhancements Phase 2.

Please see attached.

3. Indicate your organization’s support for the proposed changes in draft section 29.11(t), the proposed implementation of the Settlements and Billing for the assistance Energy transfer product:

PacifiCorp requests the CAISO to clearly state to what extent an EIM Entity can elect to participate within the Energy Assistance program. In particular, does an EIM Entity have the optionality to supply assistance energy to the Balancing Authority Area that wishes to obtain assistance while not electing to receive Assistance Energy Transfers?  As noted in comments to the tariff language, the CAISO needs to clarify whether an Energy Assistance Transfer is requested and granted by a deficient BAA or whether the Energy Assistance Transfer will be triggered automatically for any BAA failing the capacity or ramp tests. 

4. Indicate your organization’s support for the proposed changes in draft sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4, the proposed implementation of the exclusion of certain LPT exports:

PacifiCorp supports the proposed changes in sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4 of the draft tariff language. PacifiCorp finds these changes to be consistent with the proposed exclusion of HASP cleared LPT in the CAISO’s resource sufficiency evaluation. Additionally, per the revised final proposal, the CAISO stated that they would likely not curtail day-ahead (DA) LPT schedules as those schedules have been through the market clearing process.  

However, in section 34.12.4, the CAISO proposes that if an EIM Entity is under the criteria of an LPT, whether the schedule was cleared in the integrated forward market or not, will fall under the default category of “Real-Time economic hourly block export schedules that cleared the HASP” if an entity fails to explicitly state “G-FP” and “Day-Ahead hourly block export schedules not backed by Generation from non-Resource Adequacy Capacity that also cleared HASP and are protected Self-Schedules” within the miscellaneous section of the tag even though the schedule can be supported as it was a DA schedule. This approach seems problematic in the sense that the CAISO would not count those DA exports in their WEIM RSE obligation and therefore will lead to a misrepresentation of the CAISO’s overall obligation for a given hour. Today, PacifiCorp transacts with various marketers that bid and are awarded energy from the CAISO. Those schedules are used to serve PacifiCorp’s native load so the possible implications of this change, specifically pertaining to DA cleared LPT, could be as severe as load shed depending on the volume of the transaction and a lack of liquidity in the market if we were in peak summer or winter.  

PacifiCorp requests that the CAISO consider a simpler approach than the proposed text string, as stated in the draft tariff language, within the miscellaneous information on a tag. A reasonable approach would be to have G-FP1 for DA LPT schedules, G-FP2 and G-FP3 for RT LPT schedules to signal a hierarchy of curtailment. PacifiCorp believes this approach will achieve the CAISO’s goal in this initiative to accurately reflect their WEIM RSE obligation while also creating a streamlined approach that will mitigate any potential tagging errors. 

5. Indicate your organization’s support for the proposed changes in draft section 29.34(n)(3), the proposed implementation of the assistance Energy transfer product:

No comments in addition to the comments above about contradictions in the draft tariff language. 

6. Provide your organization’s comments on Appendix A:

PacifiCorp agrees with the pricing structure as proposed and outlined in Appendix A where the after-the-fact charge is set to $1,000 MWh when the soft bid cap in place and $2,000 MWh when the hard bid cap is in place. PacifiCorp believes the penalty surcharge needs to be high enough that participants would be disincentivized to use this program as part of the day-ahead portfolio set-up and view these after-the-fact charges to be adequate to prevent leaning on the market. This program should only be utilized as a last resort, when supply is scarce, and the market has extra capacity to import to a deficient balancing authority area from other participants in the footprint. 

7. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language:

No additional comments.

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language.

Please see the attached redline.  Six Cities' comments and suggested revisions are highlighted in yellow.

2. Please upload a copy of your organization’s edits and comments to the draft tariff language, in redline and showing suggested strikethrough or associated comment, to implement WEIM Resource Sufficiency Evaluation Enhancements Phase 2.

See the attached redline.

3. Indicate your organization’s support for the proposed changes in draft section 29.11(t), the proposed implementation of the Settlements and Billing for the assistance Energy transfer product:

Please note the comment and suggested revisions recommending that charges and revenues associated with Energy Assistance not be referred to as "Transfer Revenues" so as to avoid confusion with the same term as applied to transfers in the Extended Day-Ahead Market.

4. Indicate your organization’s support for the proposed changes in draft sections 29.34(l)(3), 29.34(m)(1)(B), and 34.12.4, the proposed implementation of the exclusion of certain LPT exports:

See the attached redline.

5. Indicate your organization’s support for the proposed changes in draft section 29.34(n)(3), the proposed implementation of the assistance Energy transfer product:

See the attached redline

6. Provide your organization’s comments on Appendix A:

See the attached redline.

7. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 revised draft tariff language:

See the attached redline.