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.
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.
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.
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.