1.
Please provide a summary of your organization’s comments on the Dec 11, 2024 DAME configurable parameters implementation working group discussion:
The Energy Authority (TEA) appreciated the CAISO’s written responses to stakeholder comments and confirmation that all loads and resources participating in the 2025 EDAM Market Sim will be included in its quantitative assessment of the tunable parameters for the IR/RC products. TEA looks forward to continuing to engage with this important pre-go live effort in its role as a CAISO SC, future EDAM SC, CRR market participant, and CAISO intertie market participant affected by the policy and implementation issues in play.
2.
Please provide your organization’s feedback regarding the ISO’s updated working group plan and timeline that was shared during the working group:
TEA supports CAISO’s addition of monthly working group meetings in late 2025 and early 2026, as well as the kickoff meeting planned for August 2025. TEA encourages the CAISO to schedule an interim meeting prior to Market Sim to communicate expectations and desired outcomes associated with the new products’ integration with existing market components, and answer any outstanding questions on the product design, to help entities prepare to engage constructively with them during the Market Sim period.
3.
Provide any additional comments:
Global vs. Local Parameters and Requirements Tuning: TEA questions to what extent parameters or procurement targets will be tunable at the EDAM BAA level vs. at the market-wide level, and where discretion may exist between CAISO as the MO, CAISO as a BAO, and the EDAM Entities as BAOs to influence the market solution relative to the clearing of these products on a day-to-day basis through load conformance or other means – as well as to what extent third-party loads and resources will be able to influence or respond to those discretionary decisions.
Nodal Aggregation Tuning: Recognizing the decision has been made to use nodal constraints for the products, TEA questions whether the CAISO intends to do sensitivity testing around the appropriate level of nodal aggregations of resources or loads with respect to the performance of the IR/RC products. For example, will testing inform whether there is a meaningful difference in constraining procurement according to the LAP, sub-LAP, or C-LAP aggregations within the CAISO, vs. setting the requirement as an aggregate of all load within the CAISO BAA (effectively zonal procurement relative to load but still using granular nodal functionality for distributing the requirements to resources or resource aggregations), and similarly, whether IR/RC product or cost-allocation performance would improve with finer load aggregation granularity within the PacifiCorp BAAs?
Market Seams Considerations: TEA questions whether a pre-day ahead market forecast of the expected directional volume of the WEIM transfers and RT CAISO intertie market, or of wheelthroughs and unscheduled flow across the CAISO or EDAM BAAs, is necessary to inform efficient IR/RC procurement, as well as to what extent any EDAM BAAs’ decision to enact the net-export constraint may impact product performance, and whether the quantitative analysis could be used to assess any inefficiencies that can be reasonably expected to arise during normal or tight system conditions if these externalities are not taken into account. TEA further questions whether the CAISO intends to use the quantitative analysis to address EDAM BAs’ consideration of enabling economic intertie bidding and/or convergence bidding for their areas, potentially including an assessment of the impact of both market components on the global EDAM market solution even when they are only included as elements of the CAISO BAA’s IFM.
Assessment of Likely EDAM Footprint, Potential Bucket 2 Transfers: TEA would support the CAISO including a qualitative assessment or limited high-level quantitative assessment of the impact of the addition of one or more EDAM BAAs and a sample amount of transfer capacity and flexible resource capacity increase associated with each would provide to the performance of the products overall. TEA believes this is important because of the limited transfer capacity expected between the PacifiCorp EDAM BAAs and the CAISO BAA at go-live absent significant Bucket 2 transmission contributions from point-to-point transmission rights-holders, and the potential for parameter tuning done under those conditions to be sub-optimal for an EDAM footprint that would shortly include Portland General Electric, followed by BANC, LDWP, and others.
