Comments on Draft tariff language being posted

1. Please provide a summary of your organization's feedback in response to the Draft Tariff Language on Inter-SC Trades in Regional Markets posted on September 20, 2024

PG&E appreciates the CAISO’s publication of the Draft Tariff Language for Inter-SC Trades in Regional Markets. We support the extension of Inter-SC Trades of Energy functionality for the Extended Day-ahead Market (EDAM) and Western Energy Imbalance Market (WEIM) participants, but the CAISO should be explicit in its tariff that EDAM/WEIM participants cannot submit Inter-SC trades for Ancillary Services and IFM Load Uplift Obligations. As written, the tariff doesn’t entitle EDAM/WEIM entities to make these trades; however, explicitly prohibiting AS and IFM Load Uplift Obligation trades would remove any ambiguity and keep the tariff in alignment with its current language (that explicitly prohibits WEIM and EDAM scheduling coordinators from submitting Inter-SC Trades).

2. Please provide any feedback not already captured.