1.
Please provide a summary of your organization’s comments on the Rules of Conduct Enhancements draft Tariff language.
Idaho Power appreciates the CAISO’s efforts in revising its Rules of Conduct and related penalty structure to ensure that penalties assessed are proportionate to any harm caused by a violation of the Rules of Conduct. As previously stated in communications with CAISO staff and in other comments submitted by Idaho Power, during track 2 Idaho Power continues to encourage the CAISO to consider either a distinct Rules of Conduct section or penalty structure for WEIM entities, particularly when there is minimal impact to the market or other BAAs when violations by WEIM entities occur.
Idaho Power appreciates and supports the changes to 37.5.2.2.4, Market Adjustment, stating if a Scheduling Coordinator is the only Scheduling Coordinator in the utility Service Area, it will not be assessed a market adjustment. Additionally, Idaho Power supports the change made to 37.5.2.2.1, Sanction for Inaccurate Meter Data, only applying a penalty to the to the inaccurate Meter Data for the Generating Unit when the Scheduling Coordinator demonstrates that the related inaccurate Load SQMD was caused by the inaccurate Generating Unit SQMD.
Idaho Power believes there is clarification or edits needed to two sections of the draft tariff, as described below.
First, in 37.5.2.2.3, Sanction for Missing Meter Data, the sanction is stated to be $4,000 per Trading Day. As stated in the CAISO’s draft Final Proposal, the penalty for missing T+52B is $1,000 per Trading Day and the penalty for missing T+214B is $3,000 per Trading Day. Idaho Power believes this section needs to be revised to clarify that the penalty is $1,000 per Trading Day for missing T+52B and then $3,000 per Trading Day for missing T+214B. A $4,000 per Trading Day penalty is not consistent with what is stated in the draft Final Proposal.
Second, in 37.9.4, Disposition of Proceeds, two categories of ineligible Market Participants are the following: (b) were assessed a financial Sanction during the calendar year that later was excused because FERC granted waiver of the portions of this Section 37 that initially required assessment of a financial Sanction; (c) would have been assessed a financial Sanction during the calendar year absent FERC waiver of the portions of this Section 37 that otherwise would have required assessment of a financial Sanction. Idaho Power requests clarifying language as to why these categories are deemed ineligible when a FERC waiver of the sanctions have been granted. Idaho Power believes if a FERC waiver is granted and no Penalty is ultimately assessed, the party receiving the waiver should not be deemed an ineligible Market Participant, even if FERC does not make a determination as to whether a Violation occurred or not. Idaho Power also requests clarifying language as to the timing of the ineligibility in the event FERC grants a waiver after the calendar year for a trade date in the current year the proceeds have been distributed. We would request CAISO to re-settle the trade date the proceeds were distributed if FERC later grants a waiver after the proceeds have been distributed.
2.
Please submit any additional edits or suggestions in redline.
