Comments on Draft tariff language

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

Bonneville has reviewed the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and attended the September 15^th call. Bonneville is concerned about the impact of the change to E-tagging to use the firm-provisional tag. This will have an impact on the ability of Bonneville and sub-entities in its BAA to participate in CAISO’s day ahead and hourly markets. See question 4 below for further details.

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

Bonneville has reviewed the settlements and billing section and understands that the revenue will be imbedded in an existing charge code Real-Time Congestion Offset 29.11 (t)(3).  BPA is already suballocating Real-Time Congestion Offset via measured demand ratio. Bonneville does not see any issues with this approach at this time and will be able to better understand the impact as CAISO provides the details of the implementation of these rules.

3. Provide your organization’s comments on section 29.34 EIM Operations:

No comment.

4. Provide your organization’s comments on added section 34.12.4:

Bonneville has significant 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 to sink in the Bonneville BAA. In order to allow firm provisional energy to sink in the BAA, Bonneville would be responsible for either ensuring that reserves were self-supplied for all tagged energy and/or establishing practices for Bonneville to offer reserves to back these imports. At this time, the Bonneville BAA does not have the business practices, policies and rate structures in place to provide this service.

The impact of this change is that Bonneville and other sub-entities in its BAA will no longer be able to purchase this firm provisional energy from CAISO to sink in the Bonneville BAA.

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

No further comments

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

Please see the PDF attached below the final question for DMM's complete set of comments.

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

Please see the PDF attached below the final question for DMM's complete set of comments.

3. Provide your organization’s comments on section 29.34 EIM Operations:

Please see the PDF attached below the final question for DMM's complete set of comments.

4. Provide your organization’s comments on added section 34.12.4:

Please see the PDF attached below the final question for DMM's complete set of comments.

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

Please see the PDF attached below the final question for DMM's complete set of comments.

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

See attached. 

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

See attached. 

3. Provide your organization’s comments on section 29.34 EIM Operations:

See attached. 

4. Provide your organization’s comments on added section 34.12.4:

See attached. 

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

See attached. 

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

While PG&E appreciates the opportunity to provide initial feedback on the draft tariff language, we do so with the expectation that further policy revisions will occur and require another round of updated tariff language for stakeholders to provide comments. PG&E requests that the CAISO provides a redline version for the upcoming updated tariff language, with the changes to this version highlighted.    

PG&E believes that further policy development and stakeholder consensus is needed in this initiative before the next iteration of tariff language is developed.  In response to the revised draft final proposal, PG&E[1] expressed concerns and requested revisions on multiple design elements in the proposal, including the design of the Energy Assistance option and the treatment of LPT exports. 

Please see the attached document for PG&E’s comments on the draft tariff language.

Therefore, PG&E’s comments at this moment are focused on the discrepancies between the draft tariff languages and the last revised straw proposal. Our key concerns are summarized below: 

1. Consistency between the tariff language and the policy proposal

• Differentiating Day-Ahead and Real-Time LPT exports -- Sections 29.34(l)(3)(B) and 29.34(m)(1)(B)
  • The tariff revisions to exclude lower priority exports from the CAISO BAA’s RSE obligations should reflect the changes made in revised draft final proposal to differentiate Day-Ahead and Real-Time LPT exports.  This section of the tariff should be consistent with language used in Section 34.12.4 (a) and (b) related to real-time economic and self-scheduled hourly block exports.

• Utilization of internal supply and demand response prior to Energy Assistance transfers --Section 29.34(n)(3)(B)(ii)

• The tariff language indicates that the CAISO software will exhaust all EIM Available Balancing Capacity (ABC) prior to clearing the Energy Assistance transfers.  The policy proposal[2] indicates that all internal supply and EIM ABC will be utilized prior to the clearing of Energy Assistance transfers, but the draft tariff language does not explicitly mention internal supply.  PG&E asks whether the tariff should explicitly state that all participating internal supply and EIM ABC will be dispatched prior to clearing the Energy Assistance.  PG&E also requests clarification of whether the internal supply that must be utilized prior to Energy Assistance includes demand response resources.

• Manual curtailment of low priority exports may occur when CAISO is in an EEA2 – Section 34.12.4
  • Based on comments by CAISO staff in the stakeholder call[3], it is PG&E’s understanding that CAISO intends for manual curtailments of LPT exports to occur when the CAISO BAA is in an emergency alert level 2 (EEA2), rather than an EEA3 as currently drafted.  PG&E asks that CAISO update the tariff language to reflect this understanding. 

2. Ensuring the tariff accurately reflects asymmetries between the CAISO BAA and non-CAISO EIM BAAs

• Defining the CAISO BAA equivalents to “EIM Available Balancing Capacity” and “EIM Base Schedule”
  • As previously stated, Section 29.34(n)(3)(B)(ii)) of the draft tariff language references “EIM Available Balancing Capacity”, but it is not clear to PG&E how this language related to EIM ABC would apply to the CAISO BAA.  PG&E requests consideration of additional tariff language that identifies the CAISO BAA equivalent to EIM ABC to ensure consistent application of this rule among all EIM BAAs.
  • Section 29.34(n)(3)(B)(vi) of the tariff language describes the quantity of Energy Assistance transfer that will be provided above the EIM Base Schedule.  PG&E asks CAISO to clarify whether the term “EIM Base Schedule” applies to the CAISO BAA and whether additional language is needed to specify the appropriate reference level for the CAISO BAA to determine the quantity of Energy Assistance transfers. 

3. Clarification of terminology

• Accuracy of reference to the CAISO’s energy bid cap - Section 29.34(n)(3)(B)(iii)
  • PG&E suggests replacing “price cap” with “energy bid cap.”

• Developing tariff definitions for PT and LPT exports -- Section 34.12.4
  • It may be helpful for CAISO to develop tariff definitions to describe PT and LPT exports (or High Priority and Low Priority exports).  CAISO has recently developed a definition for “Priority Wheeling Through”[4] to clarify the scheduling priority of these high-priority transactions.  Similar definitions and references to high priority and lower priority exports may help improve clarity in the tariff.

[1] Pacific Gas & Electric comments on the Revised draft final proposal and Sept. 2, 2022 stakeholder call discussion.  September 15, 2022.  https://stakeholdercenter.caiso.com/Comments/AllComments/96168e84-996e-4f49-8d30-2512c0d07b4e#org-c4e94332-de23-4e20-8ba9-9a9b72362894

[2] WEIM Resource Sufficiency Evaluation Enhancements – Phase 2 presentation.  Draft Final Proposal. September 2, 2022.  Pg. 20 at http://www.caiso.com/InitiativeDocuments/Presentation-WEIMResouceSufficiencyEvaluationEnhancementsPhase2-Sep2-2022.pdf

[3] September 15, 2022 stakeholder call on the Draft Tariff Language. 

[4] Appendix A of the CAISO Tariff (“Master Definition Supplement”)

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

PG&E has no comments at this time on Section 29.11. 

3. Provide your organization’s comments on section 29.34 EIM Operations:

PG&E offers comments on Section 29.34 in the attached draft tariff document.  A summary of those comments is also provided below.

• Sections 29.34(l)(3)(B) and 29.34(m)(1)(B) -- Differentiating Day-Ahead and Real-Time LPT exports --
  • The tariff revisions to exclude lower priority exports from the CAISO BAA’s RSE obligations should reflect the changes made in revised draft final proposal to differentiate Day-Ahead and Real-Time LPT exports.  This section of the tariff should mirror language used in Section 34.12.4 (a) and (b) related to real-time economic and self-scheduled hourly block exports.

• Section 29.34(n)(3)(B)(ii) -- Utilization of internal supply and demand response prior to Energy Assistance transfers
  • The tariff language states that all EIM Available Balancing Capacity (ABC) will be exhausted prior to clearing the Energy Assistance transfers. The policy proposal[1] indicates that all internal supply and EIM ABC will be utilized prior to the clearing of Energy Assistance transfers, but the draft tariff language does not explicitly mention internal supply.  PG&E asks whether the tariff should explicitly state that all other participating internal supply, as well as EIM ABC, will be dispatched prior to clearing the Energy Assistance.  PG&E also requests clarification of whether the internal supply includes demand response resources. 

• Section 29.34(n)(3)(B)(ii) -- Defining the CAISO BAA equivalent to “EIM Available Balancing Capacity”
  • As previously stated, the tariff language references EIM Available Balancing Capacity, but it is not clear to PG&E how this section this would apply to the CAISO BAA.  PG&E requests clarification to ensure consistent application of this rule among all EIM BAAs.

•  Section 29.34(n)(3)(B)(iii) -- Accuracy of reference to the CAISO’s energy bid cap
  • PG&E suggests replacing “price cap” with “energy bid cap.”

• Section 29.34(n)(3)(B)(vi) -- Defining the CAISO BAA equivalent to “EIM Base Schedule” 
  • The tariff language describes the quantity of Energy Assistance transfer that will be provided above the EIM Base Schedule.  PG&E asks CAISO to clarify whether the term “EIM Base Schedule” applies to the CAISO BAA and whether additional language is needed to specify the appropriate reference level for the CAISO BAA to determine the quantity of Energy Assistance transfers. 

• Section 29.34(n)(3)(B)(vi) – Further defining the quantity of Energy Assistance transfers
  • The tariff language describing the quantity of Energy Assistance transfers does not specify the duration of the Energy Assistance in relation to RSE failures.  PG&E asks for clarification that the quantity of assistance energy would be equal to and no greater than the amount needed to cure the RSE deficiency for each 15 minute interval.

[1] Pg. 20 at http://www.caiso.com/InitiativeDocuments/Presentation-WEIMResouceSufficiencyEvaluationEnhancementsPhase2-Sep2-2022.pdf

4. Provide your organization’s comments on added section 34.12.4:

PG&E offers comments on Section 34.12.4 in the attached draft tariff document.  A summary of those comments is also provided below.

• Section 34.12.4 -- Manual curtailment of low priority exports may occur when CAISO is in an EEA2
  • PG&E asks that CAISO update the tariff language to reflect statements by CAISO staff during stakeholder calls that manual curtailments of lower priority exports would occur during an energy emergency alert level 2 (EEA2), rather than an EEA3 as currently drafted.

• Section 34.12.4 -- Developing tariff definitions for PT and LPT exports 
  • It may be helpful for CAISO to develop tariff definitions to describe PT and LPT exports (or High Priority and Low Priority exports).  CAISO has recently developed a definition for “Priority Wheeling Through”[1] to clarify the scheduling priority of these high-priority transactions.  Similar definitions and references to high priority and lower priority exports may help improve clarity in the tariff.

[1] Appendix A of the CAISO Tariff (“Master Definition Supplement”)

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

No comments at this moment. 

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

PGP appreciates the efforts of the CAISO to find a balanced approach to aligning the RSE with other market processes and priority of transfers. While some inconsistencies may still exist, the results of this process are an improvement upon the status quo. The optional Energy Assistance Transfers approach outlined in the draft tariff language is reflective of the stakeholder support for this program. PGP continues to support the energy assistance concept discussed for times of oversupply, and supports prioritization of that effort as feasible.  

As discussed regularly in the WEIM Resource Sufficiency Evaluation stakeholder process, PGP continues to have concerns about the regular need for and use of load conformance actions by the CAISO. PGP encourages continued monitoring and analysis of the impact of load conformance on the RSE, as well as the CAISO’s improvement in other processes with the objective of reducing the need for load conformance actions. If the market operator is regularly taking actions to secure last minute supply, it is indicative of a potentially systematic issue in resource procurement and operational readiness that needs to be appropriately addressed.

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

PGP supports the Energy Assistance Transfer Revenue calculation, allocation and distribution approach drafted in the proposed tariff language. PGP believes this program will incentivize surplus supply is made available to WEIM and appropriately compensates entities that are able to provide aid in emergency situations.

3. Provide your organization’s comments on section 29.34 EIM Operations:

PGP requests clarifying language be added to section 29.34 to indicate the discussed differentiation between the Day-Ahead LPT Exports and the RT LPT exports and how they may be considered in the RSE.

4. Provide your organization’s comments on added section 34.12.4:

PGP supports the addition of  language in section 34.12.4 to clarify when exactly in the EEA3 process the LPT export curtailment may occur.

In such curtailment situations, PGP supports the prioritization of DA schedules over RT schedules as shown in the draft language, noting this helps to appropriately align the DA process with the WEIM processes. PGP further supports the use of the Firm-provisional tagging designation to indicate priority above non-firm but below firm supply.

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

The discussion and request for clarification on the role of RDRR and explicit DR impacts to the RSE, sequential participation in conjunction with emergency declarations, and other related questions reflects a general lack of understanding from market participants on the exact implications of various types of demand-side resource’s participation in the market and impacts to any RA or RSE related calculation. PGP noted similar concern and request for clarification in the EDAM Revised Straw Proposal. Given the criticality of this resource type, and potential for DR programs to continue to grow across the market footprint, PGP echoes the request from our EDAM comments, that a specific educational session take place regarding the participation framework of this critical resource type, with analysis and differentiation between economic DR and RDRR programs, and how their participation models and impacts to any RSE (EDAM or WEIM) may differ.

1. Please provide a summary of your organization’s comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language and September 15, 2022 stakeholder call discussion:

SCE appreciates the opportunity to comment on the Resource Sufficiency Evaluation Enhancements Phase 2 Draft Tariff Language.   Please see SCE responses below. 

2. Provide your organization’s comments on section 29.11 Settlements and Billing for EIM Market Participants:

SCE’s comments are consistent with the comments submitted on September 15, 2022 for the WEIM RSE Enhancements Phase 2 Revised Draft Final Proposal. [1] 

SCE believes it is premature to discuss or take a position on the WEIM charges for Energy Assistance Transfers.  The same issue is being discussed in the EDAM initiative and should be aligned with the WEIM RSE initiative.  

In addition, SCE understands the CAISO has the ability to “opt out” of this proposal and continue under the current framework (i.e., restrict transfers based on the last passing quantity).   This is an important feature that should be part of the proposal.  SCE understands that the ISO would initially “opt out” of the penalty structure.   SCE recommends that the CAISO be required to file with FERC for approval before changing to “opting in”.

[1] SCE Comments: Revised Draft Final Proposal – WEIM RSE Enhancements Phase 2. September 15, 2022.  Question #8 at https://stakeholdercenter.caiso.com/Comments/AllComments/96168e84-996e-4f49-8d30-2512c0d07b4e

3. Provide your organization’s comments on section 29.34 EIM Operations:

It is not clear under section 29.34(n)(3)(B)(ii) whether Energy Assistance transfers would occur before or after lower priority transfers are curtailed.  In our prior comments, SCE has mentioned that Energy Assistance transfers should not precede the curtailment of lower priority transfers (during an EEA3 and before arming load). [1]   SCE recommends that CAISO include “curtail lower priority transfers” under section 29.34(n)(3)(B)(ii) of the draft tariff.    The draft tariff should state the following:  

(ii)         the CAISO’s Security Constrained Economic Dispatch will exhaust all EIM Available Balancing Capacity and curtail lower priority transfers within the Balancing Authority Area prior to initiating Energy assistance transfers into that Balancing Authority Area;    

[1] SCE Comments: Revised Draft Final Proposal – WEIM RSE Enhancements Phase 2. September 15, 2022.  Question #8 at https://stakeholdercenter.caiso.com/Comments/AllComments/96168e84-996e-4f49-8d30-2512c0d07b4e

4. Provide your organization’s comments on added section 34.12.4:

SCE does not have additional comments.   

5. Provide any additional comments on the WEIM Resource Sufficiency Evaluation Enhancements Phase 2 draft tariff language or September 15, 2022 stakeholder call discussion:

SCE does not have additional comments.