Comments on edam access charge draft tarriff

1. Please provide your organization's comments and redlines in response to the Revised Draft Tariff Language on EDAM Access Charge in ISO BAA (Section 26 and 33.26) posted on September 30, 2024.

Six Cities’ Comments:

The Six Cities propose clarifying edits as identified in the attached redline.  In particular, the terminology  “attributable to” and “allocated to” in draft Section 26.2 makes it difficult to distinguish between amounts to be charged to versus amounts to be received by a BAA.  In the attached redline, edits proposed by the Six Cities are redlined and highlighted in green.  Redlined text without highlighting shows revisions proposed by the CAISO in the version of the draft tariff language posted by the CAISO on October 10, 2024.

Overall, the processes for developing the EDAM Recoverable Revenues and the CAISO BAA EDAM Access Charge as described in the draft tariff language are complex and unclear.  In addition to proposing the clarifying edits in the attached redline, the Six Cities request that the CAISO conduct a workshop with examples and implementation estimates based on 2023 and 2024 data.

In addition to the redlined and highlighted revisions proposed in the Attachment, the Six Cities also request the following revisions to the draft tariff language (but have not developed specific language):

Section 26.2.2 of the tariff should be supplemented to provide that the CAISO will develop and provide to each PTO estimates of Wheeling Access Charges forgone as a result of EDAM implementation.

The Six Cities also request that Section 26.2.2 be supplemented to clarify that the process for calculating EDAM Recoverable Revenues applies to non-load-serving PTOs as well as load-serving PTOs.

The revised draft tariff language posted on October 10, 2024, remains unclear with respect to whether calculation of EDAM Recoverable Revenue is optional or required.  In the Six Cities’ view, calculation of EDAM Recoverable Revenue generally should be required.  Failure to claim transmission revenues eliminated as a result of EDAM transactions effectively would provide a windfall benefit to EDAM Entity BAAs at the expense of CAISO transmission customers.  However, the Six Cities would support consideration of an exception to a requirement to calculate EDAM Recoverable Revenues where such revenues reasonably can be expected to be de minimis (e.g., $10,000 in a given year).

The Six Cities request that Section 26.2.3 be supplemented to provide that the CAISO will post on its website back-up data supporting the calculation of the charges payable by CAISO load, including data for EDAM Recoverable Revenues, by EDAM Entity, included in the EDAM Access Charge for the CAISO BAA.   

2. Please provide any feedback not already captured.

1. Please provide your organization's comments and redlines in response to the Revised Draft Tariff Language on EDAM Access Charge in ISO BAA (Section 26 and 33.26) posted on September 30, 2024.

Southern California Edison has the following comments on the Draft Tariff Language on EDAM Access Charge in the ISO BAA (SCE's comments are on the October 10 Post Stakeholder Call version).

Section 26.2.3: The Tariff language should be clear that the EDAM Access Charges allocated to Gross Load in the CAISO BAA should be billed to the load-serving Scheduling Coordinators representing Gross Load within the ISO BAA, and not to PTO entities. 

SCE suggests adding the following tariff language: “All EDAM Access Charges will be allocated to Gross Load via charges to the Scheduling Coordinators representing Gross Load in the CAISO BAA. No such charges will be allocated to PTOs”

Section 26.2.2: The Tariff language should explicitly state that CAISO PTO entities with EDAM Recoverable Revenue should include any amounts of recovered EDAM Recoverable Revenue in the Regional (High Voltage) component of its Transmission Revenue Requirement unless the PTO can demonstrate that a portion of its recovered EDAM Recoverable Revenue relates to Local (Low Voltage) facilities (for example, any EDAM interties that are Low Voltage).  This will ensure that all EDAM Recoverable Revenue relating to Regional EDAM interties benefit all CAISO Gross Load, rather than only the Gross Load of an individual PTO, pursuant to the operation of the CAISO's Transmission Access Charge.

SCE suggests the adding the following tariff language: “PTOs with EDAM Recoverable Revenue will include any amounts of recovered EDAM Recoverable Revenue in the Regional (High Voltage) component of its Transmission Revenue Requirement unless the PTO can demonstrate that a portion of its recovered EDAM Recoverable Revenue relates to Local (Low Voltage) facilities. Any demonstrated Low Voltage portion will be included in their associated Local Transmission Revenue Requirement with the remainder included in the High Voltage Transmission Revenue Requirement.”

2. Please provide any feedback not already captured.

SCE has no additional comments.