Comments on FERC 881 10/24

1. Please provide a summary of your organization’s comments on the October 24, 2024 FERC Order 881 - Managing Transmission Line Ratings phase 2 Methodologies working group call discussion:

PG&E appreciates CAISO for the call on October 24 and the opportunity to submit the following questions.

1. PG&E opposes the split implementation of ambient adjusted ratings in the real-time and day-ahead markets due to potential negative market impacts.  A split implementation creates a systematic difference between the day-ahead and real-time markets. This systematic difference can reduce market efficiency, create a wealth transfer to convergence bidders, and increase cost to load through sub-optimal dispatch and additional uplift costs (e.g., RT Congestion Offset charges). PG&E is concerned that these costs outweigh the benefit of the early implementation of ambient adjusted ratings in real-time.  PG&E suggests CAISOs extension request indicate a recommendation delaying implementation of both the day-ahead and real-time markets until after the launch of the Extended Day-Ahead Market.

2. PG&E requests clarification of the expectation from TOPs to meet compliance in July 2025.  Could the CAISO also share the takeaways from its own internal discussion with its Compliance team?

3. PG&E requests CAISO to please provide insights and implications of introducing real time AAR ratings to the reliability applications ahead of market usage.  What does the CAISO see as a benefit by applying real-time AARs to the reliability apps only, but not for market usage?

4. PG&E request clarification about the timing of the webLineR.  When would it be ready and functional?  The two timelines shared by CAISO show conflicting information, in one timeline CAISO plans to open up webLineR to allow access and testing starting from January 2025, while on another timeline, CAISO indicates that webLineR will be ready by June 2025.

5. PG&E requests CAISO to please confirm its intent to act as a clearing house for ratings on tie-lines and to please describe how the process will work.  Will the CAISO be relaying the finalized ratings for each line at each hour back to TOPs?  If so, how will this data be relayed?

6. PG&E requests clarification about whether the TOPs are expected to convey 240 hour forecast data for all CAISO controlled lines or only the lines that are AAR-ed?  If PG&E is claiming an exception for a line and rated the capacity using seasonal rating, are we still expected to include seasonal ratings data in our hourly conveyance to CAISO for these lines?

PG&E appreciates the participation in these discussions and the opportunity to seek clarification. Please do not hesitate to reach out should you have any questions. PG&E welcomes the opportunity to have additional discussions as needed.

2. Please provide any feedback not already captured.

1. Please provide a summary of your organization’s comments on the October 24, 2024 FERC Order 881 - Managing Transmission Line Ratings phase 2 Methodologies working group call discussion:

Portland General Electric would like clarification on the timeline for CAISO’s implementation of FERC Order 881 into its reliability and energy imbalance market applications.

2. Please provide any feedback not already captured.

Portland General Electric Company (“PGE”) appreciates the opportunity to comment on CASIO’s FERC Order 881 Implementation initiative. FERC Order 881 requires that PGE provide Ambient Adjusted Ratings (“AARs”) to the reliability coordinator CAISO/RC West. PGE submitted proposed revisions to its Open Access Transmission Tariff (“OATT”), Attachment Q in accordance with FERC Order Nos. 881, 881-A?to explain the timelines for calculating and submitting AARs to the RC by the July 12, 2025, Order 881 compliance deadline. PGE plans to provide AAR data to the RC by the compliance deadline as indicated in the OATT Attachment Q filing. PGE would like clarification on how CAISO’s delayed implementation and request for an extension of time will impact the ability for CAISO to receive AARs and meet the July 12, 2025, compliance implementation deadline.  

Additionally, PGE would like clarification about at which point during CAISO’s Order 881 implementation will RC West be able to serve as a clearing house for AAR data for transmission providers. PGE would like more details on when transmission providers will be able to download other transmission providers AAR data. Clarification on when transmission providers will have access to this data will assist transmission providers with calculating TTCs. PGE hopes to have access to this data ahead of the Order 881 compliance deadline for testing purposes.  

Furthermore, PGE would like to better understand impact to its energy imbalance market operations due to the discrepancy in ratings between market dispatch operating targets that are calculated using seasonal ratings; and the actual real time flow that is using ambient adjusted ratings. PGE is concerned about the potential of accruing congestion offset charges when PGE has to mitigate for market dispatches which exceeds the current ambient adjusted ratings.

1. Please provide a summary of your organization’s comments on the October 24, 2024 FERC Order 881 - Managing Transmission Line Ratings phase 2 Methodologies working group call discussion:

SDG&E appreciates the opportunity to provide comments and feedback on the October 24, 2024 FERC Order 881: Managing Transmission Line Ratings – Phase 2 Methodologies Working Group meeting.

SDG&E supports CAISO’s proposal to revise the timeline for implementation of Track 3 - Market Application and Look ahead Applications and to seek approval from FERC to delay implementation in December 2024. We believe that extending the implementation date is useful as it will enable all stakeholders more time to ensure that their systems work properly and are aligned with CAISO’s systems.

Due to an update of SDG&E’s EMS, SDG&E plans to seek FERC approval to extend the implementation date for its systems. SDG&E plans to file the request before the end of 2024.

2. Please provide any feedback not already captured.