Comments on Revised Draft Tariff and Business Practice Manual (BPM) Language

1. Provide a summary of your organization’s comments on the revised draft tariff and BPM language (optional):

The Six Cities' comments at this time are limited to draft Section 6.1.3.7 for the BPM for Reliability Requirements and are set forth in Item No. 6 below.

2. Provide your organization’s comments on draft tariff language section 40.4.6.2.1 Available Import Capability Assignment Process:

The Six Cities have no comments on this section of the draft tariff language.

3. Provide your organization’s comments on draft tariff language section 40.4.6.2.2.2 Reporting Process for Bilateral Import Capability Transfers:

The Six Cities have no comments on this section of the draft tariff language.

4. Provide your organization’s comments on draft tariff language section 40.4.6.2.2.4 Reserving import capacity as New Use Import Commitment:

The Six Cities have no comments on this section of the draft tariff language.

5. Provide your organization's comments on the revised Appendix A – Tariff Definitions:

The Six Cities have no comments on revised Appendix A -  Tariff Definitions.

6. Provide your organization’s comments on the revised draft BPM language section 6.1.3.7 Requirements for New Use Import Commitments in order to reserve Remaining Import Capability at the branch group level Hourly Shaping Factor:

The Six Cities recommend that the sixth and seventh paragraphs of draft BPM language section 6.1.3.7 be revised as follows:

LSEs must provide the CAISO with contract priority curtailment order and preference before import allocations are given out for the next RA year.   – curtailment preference Priority may be for part of the contract – if the LSE intends to keep and show the RA contract for the next RA Year – or it can be for the curtailment reduction of the entire contract if, for example, the LSE intends to sell or dispose of the contract.

A Mmaximum of 75% of an LSEs’ LSE's year ahead total import allocation (as communicated by the CAISO per step 7) can be reserved at the branch group level with multi-year applicable contracts signed by May 15th of the year prior to the applicable RA year (coincides with July RA showings) and they must be communicated to the CAISO by submitting the required template per dates specified herein. The total import allocation representsrepresenting the sum of Existing Contract Import Capability, Pre-RA Import Commitment Capability, New Use Import Commitment Capability and Remaining Import Capability as communicated by the CAISO per step 7. The total locked up amounts for each LSE represents the sum of all their Existing Contract Import Capability, Pre-RA Import Commitment Capability and New Use Import Commitment Capability.

With respect to the last paragraph of draft section 6.1.3.7, the Six Cities request that the CAISO explain the basis for allowing reservations equal to 120% of the highest summer monthly value versus 100% of the highest summer monthly value.

7. Additional comments on the Maximum Import Capability Stabilization and Multi-Year Allocation revised draft tariff and BPM language:

The Six Cities have no additional comments on the revised draft tariff and BPM language at this time.