Submitted on behalf of Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
Thompson Coburn LLP
The Six Cities' comments at this time are limited to draft Section 22.214.171.124 for the BPM for Reliability Requirements and are set forth in Item No. 6 below.
The Six Cities have no comments on this section of the draft tariff language.
The Six Cities have no comments on revised Appendix A - Tariff Definitions.
The Six Cities recommend that the sixth and seventh paragraphs of draft BPM language section 126.96.36.199 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 188.8.131.52, 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.
The Six Cities have no additional comments on the revised draft tariff and BPM language at this time.
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