Comments on Second Revised Draft Tariff Language

1. Please provide a summary of your organization's comments on the second revised draft tariff language:

 The Six Cities appreciate the CAISO’s assurances that it does not intend to require all owners of shared resources to pseudo-tie their shares to the CAISO and will allow shares of resources located in Energy Imbalance Market (“EIM”) Balancing Authority Areas to participate in CAISO markets as System Resources (whether dynamically-scheduled System Resources or System Resources submitting static schedules).  For the most part, the Second Revised Draft Tariff Language is consistent with those commitments.  However, as described in greater detail below, the second sentence of Section 3.1.3 of Appendix N appears inconsistent with those assurances.  It does not seem appropriate to require a resource share located in an EIM Entity Balancing Authority Area that is participating in CAISO markets as a System Resource to register as an EIM Resource, because that would subject the resource share to all of the provisions of Tariff Section 29.  In addition, to the extent a portion of a shared resource located in the proposed Los Angeles Department of Water and Power (“LADWP”) EIM Entity Balancing Authority Area does not receive transmission service under the LADWP OATT, the requirement proposed in Section 3.1.3 also appears to be inconsistent with Recital F in the CAISO/LADWP Energy Imbalance Market Entity Agreement (recently filed in FERC Docket No. ER21-101-000), which states that “the LADWP EIM Balancing Authority Area’s participation in the Energy Imbalance Market must be modeled and accounted for separately from the generation, transmission, or loads within the EIM Entity Balancing Authority Area not served under the EIM Entity’s OATT.”  See also Section 1.1(b) of the CAISO/LADWP Energy Imbalance Market Entity Agreement.  The Six Cities recommend revisions to draft Section 3.1.3 of Appendix N  below.

The Six Cities also request that the CAISO continue working with interested stakeholders to provide additional guidance and clarification in the appropriate Business Practice Manual on the steps a pseudo-tie participant needs to take to transfer to participation as a System Resource (either static or dynamic) and the associated timing so as to avoid any gap in Market participation in the event a pseudo-tie arrangement is suspended.

2. Provide your organization’s comments on Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area:

 The Six Cities have no comments on this section.

3. Provide your organization’s comments on Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area:

 The Six Cities have no comments on this section.

4. Provide your organization’s comments on Appendix N, Section 3 Pseudo-Ties of Shared Resources to the California ISO Balancing Authority Area:

 As noted above, the second sentence of Section 3.1.3, as drafted, appears inconsistent with the CAISO’s assurances that a shared resource located in an EIM Balancing Authority Area may continue to participate as a System Resource in the CAISO’s markets.  In addition, to the extent a portion of a shared resource is located in the proposed LADWP EIM Entity Balancing Authority Area and does not receive transmission service under the LADWP OATT, the requirement proposed in Section 3.1.3 also appears to be inconsistent with Recital F in the CAISO/LADWP Energy Imbalance Market Entity Agreement filed in FERC Docket No. ER21-101-000, which states that “the LADWP EIM Balancing Authority Area’s participation in the Energy Imbalance Market must be modeled and accounted for separately from the generation, transmission, or loads within the EIM Entity Balancing Authority Area not served under the EIM Entity’s OATT.”  See also Section 1.1(b) of the CAISO/LADWP Energy Imbalance Market Entity Agreement.  The Six Cities request that the CAISO modify the draft tariff language for Appendix N Section 3.1.3 as follows:

Each Generating Unit share must separately register with the CAISO as an independent Generating Unit according to the rules applicable to the CAISO Market in which it will participate.  If a resource share is located in a Native Balancing Authority Area that is an EIM Entity Balancing Authority Area and the share is not Pseudo-Tied to the CAISO Balancing Authority Area or registered to participate in the CAISO markets as a System Resource, the share must also register as an EIM Resource unless it is Pseudo-Tied to a Balancing Authority Area outside of the EIM Area.

5. Provide your organization’s comments on the draft Appendix B.16 - Pseudo-Tie Participating Generator Agreement:

 The Six Cities have no comments on this placeholder Appendix.

6. Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:

 The Six Cities appreciate the CAISO’s express statements in draft tariff sections 3.2.4 and 3.2.5 that if a pseudo-tie arrangement for a shared resource is suspended, “[d]uring the suspension period, the Pseudo-Tie Generating Unit may participate in the CAISO Markets as a System Resource, provided it has successfully registered as such with the CAISO and meets all the requirements of a System Resource.”  However, the Six Cities remain concerned that the process for switching from a Pseudo-Tie Generating Unit to participation in the CAISO Markets as a System Resource has not been developed or explained in any detail.  While it may not be necessary to include the details for that process in the tariff, the Six Cities consider it essential that the process be developed in detail and set forth in the appropriate BPM so that any gap in the ability of a resource share to participate in the CAISO’s Markets is avoided.  The Six Cities request that the CAISO continue working with interested stakeholders to provide additional guidance and clarification in the appropriate BPM on the steps a pseudo-tie participant needs to take to transfer to participation as a System Resource (either static or dynamic) and the associated timing so as to avoid any gap in Market participation.

1. Please provide a summary of your organization's comments on the second revised draft tariff language:

SCE is supportive of the second revision of the proposed draft tariff language except for the inconsistencies specified below that require modification.

2. Provide your organization’s comments on Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area:

?SCE supports the Second Revised Draft Tariff Language in Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area. 

3. Provide your organization’s comments on Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area:

SCE supports the Second Revised Draft Tariff Language in Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area. 

4. Provide your organization’s comments on Appendix N, Section 3 Pseudo-Ties of Shared Resources to the California ISO Balancing Authority Area:

SCE recommends that the CAISO modifies the reference to its market in the first sentence of Section 3.1.2 of the Second Revised Draft Tariff Language to be consistent with the first sentence of Section 3.1.3. of the said tariff language. 

5. Provide your organization’s comments on the draft Appendix B.16 - Pseudo-Tie Participating Generator Agreement:

?SCE recommends that the reference to the CAISO Market should be consistent throughout the second revised draft language as noted for Sections 3.1.2 and 3.1.3 of the proposed language. 

6. Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:

None.