Comments on Reliability Demand Response Resource Bidding Enhancements Track 1

1. Please share your organization’s overall position on the Track 1 revised draft final proposal:

The California Efficiency + Demand Management Council (“Council”) fully supports the Track 1 draft final proposal with no caveats.

2. Please provide comments on the CAISO’s Track 1 draft final proposal to align RDRR bidding rules with real-time price conditions consistent with FERC Order No. 831.

The Council fully supports the Track 1 revised draft final proposal with no caveats. The Council agrees with the CAISO’s response to the Department of Market Monitoring’s (“DMM”) concerns that automatically increasing RDRR bids once the $2,000/MWh hard cap goes into effect will not reflect the marginal costs of RDRRs. As the CAISO correctly noted, the settlement approved by the California Public Utilities Commission in Decision 10-06-034 specified that RDRRs (then referred to as the Reliability Demand Response Product) would have a high strike price relative to conventional generators. Also, maintaining the original RDRR bid following the hard cap going into effect would result in RDRRs being dispatch before higher-cost conventional generation which could suppress market prices when these resources are needed the most.

3. Please provide comments on the RDRR Bidding Enhancements Initiative bifurcation and timing

The Council supports bifurcating this initiative as well as the CAISO’s proposed Track 1 timeline. This element of the RDRR Enhancements initiative appears to be uncontroversial, so it is logical to decouple it from Track 2 which could potentially be more contentious. This will ensure that the necessary revisions to the CAISO tariff will be in effect in time for the summer.

4. Attachments

N/A

1. Please share your organization’s overall position on the Track 1 revised draft final proposal:

Please see DMM comments in attached PDF.

2. Please provide comments on the CAISO’s Track 1 draft final proposal to align RDRR bidding rules with real-time price conditions consistent with FERC Order No. 831.

Please see DMM comments in attached PDF.

3. Please provide comments on the RDRR Bidding Enhancements Initiative bifurcation and timing

Please see DMM comments in attached PDF.

4. Attachments

Please see DMM comments in attached PDF.

DMM comments will also be posted in the coming days at the following location, under "2022 comments on stakeholder processes": http://www.caiso.com/market/Pages/MarketMonitoring/MarketMonitoringReportsPresentations/Default.aspx#comments 

1. Please share your organization’s overall position on the Track 1 revised draft final proposal:

CLECA appreciates the effort CAISO has made to resolve infeasible dispatch by the proposal to resolve the Pmin of zero problem.  However, as a supply side resource, RDRR should also be allowed to use min load or start-up costs to manage how it will be dispatched.  For example, those parameters could be used to ensure economic PDR is dispatched prior to RDDR when the energy bids are about the same. CLECA requests the CAISO continue to refine the bidding options for RDRR.

CLECA supports the increased in the cap to 100 MW for the discrete bidding registration option.  CLECA also supports further development of the criteria that would allow parties to request a waiver for a resource that is over 100 MW.

2. Please provide comments on the CAISO’s Track 1 draft final proposal to align RDRR bidding rules with real-time price conditions consistent with FERC Order No. 831.

CLECA supports the automatic adjustment of RDRR bids when the bid cap is increased from $1,000 to $2,000/MWh.

3. Please provide comments on the RDRR Bidding Enhancements Initiative bifurcation and timing

4. Attachments

1. Please share your organization’s overall position on the Track 1 revised draft final proposal:

PG&E supports the proposal to align RDRR bidding rules with real-time price conditions with FERC order 831.

However, PG&E cautions the CAISO against potential gaming opportunities of the proposed enhancements and request that the CAISO and DMM closely monitor bidding behavior after implementation.

Finally, ensuring RDRR availability is critical for reliability and we urge the CAISO to ensure implementation of the proposed enhancements by Summer 2022.  

2. Please provide comments on the CAISO’s Track 1 draft final proposal to align RDRR bidding rules with real-time price conditions consistent with FERC Order No. 831.

PG&E supports the proposal to align RDRR bidding rules with real-time price conditions with FERC order 831.

PG&E cautions the CAISO against the risk of market participants adversely gaming the market within the proposed rules.

• This gaming risk is likely to be low, because (1) RDRR will be only be dispatched during system conditions above EEA 2 and (2) the gaming strategies often require a few conditions to be met simultaneously. For the same reason, any gaming attempts could be easily tracked.
• PG&E is willing to continue working with the CAISO to describe the potential gaming strategies in detail.
• Despite the relatively low risk, PG&E believes that the CAISO and DMM should closely monitor bidding behaviors after the proposal’s implementation and report any anomalous observations to stakeholders.
• PG&E also believes CAISO’s future policy initiatives, such as Scarcity Pricing and Price Formation, should be consistent with this proposal and allow for revision of the proposed enhancements after implementation for a more integrated and efficient market design.

3. Please provide comments on the RDRR Bidding Enhancements Initiative bifurcation and timing

PG&E supports the implementation timeline of Track 1. PG&E believes that ensuring RDRR availability is critical for reliability and requests the CAISO ensure the proposed enhancements are in place by Summer 2022.  

4. Attachments

1. Please share your organization’s overall position on the Track 1 revised draft final proposal:

Please see attached comments.  

2. Please provide comments on the CAISO’s Track 1 draft final proposal to align RDRR bidding rules with real-time price conditions consistent with FERC Order No. 831.

Please see attached comments.  

3. Please provide comments on the RDRR Bidding Enhancements Initiative bifurcation and timing

4. Attachments