Comments on Rules of conduct enhancements track 1 - straw proposal

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

APS is generally supportive of the ROCE track 1 scope items and appreciates the opportunity to comment on the straw proposal.

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

Overall, the proposed enhancements to meter data penalties fail to address materiality in late meter data submissions. The proposed rule of keeping the $1000/ trading day penalty could result in penalties for late meter submissions even if the submitted value ends up being zero. APS encourages CAISO to either remove penalties for late meter submissions that end up being zero or consider some other materiality threshold.

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

APS does not feel the current eligibility criteria is fair. The proposal maintains only participants not assessed a penalty in a year are eligible for the pro-rata distribution of the penalty fund, regardless of materiality of the impact. A potential way to address this would be to do the pro-rata distribution on a daily basis rather than yearly. For example, if an entity is penalized on a certain trade date they would not be eligible to receive funds associated with that day. A yearly distribution is still appropriate, but the calculation would be on a daily basis.

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

APS is supportive of not applying market adjustments if there are not additional scheduling coordinator IDs in a given utility distribution company (UDC) area.

6. Please provide your organization’s comments on the future track topics and comments section

APS will provide further comments when the track 2 proposal is posted.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

 APS is supportive of the T+44B notification to market participants for missing meter data.

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

The California Efficiency + Demand Management Council (Council) appreciates the opportunity to comment on the CAISO’s Rules of Conduct Enhancements Track 1 Straw Proposal (Straw Proposal).  The Council appreciates the CAISO’s efforts to develop more constructive approaches to penalties for missing, late, or inaccurate meter data.  This is especially critical given the July 13 FERC Order denying the CAISO’s April 24, 2023 waiver request for several penalties related to meter data-related infractions. 

The Council supports the proposed revisions to Settlement Quality Meter Data (SQMD) penalties in Chapter 4 because they are fairer for smaller resources like demand response.  The Council also supports a Track 2 scope to include clarifications for penalties related to customer load baseline monitoring data and recommends the CAISO also consider a cure period for corrected monitoring data beyond the T+52B timeframe.

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

The Council supports the proposed revisions to the meter data penalties contained in Chapter 4 of the Straw Proposal.  Setting the penalty for inaccurate SQMD at the lower of 30 percent of the error’s absolute value and $1000/trading day is far fairer for demand response resources and other small resources because inaccurate SQMD for smaller resources will often have an error value that is far lower than $1000/trading day.  For example, a 1 MW Proxy Demand Resource with a four-hour dispatch (4 MWh) at $500/MWh for a total settlement amount of $2,000 will in most cases have a very low absolute error value due to inaccurate data.  In this instance, a $1,000/trading day penalty would be excessive.  For the same reason, the Council also supports the one-time nature of the 30 percent penalty.  Applying a daily penalty in that instance, even if it is 30 percent of the error’s value, could quickly exceed the value of the dispatch.  

The Council also supports the proposed T+44B automatic notice for missing meter data.  This would be a helpful feature that will hopefully reduce the incidence of missing meter data which should be the CAISO’s overarching goal.  The Council presumes that market participants do not intentionally fail to provide SQMD by T+52B, and though each market participant must be aware of their responsibilities, any actions the CAISO can take to limit these occurrences would be helpful.

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

The Council reserves comment.

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

The Council reserves comment.

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

The Council reserves comment.

6. Please provide your organization’s comments on the future track topics and comments section

The Council supports the CAISO’s consideration in Chapter 8 that Track 2 consider submission requirements and penalty structures for demand response (DR) customer load baseline monitoring data.  The Straw Proposal correctly relates the concerns expressed by stakeholders in response to Proposed Revision Request (PRR) 1444, and the Council reiterates its appreciation to the CAISO for withdrawing it.  However, the ambiguity that PRR 1444 attempted to address remains, so the time is ripe to address the issue of the appropriate level at which the $500/day penalty (pursuant to Section 37.6.1.2) should be applied; i.e., at the Scheduling Coordinator or Resource ID level.

Another issue not mentioned in the Straw Proposal that should be addressed in Track 2 is the need for a cure period for corrected monitoring data following the T+52B timeframe.  Section 10.3.6.4 of the CAISO’s Tariff allows for SQMD to be recalculated up to 214 Business Days after the Trading Day, subject to a penalty for any submissions after T+52B.  The same option should exist for customer load baseline monitoring data. This is especially critical for DR providers whose delivery of data is wholly dependent on the ability of the local IOU to deliver customer meter data on a timely basis.  Though the IOUs generally deliver a majority of these data within the appropriate time frame to allow DR provider compliance with CAISO requirements, there are regular occurrences of late or incomplete data.  This places DR providers at risk for being penalized for missing or inaccurate data despite being outside of their control.  Alternatively, the CAISO could allow DR provider Scheduling Coordinators to estimate any missing meter data in order to meet the T+52B deadline without being penalized for any inaccuracies.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

The Council reserves comment.

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

The Council has no other comments to add on the Straw Proposal.

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

In light of the recent FERC order denying CAISO’s request for a waiver of penalties in ER23-1699-000, Idaho Power respectfully requests that CAISO expedite its tariff filing to change its meter penalties so that WEIM market participants do not continue to receive disproportionate penalties that this Rules of Conduct Enhancement seeks to address.  Additionally, Idaho Power requests that the tariff filing request waiver of FERC’s 60-day notice requirement to make the amendment effective upon filing.  

Alternatively, Idaho Power suggests CAISO submit an emergency 205 filing to implement the proposed provision so that the inaccurate meter penalty is based on the lower of: (a) 30% of the error’s absolute value; or (b) $1,000 per trading day.

Idaho Power believes the current penalty is grossly disproportionate to the impacts of  inaccurate meter data, particularly as applied to WEIM market participants.  The current per-day penalty structure results in a scenario where a large penalty is assessed for a persistently small meter error.  The actual harm of the error of such an error to the market is minimal and such penalties are overly punitive. 

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

There needs to be more clarity surrounding how penalties are calculated for inaccurate meter data when a generator meter error is re-submitted, which also results in the need to re-submit the load meter. As Idaho Power has raised with CAISO staff, since the load meter (ELAP) is a calculated value that includes the corrected generation meter, the ELAP resource will also need to be re-submitted to properly account for Unaccounted for Energy (UFE).  If an error is reported on the generator and an offsetting error is also reported on the ELAP resource, the penalty should only apply to the generator where the error occurred. Applying the 30% (or $1000 a day) penalty to both errors is unjust and unreasonable since the load meter change is a calculation of the changed generation meter. Additionally, when the generation meter is a non-participating resourced owned by the EESC, the corrected load meter error impact will have a direct offset to the corrected generator error impact. We would ask that CAISO consider in these scenarios that the 30% error calculation be netted between the resources since they impact the same SC.  CAISO should include a provision that sets forth that if there is an error reported for a loss on both the generator and resource, then the error will be netted and the penalty assessed to the net error.  To assess the penalty in any other manner is duplicating the penalty for essentially the same error which is unjust and unreasonable. 

As to missing meter data penalties, the $1000 a day penalty is overly punitive for resources that are not generating but in the master file.  If the value of the missing meter data is zero, a penalty should not be assessed if the error is corrected before T+214B.  Oftentimes new resources are loaded into the master file before a generator is operational due to commercial operational dates changing unexpectedly. This could result in no meter data being submitted, since an outage is placed on the resource until the unit goes operational. If CAISO is going to be changing the expectation around when meter data is expected to be submitted from expected energy to the date the resource in included in the master file, then the risk for potential missing meter data increases even if the resource is not yet operational and the value submitted would be zero.  At a minimum, a penalty should not be assessed until the T+214B settlement for zero value generation as long as CAISO has properly notified the SC that data is missing for an expected resource.  

Idaho Power is supportive of the T+44B pre-deadline automatic notice for missing meter data to market participants. 

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

 Idaho Power supports this change and has no further comments at this time.

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

Idaho Power supports this change.

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

Idaho Power supports this change.

6. Please provide your organization’s comments on the future track topics and comments section

 Idaho Power agrees that the current three-letter process should be streamlined

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

No comments at this time.

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

No additional comments.

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

On April 24, 2023, the CAISO filed a waiver request seeking to suspend application of the $1,000/day penalty in Section 37.11 of the tariff until the earlier of: (a) the effective date of any amendment from this initiative or (b) May 1, 2024. As explained in the filing letter in FERC Docket No. ER23-1699, the CAISO was, “deeply concerned about the potential for new inaccurate meter data penalty issues to arise before it can revise its tariff rules.” The CAISO also noted, “it is inappropriate to continue enforcing the meter data penalties as constructed when they can lead to unjust and unreasonable outcomes.” The requested waiver was to, “address the concrete problem that penalties for inaccurate meter data can far exceed the amount needed to support the objectives of the penalties and can be misaligned with the severity of the violation.”

Due to the large scope of the entities needing relief; however, FERC determined a waiver was not the appropriate procedural means to resolve the problem and rejected the CAISO request in an order issued on July 13, 2023. Accordingly, the CAISO Tariff continues to impose unjust and unreasonable meter penalties for small volume but long duration events.

NV Energy submits that the best and most expeditious way to address the ongoing tariff flaw and to prevent future unreasonable outcomes would be for the CAISO to submit an emergency 205 filing to implement the proposed changes in this initiative so that the inaccurate meter data penalty would be based on the lower of: (a) 30% of the error’s absolute value; or (b) $1,000 per trading day. The CAISO should not wait for the joint EIM Governing Body and Board meeting in late September but should convene a conference call to make the filing as soon as possible. The CAISO also should request waiver of the FERC’s 60-day notice provisions to make the amendment effective upon filing. This stakeholder process could continue and the CAISO could make a subsequent filing to reflect any different outcome, but at least in the interim the tariff would be just and reasonable. NV Energy notes the strong support the improvement to the meter penalty has received in this proposal in comments submitted to date.

The only other option may be for a stakeholder to file a complaint regarding the current penalty structure which the CAISO has admitted is unjust and unreasonable. This would be an unwarranted complication as the CAISO should take expedited proactive measures to address the situation. NV Energy recognizes that additional filings may be necessary to address pending penalty cases, but at least the prospective path would be clearer as the Section 205 filing may help inform the disposition of those cases.

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

NV Energy supports CAISO proposal to base the meter penalty on the lower of: (a) 30% of the error’s absolute value; or (b) $1,000/trading day. As noted in response to Question 1, the CAISO should take immediate action to correct the tariff from levying unjust and unreasonable penalties.

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

6. Please provide your organization’s comments on the future track topics and comments section

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

PacifiCorp generally supports the elements proposed as part of Track 1 within the Rules of Conduct initiative.  

PacifiCorp’s comments highlight the following:  

• Support for the proposed meter data penalty enhancements; 
• General support for the proposed market adjustment provision; 
• Support for a Joint Authority model for meter data; 
• Support for the creation of an automatic market notice for missing meter data at T+44B: 
• Request for the CAISO to add in a secondary function to the automatic market notice for missing T+44B data for new MRIDs. From Market Results Interface – Settlements (MRI-S) / Meter Data, add an exportable calendar showing when new resources (MRIDs) populate as ready for meter data submission. 
• Request for more information informational report that is replacing the annual penalty distribution filing 

PacifiCorp looks forward to further detail and engagement on this effort through the stakeholder process. 

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

PacifiCorp supports the CAISO’s proposed methodology where the lesser of a) 30% of the value error or b) $1,000/trading day will be used to distribute penalties versus the method used today which took all penalty amounts at the $1,000/trading day penalty price.  

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

In order to fully assess its support for the elimination of the annual penalty distribution filing, PacifiCorp needs more information pertaining to the informational report that will be communicated through the ISO’s website in lieu of the annual penalty distribution filing. In essence, PacifiCorp is inclined to be supportive of alleviating administrative burden at no risk to the market participants, however, the CAISO has not provided sufficient detail of what elements would be included in the informational report. PacifiCorp requests the CAISO identify the elements that would be displayed on the ISO’s website as some of the contents could potentially be sensitive. 

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

No comment. 

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

PacifiCorp generally supports the CAISO’s proposed market adjustment provision if no impacts have been observed to other market participants.  

6. Please provide your organization’s comments on the future track topics and comments section

No comment.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

PacifiCorp has no concern with the Joint Authority model for meter data. 

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

PacifiCorp strongly supports the creation of an automatic market notice for missing meter at T+44B. PacifiCorp requests the CAISO further streamline the process for which a new Market Resource ID (MRID) is added into the system. Today, in order to submit the new MRID by the deadline, PacifiCorp must continuously spot check a drop-down menu to see if the new resource is populated and ready in MRI-S for meter data submission, as there currently is no way to export MRIDs with missing meter data in MRI-S. Therefore, PacifiCorp urges the CAISO either create a calendar for participants to look forward to or add some functionality for when a new MRID has been accepted and entered into the CAISO’s system within the scope of this initiative.  

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

Pacific Gas and Electric (PG&E) thanks the CAISO for proposing this initiative and provides comments PG&E offers comments regarding the future track topic “Define Submission Requirements and Penalty Structure for DR Customer Load Baseline Monitoring Data (Sections 11.6.1 & 37.6.1).  

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

6. Please provide your organization’s comments on the future track topics and comments section

PG&E offers comments and seeks clarification regarding the future track topic “Define Submission Requirements and Penalty Structure for demand response (DR) Customer Load Baseline Monitoring Data (Sections 11.6.1 & 37.6.1).”

In this Section of the Track 1 Straw Proposal (page 19), CAISO included the stakeholders’ comments to the Proposed Revision Requests (PRR) 1444 to the Business Practice Manuals (BPM). These comments referred to the application of a sanction per resource. With over 60 resources in its portfolio, a late submission of customer baseline (CBL) and/or baseline (BASE) file data would expose PG&E to an excessive penalty of over $60,000 per trade day. PG&E requested clarification on how the sanctions will be applied. PG&E appreciates the inclusion of these comments and restates the concerns raised.

In this context, PG&E respectfully requests that the CAISO clarify why 90 days of historical data is required to monitor when as few as 14 days of data is needed to perform settlement quality meter data calculations. PG&E would also like to raise the challenge that requiring 90 days of historical meter data presents to new customers, who may not have 90 days of historical data, but do have sufficient meter data to perform settlement calculations.

PG&E respectfully requests that in Track 2 the CAISO consider reducing the requirement of historical days from 90 to 45 days. PG&E also suggests that CAISO consider an exemption for new customers or for baseline methods that don’t require 90 days of historical data to perform settlement calculations.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

Powerex appreciates the opportunity to provide comments on the CAISO’s July 6th, 2023 Rules of Conduct Enhancements Track 1 Straw Proposal.

As previously stated, Powerex supports market rules that encourage market participants to provide timely and accurate meter data for participation in the WEIM. At the same time, Powerex believes penalties applicable to late meter data corrections should be generally commensurate with the magnitude of the underlying inaccuracy, including consideration of whether the inaccurate data could be reasonably expected to result in a material negative consequence for other market participants.

CAISO’s proposal for inaccurate meter data is a penalty based on the lower of (a) 30% of the absolute value of the error and (b) $1000/trading day. CAISO states that the purpose of this proposal is to ensure “the cost is more proportional to the impact on the market and the ISO’s operations”. While Powerex supports this objective, Powerex believes that using 30% of the absolute value of the error has the potential to overstate the true impact on the market, particularly if a late change to an EIM participant’s generation meter data is offset by a corresponding (and offsetting) change to its load meter data in the same hour. In these cases, the calculated meter penalties could still significantly outweigh the actual impact of the inaccuracy on other market participants. For this reason, Powerex believes the “value of error” term in the calculation should be based on an hourly calculation of the net MWh impact of all meter data corrections submitted by the relevant Scheduling Coordinator.

As a supplement to using a calculation of the net hourly value of the error, CAISO could also consider a minimum daily penalty of $100/trading day as another bookend in the calculation to encourage market participants to provide timely and accurate meter data for participation in the WEIM, even when errors are relatively small. Powerex proposes CAISO consider defining the penalty of inaccurate meter data submissions as:

Lower of:

1. 30% of the net value of the error, or $100/trading day, whichever is higher; and
2. $1,000/trading day

Where the net value of the error is based on an hourly calculation of the net MWh impact of all meter data corrections submitted by the relevant Scheduling Coordinator.

Powerex believes the approach above would ensure that the bounds of the penalties are established in a range between $100 and $1000 per day depending on the magnitude of the error, while also using a calculation of the magnitude of the error that better reflects the actual impact on market participants when a Scheduling Coordinator submits inaccurate meter data.

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

6. Please provide your organization’s comments on the future track topics and comments section

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

See comments above. 

Powerex's comments are aslo available at CAISO Rules of Conduct Straw Proposal.pdf (powerex.com)

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

 As discussed below, the Six Cities either support or do not oppose elements of the Track 1 Straw Proposal. 

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

The Six Cities support the proposed changes to the penalties for inaccurate submission of meter data, and acknowledge the CAISO’s reasoning for proposing to retain the currently applicable penalty structure for late meter data.  Based on the explanation provided by the CAISO, the Six Cities do not oppose the CAISO’s proposal to retain the current penalties for late data. 

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

The Six Cities do not oppose this element of the Straw Proposal, and now understand that the CAISO’s proposal entails an informational posting on the CAISO website detailing the proposed penalty distribution, as opposed to an informational filing at FERC. 

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

The Six Cities do not oppose this element of the Straw Proposal. 

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

 The Six Cities take no position on this element of the Straw Proposal. 

6. Please provide your organization’s comments on the future track topics and comments section

The Six Cities have no comments at this time on the proposed scope for Track 2 of this initiative. 

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

The Six Cities concur in the proposed WEIM classification for this initiative as a joint authority item.

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

The Six Cities have no further comments at this time. 

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

SCE appreciates CAISO's efforts with this initiative and would like to thank CAISO for proposing several potential enhancements.

SCE appreciates CAISO’s extension of the Missing Measurement Data Notice (T+44B) to market participants, which CAISO currently receives internally. SCE believes this enhancement would be highly beneficial for market participants by providing notification to market participants of missing meter data prior to the T+ 52B deadline. However, producing the report and sending out the notification too early could limit its usefulness in determining what data is truly at risk of being late and subject to penalties. A report produced too early with notification, such as one at T+44B, may result in the notice including more missing measurement data than necessary, leading to additional, non-necessary reconciliation efforts for market participants. SCE proposes sending the notice closer to the data submission deadline, preferably between T+47B and T+51B, to provide more accurate and relevant information of missing meter data. 

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

 SCE does not have any additional comments at this time.

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

 SCE does not have any additional comments at this time.

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

 SCE does not have any additional comments at this time.

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

 SCE does not have any additional comments at this time.

6. Please provide your organization’s comments on the future track topics and comments section

 SCE does not have any additional comments at this time.

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

 SCE does not have any additional comments at this time.

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above:

 SCE does not have any additional comments at this time.

1. Please provide a summary of your organization’s comments on the rules of conduct enhancements (ROCE) track 1 straw proposal:

Tacoma Power thanks CAISO for conducting this stakeholder initiative and generally supports CAISO’s proposal for Track 1 enhancements.  As a recent entrant into the WEIM, Tacoma Power has been challenged to adapt to the market’s requirement for submission of widespread and frequent meter readings of settlement quality. For us, this paradigm shift has also come with potential hazards. Under the existing penalty framework, large charges can accrue from an undetected meter configuration issue and be levied on an entity without consideration of motive or market consequence. Accordingly, we appreciate CAISO’s willingness to revise its approach to enforcing meter data quality.

2. Please provide your organization’s comments on the proposed meter data penalty enhancements, as described in the straw proposal:

Tacoma Power supports CAISO’s proposed meter data penalty enhancements. In particular, Tacoma Power appreciates CAISO establishing a penalty calculation for the submission of inaccurate meter data at 30% of the absolute value of the error.  We believe that this achieves a more proportionate and equitable result for meter data issues that are small and unintentional.        

3. Please provide your organization’s comments on the proposed elimination of the annual penalty distribution filing, as described in the straw proposal:

4. Please provide your organization’s comments on the proposed penalty distribution eligibility clarification, as described in the straw proposal:

5. Please provide your organization’s comments on the proposed market adjustment provision clarification in the context of WEIM Entities, as described in the straw proposal:

Tacoma Power supports CAISO’s proposed market adjustment provision clarification in the context of WEIM Entities. 

6. Please provide your organization’s comments on the future track topics and comments section

Tacoma Power supports continued work on this initiative as part of Track 2. 

7. Please provide your organization’s comments on the proposed WEIM classification for this initiative, as described in the straw proposal:

Tacoma Power supports the governance classification of Joint Authority for this initiative.

8. Please provide additional comments on the ROCE track 1 straw proposal not mentioned above: