Comments on Draft Final Proposal

Real-time settlement review

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Comment period
Oct 23, 09:30 am - Nov 11, 05:00 pm
Submitting organizations
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Arizona Public Service
Submitted on 11/10/2020, 07:03 am

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:
Support with caveats
2. Provide a summary of your organization’s comments on this proposal:

Arizona Public Service (APS) appreciates the opportunity to comment on the California Independent System Operator (CAISO) Real-Time Settlement Review Initiative draft final proposal. APS encourages CAISO to continue monitoring the settlement metrics, publicizing measuring results, and presenting settlement issues through stakeholder process. APS supports the proposal of financially settling BASE ETSR schedule deviations at SP-Tie prices to resolve settlement issues associated with asymmetrical wheeling through EIM BAA’s. In addition, APS believes CAISO’s proposal that allows EIM entities using a load derivation approach to choose whether to settle unaccounted for energy (UFE) is an enhancement. Finally, APS supports the proposed changes to align allocation of Bid Cost Recovery and agrees this allocation adjustment is more consistent with the cost causation principle and Bid Cost Recovery settlement.   

3. Provide detailed comments including examples on the real-time settlement metrics:

APS is pleased that CAISO is conducting metrics analysis to ensure proper settlement and will continue publicizing metrics to stakeholders in the Market Performance and Planning Forum. We recommend that CAISO will not only be presenting the high level visual graph on these metrics, but more importantly, provide the following details and additional guidance/training to stakeholders to help market participants provide meaningful review before CAISO implements any settlement changes.

  • Provide numerical examples to illustrate methodology of metrics and how they were used to inform the proposed changes in this initiative.
    • Provide specific example where the metrics identified an issue with market settlements.
  • Make the metrics available in settlement data format so stakeholders can review the metrics against actual data.

APS appreciates CAISO monitoring these metrics on a periodic basis and sharing the measurement results with stakeholders so market participants can work with CAISO to ensure settlement is properly reflecting market optimization.

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

APS supports the proposal of financially settling BASE ETSR schedule deviations at SP-Tie prices to resolve issues regarding asymmetrical settlement for wheeling through EIM BAA’s. APS suggests CAISO proactively engage stakeholders during the phase of implementation to ensure stakeholders will have sufficient time between now and April 1, 2021 to manage any related configuration/design modification that potentially require remapping price locations in their vendor systems.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

APS believes CAISO’s proposal allows EIM entities who are using a load derivation approach to choose whether to settle unaccounted for energy (UFE) will be a settlement enhancement. The numerical examples for UFE and related settlement impact demonstrated in the September 29, 2020 stakeholder call has provided tremendous help for EIM BAA to obtain further understanding of the proposed changes.

Based on our understanding, APS’ concern is that it is difficult to estimate the total dollar impact in the following areas for EIM entities:

1) Risk of increasing over/under scheduling (OUS) violation frequency and charges associated with the violations

2) Net changes between UIE, neutrality and allocation charge codes that subsequently are sub-allocated to transmission customers

3) Cost shifting on BCR and/or other allocation charges between load and ETSR export across the EIM entities

APS is appreciative that CAISO will provide a Market Simulation (SIM) environment to estimate the changes and compare the settlement result with and without UFE for EIM entities who are using a load derivation approach. APS does agree with Idaho Power Company’s comment on the October 28, 2020 stakeholder’s call regarding having a full settlement statement prepared for each entity without settling UFE on historical operating date(s) would be beneficial. Market SIM often presents challenges for entities to load all necessary data to get an accurate assessment. Therefore, having a full statement without UFE provided by the CAISO in Market SIM environment would be helpful to participants for comparison prior to making their final decision.

In addition, if CAISO can also provide guidance to stakeholders regarding the possibility and the process associated with changing their decision to settle UFE or not settle UFE after implementation and/or how frequently stakeholders will be able to make changes on the UFE options. The guidance will enable stakeholders to choose the most suitable settlement options for their own entity.  

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:

APS supports the proposed changes to align allocation of Bid Cost Recovery (BCR) and agrees with CAISO that this allocation adjustment is more consistent with Bid Cost Recovery settlement cost causation principles. APS would like to obtain clarifications from CAISO if this adjustment will be implemented on an ongoing forward basis or CAISO will conduct retroactive re-settlement for this change.  

Furthermore, according to the September 29, 2020 stakeholder call, CAISO indicated that not only BCR allocation will be impacted by UFE elimination but also Flex Ramp related allocation charge codes. APS appreciates CAISO providing clarifications regarding the proposed formula adjustments to the BCR uplift cost allocation would also be applied to Flex Ramp allocation and/or any Measured Demand & Metered Demand allocation calculation. APS also appreciates that any allocation formula that contain UFE quantity as part of denominator in the equation will be evaluated by CAISO to ensure allocation will be properly aligned with existing CAISO methodology and cost causation principles for EIM entities who choose not to settle UFE.    

7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:

None.

Bonneville Power Administration
Submitted on 11/10/2020, 04:36 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:
Support
2. Provide a summary of your organization’s comments on this proposal:

Bonneville Power Administration ("Bonneville") broadly supports the enhancements and changes that are being proposed as part of the real-time settlement review initiative.  Bonneville believes that the proposal, if implemented, will result in more appropriate settlements of imbalance energy and associated neutrality charges, while simultaneously improving the overall transparency of the market settlements.  Bonneville is similarly pleased that the option of not settling UFE has been retained and additionally that the proposed enhancements to bid cost recovery transfer settlements are included.

3. Provide detailed comments including examples on the real-time settlement metrics:

Bonneville continues to support the implementation of the real-time settlement metrics, consistent with earlier filed comments.

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

Bonneville supports these enhancements.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

Consistent with previous comments, Bonneville continues to strongly support the CAISO’s proposal to allow EIM entities to choose to not settle unaccounted for energy (UFE). Given the “load derivation” approach is the most common practice being used by EIM entities and that the settlement of UFE for those entities serves no practical purpose, the proposed enhancement will simplify settlements to the general benefit of Bonneville and its customers.

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:

Bonneville supports this change and believes that it more appropriately aligns with cost causation principles.

7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:

Idaho Power Company
Submitted on 11/11/2020, 02:22 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:
Support with caveats
2. Provide a summary of your organization’s comments on this proposal:

Idaho Power supports the draft final proposal related to Asymmetrical Wheeling Changes, UFE settlement, and Bid Cost Recovery changes.  While Idaho Power is generally supportive, we request CAISO consider enhancements around the ability to properly test the UFE settlement vs. non-settlement, and the ability to perform ongoing validation around the settlement metric data so that Settlement Subject Matter Experts (SMEs) are able to independently validate the data.

3. Provide detailed comments including examples on the real-time settlement metrics:

Idaho Power supports CAISO implementing these metrics and is appreciative that CAISO will publish these results for stakeholders as part of the quarterly Market Performance and Planning Forum (MPPF). While we are supportive of this change, we request that CAISO also provide the supporting data used to develop the metrics published in the MPPF report. This data should be provided to Settlement SMEs so that they have an opportunity to analyze the data independently and look for potential policy enhancements related to real time market settlements.

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

Idaho Power supports CAISO implementing the asymmetrical wheeling proposal as described.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

Idaho Power supports the option to not settle UFE; however, Idaho Power requests that CAISO provide additional information to enable entities to make a fully informed decision regarding whether to settle UFE.  Specifically, Idaho Power requests that, in market simulation or otherwise, CAISO provide entities historical production settlement statements with UFE not being settled so that they can compare against historical production settlement statements where UFE was settled.  This would allow entities to compare the impacts of the proposal using actual production data and make a more informed decision regarding whether to settle UFE. We would also request that CAISO use historical market statements where over/under scheduling charges were assessed to the entity.

In addition, Idaho Power requests that entities designate UFE settlement/non-settlement as part of the master file change process and that CAISO allow changes to this designation as needed. This will give EIM Entities the ability to go back to settling UFE if unintended consequences are identified through the option not to settle UFE.

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:

Idaho Power supports the proposed changes to Bid Cost Recovery Transfer Settlement. We agree that proper cost causation principals should be applied consistently across all settlement charges. We also ask CAISO to review any other charges where UFE is used to allocate costs to customers on the basis of measured or metered demand to ensure proper cost causation principals are being followed.

7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:

None.

Pacific Gas & Electric
Submitted on 11/10/2020, 04:56 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:
Support
  • Support
  • Support with caveats
  • Oppose
  • Oppose with caveats
  • No position
2. Provide a summary of your organization’s comments on this proposal:

PG&E supports the CAISO in this proposal and appreciates the CAISO’s intent to more closely monitor the Real-Time Market Processes use data-driven metrics.

3. Provide detailed comments including examples on the real-time settlement metrics:

PG&E appreciates and supports the development and maintenance of the Real-Time Settlement Metrics introduced in section 3 of this initiative.  We commend the CAISO for their efforts to use the ongoing market data to identify and address the root drivers of inappropriate Real-Time market uplift costs (Real Time Marginal Losses Offset, Real Time Congestion Offset, and Real Time Imbalance Energy Offset)

 

PG&E would also encourage the CAISO to expand their metrics beyond the proposed assessments to also examine other Real-Time market behaviors, including the actual financial and energetic impacts of unscheduled energy flows between BAA entities.

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

PG&E supports the proposed changes as we believe that the proposed modifications will allow for a more accurate settlement process.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

While PG&E believes that the energy settlement process should use verified revenue meters whenever possible, we understand that not all EIM entities currently have a complete set of load meters on their distribution system.  In such circumstances we feel that the alternate Unaccounted for Energy (UFE) calculation is an appropriate settlement mechanism for ensuring accurate cost allocation for regional unmetered load deviations. 

We would also like to thank the CAISO for the UFE Settlement example spreadsheet published in September as this provided considerable clarification in the specific mechanisms and impacts of this proposed change.

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:

In reviewing the CAISO’s reasoning for this adjustment PG&E agrees with the logic behind this change and supports the proposed adjustment.

7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:

N/A

PacifiCorp
Submitted on 11/10/2020, 01:49 pm

Contact

Christine Kirsten

Transmission Market Specialist

(916) 207-4693

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:
Support
2. Provide a summary of your organization’s comments on this proposal:

PacifiCorp appreciates the opportunity to comment and supports the CAISO’s proposals to resolve the identified issues related to asymmetrical wheeling settlement and unaccounted for energy settlements. PacifiCorp is also generally supportive of the CAISO’s proposal to adjust the bid cost recovery (“BCR”) uplift cost allocation.

3. Provide detailed comments including examples on the real-time settlement metrics:

No comments

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

PacifiCorp supports the CAISO’s proposal to resolve the asymmetrical wheeling settlement issue.  PacifiCorp understands that the wheeling settlement proposal will be implemented January 1, 2021, for all existing EIM entities, based on their voluntary commitment to have base energy transfer system resources (“ETSRs”) settled by the CAISO.  PacifiCorp further understands that the CAISO proposes to implement new tariff revisions in April 2021, to make settlement of base ETSRs mandatory, instead of voluntary, for all EIM entities.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

PacifiCorp supports the CAISO’s proposal to allow EIM entities using a load derivation approach to choose whether or not to receive unaccounted for energy (“UFE”) settlements from the CAISO. As stated in its previous comments, PacifiCorp again requests that the CAISO explore whether it can implement this proposal sooner than the fall 2021 target date, and in any event, as soon as possible. The UFE charges PacifiCorp receives every day are significant and PacifiCorp would very much appreciate a sooner implementation. 

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:

PacifiCorp is generally supportive of the bid cost recovery transfer settlement proposal and believes that using load and exports in the denominator, rather than using uninstructed imbalance energy and instructed imbalance energy, better aligns with existing CAISO methodology and cost causation principles of bid cost recovery cost allocation. Further, the CAISO expects that this proposal would be implemented in coordination with the UFE proposal in fall 2021. Accordingly, if this proposal must be coordinated with the proposed UFE implementation, PacifiCorp requests that the CAISO explore whether it can implement this proposal sooner than the fall 2021 target date, and in any event, as soon as possible.

7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:

No comments

Powerex Corp.
Submitted on 11/12/2020, 11:12 am

Contact

Mike Benn - mike.benn@powerex.com

1. Provide your organization’s overall position on the Real-Time Settlement Review draft final proposal:

Please see Powerex's comments available at https://powerex.com/sites/default/files/2020-11/2020-11-12%20-%20RT%20Settlement%20Review%20Final%20-%20Powerex%20Comments.pdf

2. Provide a summary of your organization’s comments on this proposal:

Please see Powerex's comments available at https://powerex.com/sites/default/files/2020-11/2020-11-12%20-%20RT%20Settlement%20Review%20Final%20-%20Powerex%20Comments.pdf

3. Provide detailed comments including examples on the real-time settlement metrics:

Please see Powerex's comments available at https://powerex.com/sites/default/files/2020-11/2020-11-12%20-%20RT%20Settlement%20Review%20Final%20-%20Powerex%20Comments.pdf

4. Provide detailed comments including examples on the asymmetrical wheeling settlement issue:

Please see Powerex's comments available at https://powerex.com/sites/default/files/2020-11/2020-11-12%20-%20RT%20Settlement%20Review%20Final%20-%20Powerex%20Comments.pdf

5. Provide detailed comments including examples on the unaccounted for energy settlement:

Please see Powerex's comments available at https://powerex.com/sites/default/files/2020-11/2020-11-12%20-%20RT%20Settlement%20Review%20Final%20-%20Powerex%20Comments.pdf

6. Provide detailed comments including examples on the bid cost recovery transfer settlement:
7. Additional comments on the draft final proposal or Real-Time Settlement Review initiative:
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