1.
Please provide a summary of your organization’s comments on the EDAM ISO BAA Participation Rules track A1 draft tariff language:
SCE has reviewed the tariff language for the three sections 11, 26, and 27 relating to the specifics of how EDAM applies to the ISO and its individual Participating TOs, particularly relating to allocations of EDAM amounts of revenue or costs to individual PTOs or ETC/TOR entities. SCE believes the tariff language reflects the Track A1 Final Proposal and has identified only one instance where SCE proposes a tariff language change, relating to the internal allocation of CAISO-wide Excess Wheel-Through Recoverable Revenue (see item 3 below).
3.
Provide any redline changes and embedded comments on Section 26 – Transmission Rates and Charges and all related subsections as an attachment to this comment template, and provide any additional comments on section 26 in the text box below:
When providing additional comments in the text box below, please specify the subsection(s) your comments refer to.
Excess Wheel-Through Recoverable Revenue is a collective ISO BAA calculation by definition, since there is a single determination of CAISO imports and exports, considering all ISO BAA Scheduling Points, and which are netted against each other. SCE does not see how that can be divided up to each PTO directly based on a PTO specific calculation, as the following tariff language states:
26.2.1.3 Excess Wheel-Through Recoverable Revenue
The individual excess wheel-through recoverable revenue is an annual calculation of the twelve (12) monthly aggregations from the prior year, with each month calculated as the product of (a) the excess wheel through quantity computed as the total export transfer quantity in MWh from the CAISO Balancing Authority Area less the total import transfer quantity in MWh into the CAISO Balancing Authority Area, bounded from below by zero, and (b) the applicable regional or local wheeling access rate of the applicable transmission owner for the transfer location in effect at the time of the annual calculation.
SCE proposes that this component of the Recoverable Revenue should be allocated to PTOs on the basis of Gross Load. If the CAISO intends to directly determine an Excess Wheel-Through Recoverable Revenue for each PTO directly, the calculation description should be more clearly stated. For example, it is unclear how the transfer locations to be used in the calculation are to be determined. Is there only one for each PTO, and if so, which one?
