Comments on Draft Final Proposal

1. Provide a summary of your organization’s comments on the draft final proposal.

LADWP welcomes the opportunity to submit comments on the CAISO’s EIM sub-entity Scheduling Coordinator (SC) draft final proposal.  LADWP generally supports the proposal except for the comments outlined below.

Importantly, LADWP strongly agrees that “an entity can neither unilaterally decide to become an EIM sub-entity nor be compelled to become an EIM sub-entity”. Furthermore, any financial impact from creating an EIM sub-entity SC should be borne by the EIM sub-entity unless otherwise expressly agreed to by the EIM sub-entity and EIM Entity. 

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

LADWP recognizes the EIM Entity has overall reliability responsibility. That said, the EIM sub-entity should be Resource Sufficient to prevent leaning. As such, Resource Sufficiency evaluation should be performed for all entities: the EIM Entity and each EIM sub-entity.  This is to ensure there is no leaning: EIM sub-entity on EIM Entity or EIM Entity on EIM sub-entity. The EIM Entity and the EIM sub-entity must each be independently Resource Sufficient.

4. Provide your organization’s comments on the model submission proposal for this initiative.

The text states, CAISO maintains the full network model.  Operationally, the EIM Entity maintains the full network model for its control area.  LADWP appreciates the Entity having discretion over the ability of the EIM sub-entity submitting Network Model updates. That said, LADWP does not believe delegating the authority of model submission is good practice and will likely lead to coordination issues and potential reliability issues.

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

LADWP welcomes the ability to block ADS dispatch of EIM sub-entity resources. Further LADWP supports the fact that any financial impact should be borne by the EIM sub-entity unless otherwise expressly agreed to by the EIM sub-entity and EIM Entity. 

Manual Dispatch:  LADWP does not believe the EIM sub-entity should have access to BAAOP nor the ability to manually dispatch resources. The EIM sub-entity should act through the EIM Entity to input manual dispatches.  Otherwise, there is a lack of situational awareness at the EIM Entity level and the possibility of failing balancing tests depending on the timing of the manual dispatch.  Everything needs to be coordinated through the EIM Entity for reliability purposes.

6. Provide your organization’s comments on the forecasting proposal for this initiative.

Supply forecast:

LADWP supports the CAISO’s proposal that the EIM Entity will retain the ability to require an EIM sub-entity to use the CAISO provided forecast, or to allow the EIM sub-entity to use its own forecast. In retaining the ability to require the EIM sub-entity to use the CAISO forecast, LADWP would like clarification that if EIM sub-entity SC elects to use its own forecasting services for variable energy resources, and its own forecast proves to be inaccurate, the EIM Entity can require the EIM sub-entity switch back to the CAISO forecast.

 LADWP supports the CAISO’s proposal that the EIM Entity will determine if they will be responsible for the load forecast for their entire area.

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

The EIM Entity may not have a contractual basis to sub-allocate EIM costs from the EIM Entity to the EIM sub-entity.  For example, the text states that the BCR (bid cost recovery) charge is allocated by the EIM Entity for the EIM Entity to sub-allocate to the EIM sub-entity.  This presupposes a mechanism in place to sub-allocate those costs, which is not necessarily true. The EIM sub-entity may not take service from the EIM Entity pursuant to the EIM Entity’s OATT or there may be reasons why non-OATT transmission service agreements can not be amended to sub-allocate EIM costs.  To address these circumstances, CAISO must in all cases fully settle all EIM related charges (not just for resources) directly with the EIM sub-entity.  Alternatively, CAISO must not permit an EIM sub-entity to participate in the EIM without the demonstration of a contractual mechanism in place (either directly with CAISO or with the EIM Entity, or both, if necessary) to settle all EIM related charges.

8. Provide your organization’s comments on the system access proposal for this initiative.

LADWP believes the EIM Entity is responsible for reliability and only the EIM Entity should get access to BAAOP.

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

LADWP recognizes CAISO is not being prescriptive on intra BA transfers. However, in LADWP’s experience it’s critical to have good accounting of the market net scheduled interchange for the EIM sub-entities and be able to correlate that to the EIM sub-entity NSI.  Otherwise, it becomes an operational risk, and can cause area control error excursions that are extremely difficult to trace.  As such, some statement should be included in this proposal that requires proper NSI accounting even if it does not eloborate on all the details.

10. Provide your organization’s comments on the outage management proposal for this initiative.

As a BA, LADWP requires outages to be submitted directly to LADWP so there is a record in LADWP’s OMS application, as well as in CAISO‘s webOMS, and additionally to perform studies, etc...  Furthermore, webOMS is a back-up to LADWP’s OMS application, which is the primary user interface Operators use for outage information.

LADWP would ask CAISO to expand on how the webOMS outage would become available in LADWP’s OMS application if LADWP’s application did not initiate it and it was entered directly into webOMS; not all applications can pull webOMS outages and create an outage record. The EIM Entity is responsible for the reliability of the control area and must therefore control outage information.

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

The proposal fails to address the coordination with the EIM Entity. LADWP asks that CAISO include some form of coordination with the EIM Entity. Additionally, LADWP requests that no special arrangements or workarounds be allowed without EIM Entity sign-off such as dynamically scheduling from the EIM sub-entity

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

EIM Governing Body should have primary authority.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

The proposal does not address intra-BAA transfers between EIM sub-entity areas, and therefore fails to define the formulation of the load base schedule for each EIM sub-entity, leaving a critical gap in the settlement solution for the enhancement.  Lacking this defined load base schedule, LADWP is unable to evaluate implementation requirements and settlement design.  LADWP requests that CAISO define the load base schedule definition for EIM sub-entities prior to moving forward with the proposal.

1. Provide a summary of your organization’s comments on the draft final proposal.

PacifiCorp appreciates the opportunity to comment on the CAISO’s draft final proposal for the EIM Sub-Entity scheduling coordinator role. In general, PacifiCorp is supportive for the majority of CAISO’s proposals but concerned that other proposals do not consider the impacts on the reliability of the Balancing Authority Areas (BAAs) in the EIM.   

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

4. Provide your organization’s comments on the model submission proposal for this initiative.

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

PacifiCorp is concerned about the CAISO’s proposal to allow the EIM Sub-Entity to have the ability to manually dispatch. This proposal could impact the reliability of the Balancing Authority, because the EIM Sub-Entity does not have the responsibility to balance generation and load.  Additionally, all resource derates or outages should be communicated through the outage tool, which should negate any reason to use the manual dispatch tool. Furthermore, all manual dispatch requests should go through the EIM Entity rather than allowing the EIM Sub-Entity the ability to perform this function.  Therefore, PacifiCorp requests additional clarification about the necessity of this proposal.  If CAISO deems that this proposal is necessary, then PacifiCorp requests that this proposal become optional for each EIM Entity to determine whether this functionality would be appropriate.  

6. Provide your organization’s comments on the forecasting proposal for this initiative.

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

8. Provide your organization’s comments on the system access proposal for this initiative.

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

PacifiCorp understands that the energy transfers will only be modeled at the BAA level.  However, PacifiCorp does not understand how the CAISO intends to assess the over/under scheduling penalties at the Sub-Entity level when the intra-change is not modeled. PacifiCorp requests clarification about how CAISO intends to assess the over/under scheduling penalties during instances when the Sub-Entity is purchasing or selling energy outside the EIM Entity BAA and/or within.  

Specifically, would the Sub-Entity interchange and intra-change reservations be included in their Base Schedules for the over/under scheduling assessment?  Would the Sub-Entity submit a single hourly base schedule value that included all relevant E-Tags? 

10. Provide your organization’s comments on the outage management proposal for this initiative.

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

1. Provide a summary of your organization’s comments on the draft final proposal.

Platte River Power Authority (Platte River) appreciates the California Independent System Operator’s (CAISO) efforts to develop its?March 18, 2021,?Western EIM Sub-Entity Scheduling Coordinator (SESC) Role?Draft Final Proposal?(Proposal) and generally supports the concepts in the Proposal.?? 

Platte River’s comments to the Proposal relate solely to system access. Platte River seeks additional, narrowly-tailored SESC access to the Customer Market Results Interface (CMRI) and the Balancing Authority Area Operations Portal (BAAOP) or other mechanism to meet SESC operational needs. Platte River also suggests additional language that provides flexibility for system access needs identified during implementation but after the Proposal is finalized.   

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

Platte River has no comments on this section. 

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

Platte River has no comments on this section. 

4. Provide your organization’s comments on the model submission proposal for this initiative.

Platte River has no comments on this section. 

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

Platte River has no comments on this section. 

6. Provide your organization’s comments on the forecasting proposal for this initiative.

Platte River has no comments on this section. 

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

Platte River has no comments on this section. 

8. Provide your organization’s comments on the system access proposal for this initiative.

In addition to the SESC CMRI access listed in the Proposal, Platte River requests SESC access to load base schedules (sum of generation minus losses) and partial access to the EIM Entity Scheduling Coordinator menu, so each SESC can see its balancing test results, flex test results, and bid range test results.

Platte River also requests a new BAAOP interface or other mechanism for SESC marketing groups to access only their entity’s generation data, while ensuring compliance with FERC Standards of Conduct, reliability considerations, and fair market principles, to allow the SESC marketing groups, as opposed to the transmission groups, to manage and dispatch their own generation as they do today.

Platte River would recommend that the below language be added in the “System Access” section of the Proposal to account for the uncertainty in final SESC access needs as this new role is implemented.

“As the SESC role is new, implementation will likely uncover additional access needs that may not be captured in the final version of the EIM sub-entity proposal. CAISO, EIM Entity Scheduling Coordinators, and SESCs will work together to establish the access needed for the SESC role.”

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

Platte River has no comments on this section. 

10. Provide your organization’s comments on the outage management proposal for this initiative.

Platte River has no comments on this section. 

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

Platte River has no comments on this section. 

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

Platte River has no comments on this section. 

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Platte River has no comments on this section. 

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

Platte River has no comments on this section. 

1. Provide a summary of your organization’s comments on the draft final proposal.

Public Generating Pool (PGP) supports the draft final proposal and appreciates the responsiveness of CAISO in addressing our concerns and providing further clarity on a number of topic areas. PGP seeks clarification on one remaining aspect of the proposal that addresses allocating over/under scheduling charges in the instance where an EIM sub-entity scheduling coordinator (SESC) within a BAA elects to submit its own load forecast and EIM entity fails the balancing test.

This initiative is of interest to PGP and its members given that PGP has utility members that could be eligible for the sub-entity scheduling coordinator role when BPA joins the EIM as well as members that are EIM entities themselves. PGP believes the increased transparency that will result from allowing loads and resources within an EIM entity’s balancing authority area (BAA) to transact and settle with the CAISO has the opportunity to provide benefits to both future EIM SESC’s and EIM entities. 

PGP agrees with and supports CAISO’s determination that registration as an EIM sub-entity scheduling coordinator must be supported by the EIM entity and agreed to by the sub-entity; neither should be able to unilaterally decide or be compelled to be a sub-entity. This approach ensures that both parties have the optionality to determine whether the SESC role is acceptable. PGP appreciates and supports CAISO’s clarification regarding the eligibility criteria that ensures BPA’s Slice customers are eligible for the EIM sub-entity SC role. 

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

PGP supports the CAISO’s proposal and appreciates CAISO modifying the eligibility criteria language to ensure that entities that receive partial service from an EIM entity, but also own distribution or transmission facilities, and own or control one or more resources for serving its customers, such as BPA’s Slice customers, are eligible for the EIM sub-entity SC role. PGP also appreciates CAISO clarifying that it would allow certification of third-party scheduling coordinators for EIM SESCs and that these third parties would be authorized to fulfill this SESC role on behalf of eligible sub-entities should the sub-entities choose to use their services. 

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

No comments.

4. Provide your organization’s comments on the model submission proposal for this initiative.

No comments.

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

No comments.

6. Provide your organization’s comments on the forecasting proposal for this initiative.

In comments submitted on the revised proposal, PGP requested that CAISO provide clarity on language that states “if a sub entity submits its own load forecast, the entire BAA will automatically fail the balancing test, and the entire BAA will be subject to over/under scheduling charges.” PGP had concerns with this language because it does not seem reasonable for the entire BAA to automatically fail the balancing test if a sub-entity submits its own load forecast. In the draft final proposal CAISO clarified that if an EIM sub-entity within a BAA elects to submit its own load forecast, the entire BAA will automatically be subject to over/under scheduling charges.” While PGP appreciates this clarification, and supports removing the automatic failure provision, PGP questions why the over/under scheduling charges would not be allocated at the EIM entity level and then sub-allocated to the SESC according to the EIM entity’s OATT, as is the recommendation for allocating bid cost recovery charges and real-time offset charges. Perhaps this is the intent of the language, but further clarification would be helpful.

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

No comments.

8. Provide your organization’s comments on the system access proposal for this initiative.

No comments.

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

No comments.

10. Provide your organization’s comments on the outage management proposal for this initiative.

No comments.

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

No comments.

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

PGP agrees that the EIM Governing Body should have primary approval authority for this initiative.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments.

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

No comments.

1. Provide a summary of your organization’s comments on the draft final proposal.

SCE reaffirms its comments provided in response to the Revised Straw Proposal. Those comments can be viewed here. California ISO - All comments (caiso.com). Further, SCE is particularly interested in hearing the CAISO’s opinion on whether any changes are necessary in the determination of collateral arrangements for the EIM entity and sub-entity given that some market transactions will be settled at the balancing authority level with the EIM entity and, other transactions will settle at the entity or resource level.  Will each entity be financially responsible for the portion of any transaction submitted to the CAISO that will be settled at the EIM entity level or BAA level? For example, will the EIM entity be financially responsible for the intertie transfers associated with the sub-entity?

SCE supports the price formation representation provided within the draft final proposal.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

 SCE agrees that the resource sufficiency evaluation (RSE) should be applied uniformly at the BAA level to all EIM BAAs with the EIM entity having responsibility for ensuring that its BAA satisfies its RSE requirements for the capacity and flexible ramping tests. Given that the CAISO conducts the evaluation at the BAA-level currently, that practice should continue such that the EIM entity SC settles internally with the sub-entity SC when the BAA fails the RSE. Further, movement of the final base schedule submission deadline from T-55 to T-30 while introducing an additional RSE run and the provision of a curing period for any deficiencies, supports SCs in their effort to submit balanced base schedules to the CAISO and SCE supports this accommodation. 

4. Provide your organization’s comments on the model submission proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

6. Provide your organization’s comments on the forecasting proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

8. Provide your organization’s comments on the system access proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

10. Provide your organization’s comments on the outage management proposal for this initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

SCE supports the determination that the EIM Governing Body has primary decision-making authority for this initiative.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

SCE has no further comment on this aspect of the draft final proposal. SCE’s earlier comments on this matter may be viewed here. California ISO - All comments (caiso.com)

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

SCE acknowledges the representation within the draft final proposal for locational marginal pricing for each sub-entity at its load aggregation point. The approach facilitates the potential for price separation within the EIM BAA where the sub-entity is located when congestion arises at the location of the sub-entity. In contrast, absent congestion within the sub-entity’s location, the entire BAA should have a uniform locational marginal price in the relevant market when that market clearing occurs and no other sub-entity exists or experiences congestion within that BAA.  

1. Provide a summary of your organization’s comments on the draft final proposal.

Tri-State Generation and Transmission Association, Inc. (Tri-State) appreciates the opportunity to submit comments on the California Independent System Operator’s (CAISO) Western Energy Imbalance Market (EIM) Sub-Entity Scheduling Coordinator (SESC) proposal.

Tri-State supports and has previously advocated for the concept of a more accurate, verifiable, and transparent settlement process for non-participating loads and resources of entities residing within an EIM entity.  Tri-State would also encourage finding ways to improve these processes for all entities, not just those that qualify, choose, and/or are allowed by their host EIM entity to become an EIM sub-entity. 

For its system within the PSCo BA, Tri-State has not yet determined whether it will choose to pursue the proposed Sub-Entity Scheduling Coordinator path or the Participating Resource Scheduling Coordinator path as it has done within the PNM BA.  The arrangements among the utilities within the PSCo BA are somewhat complex, and it’s not yet clear to Tri-State how these arrangements may impact the roles of the EIM entity and/or EIM sub-entity(s).  Tri-State, for instance, is: a transmission provider with NITSA customers within the PSCo BA, a NITSA customer of PSCo for some of its loads and resources within the BA, a BA only customer of PSCO for some of its loads and resources within the BA, and a NITSA customer of at least one potential future EIM sub-entity within the PSCo BA.  Where/how would non-participating loads and resources of a NITSA customer of an EIM sub-entity reside and be accounted for – with that EIM sub-entity, or the EIM entity?  Would it matter or would the answer differ if the NITSA customer were also an EIM sub-entity?  The answers to these details would certainly impact Tri-State’s decision process.  These issues would also impact how an EIM entity or EIM sub-entity would appropriately recover their costs associated with the WEIM in their OATT. 

Tri-State also has a question regarding the requirements of an EIM sub-entity.  In the draft proposal on page 6 is the statement “This in turn means that they are more likely to have a well-defined service territory bounded by distribution-transmission interfaces, which will allow for more accurate forecasting, modeling, scheduling, and accounting for their associated loads and non-participating resources in the EIM”.  Is a “well defined service territory bounded by distribution-transmission interfaces” a requirement to be a sub-entity – and if so, how is it defined? Tri-State believes caution should be exercised to ensure that there is no discrimination across customers on the basis of allowing participation as an EIM sub-entity. 

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

No additional comments to those above at this time.

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

No comments at this time.

4. Provide your organization’s comments on the model submission proposal for this initiative.

No comments at this time.

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

No comments at this time.

6. Provide your organization’s comments on the forecasting proposal for this initiative.

No comments at this time.

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

No additional comments to those above at this time.

8. Provide your organization’s comments on the system access proposal for this initiative.

No comments at this time.

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

No comments at this time.

10. Provide your organization’s comments on the outage management proposal for this initiative.

No comments at this time.

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

No comments at this time.

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

No comments at this time.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments at this time.

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

We feel additional details may be needed as noted above.

1. Provide a summary of your organization’s comments on the draft final proposal.

Xcel Energy thanks the California ISO and all EIM stakeholders for participating in this straw proposal process. Creation of the sub-entity scheduling coordinator role is key to Public Service Company of Colorado’s (PSCo) implementation of the EIM in Colorado.  Stakeholders from within the PSCo area and across the west have brought forth unique perspectives and provided thoughtful feedback which have been useful and helpful. Xcel Energy generally supports the language in the California ISO’s proposal to create the role of a sub-entity scheduling coordinator. 

Through discussions taking place after this final draft proposal was presented, it was identified that there may be a gap in the definition of the SESC role and definition of the SESC load aggregation point (LAP). Primarily, what happens when an SESC has someone else’s load within their sub-area? Several re-reads of the proposed roles and responsibilities of the SESC have not revealed what the preferred or required method of handling non-SESC loads within an SESC area might be.

Understanding it is late in the game to make major changes, Xcel Energy respectfully submits a request for clarification with regards to this question, which is detailed further in response to question 2. With that only exception, Xcel Energy supports all remaining proposed concepts and definitions.

2. Provide your organization’s comments on the proposed roles and responsibilities of the EIM sub-entity scheduling coordinator.

 Xcel Energy requests additional clarifying language defining the responsibilities of sub-entity scheduling coordinators to represent and/or settle loads within the SESC-area that are not served by the SESC as the load serving entity (LSE). Through the implementation process, Xcel Energy realized that in Colorado’s diverse LSE environment, there are entities which serve load in more than one proposed LAP area (illustrated in: Attachment_1_ XE_SESC_Loads-CAISO_Sub_Entity_Straw_Proposal_Final_Draft.pptx). These loads may or may not be included in the SESC load forecast, and load imbalance may be contractually served by the SESC, or by another entity. It seems unclear in the proposed language if those non-participating loads foreign to the SESC are settled by the SESC at the SESC LAP or by the EIM Entity at the EIM SC LAP, or something else. This scenario may be further complicated if an SESC has load in another SESC area, raising the question: within which area (LAP) does the load reside?

One solution may be to require the host area SESC to collect and aggregate loads in a manner which represents the historical, real time, forecast, and meter values for loads within its SESC LAP. Another solution may be to allow non-contiguous LAP design, which would enable an SESC to provide load information regardless in which other SESC area the load resides.

Xcel Energy acknowledges that in this late stage, this comment may cause some concern and we hope this observation is received as well intended and able to be resolved quickly.

3. Provide your organization’s comments on the resource sufficiency evaluation proposal for this initiative.

Xcel Energy supports the CAISO’s proposal for resource sufficiency evaluation. 

4. Provide your organization’s comments on the model submission proposal for this initiative.

 Xcel Energy supports the CAISO’s proposal for network model submission.

5. Provide your organization’s comments on the dispatch options proposal for this initiative.

Xcel Energy supports the CAISO’s proposal for generation dispatch.  

6. Provide your organization’s comments on the forecasting proposal for this initiative.

Supply Forecast

Xcel Energy generally agrees with the CAISO’s proposed design. It is important that the EIM Entity has a complete set of base schedules. It follows then, that the EIM Entity should require all VER resource SCs to either procure and provide a self-supplied VER forecast or be required to use the CAISO provided forecast. However, the language of the proposal seems to preclude the EIM Entity from viewing individual resource forecasts submitted by each SESC, instead providing only a ‘summed format’ of the SESC VER forecasts.  Given the EESC’s role as a reliability function organization with default authority over the network model and some transmission functions like outage management, it is unclear why the EESC would not receive individual resource forecasts as well as summed resource forecasts. Xcel Energy proposes the following change in language:

“To ensure that the EIM entity is still able to perform its balancing function and pass the RSE, the CAISO proposes to provide the ability for the EIM entity to view, in both a summed format and per-resource format, the forecast of all of the variable energy resources within its balancing authority area.”

Load Forecast

Xcel Energy supports the CAISO’s proposal providing the EIM Entity with ultimate authority to allow or disallow a sub-entity to provide their own load forecast.

7. Provide your organization’s comments on the meter data, settlements and invoicing proposal for this initiative.

Xcel Energy supports the CAISO’s proposal for meter data, settlements, and invoicing. Xcel Energy also recognizes and concurs with Platte River Power Authority’s previous comments that market sensitive information received by the EESC through these processes be treated with strict adherence to FERC Standards of Conduct.

8. Provide your organization’s comments on the system access proposal for this initiative.

Xcel Energy supports the CAISO’s proposal for system access. 

9. Provide your organization’s comments on the energy transfers proposal for this initiative.

Xcel Energy supports the CAISO’s proposal for energy transfer management.

10. Provide your organization’s comments on the outage management proposal for this initiative.

Xcel Energy supports the CAISO’s proposal. The purpose of the SESC role is to preserve autonomy and control for qualified sub-entities’ resources and assets. It seems to naturally follow that the EIM Entity may desire to delegate to sub-entities’ responsibility and authority to submit generation and transmission outages. As transmission and generation operators, a sub-entity has intimate knowledge of their own asset performance and availability- a purview which the EIM Entity may lack.

11. Provide your organization’s comments on the EIM sub-entity onboarding proposal for this initiative.

Please include comments on the tracks proposed as part the implementation process.

Xcel Energy supports the CAISO’s proposal and descriptions of the SESC onboarding process, which seem to reflect the necessary steps and coordination to onboard a new SESC within an EIM Entity area.

12. Provide your organization’s comments on the proposed EIM Governing Body classification to have primary approval authority for this initiative.

 Xcel Energy supports the CAISO’s proposal classifying the EIM Governing Body as primary approval authority.

13. Provide any additional comments on the draft final proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No additional Comments

14. Provide your organization’s comments on the proposals discussion of price formation within a sub-entity.

Xcel Energy generally supports the propsed method of price formation within a sub-entity, however Xcel Energy's comments in response to question 2 may have implications on price formation.