Comments on Issue Paper/Straw Proposal

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

APS welcomes the opportunity to comment on the Western EIM base schedule submission deadline initiative and is supportive of looking at the best timing of base schedules submission to produce the best market results in terms of reliability and price outcomes. APS believes that these priorities can be better met with the changes proposed in adjusting the final submission deadline for base schedules and the added ability to include start-up energy in EIM Entities base schedule submissions.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

APS is supportive of and believes it is operationally feasible to adjust the final base schedule submission deadline from T-40 to T-30. While supportive of the final submission deadline adjustment, APS would like CAISO to consider the adjustment of the T-75 and T-55 submission deadlines. APS at times struggles to account for load and interchange schedule changes at these submission windows. It is our experience and understanding that load can change five minutes before these earlier submission windows, and that interchange can change two minutes before. Depending on the volume of changes and the latency of software systems the corresponding adjustments required to generation base schedules may be late or is prone to errors due to time pressure. For these reasons we would like to request the change of T-75 submissions to T-70, and the change of T-55 submissions to T-50. This would allow 20 minutes between all submission times (T-70, T-50, T-30) and allow for more accurate submissions across the full submission windows. APS recognizes that a change to T-70 may not be feasible because of the HASP process and inter-tie bid submission deadline of T-75, but unsure if there is interdependencies between the T-75 submission and these market processes. Also, it may be helpful to stakeholders to add more detail to the timeline in Figure 1 to include load changes, and base ETSR changes to illustrate the timing of these inputs into the submission window.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

APS supports the ability to include start-up energy below Pmin in the base schedule submission for credit in balancing tests. APS believes though that this energy should be accounted for in the flex ramp capacity test much the same way energy from non-participating resource energy is accounted for. In reading the straw proposal it is our understanding that the resources which have start-up energy scheduled on them will not receive DOT’s and in turn would not have a T-7.5 initial point or schedule for the test intervals of the flex ramp test. It is our opinion that the best market solution for reliability would be to send DOT’s, maintain flex capacity for the expected start-up energy and movement between one hour to the next. A scenario could occur across the EIM footprint in a spring day with many units starting up for the evening ramp where this downward capacity is needed on the system and would be better accounted for how non-participating resource energy is in the market solution today. 

APS would like to highlight and better understand the after the fact monitoring rules around scheduling of startup energy. There are understandable scenarios in which a resource could have startup energy non-monotonically increasing, a base schedule could go to 0 after base schedule below Pmin, and base schedules below Pmin for longer timeframe than expected. A unit failed start or run back is a common event for thermal generators that could result in a base schedule going to 0 after a base schedule below Pmin or result in non-monotonically increasing schedules. CAISO may consider reviewing OMS outages placed on the resource during the timeframe to help determine causes. Also, CAISO should consider utilizing the GRDT field for start-up time for resources production levels below Pmin to allow for scheduling coordinators to communicate what is a reasonable amount of time for a unit to produce energy below Pmin in start-up. It may also consider a predefined start-up energy profile in scenarios where a unit may not start-up with monotonically increasing values due to auxiliary loads ramping up or other considerations.

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

APS agrees that the current scope of the initiative would constitute primary approval authority of the EIM Governing Body. But recognizes that extending the scope in subsequent proposals could change the initiative to hybrid. One such consideration would be the impact of the new FMM start time of T-29 in place of the current T-37.5. CAISO is implementing the inter-tie deviation settlement on 1/1/21 which outlines e-tag practices for participation on the inter-ties with CAISO’s market. It may be appropriate to modify the rules of that initiative to allow a later submission of an e-tag to be picked up by the FMM with the new runtime. If this change or other changes are added to the scope it could change the classification to a hybrid authority classification.    

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

APS would like to request the expected implementation date for this initiative in the next proposal to allow for appropriate system changes and change management to be planned out.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

The Bonneville Power Administration (Bonneville) appreciates the opportunity to comment on the California Independent System Operator’s (CAISO) issue paper/straw proposal.  Bonneville is particularly pleased that the CAISO is following through on its contractual commitment memorialized in the Bonneville-CAISO Implementation Agreement to propose changing the T-40 base schedule submission deadline to T-30. 

Bonneville is a federal power marketing administration within the U.S. Department of Energy that markets electric power from 31 federal hydroelectric projects and some non-federal projects in the Pacific Northwest with a nameplate capacity of 22,500 megawatts. Bonneville currently supplies 30% of the power consumed in the Northwest. Bonneville also operates 15,000 miles of high voltage transmission that interconnects most of the other transmission systems in the Northwest with Canada and California. Bonneville is obligated by statute to serve Northwest municipalities, public utility districts, cooperatives and other regional entities prior to selling power out of the region.

Bonneville strongly supports both of the changes set forth in the issue paper/straw proposal.  Moving the T-40 base schedule submission deadline to T-30 will allow Energy Imbalance Market (EIM) Entities to submit more accurate base schedules which will have a positive impact on market operations and reduce imbalance.  Likewise, allowing entities to submit base schedules below a resource’s minimum load will allow more accurate base schedules which, in turn, will have a positive impact on the market through reducing imbalance.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

Bonneville supports the proposal to change the T-40 base schedule submission deadline for EIM Entities to T-30.  This change should allow EIM Entities to submit more accurate base schedules which Bonneville expects to benefit the overall market and the EIM Entity through more effective market dispatches resulting in less imbalance. 

Bonneville also believes (see comments) that the CAISO should consider moving the other market timeframes closer to the operating hour across the market footprint. For example, moving the T-55 base schedule submission deadline for market participants forward to T-45 would be particularly advantageous as resources and loads within EIM Entities’ Balancing Authority Areas will be able to submit more accurate schedules closer to the operating hour.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

Bonneville supports the proposal to include a resource’s startup energy in its hourly resource plan.  This change will result in more accurate base schedules which will benefit overall market dispatch and operation, as well as reduce imbalance in the market.  In addition, accurately capturing the startup energy of larger resources should help their ability to pass the resource sufficiency evaluation by providing more accurate information for its balancing test.

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

Bonneville supports the EIM Governing Body having primary approval authority for this initiative.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

As articulated in its response to number 2 above, Bonneville believes that the CAISO should also consider moving the other market timelines closer to the operating hour.  Doing so will allow the submission of more accurate base schedules that further benefit the overall market beyond just moving the T-40 deadline to T-30. 

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

 Idaho Power tentatively supports the proposal, with caveats and questions. 

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

Idaho Power tentatively supports the proposal, with caveats and questions. 

Idaho Power asks that CAISO provide a more detailed explanation of the benefits of the proposal.  Absent changes to other timelines, the benefits appear minimal.  We would appreciate additional detail on what CAISO views as the benefits. 

Idaho Power also questions whether CAISO has considered moving the T-55 time for changes to base schedules and the T-55 Resource Sufficiency tests later in light of the move to T-30 for final changes.  As CAISO’s proposal stands, with only the T-40 deadline moving, the proposal does not appear to benefit most EIM entities’ transmission customers that are wheeling or importing/exporting from the area using e-tags.  These customers will still be required to submit their final e-tags for inclusion in base schedules to the EIM Entity (per the EIM Entity’s tariff) by T-57, and will still be subject to imbalance charges for deviations from that schedule.  This change appears to only benefit customers whose transactions are entirely within a single EIM Entity’s BAA. 

On the other hand, moving the T-55 deadline as well would allow EIM entities to correspondingly change their tariffs to shift the T-57 transmission customer base schedule submission deadline, thereby allowing all customers more time to finalize schedules and minimize imbalance charges.

If CAISO at some point proposes to move the T-55 deadline (or other deadlines) as well, then it must allow sufficient time in the initiative schedule for EIM entities to reach agreement on the appropriate deadline for final transmission customer base schedule submissions, and for the necessary tariff changes and FERC filings to be made, as well as vendor systems changes. Idaho Power is not advocating for this change at this time as more analysis of the impact would need to be done.

Idaho Power also asks that CAISO retain the T-40 Resource Sufficiency test as an advisory result, similar to the T-55 test.  This additional information would be very helpful to EIM entity scheduling coordinators as they prepare for the T-30 deadline and final test.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

No comments.

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

Idaho Power supports this proposal falling under the EIM Governing Body’s primary approval authority.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

No comments.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

PG&E understands the intent of this initiative is to provide EIM scheduling coordinators with additional flexibility to submit more accurate base schedules closer to the operating hour and base schedules that reflect start-up energy. Specifically, CAISO is proposing two changes:

1. To delay the deadline for submitting a base schedule by ten minutes to “T-30” from today’s deadline of “T-40”.  It is suggested that the proposed change should allow for more accurate base schedules and therefore an increase in market efficiency associated with changing forecasts of load, renewables, and contractual obligations that might only realize close to real-time. This proposed change would be possible by truncating the time available to solve the market optimization for Interval 1 of the Real-Time Pre-Dispatch market run. This truncation in run-time could come at the cost of additional instances where the optimization does not yield a feasible result for the RTPD interval 1 and results in suboptimal results.

PG&E respectfully requests that CAISO to consider the following two comments:

1. CAISO should provide a discussion of the potential costs and benefits of associated with this change.
   • who is benefiting from this change and the order of magnitude of any benefits?
   • summary of the feasibility tests and their results that CAISO has already run.
   • a detailed explanation of the negative market impacts of the RTPD interval 1 not solving in time and the potential impact of a loss of run-time on future market design enhancements
2. CAISO should be able to spot issues and revert to the “T-40” timeline if issues arise.

2. To allow EIM base schedules to reflect Start-Up energy.  This proposed change would require a change to the formula for allocation of bid-cost recovery payments with the goal of ensuring equity among those that are full CAISO members and those that are EIM entities. This change would reduce EIM participants uninstructed energy (UIE) which currently captures the start-up energy.  It is PG&E’s understanding, that for some EIM entities, the start-up energy is a non-trivial portion of load and making this change would directly benefit those participants.

PG&E does not have any substantive comments on the proposal to reflect start-up energy in EIM base schedules.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

Changing the submission deadline from “T-40” to “T-30” would give the market optimization ten fewer minutes to solve the RTPD interval 1. PG&E is primarily concerned with truncating the run-time for RTPD interval 1.  While this change potentially provides benefits to some of the market participants or to the market as a whole, it also comes with a potential cost.  With this inherent trade-off in mind, PG&E would like to express the following comments: 

1. PG&E would like to see a more detailed explanation of the benefits.  PG&E is unclear on what types of benefits will result from delaying the base schedule submission deadline by ten minutes and to whom those benefits accrue.  Could the CAISO or the EIM participants provide any estimate of the benefits to participants or to the market?

2. PG&E would like to see more detail on the feasibility tests and test results for truncating RTPD interval 1.  PG&E understands that CAISO has performed feasibility tests and we’d like to understand these tests and their results in more detail. PG&E believes this will help inform the decision by providing perspective on the potential costs associated with truncating the run-time for RTPD interval 1.

PG&E did a quick analysis to assess the current rate at which RTPD interval 1 doesn’t solve within its allotted time. It is our understanding that when an RTPD interval does not solve, the model reverts to a DC-OPF model and yields LMP data all losses at a value of $0. Based CAISO OASIS data, the losses component of the PG&E DLAP LMP has a zero value approximately 10% of the time (see Table 1 below). This is the current failure rate.

Table 1. Estimate of the rate at which the market optimization does not solve during its allotted time for RTPD Interval 1. The rate is calculated as the percentage of RTPD Interval 1’s that have a marginal losses component of LMP equal to zero.

3. CAISO should explain the negative market impacts associated with RTPD not solving in time

PG&E is concerned that further limiting the run-time for RTPD interval 1 will significantly increase the frequency of non-convergence, potentially to the point where RTPD interval 1 is mostly or solely relying on DC-OPF.  PG&E believes further discussions are warranted on the consequences of solving RTPD interval 1 mostly, or solely, using DC-OPF.  CAISO should detail the effects that relying on DC-OPF might cause to market dispatch, market efficiency, and settlements. CAISO should also discuss the potential impact of a loss of run-time on future market design enhancements.

4. CASIO should be able to spot issues and revert to the “T-40” timeline. 

It is often said that one cannot manage what one does not measure.  PG&E would like to suggest that CAISO monitor key metrics associated with this change (e.g., frequency off non-convergence of RTDP interval 1, or other metric optimization performance for RTDP interval 1).   This could provide CAISO with advanced warning if this truncated run-time is causing market issues and allow CAISO to intervene.

One key intervention is the option to revert to the old timeline.  CAISO has, at times, needed to revert to old methods. PG&E is suggesting that CAISO ensure that it can revert to the older “T-40” deadline by making sure that any changes (software, tariffs, business practice manuals, …, etc.) reflect this ability to revert to the “T-40” timeline. 

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

PG&E does not have any substantive comments on to provide on this question

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

PG&E does not have any substantive comments on to provide on this question.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

PG&E does not have any additional comments on to provide on this question.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

PacifiCorp submits the following comments to the California Independent System Operator Corporation (“CAISO”) on the Western EIM Base Schedule Submission Deadline issue paper and straw proposal published September 24, 2020, (“Straw Proposal”). PacifiCorp generally supports the proposal and appreciates the opportunity to provide the following comments for the CAISO’s consideration. 

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

Currently, the resource sufficiency evaluation (“RSE”) requirements are updated and change between the T-55 and T-40 RSE with no opportunity for EIM entities to change schedules after the final T-40 RSE requirements are published. This process leaves EIM entities with no opportunity to mitigate for failures due to the T-40 RSE requirement changes. In its Straw Proposal, the CAISO proposes that, “The final base schedule test will also be moved to after the T-30 deadline.” PacifiCorp requests clarification regarding whether this proposal applies to all four RSE tests or only the balancing test.

In addition, because the final RSE is proposed to move from T-40 to T-30 with no change to how the RSE requirements will be updated from T-55 (i.e., the RSE requirements may change), PacifiCorp believes it would be appropriate and beneficial to maintain the T-40 RSE and publish advisory results to allow EIM entities the ability to review and make schedule changes to meet the RSE requirements as determined at T-40.

PacifiCorp also supports the addition of a proposal to modify the deviation histogram to align with the proposed T-30 financially binding deadline (“T-30 Financially Binding Deadline”), wherein the histogram would use the deviation between the T-30 Financially Binding Deadline and the T-20 tagging deadline instead of the deviation between the currently effective T-40 financially binding deadline (“T-40 Financially Binding Deadline”) and the T-20 tagging deadline.

PacifiCorp notes that transmission customers of an EIM entity are not allowed to make base schedule changes past T-57, which are due to the CAISO by T-55 (“T-55 Base Schedule Submission Deadline”). Except for schedule changes made by the EIM entity by the currently effective T-40 Financially Binding Deadline, any deviation from those base schedules after the T-55 Base Schedule Submission Deadline are subject to imbalance settlements. PacifiCorp recommends that the CAISO consider moving the T-55 Base Schedule Submission Deadline pursuant to CAISO tariff section 29.34(f)(1)(B) to T-50. The benefits discussed in the CAISO’s Straw Proposal associated with more accurate scheduling of generation would also apply to transmission customers that are currently required to submit schedules by the T-55 Base Schedule Submission Deadline and would result in lower imbalance settlements for the transmission customer. Specifically, PacifiCorp believes it would be beneficial to allow transmission customers to submit initial generation base schedules (schedules that do not affect interchange) at T-75, as is done today, and submit changes to those base schedules up to a proposed T-50 base schedule submission deadline, instead of the T-55 Base Schedule Submission Deadline.

In addition, PacifiCorp believes there is similar, if not more, value in also moving the interchange schedule submission deadline, currently required at T-55 (“T-55 Interchange Schedule Submission Deadline”), to a proposed T-50 interchange schedule submission deadline, including updates to the variable energy resource and load forecasts. PacifiCorp understands that changing the T-55 Interchange Schedule Submission Deadline is a significant undertaking and would require testing and collaboration among EIM entities and the CAISO. Therefore, PacifiCorp suggests that the CAISO consider a “phase 2” to this initiative to implement these interchange schedule submission deadline changes at a later time.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

In the Straw Proposal, the CAISO states that, “the submission of more accurate base schedules will minimize uninstructed imbalance energy settlement as the startup energy will be reflected in a base schedule.”  PacifiCorp seeks clarification and further explanation regarding how uninstructed imbalance energy settlements will be minimized. Will the startup energy base schedules receive a dispatch operating target (“DOT”) similar to the DOT received on base schedules without an energy bid? If so, would there be any notable change to the relationship between the external DOT and the internal DOT during the intervals in which startup energy is base scheduled? If not, how will the EIM dispatch a resource during the intervals in which startup energy is base scheduled?

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

PacifiCorp supports the CAISO’s proposal to classify this entire initiative to be presented to the EIM Governing Body for decision using its primary approval authority.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

No comments. 

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

Please see Powerex's comments at https://powerex.com/sites/default/files/2020-10/2020-10-14%20EIM%20Base%20Schedule%20Comments.pdf

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

Please see Powerex's comments at https://powerex.com/sites/default/files/2020-10/2020-10-14%20EIM%20Base%20Schedule%20Comments.pdf

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

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

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

PGP appreciates CAISO’s efforts on continuous improvements in market functionality and supports moving forward with both portions of this initiative. 

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

PGP agrees that moving the timing of EIM base schedule submissions closer to the hour will reduce the risk of uninstructed imbalance that could result from late schedule changes that may occur due to bilateral trading, contractual arrangements, or load changes.  It is also possible that moving the T-40 base schedule deadline may result in additional benefits.  For example, the intertie schedule deviation histogram should capture the improved accuracy resulting from this proposal.  PGP would like CAISO to verify that existing processes that benefit from this proposal have been modified to capture this improved accuracy.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

PGP supports the inclusion of a resource’s startup energy in hourly resource plans and agrees that this change will result in more accurate base schedules and reduced uninstructed imbalance.   PGP agrees that inclusion of startup energy only in the RSE balancing test is appropriate.  However, since resources that are ramping up do not always behave as expected, this should be monitored closely to ensure that this test performing as intended. 

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

PGP supports the EIM Governing Body having primary approval authority on this initiative. 

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

If this initiative is successful, PGP encourages CAISO to investigate the possibility of moving the T-75 and T-55 market submission deadlines closer to the operating hour.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

PPC appreciates the opportunity to provide feedback on CAISO’s Western EIM Base Schedule Submission Deadline proposal. PPC represents the interests of nearly 100 public and consumer owned utilities in the Northwest. PPC’s members are interested in the potential development of this policy from several perspectives: as purchasers of preference power and transmission services from BPA (which is planning to join the EIM in 2022), as load serving entities in the current and/or future EIM footprint, and as current, planned and potential EIM participants themselves. 

PPC supports the changes put forth in the straw proposal.  In particular, PPC appreciates CAISO’s pursuit of “moving the market closing timeline for financially binding hourly resource plans from T-40 to T-30” consistent with its commitment in BPA’s Implementation Agreement.^[1]

[1] CAISO and BPA Energy Imbalance Market Implementation Agreement, pg. 15.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

PPC supports the proposal to change the final financially binding base schedule from T-40 to T-30.  As noted in the proposal, this change will allow BPA to update base schedules through T-30 for its Slice customers consistent with the flexibility allowed in their current contracts.  It will also create benefits for other EIM participants through allowing for more accurate scheduling and reduced uninstructed imbalance.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

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

PPC supports the EIM Governing Body having primary authority on this initiative.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

In the Implementation Agreement with BPA, CAISO also committed to “explore with Bonneville and other stakeholders other potential enhancements to the EIM fifteen minute market timelines.”[1]  PPC asks that CAISO consider expanding the scope of this initiative to include other potential timeline improvements and looks forward to exploring such enhancements with CAISO and other stakeholders.

[1] CAISO and BPA Energy Imbalance Market Implementation Agreement, pg. 15.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

SMUD appreciates the opportunity to provide comments and input on the CAISO’s Western EIM Base Schedule Submission Deadline Issue Paper/Straw Proposal, dated September 24, 2020 (Proposal).  SMUD is an active market participant in the Western EIM through the Balancing Authority of Northern California (BANC) Balancing Authority (BA). Accordingly, we have a direct interest in this initiative.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

SMUD supports the proposal to change the T-40 deadline to T-30.  The T-30 proposal allows an opportunity to submit more accurate schedules and provides greater operational flexibility.  The current T-40 deadline causes less accurate base schedules and greater deviations in the operating hour.  The additional 10 minutes to submit a base schedule will allow a greater range of resources to participate in the market, allow the EIM to operate more efficiently, and reduces imbalance charges.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

SMUD supports the proposal to allow inclusion of start-up energy as part of the hourly resource plans.  SMUD has resources with long-lead start-up timeframes.  This will reduce the volume of energy injected into the market without base schedules and lower the operational burden to perform load conformance during the start-up of long lead time resources.

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

SMUD considers this initiative within the primary approval authority of the EIM Governing Body.

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

Salt River Project Agricultural Improvement and Power District (SRP) requests clarification and additional time to analyze effects of moving the market closing timeline for financially binding base schedules from 40 minutes before the operating hour (T-40) to 30 minutes before the operating hour (T-30).

SRP generally supports allowing startup energy to be accounted for in the base schedule for all resources, independent of any adjustment of financially binding base schedule timelines (T-40 or T-30). We believe there is a need to further revise or clarify the Base Schedule Aggregation Portal (BSAP) validation and after-the-fact monitoring requirements to allow for justifiable deviations from the items in the straw proposal.

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

SRP requests clarification and additional time to analyze effects of moving the market closing timeline for financially binding base schedules from T-40 to T-30.  SRP has significant concerns that limiting the timeline to position our resources will adversely affect our ability to adequately mitigate risks and infeasibilities prior to the Real-Time Dispatch, and SRP may have less than 4 minutes to resolve any infeasibilities identified.  This timing limitation is based on the fact that many of SRP’s resources require at least 25 minutes to support changes (including starts if necessary) resulting from infeasibilities, and it is unreasonable given other necessary processes for this to be completed in parallel for balancing area operations.  In addition, this proposal has the potential to either increase reliability risks within SRP’s Balancing Authority (depending on the consequences of each particular failure and SRP’s system conditions at the time of failure) or significantly limit SRP’s ability to fully participate within the Energy Imbalance Market (EIM).  Further, SRP requests clarification as to whether there would be changes or impacts to other intervals, which may create additional concerns for SRP. 

If CAISO implements the proposed change, SRP strongly urges CAISO to include PacifiCorp’s suggestion, made during the September 30 stakeholder call, that CAISO use T-40 base schedules as advisory to allow EIM entities the opportunity to conduct mitigation steps to pass the appropriate tests between T-40 and T-30.

Alternatively, SRP could support CAISO’s proposed change if such a change were optional, allowing EIM entities to choose either T-30 or T-40 as the market closing timeline for financially binding base schedules.

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

SRP generally supports the proposal to allow resources’ startup energy to be included within hourly resource base schedules. However, we believe EIM Entities would benefit from a greater understanding of the implications of these changes. We also urge CAISO to revise the proposed BSAP validation rules and after-the-fact monitoring due to justifiable deviations. With SRP’s base schedule optimization software, changing unit initial conditions from one optimization run to the next may alter the hourly base schedule submissions so the unit appears to transition from startup to a stable condition and then back to startup. The submission deadlines are so far in advance of the trade hour that conditions may change and warrant base schedule adjustments for economics or reliability that appear to violate the validation in the straw proposal. Additionally, unusual circumstances such as plant trouble, trips, or testing may justify the submission of base schedules that are not monotonically increasing, that may exceed typical startup times, or that may have a 0 MW base schedule in an hour following a base schedule below minimum load (Pmin). SRP requests clarification on what justification would be required to demonstrate the need to fail the BSAP validation or deviate from the after the fact monitoring requirements listed in the straw proposal or that CAISO revise the validation rules to account for such circumstances.

SRP requests that CAISO also clarify if the submission of startup energy below Pmin would apply to all resources, including non-participating resources/participating resources (NPR/PR), multi-stage generator (MSG)/non-MSG. SRP is supportive of this proposed change applying to all resources.

Additionally, please clarify if an EIM Entity would be allowed to bid during hours when the base schedule is below Pmin. SRP’s preference is that CAISO allow bidding during these startup periods.

Finally, SRP requests that CAISO clarify if the submission of base schedules below Pmin for testing purposes would be an acceptable application of this initiative in addition to startup energy. In order to allow time for software changes associated with this implementation, SRP needs responses to these requests for clarification no later than early December.

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

SRP supports CAISO’s proposal for the EIM Governing Body to have primary approval authority for this initiative.   

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.

EIM entities will require time to revise their Open Access Transmission Tariffs (OATT) and vendor software configuration. SRP requires at least 120 days from the time a revision is approved (either by FERC or the CAISO in the case of a change not requiring FERC approval) to post revisions to its OATT, receive public feedback on the changes and then seek SRP Board approval of the changes. SRP requests CAISO consider this need when determining the implementation dates for this initiative, and any other initiative that may require EIM Entity OATT revisions to implement the changes to the market rules.

1. Provide a summary of your organization’s comments on the issue paper/straw proposal.

SCE’s support of the proposed changes within this initiative remains contingent on the CAISO demonstrating that the proposed changes, if introduced, will not impede market performance and the delivery of timely AC-based market solutions and dispatch schedules for resources in the market. 

SCE requests that the CAISO conduct tests and report the results of such tests to its stakeholders. This measure is intended to provide comfort to stakeholders that this change to the base schedule submission deadline and the inclusion of startup energy in market participant schedules for the EIM and CAISO balancing authority areas will be compatible with the other market mechanism changes being introduced to the CAISO market. 

Also, SCE requests that the CAISO preserve the option to deactivate or turn off operation of the changes should the RTPD market software consistently fail to produce feasible AC based dispatch schedules for resources in the market within the available run time for the solution outcome.  

2. Provide your organization’s comments on the proposal to change the final financially binding base schedule submitted by the Western EIM entity scheduling coordinator from T-40 to T-30 of the operating hour.

SCE is understanding of the CAISO’s desire to accommodate the Western EIM entities’ request for a push-out of the submission deadline for their base schedules. However, SCE requests that the CAISO demonstrate that the RTPD software run coupled with the integration of the proposed base schedule submission deadline change and the new flexi ramp refinements be tested to ensure that the deployment scenarios for the flexi ramp product can be accommodated within the run time of the RTPD software thereby producing timely and feasible dispatch schedules for all resources without compromising product delivery and market performance. 

3. Provide your organization’s comments on the proposal to allow resources’ startup energy to be included within all EIM entities’ hourly resource plans.

SCE prefers the inclusion of startup energy in the base schedules of EIM entities and the CAISO BAA suppliers’ day-ahead schedule on the contingency that such a change does not affect the timely delivery of feasible AC based market solutions and dispatch schedules for resources such that the market’s performance remains unaffected. SCE encourages the CAISO to test the change and report its findings to stakeholders prior to taking this change for consideration by the EIM Governing Body and CAISO Board of Governors. In addition, the CAISO must consider the other mechanism changes that the CAISO has received approval for at FERC that await implementation as well as the policy development approvals secured thus far within the CAISO’s stakeholder process for refinements to the flexible ramping product to ensure compatibility exists among the changes to be introduced to the market.  

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

SCE supports primary approval authority for the EIM Governing Body for those aspects of this initiative that exclusively apply to the EIM entities despite its effect on market participants within the CAISO balancing authority area. The schedules of suppliers within the CAISO BAA will require adjustment for the inclusion of startup energy in their day-ahead schedules to ensure consistent treatment of schedules within the optimization software for the IFM. This area should remain the primary authority of the CAISO Board of Governors such that any effects within the IFM software can be considered by the CAISO Board of Governors. Since the EIM entities only participate in the CAISO real-time market, it seems possible that matters pertaining to the day-ahead market should remain severable from the EIM Governing Body’s authority. 

5. Provide any additional comments on the issue paper/straw proposal for the Western EIM Base Schedule Submission Deadline initiative.