Comments on Revised Straw Proposal

1. Provide a summary of your organization’s comments on the revised straw proposal.

The Bonneville Power Administration (Bonneville)[1] appreciates the opportunity to submit comments on the California Independent System Operator’s (CAISO) Western Energy Imbalance Market (EIM) Sub-Entity Scheduling Coordinator (SESC) revised straw proposal.  Except as discussed below, Bonneville generally supports the CAISO’s proposal.  In particular, Bonneville appreciates the CAISO’s attempt at balancing the needs and interests of SESCs and EIM Entities, who retain the overall reliability responsibility for their respective Balancing Authority Areas (BAA).  Bonneville is also sympathetic with the CAISO’s concerns about how to allow robust participation by potential SESCs while not overwhelming CAISO staff and systems with too many entities seeking to become SESCs.

That said, Bonneville opposes certain aspects of the CAISO’s proposed eligibility criteria for SESCs that would arbitrarily exclude certain customers in Bonneville’s BAA from becoming SESCs.  In this regard, Bonneville believes the CAISO’s proposed eligibility criteria are unduly discriminatory toward certain entities that take long-term wholesale requirements service.  Bonneville proposes changes to the criteria below that address this discriminatory treatment.  Additionally, Bonneville seeks three clarifications on the eligibility criteria.   

[1] 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 MW. Bonneville currently supplies around 30 percent 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 then other regional entities prior to selling power out of the region.

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

In this section, Bonneville addresses two aspects of the CAISO’s proposal: first, the proposed eligibility criteria for SESCs, and second, the EIM Entity’s role in SESC participation in its BAA. 

Proposed SESC Eligibility Criteria: The CAISO identifies three general eligibility criteria for SESCs.  The first criteria contains a proposed requirement that a SESC cannot receive long-term wholesale requirements services from the EIM Entity.  Bonneville opposes this requirement as proposed on the grounds that it is unduly discriminatory.  The practical effect of this requirement is to exclude all customers taking requirements power from Bonneville from being able to participate as a SESC.  Noticeably absent in the CAISO’s proposal is any attempt to justify or rationalize this requirement.  In short, Bonneville does not believe such a sweeping requirement can be justified or rationalized in this context.

While the CAISO’s proposed language is unduly discriminatory, Bonneville believes it can be easily modified to address that discrimination.  The modification Bonneville proposes below draws a distinction between the types of wholesale requirements Bonneville serves.  At a high-level, Bonneville provides service to two types of customers: full requirements customers where Bonneville serves the entirety of their load and partial requirements customers where Bonneville serves a portion of the customer’s load.  Partial requirements customers generally have their own resources or marketing plans to serve the portion of their load not served by Bonneville.  It makes sense that full requirement customers, who are a majority of Bonneville’s requirements customers, would not be eligible to serve as SESCs since they rely on Bonneville to serve their load.  However, Bonneville believes partial requirements customers (a handful of Bonneville’s requirements customers) should be able to participate given that they generally have their own resources to serve their load and market their resources as well as own distribution and transmission facilities.  In that regard, Bonneville proposes add the term “full” to the first criteria.   

Be an electric utility embedded within an EIM entity balancing authority area and not receive “FULL” long-term wholesale requirements services from the EIM Entity.       

Bonneville notes that the Public Generating Pool has also proposed this exact inclusion.  This proposed inclusion will remedy the undue discrimination contained in the CAISO’s proposed criteria and will allow a few of Bonneville’s customers to participate as SESCs if they choose to do so.

In the second bullet, Bonneville requests clarification of what the term “regulated electric service” means.  Non-jurisdictional entities such as Bonneville and its public customers are not regulated by Federal or state utility commissions in the traditional sense.  However, they generally have rigorous approval processes such as board reviews and administrative/stakeholder processes in place for setting rates, tariffs, and policies applicable to electric service.  Bonneville believes these processes should be sufficient to meet the CAISO’s proposed criteria in this context.  Bonneville asks that the CAISO explicitly acknowledge that these processes do satisfy the “regulated electric service” requirement in its final proposal or further explain the rationale behind excluding public power utilities.  Alternatively, the CAISO could delete the term “regulated electric service” altogether from the second criteria without losing the effect of the criteria overall.

Bonneville also requests clarification of whether a scheduling agent for a public customer meets the definition of a SESC.  Several of Bonneville’s partial requirements customers have procured the services of a third-party scheduling agent that manages the scheduling of resources to those customers’ loads.  It makes sense that a third-party scheduling agent could functionally serve as the SESC on a customer’s behalf under the CAISO’s proposal.  However, the CAISO’s proposal does not explicitly address this question.  In its final proposal, Bonneville requests that the CAISO clarify that a scheduling agent of a sub-entity is eligible to be a SESC.

Finally, Bonneville requests clarification regarding the location of a SESC’s potential resources relative to the location of its loads.  More specifically, Bonneville requests clarification of whether a SESC could have resources both within an EIM Entity’s BAA and outside of the BAA that serve load within the EIM Entity’s BAA?  Does it matter if those resources are pseudo-tied (or telemetered) into the BAA where those loads are located?

EIM Entity’s Role In SESC Participation:  Bonneville supports the CAISO’s proposal allowing EIM Entities the autonomy to determine whether to allow SESC participation in its BAA and, if so, whether to apply the CAISO’s SESC criteria with or without an existing contractual or tariff-based practice for accounting for imbalance energy.[1] 

[1] While Bonneville is submitting comments to this proposal that advocates for some of its customers to be eligible under the SESC criteria, Bonneville has not made a decision whether to allow SESCs in its BAA if the CAISO modifies its criteria consistent with these comments.  Bonneville’s decision regarding SESC participation would likely come after Bonneville has experience as an EIM Entity, if it makes a decision to participate in the EIM.  A decision to allow SESCs in Bonneville’s BAA would likely necessitate changes to both Bonneville’s tariff and rate schedules.  Bonneville would propose those changes in the appropriate tariff and rate proceedings. 

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

Bonneville supports the CAISO’s proposal regarding maintaining the resource sufficiency evaluation at the EIM Entity BAA level because the EIM Entity has overall reliability responsibility for its BAA.  As noted in the Straw Proposal, a SESC can submit base schedules prior to the T-55 deadline.  After the deadline, only the EIM Entity can revise base schedules for the BAA.  The SESC will have visibility to see what, if any, changes the EIM Entity makes after the T-55 deadline.  Any imbalance caused by the EIM Entity changing the base schedule after the T-55 deadline will be worked out between the EIM Entity and SESC(s) pursuant to tariff provisions, rate schedules, or agreements.

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

Bonneville supports the CAISO’s proposal regarding the submission of network model updates.  Bonneville appreciates the CAISO’s willingness to allow an EIM Entity to choose whether to allow a SESC to submit its own network model updates directly to the CAISO or not.  It also appreciates the clarity that if a SESC submits model update(s) directly to the CAISO, it must also update the EIM Entity of the model update(s), as well.

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

Bonneville supports the CAISO’s ADS proposal, particularly the ability of the EIM Entity to decline the ADS signal for its BAA.  This is necessary for the EIM Entity to preserve its balancing functions.  Bonneville also believes it is appropriate for any financial impact as a result of this to be resolved between the EIM Entity and SESC(s).

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

Bonneville supports the CAISO’s proposal regarding flexibility provided to an EIM Entity to determine whether to require a SESC use the CAISO’s supply forecast, or allow the SESC to use its own.  Likewise, Bonneville supports the CAISO’s proposal allowing EIM Entity to determine if it will be responsible for the load forecast in its BAA (including any SESC loads), or allow a SESC to use their own forecast.  Finally, Bonneville also supports the CAISO’s proposal to allow an EIM Entity determine whether to require a SESC to use the CAISO’s load forecast or whether the SESC can use its own.

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

Bonneville supports the CAISO’s proposal that a SESC scheduling coordinator submit meter data for the non-participating resources, as well as metered load, in its area.  Bonneville also supports the CAISO’s proposal to create settlement statements and invoices for the SESC. 

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

Bonneville supports the CAISO’s comments regarding a SESC’s access to the market systems identified in the proposal.

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

Bonneville supports the CAISO’s proposal that an EIM Entity Scheduling Coordinator (EESC) will continue to be responsible for the submission of all intertie transfers used by SESCs as part of the EESC’s base schedule.  This is a logical approach since the EIM Entity is responsible for ensuring balanced schedules, net interchange, and tagging within the EIM Entity’s BAA.

Bonneville also supports the CAISO’s decision not to mandate how intra-EIM area transfers are conducted.  Rather, the CAISO proposes to leave the specifics of intra-EIM area transfers to the EIM Entity and SESCs.  Presumably, these specifics will be addresses in the EIM Entity’s tariff, rate schedules, and/or agreements. 

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

Bonneville supports the CAISO’s proposal regarding outage management.  As an RC West member, Bonneville will continue submitting outage information for its BAA to the CAISO using the webOMS application.  Bonneville is also supportive of the CAISO’s proposal to allow an EESC to delegate to SESCs to submit generation outages for the resources the SESC is responsible for and giving the EESC visibility to any outages submitted by the SESC.

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.

Bonneville supports with caveats the CAISO’s proposal regarding SESC onboarding, which is fairly comparable to the process used to onboard an EIM Entity.  Noticeably absent, however, in the CAISO’s proposal is any discussion of the coordination that the CAISO and SESC will have to do with the EIM Entity.  Bonneville believes that the CAISO should provide more details in its proposal about how coordination with the EIM Entity will be done throughout the onboarding process.  The CAISO’s SESC proposal is indisputably a three-party arrangement.

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

Bonneville supports the CAISO’s proposal that the EIM Governing Body have primary authority for this initiative.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Bonneville has no additional comments on this proposal.

1. Provide a summary of your organization’s comments on the revised straw proposal.

 See specific comments below.

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

Idaho Power supports CAISO’s proposal that the sub-entity scheduling coordinator role would have to be mutually agreed-upon by both the EIM entity and the potential sub-entity.  Idaho Power does not have comments at this time on the other aspects of this topic or the eligibility requirements.

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 Automatic Dispatch System (ADS) proposal for this initiative.

 No comments at this time.

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

Idaho Power supports CAISO’s proposal that the EIM entity have the ability to require a sub-entity to use the CAISO VER forecast, or allow it to use its own.  Idaho Power also supports CAISO’s proposal with respect to the EIM entity’s choices regarding load forecasts.

Idaho Power also appreciates and supports CAISO’s proposal to provide EIM entities the ability to view the summed VER forecasts for the sub-entity scheduling coordinators within their balancing authority area.  Idaho Power requests that CAISO provide a more detail on this new screen (what system it would be in, what it would look like, etc.).

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

No comments 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.

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

Idaho Power supports the proposed EIM Governing Body classification.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments at this time.

1. Provide a summary of your organization’s comments on the revised straw proposal.

PacifiCorp appreciates the opportunity to comment on the CAISO’s revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role.  In general, PacifiCorp is supportive of the CAISO’s proposed framework, including the articulated roles and responsibilities amongst CAISO, EIM Entities, and potential EIM Sub-Entities, and appreciates the additional details that CAISO has added to this initiative.

PacifiCorp strongly supports CAISO’s conclusion that any entity’s registration as an EIM sub-entity scheduling coordinator must be supported by the EIM Entity and agreed to by the sub-entity – that an entity can neither unilaterally decide to become a sub-entity nor be compelled to become of a sub-entity. The implementation of a sub-entity inside an EIM Entity BAA will necessarily require operational changes, potential changes to an EIM Entities Open Access Transmission Tariff (OATT), and changes in billing practices. While PacifiCorp is supportive of entities who desire to seek EIM sub-entity status, it is critical that the implementation of this status is coordinated and agreed upon across CAISO, the EIM Entity, and the entity seeking sub-entity status.

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

No Comment. 

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

PacifiCorp supports the CAISO’s proposal to continue performing the resource sufficiency evaluation at the BAA level. Additionally, PacifiCorp supports the proposal to allow the EIM Entity to maintain the ability to make changes to Base Schedules after T-55. 

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

PacifiCorp supports CAISO’s proposal that the EIM Entity maintain responsibility for any Network Model changes.

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

PacifiCorp is supportive of the CAISO proposal to allow the EIM Entity and Sub-Entity to pull resource data from ADS. Additionally, PacifiCorp is supportive that the EIM Entity would continue to have the ability to manually dispatch to maintain a balanced system.

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

PacifiCorp supports the CAISO’s proposal that the EIM Entity retain the ability to require an EIM Sub-Entity to: (a) use the CAISO-provided VER forecast or to submit their own VER forecast, and (b) have the ability for the EIM Entity to have visibility over the Sub-Entity VER forecasts. Additionally, PacifiCorp is supportive of the CAISO proposal to allow EIM Entities to determine if they will be responsible for the load forecast of their BAA or if the Sub-Entity would be allowed to submit a load forecast. PacifiCorp is supportive of these proposals because the entire BAA would be subject to different over-and under-scheduling penalty rules where the BAA would have to pay penalties on actual load imbalances by allowing a Sub-Entity to submit their own load forecast.

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

PacifiCorp is supportive of the CAISO’s proposal to continue allocating Bid Cost Recovery and the real-time offsets to the EIM Entity and to directly settle the flexible ramp product settlements to the EIM Sub-Entity.

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

No Comment. 

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

 PacifiCorp is supportive of CAISO’s proposals for both the intra-BAA transfers and Interchange transfers which maintains the current approach.

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

As a Balancing Authority Area (BAA), PacifiCorp requires all generation and transmission customers within the BAA boundaries to submit outages directly to PacifiCorp to perform studies on a different timeline than required by CAISO or RC West. Currently, PacifiCorp requires outages to be submitted a minimum of 1 week prior to CAISO’s requirements to allow time to perform the NERC required TPL studies (Transmission System Planning Performance). The Reliability Coordinator Procedure RC-0320 does not ensure appropriate time is given to the EIM Entity to perform these reliability studies if the EIM Entity’s outage processes can be bypassed by allowing a Sub-Entity to submit directly to CAISO webOMS.

PacifiCorp requests additional outage management controls and requirements to ensure that EIM Sub-Entities cannot bypass any EIM Entity processes and submit outages without the knowledge or consent of the EIM Entity. Additionally, PacifiCorp recommends that both the transmission and generation outage management process for EIM Sub-Entities is defaulted to the EIM Entity and that the EIM Entity retains all outage submission responsibilities unless the EIM entity elects to delegate this role to the EIM Sub-Entity as part of the Sub-Entity agreement.

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 Comment. 

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

 PacifiCorp supports the proposed EIM Governing Body classification to have primary authority.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

PacifiCorp supports the general objective of striking a balance by limiting the types of entities that may qualify to register as a sub-entity.  However, PacifiCorp requests further clarification and modification regarding the last bullet of qualifying criteria on page 8 of the revised straw proposal – the requirement that an EIM sub-entity must own or control one or more resources for the primary purpose of serving its eligible customers.  PacifiCorp requests further clarification to this criterion to make clear that the resources an EIM sub-entity owns or controls for the primary purpose of serving its eligible customers must be included in the full network model.  This would be required so that the sub-entity can demonstrate it is balanced and meet the requirements set forth in the revised straw proposal.

1. Provide a summary of your organization’s comments on the revised straw proposal.

Platte River Power Authority (“Platte River”) appreciates the California Independent System Operator’s (“CAISO”) efforts to develop its January 21, 2021 Western EIM Sub-Entity Scheduling Coordinator Role Revised Straw Proposal (the “Straw Proposal”) and generally supports the concepts in the Straw Proposal.  

Platte River understands this initiative responds to the Energy Imbalance Market (“EIM”) implementation agreement between the CAISO and Public Service Colorado (“PSCo”), which was filed with FERC and became effective on July 29, 2020 (the “PSCo EIM Implementation Agreement”).[1] The PSCo EIM Implementation Agreement includes a set of principles[2] recognized by the parties as essential to PSCo’s participation in the EIM. These principles govern PSCo’s transition to the EIM from the Joint Dispatch Agreement (“JDA”) among Platte River, Black Hills Colorado Electric, LLC, Colorado Springs Utilities, and PSCo. Because the transition to the EIM may require termination of the JDA, recognizing the JDA’s provisions as part of the EIM implementation is essential.[3] As a JDA party, Platte River appreciates the opportunity to submit comments on CAISO’s Straw Proposal.    

Platte River’s comments focus on the need to (1) ensure that EIM entities and EIM sub-entities work together to establish terms and conditions for EIM sub-entity participation, (2) ensure that the FERC Standards of Conduct, reliability considerations, and fair market principles govern all terms and conditions and processes established for EIM sub-entity participation, (3) further clarify the eligibility criteria to explicitly account for municipal and other types of governmental utilities, (4) confirm Platte River’s agreement with the discretion given to EIM entities to allow sub-entities to work with CAISO directly to maintain the EIM sub-entity’s network model, (5) confirm the importance to reliability of EIM sub-entities’ access to webOMS for outage reporting, and (6) confirm that the EIM Governing Board is the right authority to approve the changes contemplated by the straw proposal. 

[1] ?See?FERC Docket No. ER20-1937, and?FERC approval letter?and?CAISO/PSCo Implementation Agreement.? 

[2] ?See?PSCo EIM?Implementation Agreement?at?Section 14.?

[3] ?See?PSCo EIM Implementation Agreement,?Exhibit B.? 

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

Platte River believes that, in general, the proposed roles and responsibilities and EIM sub-entity eligibility criteria are sound, but Platte River recommends some important refinements and clarifications.

1. The eligibility criteria in the straw proposal may introduce an inadvertent barrier, specifically because of the second element, which requires an EIM sub-entity scheduling coordinator to “own a distribution system or transmission facilities directly connected to the transmission system of the EIM entity for the purpose of providing regulated electric service to eligible retail or wholesale customers” (emphasis added).  This would appear to imply that eligibility hinges on an EIM sub-entity’s status as jurisdictional to a state public utility commission. This would exclude municipal and other types of governmental utilities. Platte River recommends avoiding this problem by modifying the language as follows: 

“own a distribution system or transmission facilities directly connected to the transmission system of the EIM entity (a) for the purpose of providing regulated electric service to eligible retail or wholesale customers, or (b) in its capacity as a Local Publicly Owned Electric Utility.”[1]

2. The discretion given to EIM entities to define the terms and conditions of an EIM sub-entities’ participation requires effective coordination, mutual agreement, and strict adherence to FERC Standards of Conduct, reliability considerations, and fair market principles.

1. 1. EIM Entities and EIM sub-entities should negotiate the terms and conditions of participation up front and come to a consensus on any needed tariff changes. Platte River would recommend the following modifications to the second sentence of the first full paragraph on page 9 to emphasize the need to establish agreements and coordinate effectively:

“Authorization of participation by sub-entities within an EIM entity balancing authority area, including the specific terms and conditions for participation and termination, should be developed through an agreement between the EIM Entity and EIM sub-entity or the regulatory process applicable to each EIM entity, most likely by amendment of the EIM entity OATT, prior to such services being implemented by the CAISO. All terms and conditions and processes must be developed between the EIM entity and the EIM sub-entities within its balancing authority area so as to ensure strict adherence to FERC Standards of Conduct, reliability considerations, and fair market principles.

[1] As defined in the CAISO Fifth Replacement Electronic Tariff, Appendix A.? 

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

Platte River recommends that the CAISO rules make clear that base schedule changes must be determined by System Operators[1] and necessitated by reliability considerations, not market factors. To do so Platte River requests that CAISO clarify what changes, and for what reasons, an EIM entity can make to an EIM sub-entity’s base schedule.

[1] As defined by NERC in the Glossary of Terms Used in Reliability Standards.

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

Platte River submitted its network model, and anticipates submitting updates to its network model, directly to CAISO. Platte River agrees with the flexibility given to EIM entities to allow EIM sub-entities to do this. Platte River believes this flexibility benefits EIM entities’ balancing authorities in fulfilling their obligation to ensure that the full network model has the detail and accuracy needed to facilitate reliability and enable valid market results. 

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

Platte River recommends that the CAISO rules make clear that any ADS signals declined by the EIM entity must be determined by System Operators[1] and necessitated by reliability considerations, not market factors. Platte River recommends the following modifications to the second sentence on page 12 in the paragraph under Automatic Dispatch System:

“The ability to decline individual ADS signals for reliability purposes will reside with the EIM entity’s balancing authority to preserve its ability to perform balancing functions necessary to comply with applicable reliability standards.” 

[1] As defined by NERC in the Glossary of Terms Used in Reliability Standards.

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

Given the negative consequences for the EIM entity (automatic failure of the CAISO’s balancing test), Platte River does not see a need for EIM sub-entities to submit their own load forecasts and sees no value in preserving this option in the Straw Proposal. 

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

Platte River reiterates that all information sharing must be done in strict adherence to FERC Standards of Conduct, reliability considerations, and fair market principles.

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

Platte River has no comments on this section.

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’s primary tool to communicate outage information will be Sunnet iTOA, which will simultaneously communicate outage information to webOMS and CROW (SPP’s outage reporting tool). As back-up and for reliability purposes, EIM sub-entities must have direct access to webOMS. CAISO is currently working with Platte River to establish direct access rights to webOMS.

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.

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

Platte River concurs that the EIM Governing Board is the right authority to approve the changes contemplated by the Straw Proposal.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

Platte River commends CAISO’s continued commitment and current efforts to identify and implement targeted improvements to the CAISO’s EIM by leveraging the power of geographic diversity to better integrate renewables, enhancing reliability through increased operational visibility across electricity grids, and improving congestion management for transmission facilities across the western interconnection. 

1. Provide a summary of your organization’s comments on the revised straw proposal.

Public Generating Pool appreciates the substantial detail and clarity provided in the revised straw proposal regarding eligibility and roles and responsibilities between EIM entities and EIM sub-entity scheduling coordinators (SESC). Overall, PGP supports the proposal, with requests for clarification in a few areas. 

Integral to PGP’s support of this proposal is 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 to be a sub-entity, nor be compelled to become a sub-entity. This approach ensures that both parties have the optionality to determine whether the SESC role is acceptable. PGP agrees that the decision of an EIM entity to allow “some” but not all qualifying entities to participate as an SESC should be determined on the basis of the EIM entity’s OATT. PGP believes caution will need to be exercised to ensure that there is no inadvertent discrimination across customers on the basis of allowing participation as a sub-entity SC. PGP believes this determination is most appropriately made through the EIM entity’s OATT tariff/tariff amendment process.
 

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 that eligibility for the EIM SESC should be limited to electric utilities located in an EIM entity BAA that own a distribution or transmission system and serve eligible customers from resources they own or contract for. PGP suggests one clarification to the language below that we believe meets the intent of the eligibility criteria and would 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, would not be excluded from the EIM sub-entity SC role. 

An EIM sub-entity must:
o    Be an electric utility embedded with an EIM BAA and not receive long-term wholesale full requirements services from the EIM entity
o    Own a distribution system or transmission facilities directly connected to the transmission system of the EIM entity for the purpose of providing regulated electric service to eligible retail or wholesale customers
o    Own, control and/or schedule one or more resources for the primary purpose of serving its eligible customers.

PGP also believes it appropriate 1) to allow certification of third-party scheduling coordinators for EIM SESCs; and 2) to authorize these third-parties to fulfill this SESC role on behalf of eligible sub-entities should the sub-entities choose to use their services. For example, The Energy Authority (TEA) contracts with a number of public power electric utilities to provide marketing and scheduling services for their owned and contracted resources within the Bonneville Power Administration (BPA) BAA.  These utilities would be eligible to be EIM sub-entities under the current proposal. In addition, TEA is also a certified Scheduling Coordinator in the CAISO’s Physical Markets for several loads and resources within California and anticipates it may schedule future participating resources in the EIM on behalf of customers within the BPA BAA.  PGP believes these customers should continue to be able to utilize TEA to fulfill their duties as future EIM sub-entities within the BPA BAA.
 

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

PGP supports the CAISO’s proposal to continue the resource sufficiency evaluation (RSE) at the EIM entity level. PGP believes it is reasonable to allow the EIM entity to determine the exact timing for SESC base schedule submissions prior to T-55 and PGP also agrees that following the T-55 RSE, schedules should only be modified by the EIM entity who would communicate changes to the sub-entity.

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

PGP supports CAISO’s proposal that the EIM entity should retain responsibility and authority for the submission of the full network model as it bears the ultimate responsibility for the BAA. PGP also supports the CAISO’s proposal to offer functionality that will allow the EIM entity to delegate the ability for the sub entities to submit their model directly to the CAISO.

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

PGP supports the CAISO proposal to provide access for ADS resource data within the sub-entity to be pulled by both the sub-entity and the EIM entity to ensure the maximum visibility to both entities. PGP strongly supports the CAISO’s proposal for the ability to decline the ADS signal to reside with the EIM entity to preserve their ability to perform balancing functions. We agree that this reliability function appropriately resides with the EIM entity.

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

Supply Forecast: 
CAISO proposes that an EIM entity retain the ability to require an EIM sub-entity to use the CAISO provided forecast, or to allow the sub-entity to use its own forecast. To address concerns with multiple sub entities electing to use their own variable energy forecasts – which could lead to a significant difference between the CAISO forecast in the RSE and create risks for the EIM entity passing RSE – the CAISO proposes to provide the ability for the EIM entity to view the summed VER forecasts for the entire BAA. PGP supports this proposal but further recommends that the EIM entity should be responsible for determining the exact timing for sub-entity submission of VER forecasts to prior to T-55 to in order to ensure the EIM entity has enough time to respond to significant differences between the CAISO provided forecast and sub-entity forecast, should these materialize.

Load Forecast:
PGP supports the CAISO proposal that EIM entities should determine if they will be responsible for the load forecast for their entire BAA, or if they will allow sub entities to determine their own load forecast. PGP seeks clarification on the aspect of CAISO’s proposal 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 does not believe it would be appropriate for the entire BAA to automatically fail the balancing test if a sub-entity submits its own load forecast. We do not believe this is likely the intent of this language and request clarification.
 

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

PGP believes the CAISO’s proposal to create statements and invoices at the EIM sub-entity SC level for all charges and allocations associated with the sub-entity’s resources is reasonable.  However, we suggest the EIM entity have visibility with respect to these statements and invoices, if requested. PGP also believes it is appropriate to continue allocating bid cost recovery charges and real time offset charges at the EIM entity level with sub allocations to EIM sub-entity SC’s performed according to the EIM entity’s OATT.  We seek clarification on when a sub-entity might be allocated bid cost recovery charges, since said charges would seem tied to participating resources, and not to non-participating resources. 

CAISO further proposes that each sub-entity shall have access to all bill determinants/charge codes that provide EIM sub-entity specific or EIM sub-entity resource specific information. In addition, the EIM SESC will have visibility of the bill determinants published in the BAA specific common files. PGP supports this and believes this visibility is necessary and appropriate.
 

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.

PGP supports CAISO’s proposal that the EIM entity SC retain responsibility for the submission of all generation outages within their BAA while allowing functionality for an EIM entity to delegate that responsibility to sub entities. PGP believes outage management is an essential reliability function that should be retained by the EIM entity, unless otherwise determined by the EIM entity, and we therefore support CAISO’s proposal.

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.

PGP has no concerns and supports the proposed EIM sub-entity onboarding proposal.

14. 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.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No further comments.

1. Provide a summary of your organization’s comments on the revised straw proposal.

SCE reaffirms its support for the creation of the EIM sub-entity scheduling coordinator (SC) role such that non-participating loads and resources within an EIM entity’s balancing authority area (BAA) can transact and settle with the CAISO. This mechanism introduces a new level of transparency for the recognition of those non-participating loads and resources within EIM BAAs while extending the incentives within the CAISO market directly to non-participating resources, albeit on a limited basis, with the expectation that the efficiency of EIM operations should improve. 

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

SCE reaffirms its support for the creation of the sub-entity SC role where possible within EIM BAAs thereby facilitating accounting for and the settlement of non-participating resources and loads within an EIM entity BAA. Appropriate delegation and coordination of the roles and responsibilities of the EIM SC and EIM sub-entity SC offer the opportunity to rationalize the relationship between the EIM sub-entity and EIM entity as well as the EIM sub-entity and the CAISO as the EIM sub-entity SC transacts directly in the CAISO market. 

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, support 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 supports the flexibility within the CAISO’s proposal on the submission of the full network model information for the BAA. SCE concurs that any delegation of the information to be submitted on the network model for the area served by the EIM sub-entity must be supported by permission from the EIM entity which is ultimately responsible for EIM participation and/or the reliability within the BAA. 

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

SCE affirms that the EIM entity’s reliability commitment supersedes the internal relationship between the EIM entity and the EIM sub-entity such that resources represented by the sub-entity remain exposed to the financial risk of the EIM entity’s refusal of the automatic dispatch signal if that signal is not applicable to any of the sub-entity’s resources. While sub-allocation of costs associated with the dismissal of the signal is a possibility, there is a strong incentive for the EIM entity and sub-entity to mitigate such risks particularly when their individual base schedules are balanced. 

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

SCE affirms the CAISO’s proposal for the EIM sub-entity SC to use either the CAISO forecast for the variable energy resources represented by that EIM sub-entity or for the sub-entity to use a third-party service to provide the forecasting service for the resources. The CAISO’s proposal offers a transparent election that must be made by the EIM entity and EIM sub-entity while illuminating the automatic failure of the balancing test by the BAA when the election is made to use the EIM entity’s or sub-entity’s own load forecast. SCE concurs with the structure of this incentive though SCE recognizes that errors in the CAISO forecast are likely to result in cost shifts to any market participant that chooses to use its own load forecast. 

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

SCE supports the universal application of the metering requirements and metered data provisions that govern EIM entities within the CAISO Tariff and Business Practice Manuals for EIM entities to the EIM sub-entity. In addition, the CAISO’s proposal for the generation of statements and invoices associated with the EIM sub-entity’s resources is supported by SCE. Though bid cost recovery will be settled at the EIM entity level followed by sub-allocation to the EIM sub-entity under the EIM entity’s OATT, SCE remains mindful of the changes in incentives within the CAISO market under this settlement arrangement when the mechanism within the EIM entity’s OATT lacks perfect alignment with the incentive structure in the CAISO’s cost allocation mechanism.  

SCE agrees that the CAISO’s proposed risk sharing between the EIM entity and sub-entity in relation to over/under scheduling costs for the RSE and based on the metered demand preserves transparency in the settlement process as well as the incentives for balanced schedules to be submitted by the EIM entity and sub-entity. 

Further SCE agrees with the CAISO’s proposal for direct settlement of the flexible ramp movement with the EIM sub-entity for all resources which the sub-entity SC represents. 

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

SCE concurs with the CAISO’s proposal to grant access to the EIM sub-entity access to the following CAISO systems: Automatic Dispatch Signal, Base Aggregation Scheduling Portal, Customer Market Results Interface, Market Results Interface for Settlements and CAISO webOMS. 

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

SCE supports the CAISO‘s proposal for the EIM entity to be singularly responsible for submitting inter-BAA energy transfers on interties given the EIM entity’s responsibility for reliability within its BAA. When multiple sub-entities exist within the EIM BAA, coordination of the energy transfers between BAAs on interties is very important for ensuring reliability within any BAA that is a party to the intertie transaction. 

Also, SCE supports the CAISO’s proposal to allow intra-BAA energy transfers to be handled and settled between the EIM entity and its sub-entity while requiring that parties to the intra-BAA energy transfers reflect those transactions on their base schedule submissions to the CAISO. 

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

SCE supports the CAISO’s decision to avoid overruling outage management coordination provisions in place for Reliability Coordinator (RC) West members while allowing all non-RC West members who are EIM entities or sub-entities to report their outages through the CAISO outage management software, webOMS. SCE supports the extension of similar provisions to sub-entity SCs for reporting transmission outages for equipment that the sub-entity is the Transmission Operator. 

Further, SCE supports the rejection of outages submitted by neighboring Reliability Coordinators. Since outage coordination communication protocols exist in each control area that will ensure all relevant parties are aware of resource availability, the EIM entity SC will remain the responsible party for reporting outages within its BAA. 

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 offers no comments on the on-boarding process proposed by the CAISO for the sub-entities since the sub-entities and EIM-entities are better situated to comment on those proposed arrangements.? 

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

SCE supports the decisional classification proposed for this initiative since this matter directly affects the EIM BAAs, particularly those that are likely to grant the operation of EIM sub-entities within their BAAs.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

SCE requests information from the CAISO on how the CAISO’s credit policy will be applied to EIM sub-entities. Will the existing credit policy provisions applicable to an EIM entity also apply to the EIM sub-entity? 

1. Provide a summary of your organization’s comments on the revised straw proposal.

The Southwest Public Power Agency (“SPPA”) appreciates the opportunity to submit comments on the CAISO’s revised straw proposal to establish an EIM Entity Sub-Entity Scheduling Coordinator (“SESC”) Role. SPPA is a joint action agency established under Arizona state law, comprising publicly owned, not-for-profit irrigation and electrical districts, municipal electric utilities and tribal utilities. SPPA Members include: Aguila Irrigation District, Ak-Chin Energy Services, Buckeye Water Conservation & Drainage District, City of Safford, Electrical District No. 2 of Pinal County, Electrical District No. 3 of Pinal County, Electrical District No. 4 of Pinal County, Electrical District No. 6 of Pinal County, Electrical District No. 7 of Maricopa County, Electrical District No. 8 of Maricopa County, Gila River Indian Community Utility Authority, Harquahala Valley Power District, Maricopa County Municipal Water Conservation District 1, McMullen Valley Water Conservation & Drainage District, Navajo Tribal Utility Authority, Ocotillo Water Conservation District, Roosevelt Irrigation District, Tonopah Irrigation District, Town of Thatcher, and Town of Wickenburg (the "SPPA Members"). Additionally, the City of Williams and Tohono O’odham Utility Authority are in the process of becoming members and will likely do so in 2021. 

SPPA appreciates the CAISO’s clarification in the revised straw proposal that SPPA Members cannot be compelled to become an SESC with its statement that “[t]he registration as an EIM sub-entity scheduling coordinator must be supported by the EIM entity and agreed to by the sub-entity; an entity can neither unilaterally decide to become a sub-entity nor be compelled to become a sub-entity.” As SPPA noted in its initial comments, this is an important and needed clarification as the nature of many SPPA Members’ metering and interconnections will make it difficult—as currently structured—for many to satisfy the metering and telemetry requirements of CAISO Tariff and become a functioning SESC.  

That being said, in the future SPPA Members may make the necessary metering and interconnection upgrades to their systems that would allow them to satisfy the CAISO Tariff and be able to function as an SESC. The SPPA Members, however, are concerned that two aspects of the revised straw proposal arbitrarily cut off their ability to participate as an SESC in the future. 

First, the revised straw proposal states that:

the sub-entity must be implemented within a reasonable period of time following implementation of the EIM entity, and in no circumstance should they be permitted to do so later than three years following the implementation date of the EIM entity. Delay beyond three years would not be considered necessary to account for the complexities of transition.

Requiring a sub-entity to become registered as an SESC within three years would likely foreclose those SPPA Members—an presumably other qualified sub-entities in the EIM footprint—that wanted or planned to become an SESC but needed more than three years to make the necessary physical updates to their systems. This three year requirement is also not flexible for those sub-entities that, due to changes in load or resource mix down the road, may find the SESC role more attractive than they currently do. 

While SPPA can understand the CAISO imposing a three-year onboarding requirement from the date that a sub-entity elects to become an SESC, SPPA does not understand the need to impose a three-year, permanent cut off “following the implementation date of the EIM entity.” SPPA urges the CAISO to reconsider this three-year requirement in its draft final proposal. 

The second aspect of the revised straw proposal that SPPA is concerned may arbitrarily restrict its Members’ ability to become SESC in the future is the revised straw proposal’s SESC eligibility requirement that sub-entities not receive “long-term wholesale requirements services from the EIM Entity” and CAISO Staff’s suggestion at the January 28, 2020 stakeholder meeting that the SESC role would not be available to “small irrigation districts.” 

SPPA echoes the comments made by the Utah Associated Municipal Power Systems (“UAMPS”) at the January 28th stakeholder meeting that transmission dependent utilities that purchase their own power can and should be allowed to take on the role of an SESC. These utilities that rely on an entity for certain services but otherwise purchase and schedule their own power should not be categorically excluded from the SESC role. SPPA urges CAISO to clarify that transmission dependent utilities that purchase and schedule their own power should be eligible to become SESCs. 
 

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

See comments above.

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 Automatic Dispatch System (ADS) 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 comments at this time.

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

See comments above.

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.

14. 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.

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No comments at this time. 

1. Provide a summary of your organization’s comments on the revised straw proposal.

Utah Associated Municipal Power Systems (UAMPS) appreciates the opportunity to comment on this Western EIM Sub-Entity Scheduling Coordinator Role California ISO Revised Straw Proposal.  UAMPS thanks Xcel Energy-Colorado, Platte River Power Authority, Colorado Springs Utilities and Black Hills Energy-Colorado for highlighting this issue with their application to join the EIM.  UAMPS, as well as others, have been discussing the need for a change in the structure of EIM to have direct operations and settlement data exchanges between the market operator and all entities subject to EIM in public forums and bilateral meetings since the beginning of EIM.  Contrary to the nomenclature used in EIM, all load and generation in the EIM participates regardless whether they are deemed “Participating” or “Non-participating” by CAISO and the EIM Entities. Because of this, all entities that have a need and a capability should be allowed to be a EIM Sub-Entity.  Our understanding is that other markets operate this way.

The current structure of the EIM is contractually set up between CAISO, an independent system (market and transmission) operator and an EIM Entity.  An EIM Entity is primarily a Balancing Area Authority, but there does not appear to be any criteria on whether the EIM Entity represents the BAA’s transmission function, load serving function, grid operations function or a combination.  It appears that each EIM Entity sets up their internal structure and administration of the EIM any way they want to.  Therefore, for Sub-Entities inside of a EIM Entity there is a disconnect between the independence and transparency of the market, which is shown in the lack of timeliness and accuracy of the settlement data.

One issue that was raised is the cost of restructuring (primarily metering and communications) for an EIM Entity to accommodate Sub-Entities.  UAMPS recognizes this and knows that it is one of the costs of moving into a new market structure.  All EIM Entities expended large amounts of money to upgrade their systems to be an EIM Entity and so to make the EIM include Sub-Entities and make the market more efficient and accurate, there may have to be more funds expended.  Since the benefits of EIM are so large, the expenditures should be able to be done without too much pain. 

As with our prior communications, UAMPS is primarily interested in receiving accurate settlement data from the EIM.  We have been requesting this from our respective EIM Entities and CAISO since 2014 and have made a little headway, but still cannot validate our settlements.  Since a large part of the settlement costs are allocated, we need to know both the numerator and denominator of the allocated charge.  For some reason, the denominator seems to be top secret information and a Sub-Entity is supposed to trust whatever charges come from CAISO and/or the EIM Entity.  If the settlement process could be fixed through some other means, the full blown Sub-Entity proposal may not be needed by UAMPS.     

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 Automatic Dispatch System (ADS) proposal for this initiative.

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.

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.

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

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

1. Provide a summary of your organization’s comments on the revised straw proposal.

WPTF appreciates this opportunity to provide these brief comments on the CAISO’s Western EIM sub-entity scheduling coordinator role. The comments included herein focus primarily on the potential implications of allowing new LAPs to be created within an EIM BAA where the load within each LAP, or load not included in any of the new LAPs, will be settled at its corresponding price. Given that there has been minimal discussion on the pricing aspect of the proposal, WPTF believes the most prudent step forward is to continue discussions on this element of the proposal in a separate initiative or Phase 2 of this effort. The lack of details at this point in the policy process makes it infeasible for stakeholders to fully understand and opine on the implications of the overall proposed policy.

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 Automatic Dispatch System (ADS) proposal for this initiative.

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

It is WPTF’s understanding that the EIM BAA will automatically fail the balancing test if any sub-entity within that EIM BAA submits its own load forecast, and thus the EIM BAA will be subject to over/under-scheduling charges. It seems as though this rule would result in few, if any, EIM BAAs allowing a sub-entity to submit its own load forecast. Therefore, WPTF asks for additional discussion on the automatic failure so we can better understand the reasoning behind this element of the proposal and why it would be appropriate for the EIM BAA to fail the test if one sub-entity uses its own load forecast.

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

It is WPTF’s understanding that the CAISO is proposing to continue allocating some charges (BCR and Real-time offset) at the EIM Entity level, which is then allocated to the sub-entities based on the EIM entity’s OATT. On the other hand, the proposal notes that the CAISO will allocate other charges/costs to the EIM sub-entity level (over/under-scheduling penalties and flexible ramp movement) rather than first allocating to the EIM Entity level and then allowing the EIM entity’s OATT to determine the sub-allocation of such costs to the sub-entities. WPTF believes additional discussion would be useful around why the latter two cost categories will now be allocated directly to the EIM sub-entity level whereas the first two will remain at the EIM entity level and then allocated based on existing OATTs. Does this element of the proposal align with the existing OATT framework? In other words, could it be the case that some entities within an EIM BAA are allocated the latter two charges based on different billing determinants?

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.

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.

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

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

It is WPTF’s understanding that within this effort the CAISO is proposing to settle load within an EIM sub-entity at its own LAP price and all the remaining load outside of the sub-entity, but still within the overall EIM BAA, at different LAP price(s). This understanding is based solely on the brief discussions had during the stakeholder call; the policy papers do not include any discussion of this element of the proposal. Thus, WPTF respectfully requests that the CAISO ensure the next iteration of the proposal includes more details regarding the impacts of this proposal on LAP pricing and how the various loads within an EIM BAA, e.g., load within a sub-entity versus load outside of the sub-entity, will be settled. We request the additional detail cover the scenario where there is one sub-entity within a single EIM BAA as well as where there is more than one sub-entity within a single EIM BAA. If the CAISO intends to have the next iteration be the final proposal, WPTF then also asks that the pricing element of the proposal continue to be discussed either in a Phase 2 or separate policy initiative. Stakeholders need to have the ability to understand what is being proposed and an opportunity to provide insights prior to the policy being in the final proposal stage. The pricing element has yet to receive the attention necessary for stakeholders to fully understand the proposal and potential implications.

WPTF believes additional discussion is warranted regarding the potential implications of having load within an EIM BAA settled at different prices. WPTF believes the proposal may result in cost shifting among LSEs within an EIM BAA in a way that the LSEs most likely facing higher costs will not be able to mitigate and is a result of another LSE’s decision. For example, one LSE may meet the criteria to be a sub-entity and opt to have its load settled at a new LAP price whereas another LSE may not meet the criteria and cannot have a separate LAP price. The decision of the first LSE seems to have a direct impact on the other LSE. A sub-entity created within an area that has a robust transmission system will likely result in a lower LAP price for its load due to lower congestion costs on that part of the system; LSEs outside of that area residing on less robust parts of the transmission system will now have their load settled at a higher price because it now reflects the higher congestion costs only on its part of the system. The LSEs facing higher load prices under this proposal will have no means of mitigating that higher cost, and the higher cost comes from the decision of the other LSE to create sub-entity.

Additionally, WPTF believes it would be useful to better understand the background as to why at the onset of EIM a single LAP was created for each EIM BAA. For example, was the fact that some areas of the transmission system are less robust than others thus a single LAP price was a way of ensuring LSEs on less robust areas are not exposed to unduly high prices? Having that information will better help stakeholders evaluate if this proposed change to pricing results in appropriate changes in how load will be settled or if other alternatives need to be considered.

WPTF thanks you for consideration of these comments.

1. Provide a summary of your organization’s comments on the revised straw proposal.

Xcel Energy (Public Service Company of Colorado) appreciates the efforts taken by the CAISO to revise and adapt this straw proposal based on stakeholder feedback. Largely, the revised straw proposal seems to address many of the requested clarifications and additional details. Xcel Energy supports with caveats the descriptions of the sub-entity scheduling coordinator definition, roles, responsibilities, as presented by the CAISO in this Revised Straw Proposal.

Generally, Xcel Energy believes that the revisions contained therein represent necessary clarifications and definitions. However, Xcel Energy seeks additional clarification and discussion on four key elements within our comments.  Largely, these caveats are an attempt to navigate some structural uniqueness within the PSCo BAA and negotiate reasonable and acceptable outcomes to resolve the challenges to implementing and operating the WEIM within the PSCo BAA.

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

Support with caveat:

As acknowledged within the Revised Straw Proposal, Public Service Company of Colorado (PSCo) has entered into an implementation agreement with the CAISO that contemplates the creation of the role of sub-entity scheduling coordinator (SESC). The objective of this role is to maintain operational autonomy of the parties of the Joint Dispatch Agreement in the PSCo Balancing Authority Area (BAA), which will facilitate the participation of these utilities in the EIM.

To further clarify the roles and responsibilities, the CAISO has defined qualifications of a sub-entity scheduling coordinator.  PSCo supports the definition of the SESC, noting that because the SESC is associated with a custom Load Aggregate Point (LAP). An SESC must not be otherwise have existing agreements which result in an SESC being represented by default within another entity’s LAP. This is supported and further clarified by the CAISO’s description of having “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.”

Xcel Energy supports the statement that an entity can neither be compelled to become, nor unilaterally declare themselves to be an SESC. It is important to Xcel Energy that we continue to collaborate with all our Colorado partners to drive progress in efficiencies provided by organized markets, while ensuring this progress is fair and reasonable to stakeholders.

Extending further, the CAISO contemplates, and Xcel Energy supports that recognized contractual or tariff-based imbalance practices within the EIM Entity may necessitate an alternative approach to calculating imbalance, and that the CAISO will honor such arrangements.

Caveat:

Within this revised straw proposal, the CAISO has communicated that an entity which meets criteria to become an SESC “at least in part, depend[s] upon transmission service from the host EIM entity to meet their regulatory obligations.”  It seems implied that the SESC role may take various transmission ancillary services under the OATT, though the term “transmission service” seems overly broad. Xcel Energy would like to see this language refined to remove any potential conflicts that may indicate eligibility other than by EIM Entity approval.

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

Support with caveat:

Xcel Energy supports resource sufficiency being performed at the EIM Entity level and agrees that this approach is consistent with non-market activities incumbent upon a BAA.

Caveat:

Xcel Energy seeks additional clarification if the activity of balancing for the purpose of satisfying the final resource sufficiency evaluation period may be delegated to an entity other than the EIM Entity Scheduling Coordinator, so long as the EESC retains final responsibility and authority over this activity.

Xcel Energy also seeks additional clarification on the technological approaches that the CAISO may facilitate for resource sufficiency evaluation awareness among sub-entities prior to the final RSE period. 

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

Support

5. Provide your organization’s comments on the Automatic Dispatch System (ADS) proposal for this initiative.

The EIM entity may not be best positioned or best informed to decide the reasonability of a particular dispatch instruction on behalf of their sub-entities. Because of this, Xcel Energy asks the CAISO to consider and discuss a modified approach, where the EIM entity have authority to delegate to a sub-entity scheduling coordinator the ability to decline an ADS signal for the subset of resources within the SESC area.

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

Support

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

Support

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

Support

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

Support

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

Support with caveat:

Xcel Energy supports the ability to delegate to a sub-entity the responsibility for submitting generation and transmission outages directly to the CAISO webOMS.

Caveat:

Xcel Energy seeks further discussion from CAISO on why it may be unacceptable or infeasible for the CAISO to accept outages submitted to neighboring reliability coordinators for use in the EIM market. Requesting non-CAISO RC West customers to submit outages to both the CAISO webOMS and their RC’s outage management system may be technologically feasible, but it seems to introduce additional room for error as dual entry now must be performed by the entity. Understanding that there may be a misalignment between the outage submission requirements in the CAISO market and outage submission requirements in the entity’s reliability coordinator area, it seems more practical in the long-term to resolve those mismatches by exploring an approach to modify submissions to the entity’s RC which align with the CAISO market requirements. This might be implemented by the entity working with their RC to enable submissions to their RC which do conform to the CAISO’s requirements.

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.

Support

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

Support

15. Provide any additional comments on the revised straw proposal for the Western EIM Sub-Entity Scheduling Coordinator Role initiative.

No additional comments