1.
Please provide your organization’s comments on the 2023 Tariff Clarifications draft tariff language changes
Section 4.5.3.2.2: The proposed revised language: “, unless the E-Tag is associated with delivery of emergency assistance Energy from or to another Balancing Authority Area to the CAISO Balancing Authority Area“ is ambiguous due to differences in the language underlined. Does the exception for E-tags for emergency assistance energy apply only for deliveries to the CAISO BAA, or is the exception intended to be bi-directional? Please clarify.
Section 6.5.2.3.1.2: It is not clear to the Six Cities why it makes sense to provide updated CAISO Forecasts of CAISO Demand after the Day-Ahead Market has run, except for the CAISO Forecast of CAISO Demand that was used in the Day-Ahead Market run for a given day. With respect to the sections referenced in the explanation column, Sections 6.5.10.1.1, 6.5.10.1.2, 6.5.10.1.3, and 6.5.10.1.5 involve information that is provided after-the-fact under normal circumstances, and the thirty day window makes sense. Section 6.5.11 is somewhat ambiguous, as the reference to “this report” is not entirely clear. Section 6.5.12 should be added to the Tariff Clarifications filing, as described below.
Section 6.5.12: This section, referenced in the explanation column for the proposed change to Section 6.5.2.3.1.2, is unclear as currently worded in the tariff, and a clarification should be included in the Tariff Clarifications filing. Section 6.5.12 currently reads:
6.5.12 Wind and Solar Forecast and Output
Each day prior to the applicable Integrated Forward Market, the CAISO will publish Generation outage data for each Existing Zone Trading Hub aggregated by fuel category, for example thermal, hydro or renewable, to the extent such disclosure is consistent with the confidentiality requirements in Section 20. The report will be for the current Trading Day and for twenty-nine (29) days that follow the current Trading Day. To the extent that the CAISO fails to provide this report on any given Operating Day, the CAISO will endeavor to provide this report within the next thirty (30) days for any given successful Integrated Forward Market run, after which the information will not be provided.
The caption for the section refers to Wind and Solar Forecast and Output, but the body of the section refers to Generation outage data for resources of multiple types. The section should be clarified with respect to the types of resources covered by the reports.
Appendix DD, Section 8.9.2, Sixth Paragraph, First Sentence: The second proposed change to the section and reasons for it are not clear. Six Cities do not object to addition of the words “or retain” to the indicated sentence, but it is not clear why the reference to Groups A and B would be inconsistent with adding the “or retain” language.
