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Please submit comments on the draft 2022 catalog. You may upload documents using the "attachments" field below:
General Comments
The Bonneville Power Administration (Bonneville)[1] appreciates the opportunity to comment on the CAISO’s 2022 Draft Policy Initiatives Catalog dated April 29, 2021. Bonneville’s comments are limited to the Load, Export, & Wheeling Priorities Phase 2 and EIM Resource Sufficiency Evaluation Enhancements Initiatives.
6.4 Load, Export, & Wheeling Priorities Phase 2
Bonneville believes the description of this initiative is mischaracterized. The initiative needs to include the development of both a process that would permit wheel-through transactions to reserve transmission across the CAISO system and that would permit CAISO loads to secure transmission across the CAISO system.
CAISO does not have a forward open access transmission procurement framework in place for wheel-throughs or imports to serve load within the CAISO balancing authority area (BAA). Consequently, there is no ability for wheel-throughs to request, reserve, and pay for firm transmission over CAISO’s transmission system outside the day-ahead and real-time energy market framework. The description of this initiative indicates that it will include the development of a process that would permit wheel-through transactions to reserve transmission across the CAISO system. Yet, there are also no explicit processes or rules in place for California loads to secure firm transmission rights over CAISO’s system akin to a “designation of network resources.” CAISO’s Maximum Import Capability (MIC) is not a construct that determines or provides transmission rights and priorities, nor should it evolve to become such a framework. And claiming CAISO’s current MIC for CAISO native load would provide unduly discriminatory and preferential treatment to native load that violates FERC open access principles. This initiative needs to take a holistic look at CAISO’s planning processes, calculations of available transfer capability, and the ability for both wheel-throughs and CAISO loads to be able to reserve, secure, and pay for transmission across the CAISO’s system.
6.9 EIM Resource Sufficiency Evaluation Enhancements
Bonneville believes the primary objective of this initiative must be to ensure the Resource Sufficiency Evaluation (RSE) is accurate, effective, and equitably applied to all EIM Entities and the CAISO BA. The CAISO DMM’s recent analysis[2] showed the CAISO BAA was showing thousands of MWs of constrained capacity as available in its bid-range capacity test during tight conditions last summer. As a result, DMM recommended that CAISO eliminate constrained capacity that would be unavailable regardless of EIM transfers from the bid-range capacity test. This recommendation should be explicitly included within the scope of this initiative.
Additionally, Bonneville requests this initiative explicitly address other remaining shortcomings that contributed to the RSE results of last summer showing the CAISO BAA passing the RSE while in energy emergency stages 2 and 3. These should include at a minimum:
- Appropriate treatment of EIM transfers
- A comprehensive methodology for addressing uncertainty
- Re-consideration of how ancillary services are accounted for
- Development of a process for ongoing review of the RSE results.
Regarding the decisional classification, the EIM Governing Body is given advisory authority for this initiative. However, this initiative should undoubtedly be within the EIM Governing Body’s primary authority given that the EIM RSE would not exist but for the EIM.
[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 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] Section 3 of the CAISO Department of Market Monitoring 4th Quarter 2020 Report on Market Issues and Performance, Q4 2020 - Final (caiso.com).
