California ISO - All comments

Arizona Public Service

Submitted 09/03/2020, 07:11 am

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support with caveats

2. Provide a summary of your organization’s comments on this proposal:

Arizona Public Service (APS) appreciates the opportunity to comment on the California Independent System Operator (CAISO) Real-Time Settlement Review Initiative. APS supports the proposal of financially settling BASE ETSR schedule deviations at SP-Tie prices to resolve issues regarding asymmetrical settlement for wheeling through EIM BAA’s. In addition, APS believes CAISO’s proposal that allows EIM entities using a load derivation approach to choose whether to settle unaccounted for energy (UFE) will be an enhancement for settlement; APS recommends CAISO provide numerical examples to demonstrate the end-to-end settlement impact to the whole market on all related UFE elements. This will help stakeholders obtain a full understanding prior to having to make a decision to either settle or not settle UFE.

3. Provide detailed comments including examples on the real-time settlement metrics:

APS is pleased that CAISO is conducting metrics analysis to ensure proper settlement. We recommend that CAISO provide the following details and additional guidance/training to stakeholders to help market participants provide meaningful review before CAISO implements additional changes.

Provide numerical examples to illustrate methodology of metrics, and how they were used to inform the proposed changes in this initiative.
- Provide specific example where the metrics identified an issue with market settlements.
Make the metrics available in settlement data so stakeholders can review the metrics against actual data.

APS appreciates CAISO to continue monitoring these metrics on a periodic basis and share the measurement results with stakeholders so market participants can work with CAISO to ensure settlement is properly reflecting market optimization.

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

APS supports the proposal of financially settling BASE ETSR schedule deviations at SP-Tie prices to resolve issues regarding asymmetrical settlement for wheeling through EIM BAA’s. APS would like the CASIO to provide clarification on the implementation timeline for this initiative. Originally when APS agreed to interim/immediate asymmetrical solution it was presented as a fall 2020 implementation. The timeline in this initiative does not address other CAISO communications stating a 1/1/2021 go live with retroactive resettlements to 10/1/2020.

Retroactive adjustments to 10/1/2020 will create potential financial exposures and/or uncertainties to stakeholders’ 2020 Financial Statements. Typically, an accrual would be created for this exposure, but given stakeholders’ do not have access and full visibility into the data needed to re-create the change to the Base ETSR settlement and RTCO charge code change, it is not possible for EIM entities to calculate and estimated accrual. APS recommends CAISO not to retroactively adjust TD 10/1/2020 through TD 12/31/2020 settlement.

If CAISO has already decided to proceed retroactive adjustments, APS requests CAISO to provide each EIM entity the estimated/changed dollar amounts with supporting calculation details to ensure the adequacy of our Financial Statements and in compliance with the reporting requirement for Generally Accepted Accounting Principles (GAAP).

5. Provide detailed comments including examples on the unaccounted for energy settlement:

APS believes CAISO’s proposal to allows EIM entities who are using a load derivation approach to choose whether to settle unaccounted for energy (UFE) will be an enhancement. However, it is APS’ opinion that CAISO has not yet fully explained all downstream impacts of electing or not settle UFE to the EIM entities. APS recommends CAISO provide further clarification why UFE exists in the current state, and if there could be impacts if some entities elect to settle UFE and others do not settle UFE.

The UFE settlement is associated with unaccounted for energy derived from: (1) Loss factor differences between EIM entities’ OATT rates vs. CAISO’s Actual Loss rates from energy flow, and (2) other load deviation, example: differences between 5-minute meter value vs. hourly meter value. APS would like to suggest if CAISO can remove the loss factor differences, but still account for other load deviation for UFE settlement. If the UFE settlement is completely eliminated, APS is concerned that unaccounted for energy issues will be obscured by processing deviations through UIE on Load, and/or RTIEO & RTCO neutralize process. Continuing to settle final load deviations will help EIM participants focus on the cause of the UFE and perform analysis to address/resolve potential issues. The existing proposal could result in stakeholders losing transparency around UFE load deviations in the RTIEO and RTCO settlement.

If EIM entities elect not to settle UFE, CAISO will assume the OATT loss factor of zero and will not calculate losses into the hourly load base schedule, and the EIM entity will not incorporate losses in the load derivation meter calculation. Given that losses will not be accounted for, APS would like to obtain further clarifications on how the actual loss of energy will be accounted for in settling in this scenario.

Finally, APS recommends CAISO demonstrate the settlement impact by providing numerical example(s) so stakeholders can better understand the change. APS’ concern is if RTIEO and RCTO charge codes will be absorbing the changes from eliminating UFE, as those are sub-allocated to transmission customers.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

APS requests CAISO to provide stakeholders for any related configuration/design modification in a timely manner. For example, the logic behind BASE ETSR pricing may impact stakeholders’ pricing library and could require remapping price locations in the vendor system. Sufficient time to allow stakeholders to implement system changes needs to be included in the initiative’s timeline. Furthermore, CAISO should ensure all necessary testing will be performed prior to implementation.

Bonneville Power Administration

Submitted 09/04/2020, 08:46 am

Contact

Sarah Burczak

Business Transformation Office

seburczak@bpa.gov

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support

2. Provide a summary of your organization’s comments on this proposal:

Bonneville Power Administration (Bonneville) appreciates the opportunity to comment on the CAISO Real-Time Settlement Review Straw Proposal dated Aug. 17, 2020.

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 in general is supportive of the implementation of the initiative and has a few specific comments on the proposal to allow energy imbalance market entities using a load derivation approach to choose whether to settle unaccounted for energy.

3. Provide detailed comments including examples on the real-time settlement metrics:

Bonneville is supportive of the proposed real-time settlement metrics enhancements. The three metrics being proposed will help improve the transparency of the market results and allow EIM entities better insight into which portion of real-time market (i.e., FMM or RTD) is driving the real-time neutrality. Bonneville believes that these metrics will be a valuable enhancement and will help the CAISO and EIM entities better understand the potential cost drivers of financial neutrality, the allocation of congestion costs, and potential costs shifts between balancing authority areas.

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

Bonneville supports.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

BPA supports the CAISO’s proposal to allow EIM entities to choose between a “load aggregation” or a “load derivation” approach for calculating load. This proposal recognizes that the “load derivation” approach is the most common practice being used by EIM entities and that the settlement of unaccounted for energy (UFE) for those entities serves no practical purpose. For those using the “load derivation” approach, all energy has been accounted for due to the use of a top-down (i.e., generation minus interchange) “load derivation” approach for the purposes of calculating the balancing authority area load meter. As such, the settlement of UFE for EIM entities using the “load derivation” technique is unnecessary, due to all energy having been already accounted for, and only serves to complicate EIM settlements with no perceivable benefits. Further, most EIM entities already recover the bulk of the BAA losses through various OATT provisions. BPA also supports the option to use a “load aggregation” method and to continue settling UFE for those BAAs that wish to do so.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

California Department of Water Resources

Submitted 09/03/2020, 11:18 am

Contact

Rodrigo Avalos (rodrigo.avalos@water.ca.gov)

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

No position

2. Provide a summary of your organization’s comments on this proposal:

CDWR is not an EIM Entity, however supports CAISO’s efforts in streamlining the EIM settlements process in Real Time. CDWR asks the CAISO to clarify any potential indirect impact on market participants within the CAISO BAA. CDWR assumes minimal to no impact, and it would be helpful if CAISO clarifies which scheduling coordinator charge codes may be impacted by this proposal, and how?

3. Provide detailed comments including examples on the real-time settlement metrics:

None.

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

None.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

None.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

None.

Idaho Power Company

Submitted 09/03/2020, 02:31 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support with caveats

2. Provide a summary of your organization’s comments on this proposal:

Overall, Idaho Power is generally supportive of the recommendations in this proposal, but requests further information on metric data and on UFE examples and analysis.

3. Provide detailed comments including examples on the real-time settlement metrics:

Idaho Power appreciates CAISO’s commitment to maintain and improve the quality and transparency of market settlements by generating metrics to monitor settlements performance and accuracy and identify any inappropriate cost shifting that may be occurring as part of the real-time market settlement process. To promote transparency and the ability for entities to make recommendations on additional metrics, CAISO should clarify and provide further detail on the following:

How the metrics listed on pages 4-6 of the Real-Time Settlement Review Straw Proposal are being consistently evaluated. For example, CAISO indicates for both Metric 1 and 2 that they can be produced per BAA or for the EIM area as a whole. In addition, CAISO states that the metrics can be evaluated for each trade date or over a period. Please provide details and clarification on how these metrics are being evaluated on a consistent basis (what EIM area(s) are being regularly evaluated, what time frames are being evaluated, and how often are they being evaluated).
Provide metric data to EIM Entities. Idaho Power appreciates that CAISO is evaluating these metrics, but given the importance of transparency and accuracy in settlements, CAISO should share the metrics with EIM Entities as well. This will allow EIM Entities to perform their own analysis independently on an on-going basis.

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

Idaho Power is generally supportive of the proposal on the asymmetrical wheeling issue.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

Idaho Power appreciates CAISO evaluating the appropriateness of the current settlement of UFE. Idaho Power has observed for some time that UFE is caused by the difference between CAISO’s real time power flow loss factor and our OATT loss rate that is applied to our load meter for settlement purposes.

Idaho Power is preliminarily supportive of the proposal to allow EIM Entities that use the load derivation approach for measuring demand to choose whether to settle UFE. However, Idaho Power needs more information to fully analyze the proposal:

CAISO should provide specific examples (using actual trade data), of settling UFE vs. not settling UFE for those EIM Entities that use the load derivation approach.
CAISO should provide any analysis it has performed of this proposal. In addition, CAISO should provide the data necessary for each EIM Entity to perform its own determination of whether this change is appropriate for it.
CAISO should confirm and demonstrate through data or analysis that giving EIM Entities the option to settle or not settle UFE will not create further seams issues, neutrality, or settlement mismatches in other charge codes. For example, the fact that EIM Entities have the option to settle or not settle Base ETSRs has created issues that CAISO is now trying to solve in this very initiative. CAISO should demonstrate that the option of not settling UFE does not create any additional impacts to the accurate settlement of EIM transactions.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

Pacific Gas & Electric

Submitted 09/04/2020, 02:51 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support

2. Provide a summary of your organization’s comments on this proposal:

PG&E supports the CAISO in this proposal and appreciates the CAISO’s intent to more closely monitor the Real-Time Market Processes use data-driven metrics.

3. Provide detailed comments including examples on the real-time settlement metrics:

PG&E appreciates and supports the development and maintenance of the Real-Time Settlement Metrics introduced in section 3 of this initiative. We commend the CAISO for their efforts to use the ongoing market data to identify and address the root drivers of inappropriate Real-Time market uplift costs (Real Time Marginal Losses Offset, Real Time Congestion Offset, and Real Time Imbalance Energy Offset)

PG&E would also encourage the CAISO to expand their metrics beyond the proposed assessments to also examine other Real-Time market behaviors, including the actual financial and energetic impacts of unscheduled energy flows between BAA entities.

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

PG&E supports the proposed changes as we believe that the proposed modifications will allow for a more accurate settlement process.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

While PG&E believes that the energy settlement process should use verified revenue meters whenever possible, we understand that not all EIM entities currently have a complete set of load meters on their distribution system. In such circumstances we feel that the alternate unaccounted for energy (UFE) calculation is an appropriate settlement mechanism for ensuring accurate cost allocation for regional unmetered load deviations.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

N/A

PacifiCorp

Submitted 09/04/2020, 01:06 pm

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support

2. Provide a summary of your organization’s comments on this proposal:

PacifiCorp appreciates the opportunity to comment and supports the CAISO’s proposals to resolve the identified issues related to asymmetrical wheeling settlement and unaccounted for energy settlements.

3. Provide detailed comments including examples on the real-time settlement metrics:

No comments

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

PacifiCorp supports the CAISO’s proposal to resolve the asymmetrical wheeling settlement issue and has already provided the CAISO with an attestation for the CAISO to settle all base energy transfer system resources (“ETSRs”) with existing and any new EIM entities. PacifiCorp is continuing to work with existing EIM entities on the appropriate ETSR changes to allow the CAISO to settle all base ETSRs.

5. Provide detailed comments including examples on the unaccounted for energy settlement:

PacifiCorp appreciates the CAISO’s attention and work on this issues surrounding unaccounted for energy settlements, and supports the CAISO’s proposal to allow EIM entities using a load derivation approach to choose whether or not to receive unaccounted for energy (“UFE”) settlements from the CAISO.

PacifiCorp requests that the CAISO explore whether it can implement this proposal sooner than the fall of 2021 target date, and in any event, as soon as possible. The UFE charges PacifiCorp receives every day are significant and PacifiCorp would appreciate a sooner implementation if at all possible.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

No comments

Portland General Electric Company

Submitted 09/04/2020, 07:59 am

1. Provide your organization’s overall position on the Real-Time Settlement Review issue paper/straw proposal:

Support with caveats

2. Provide a summary of your organization’s comments on this proposal:

3. Provide detailed comments including examples on the real-time settlement metrics:

4. Provide detailed comments including examples on the asymmetrical wheeling issue:

5. Provide detailed comments including examples on the unaccounted for energy settlement:

While PGE is generally supportive of the CAISO’s proposal to provide EIM Entities the option not to settle UFE, it’s not entirely clear when reading the straw proposal what the full implications of such an election would be. PGE recommends that the CAISO’s next draft include the following details:

A more comprehensive description of the settlement mechanics associated with an entity’s decision not to settle UFE. For instance, the CAISO indicated in the stakeholder meeting that a “flag” would be used to identify whether an entity has elected to settle for UFE. The CAISO also indicated that an entity should still expect to see the real time loss determinant in their settlement calculations, but that for an entity who had elected not to settle UFE, the UFE equation would simply equal “zero.” Providing this level of detail is extremely helpful to stakeholders but the description the CAISO has provided in the straw proposal lacks specificity;
For comparison, stakeholders would benefit from additional settlement examples that detail how each of the corresponding determinants are calculated under the two options. Additionally, it’s not clear to PGE how charge codes that use and/or rely upon the same determinants that are used in the calculation of UFE would be impacted. For example, the straw proposal indicated that the EIM Entity will apply an OATT loss factor of zero in the load derivation meter calculation and that the ISO will exclude the EIM BAA from calculation of UFE. Implicit within this statement, however, is that an EIM Entity’s load base schedule will be calculated differently, and, as such, there will be impacts to Uninstructed Imbalance Energy (UIE) for load. Additionally, because UFE and UIE are offset in RTIEO there will be impacts to CC 64770. Providing examples that walk through or highlight the full extent of these changes (and changes to other charge codes that stakeholders may not be considering) will be enormously helpful in preparing entities to make informed decisions about their election options.

6. Additional comments on the issue paper/straw proposal or Real-Time Settlement Review initiative:

Would a change in PGE's five-minute submitted ELAP load impact the requirement amount for balancing a test in any way? In other words, is that an input to the load forecasting model?