California ISO - Department of Market Monitoring
Submitted 09/23/2020, 09:01 am
2.
Provide your organization’s comments on Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
3.
Provide your organization’s comments on Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
4.
Provide your organization’s comments on Appendix N, Section 3 Pseudo-Ties of Shared Resources to the California ISO Balancing Authority Area:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
5.
Provide your organization’s comments on the draft Appendix B.16 - Pseudo-Tie Participating Generator Agreement
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
6.
Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
7.
Please provide your organization’s overall position on the final proposal:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
8.
Provide a summary of your organization's comments on this proposal:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
9.
Provide your organization’s comments on the metering and telemetry requirements, as described within the final proposal:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
10.
Provide your organization’s comments on the outage and management reporting requirements, as described within the final proposal:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
11.
Provide your organization’s comments on the treatment of minimum load and start-up costs, as described within the final proposal:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
12.
Provide any additional comments on the final proposal for the Pseudo-Ties of Shared Resources initiative:
Please see item1 for comments on Final Proposal & Revised Draft Tariff Language
Six Cities
Submitted 09/18/2020, 01:05 pm
Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
1.
Please provide summary of your organization’s comments on the revised draft tariff language:
Oppose with caveats
As described below, the Six Cities have several significant concerns with the revised draft tariff language and the Pseudo-Tie Participating Generator Agreement, particularly (1) concerns with application of the allocation protocol to owners of shared resources that elect not to enter into a pseudo-tie arrangement, and (2) proposed provisions in the draft tariff language and the Pseudo-Tie Participating Generator Agreement that fail to ensure the ability of portions of shared resources to participate in the CAISO markets in the event a pseudo-tie arrangement is suspended or terminated.
2.
Provide your organization’s comments on Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area:
3.
Provide your organization’s comments on Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area:
4.
Provide your organization’s comments on Appendix N, Section 3 Pseudo-Ties of Shared Resources to the California ISO Balancing Authority Area:
Re Proposed Section 3.2.1 Each Scheduling Coordinator that represents a Generating Unit share participating in a CAISO Market as a Pseudo-Tie Generating Unit must operate in accordance with an allocation protocol. The resource owners must agree upon a shared resource allocation protocol that satisfies the CAISO allocation protocol requirements of this Section 3 of Appendix N, and they must appoint a Scheduling Coordinator as the protocol administrator. The Scheduling Coordinator appointed as the protocol administrator will provide telemetry to CAISO, coordinate the shared logical metering procedure, and ensure that the combined operational characteristics of the shares do not exceed the associated physical capability of the resource. The obligations of the Scheduling Coordinator appointed as the protocol administrator are in addition to the obligations of a Scheduling Coordinator that represents any individual share.
Six Cities’ Comment: The Six Cities oppose deletion of the language shown as stricken from the first and second lines above. CAISO’s proposal to delete that language is inconsistent with its assurances that shares of Generating Units have the option of continuing to participate in CAISO markets as dynamically scheduled resources. It also is inconsistent with the proposed language in Section 3.2.4 that would allow a Generating Unit whose Pseudo-Tie Resource registration has been suspended to continue participating in CAISO markets as a System Resource.
Re Proposed Sections 3.2.4 and 3.2.5 generally:
Six Cities' Comments: The Six Cities generally oppose the language of these sections as currently drafted and believe that significant modifications are necessary to ensure that portions of shared resources are able to continue participating in the CAISO markets in the event a pseudo-tie arrangement is suspended or terminated. This is essential (1) to be consistent with the CAISO's repeated assurances that participation in a pseudo-tie arrangement is optional, (2) as a matter of fundamental fairness to the owners of portions of shared resources affected by the suspension or termination of a pseudo-tie arrangement, and (3) to ensure that the CAISO markets have continuing access to capacity and energy from resources affected by the suspension or termination of a pseudo-tie arrangement.
5.
Provide your organization’s comments on the draft Appendix B.16 - Pseudo-Tie Participating Generator Agreement
Re Section 3.2.1 generally:
Six Cities' Comments: The Six Cities generally oppose the language of this section as currently drafted and believe that significant modifications are necessary to ensure that portions of shared resources are able to continue participating in the CAISO markets in the event a pseudo-tie arrangement is suspended or terminated. This is essential (1) to be consistent with the CAISO's repeated assurances that participation in a pseudo-tie arrangement is optional, (2) as a matter of fundamental fairness to the owners of portions of shared resources affected by the suspension or termination of a pseudo-tie arrangement, and (3) to ensure that the CAISO markets have continuing access to capacity and energy from resources affected by the suspension or termination of a pseudo-tie arrangement.
6.
Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:
Six Cities' Comment: In light of the significance of the allocation protocol in implementing any pseudo-tie arrangement, the draft allocation protocol template should be posted and made available for comment by stakeholders.
7.
Please provide your organization’s overall position on the final proposal:
8.
Provide a summary of your organization's comments on this proposal:
See Six Cities' previous comments on the proposal.
9.
Provide your organization’s comments on the metering and telemetry requirements, as described within the final proposal:
10.
Provide your organization’s comments on the outage and management reporting requirements, as described within the final proposal:
11.
Provide your organization’s comments on the treatment of minimum load and start-up costs, as described within the final proposal:
12.
Provide any additional comments on the final proposal for the Pseudo-Ties of Shared Resources initiative:
Southern California Edison
Submitted 09/16/2020, 02:24 pm
1.
Please provide summary of your organization’s comments on the revised draft tariff language:
Support
SCE supports the revised tariff language presented by the CAISO. Further SCE encourages the CAISO to review Section 2.2.1.2 of Appenix N for any conlficts with Section 1.2.1.2 and Section 3 of Appendix N. SCE remains supportive of the proposal for a Sharing Protocol, Sharing Protocol Administrator and the use of the CAISO's existing settlement quality metering data methodology for teh metring arrangements among Pseudo-Tied generating units.
2.
Provide your organization’s comments on Appendix N, Section 1 Pseudo-Ties of Generating Units to the California ISO Balancing Authority Area:
SCE supports the amendment made to the initial draft tariff language to reflect the necessary consistency needed with Section 3 of Appendix N to the CAISO’s tariff.
3.
Provide your organization’s comments on Appendix N, Section 2 Pseudo-Ties of Generating Units out of the California ISO Balancing Authority Area:
?SCE encourages the CAISO to review the tariff language at Section 2.2.1.2 of Appendix N for consistency with Section 1.2.1.2 and Section 3 of this Appendix N. A similar amendment that was made to Section 1.2.1.2 may be necessary for Section 2.2.1.2 of Appendix N which requires that the entire output of the Pseudo-Tied generating unit be delivered to the CAISO Balancing Authority but excludes any reference to a share of the generating unit as Section 3, Appendix N requires to accommodate shares owned by non-EIM entities.
4.
Provide your organization’s comments on Appendix N, Section 3 Pseudo-Ties of Shared Resources to the California ISO Balancing Authority Area:
SCE recommends that the CAISO corrects the spelling for Scheduling in Section 3.2.5 of Appendix N of the revised tariff language.
5.
Provide your organization’s comments on the draft Appendix B.16 - Pseudo-Tie Participating Generator Agreement
SCE supports maintaining the terms and conditions currently represented within Appendix B-16 of the CAISO tariff.?
6.
Provide any additional comments on the draft tariff language. Upload redlined tariff language using "attachments" field below:
SCE has no additional comments on the draft tariff language, nor the revised tariff language posted for review by the CAISO.
7.
Please provide your organization’s overall position on the final proposal:
Support
SCE supports the CAISO’s final proposal to modify the scheduling, metering and outage requirements for Pseudo-Tied generating units owned by EIM and non-EIM entities.
8.
Provide a summary of your organization's comments on this proposal:
SCE supports the CAISO’s proposal to modify the scheduling, metering and outage requirements for Pseudo-Tied generating units owned by EIM and non-EIM entities.
9.
Provide your organization’s comments on the metering and telemetry requirements, as described within the final proposal:
?SCE supports the CAISO’s decision to propose use of a settlement quality metering data plan as well as the telemetry arrangements among the generating units operated as Pseudo-Tied generating units as represented within the final proposal.
10.
Provide your organization’s comments on the outage and management reporting requirements, as described within the final proposal:
SCE supports the final proposal for a Sharing Protocol and the described responsibilities of the Sharing Administrator within the final proposal in relation to outage coordination, metering and management reporting requirements.
11.
Provide your organization’s comments on the treatment of minimum load and start-up costs, as described within the final proposal:
SCE supports the distribution among the individual Pseudo-Tied generating units such that the aggregate of the relevant shares is equivalent to the total minimum load and start-up costs for the generating unit.
12.
Provide any additional comments on the final proposal for the Pseudo-Ties of Shared Resources initiative:
