Comments on Draft final proposal

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

Avista appreciates the opportunity to provide comments on this Initiative. Avista is generally in support of the changes proposed in the final draft proposal; it is essential to note that WA CCA program final rules were issued Thursday, 9/29/22, after the conclusion of the stakeholder call on the same day. Therefore, Avista will need additional time to examine this language to understand its effects on EIM entities and looks forward to collaborating on a longer-term solution to support WA reporting when Washington opens its rulemaking on treating EIM imports.

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

CAISO had initially proposed to model the geographic boundaries of Washington to differentiate load and generation inside and outside Washington. However, Avista appreciates that the CAISO was responsive to several stakeholders’ concerns that the incorporation of this step should wait until program design rules are finalized and reevaluate if needed.

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

Updating GHG reference costs, Avista agrees with the phased approach CAISO proposes for data sources on allowance prices for updating the GHG reference costs associated with dispatching those resources.

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

As a multijurisdictional utility, Avista looks forward to furthering collaboration with Ecology and CAISO to examine this underlying data and determine an appropriate approach to quantify Avista’s obligation in the state.

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

 Avista supports CAISO’s proposal of joint authority for this Initiative.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

no additional comments.

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

Bonneville would like to thank CAISO staff for their engagement with BPA staff on this issue.  BPA appreciates the CAISO’s recognition of BPA’s unique reporting considerations.  BPA is generally supportive of the CAISO’s draft final proposal.  

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

BPA supports the CAISO not modeling WA borders or making demand forecasts for BAAs with boundaries that span multiple states.  BPA understands the CAISO will provide BPA with instructed energy imbalance, which BPA believes will provide it sufficient information to pro rata allocate this imbalance to Washington loads consistent with the Washington Department of Ecology’s GHG reporting rules.  However, BPA disagrees with CAISO’s characterization that this is just a “rough approximation” of WEIM transactions used to serve load within Washington, as page 9 of CAISO’s Draft Final Proposal suggests.  Rather, as explained in BPA’s previous comments, given the nature of a multistate BAA, this method is no less accurate than the method originally proposed by the CAISO.   BPA looks forward to continued conversations with the CAISO on an appropriate method when Ecology further updates its rules.

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

BPA appreciates the CAISO’s acknowledgement and respect with regard to BPA’s different reporting and market design considerations.  BPA clarifies that while the GHG reference costs do not apply to BPA’s participating resources, it generally supports the concept. 

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

See response to question 2 above.

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

No comment.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

No comment.

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

PacifiCorp appreciates the opportunity to provide comments on this important Initiative. PacifiCorp is generally in support of the changes proposed in the draft final proposal.  Please note that WA CCA program rules were issued Thursday September 29th, 2022, after the conclusion of the stakeholder call that same day. Consequently, stakeholders will need additional time to examine these to understand effects to EIM entities, and looks forward to collaborating on a longer-term solution to support WA reporting, assuming Washington opens its rulemaking determining the method for addressing imported electricity associated with a centralized electricity market, as required by the CCA by 2026[1].

[1] In consultation with any linked jurisdiction to the program created by this chapter, by October 1, 2026, the department, in consultation with the department of commerce and the utilities and transportation commission, shall adopt by rule a methodology for addressing imported electricity associated with a centralized electricity market. (RCW 70A.65.080(1)(c))

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

CAISO had originally proposed to model the geographic boundaries of Washington in an attempt to differentiate load and generation inside and outside Washington.  PacifiCorp appreciates that the CAISO was responsive to several stakeholders’ concerns that this step was premature and removed that element from the proposal.   

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

PacifiCorp generally agrees with the phased approach CAISO proposes to address the difficult circumstance of the first allowance auction being after the start of the allowance requirement. 

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

Regarding CAISO’s proposal to support WA reporting with settlement statements (using real-time net negative imbalance energy transactions for the purposes of estimating EIM “imports” into the state) PacifiCorp, as a multijurisdictional utility, looks forward to further collaboration with Ecology and CAISO to examine this underlying data and determine an appropriate approach to quantify PacifiCorp’s obligation in the state.

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

PacifiCorp supports  CAISO’s proposal of joint authority for this Initiative.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

PacifiCorp has no additional comments at this time.

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

Powerex appreciates the opportunity to comment on the CAISO’s September 22, 2022 Washington State Western Energy Imbalance Market Greenhouse Gas Enhancements Draft Final Proposal (“Draft Final Proposal”)[1].

The Draft Final Proposal Will Double-Count The Output Of Clean Washington Resources

As described in the Draft Final Proposal, CAISO would use EIM dispatches, based on instructed imbalance energy, to provide WEIM entities with an annual calculation of WEIM transactions used to serve electricity demand in Washington.

The specifics of how this calculation would be performed are unclear from the Draft Final Proposal. During the stakeholder call on September 29, however, CAISO indicated that it intends to calculate a “net” EIM transaction quantity for WEIM entities in Washington equal to:

• An entity’s total load served by the WEIM; minus
• The entity’s internal generation dispatched in the WEIM.

This calculation will serve as a proxy for the quantity of WEIM imports for the respective entity.

For example, Powerex’s understanding is that an entity in Washington with 1000 MW of load served by the WEIM and 800 MW of internal generation dispatched in the EIM would be calculated to have received 200 MW of WEIM imports for purposes of Washington State GHG reporting (i.e., 1000 MW load – 800 MW generation = 200 MW import).

Netting the dispatches of internal generation and load in Washington implicitly “assigns” all of the output of in-state resources to serving Washington load. However, the CAISO already uses a separate algorithmic “deeming” approach to assign the output of resources outside of California – including EIM resources located in Washington – to imports into California that serve California load. The CAISO uses this “deeming” approach for reporting purposes under California’s Cap and Trade Program.

It is critical to note that the CAISO’s WEIM optimization model identifies resources, including those located in Washington State, as “deemed delivered” to California to be serving load in California.[2]  This can occur even when the resource is not actually increasing its production in the EIM, and even when the BAA in which it resides is not actually exporting any energy.  

Powerex believes this will result in systemic double-counting of the output of clean resources in Washington—and particularly Washington hydro resources—as simultaneously meeting load in two different states.  Specifically, the same megawatts from the same clean resource will be:

1. Explicitly deemed to have been exported from Washington to serve load in California (by the CAISO’s deeming algorithm); and simultaneously
2. Implicitly assigned to meet Washington load (through the netting of generation and load to calculate each entity’s WEIM imports).

For example, assume an entity in Washington has:

• 1000 MW of load served by the WEIM;
• 800 MW of internal generation that is dispatched by the WEIM; and
• All 800 MW of the WEIM output is deemed to be delivered to California.

In this case, CAISO apparently intends to calculate and report that the entity received only 200 MW of EIM Imports.  The inescapable implication is that the 800 MW produced by the resources in Washington will be simultaneously reported to:

• Washington State’s Department of Ecology as serving load in Washington State; and also
• California’s Air Resources Board as serving load in California.

The Draft Final Proposal confirms that CAISO does not intend to make any adjustments to its proposed calculation of net WEIM imports to Washington to reflect instances when the output of Washington resources is deemed to serve California load. 

Not a Hypothetical Concern - Evidence from 2021

Powerex notes that the double-counting concern is not hypothetical, nor would it be insignificant.[3] Powerex’s recent analysis of the WEIM GHG approach illustrates that the WEIM deeming algorithm already results in a volume of annual deemed deliveries from hydro-based BAAs that substantially exceeds the total EIM exports from those BAAs, sometimes multiple times over.

Washington regulation creates an obligation to report a wide range of import and export activity, including that which occurs through the EIM.[4]  Failure to acknowledge and include the magnitude of Washington State generation that the CAISO’s optimization model is deeming to be exported out of Washington in order to serve load in California leaves a glaring and unreported gap, as there will be no tracking or record of the volume or type of generation that must implicitly be imported into Washington State to make up for the deemed exports to California. 

The Draft Final Proposal explicitly identifies that “…Washington resources attributed to California will not impact volume of net WEIM transfers into WA, as the GHG transfers will not be calculated.”[5]  It is critical to note that:

1. Washington clean resources that are deemed to have served California load are paid an explicit payment (GHG shadow price) by CAISO in the EIM for this delivery.

2. Failure to recognize the offsetting unspecified imports to Washington State that are created by deeming Washington generation as serving California load, will:

1. reduce the demand for Washington State carbon allowances; and  
2. reduce the incentives to procure new clean and renewable supply by allowing the same clean resources to simultaneously meet load in two different states.

The CAISO’s proposed calculation of imports will result in clear and unambiguous double-counting of clean resource output towards both California and Washington’s carbon pricing programs, and is in clear conflict with the environmental goals of these programs.  Powerex urges the CAISO to revise its calculation of imports.  Avoiding this double-counting would be straightforward, requiring that the reported import quantity into Washington State for each applicable entity for each interval be increased to properly reflect the quantity of that entity’s Washington sourced electricity that the CAISO is reporting as serving load in California.

The Draft Final Proposal Risks DEBs That Do Not Allow Washington GHG-Emitting Resources To Accurately Reflect Their GHG Compliance Costs

Powerex supports the CAISO’s proposal to allow generation resources located inside Washington state that are subject to Washington GHG regulation to include GHG compliance costs in the calculation of their default energy bids and default commitment costs, recognizing that these are real costs that in-state generators face (and therefore will appropriately include in their hourly offer prices in the WEIM). 

Prior to an allowance auction in Washington, CAISO proposes to use $41/MTCO₂e as a proxy for the cost of Washington GHG allowances. CAISO’s proposal is based on a modelling scenario produced by Vivid Economics that assumes that the Washington program will be linked with California by 2025. The same report also provides a second “no linkage” scenario that results in an estimated allowance cost of $58/MTCO₂e. Both values are estimates only. The only known information regarding the potential cost of allowances that will be available prior to an auction is the ceiling price, expected to be roughly $80/MTCO₂ for 2023[6].

Powerex believes CAISO must balance two competing risks:

• That an inaccurately low DEB could cause Washington resources to sell their output below their actual costs (including their own independent estimate of their GHG compliance costs) when CAISO’s market power mitigation procedures are triggered; or
• That an inaccurately high DEB could allow GHG-emitting resources in Washington to successfully identify and exercise local market power by increasing their offer prices relative to their actual costs, and that those actions could have a material impact on competitive outcomes in the WEIM.

Powerex believes that this latter potential risk - of local market power being exercised based on over-stated GHG costs - is very limited, for several reasons:

1. The difference between using the allowance ceiling price of approximately $80/MTCO₂e (relative to CAISO’s proposal to use $41/MTCO₂e) is only roughly $17/MWh[7] for a typical natural gas plant;
2. The timeframe for using the cap is limited until the first auction occurs; and
3. The WEIM is a competitive market in which natural gas resources in Washington will continue to be highly incented to offer their supply at their estimated marginal costs.

For these reasons, Powerex believes that the risk of local market power being exercised and having a material impact on competitive market outcomes due to over-stated GHG costs is de minimis and falls well short of warranting the negative consequences of potentially over-mitigating resource to levels that are below their costs.

Powerex instead believes that CAISO should respect the autonomy of each market participant to submit offers that are consistent with their own independent estimate of their operating costs, including their potential GHG compliance costs.

[1] Draft Final Proposal - Washington WEIM Greenhouse Gas Enhancements

[2] CARB MRR §95102 - “Imported electricity” means electricity generated outside the State of California and delivered to serve load located inside the State of California.…. Imported electricity shall include Energy Imbalance Market (EIM) dispatches designated by the CAISO's optimization model and reported by the CAISO to EIM Participating Resource Scheduling Coordinators as electricity imported to serve retail customers load that are located within the State of California. (definition shortened, emphasis added).

[3] See Powerex.com (July 2022). “Examining the Western EIM’s Deeming Approach to GHG Pricing Programs” (executive summary and full paper available).  Chart 12 from the full paper demonstrates that several balancing authorities experienced deemed exports of specified generation to California that exceeded their total physical exports during the same periods.

[4] WAC 173-441-124.(3).(a).(ii) Delivered electricity. The electric power entity must report imported and exported electricity in MWh disaggregated by first point of receipt (POR) or final point of delivery, as applicable, and must also separately report imported and exported electricity from unspecified sources and the energy imbalance market, and from each specified source. First points of receipt and final points of delivery (POD) must be reported using the standardized code used in e-tags, as well as the full name of the POR/POD. (emphasis added)

[5] CAISO Draft Final Proposal, page 9.  GHG Transfers as calculated by CAISO are otherwise referred to as “deemed deliveries” from outside California to serve California load.

[6] See WAC 173-446-335 (page 59) for an explanation of the calculation of the auction ceiling price.

[7] A typical gas plant in Washington may face a potential GHG compliance cost of approximately $34.50/MWh (i.e., 0.43 MTCO₂e/MWh * $80/MTCO₂e). CAISO’s proposal to use an allowance price of $41/MTCO₂e, however, would only allow a gas plant to include GHG costs in its default bid for approximately $17.50/MWh.

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

Please see comments above.  

Powerex’s comments are also available at Washington WEIM Greenhouse Gas Enhancements Draft Final Proposal Comments

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

Please see comments above.  

Powerex’s comments are also available at Washington WEIM Greenhouse Gas Enhancements Draft Final Proposal Comments

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

Please see comments above.  

Powerex’s comments are also available at Washington WEIM Greenhouse Gas Enhancements Draft Final Proposal Comments

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

Please see comments above.  

Powerex’s comments are also available at Washington WEIM Greenhouse Gas Enhancements Draft Final Proposal Comments

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

Please see comments above.  

Powerex’s comments are also available at Washington WEIM Greenhouse Gas Enhancements Draft Final Proposal Comments

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

PGP generally supports the proposal and appreciates CAISO’s responsiveness to the Washington Utilities’ comments. PGP requests further clarification with respect to treatment between transfers between WEIM Entities that are fully within Washington, as articulated below. 

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

PGP supports the removal of modeling Washington’s borders and demand forecast, for the reasons discussed in the Washington Utilities comments submitted September 6, 2022. 

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

PGP is supportive of the approach proposed but requests further review of the reference costs following implementation of the program in January 2023 and the first allowance auction in February.

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

While PGP is generally supportive of the approach proposed, there is one remaining point of clarification with respect to reporting of imports from the WEIM.  On September 29, 2022, the Washington Department of Ecology issued its final program rules implementing the Climate Commitment Act Cap-and-Invest Program.  In section WAC 173-446-040, the rules clarify that for electricity transferred through the energy imbalance market that is generated by a first jurisdictional deliverer with a compliance obligation, there is no compliance obligation for that same electricity if it is delivered to an energy imbalance market purchasing entity in Washington.  PGP is interpreting this language to indicate that a transfer from one WEIM Entity to another WEIM Entity wholly within Washington would not incur a compliance obligation.

PGP understands that WEIM Entities can use dynamic ETSR e-tags to identify transfer quantities from each WEIM Entity and can therefore separately identify transfers from other WEIM Entities that are wholly within Washington State.  However, PGP requests further discussion with the CAISO to understand how to identify the portion of those transfers that are wheel-throughs versus portions that are sunk within a WEIM Entity in Washington. PGP’s understanding of Ecology’s rule is that energy that is wheeled through a WEIM Entity BAA would not incur a compliance obligation.  While WEIM Entities can determine total wheel-throughs, PGP is not aware of a way to separately identify the source of those wheel-throughs.

PGP also believes that further discussion with the Dept. of Ecology is warranted with respect to how to treat transfers from multi-state WEIM Entities with footprints partially in Washington (PacifiCorp, Avista, BPA) to WEIM Entities wholly within Washington.  However, PGP’s view is that there is not sufficient clarity in Ecology’s current rules for further clarification or changes from the CAISO at this time. 

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

PGP supports the proposal for joint authority for this initiative.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

None at this time. 

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

Puget Sound Energy (PSE) acknowledges the complexities with this initiative and timing relative to the parallel rulemaking at the Washington Department of Ecology (Ecology)[1] for the Climate Commitment Act program rules and appreciates the CAISO taking its prior comments into consideration. PSE is generally supportive of the proposed changes, though it would appreciate a public disclosure by CAISO of the basis of regulatory support for its interpretation for the requirement to apply a GHG cost to default energy bids to Washington resources. PSE also seeks clarification if this change would apply only to Washington-sited resources, or all resources committed to serve Washington load. Additionally, Ecology’s final rules published September 29, 2022 create the need for further discussion of next steps with regard to the long-term WEIM approach to addressing the complexities of Washington’s Climate Commitment Act.

[1] WAC 173-446

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

PSE supports CAISO’s proposal not to include modeling of the Washington border and demand forecast at this time.

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

PSE supports CAISO’s 3-phase approach to updating GHG reference costs for Washington resources, but acknowledges this may need to be revisited as stakeholders work through Ecology’s final rules and subsequent clarification and guidance. As stated above, PSE seeks clarification if this change would apply only to Washington-sited resources, or all resources committed to serve Washington load.

The interim carbon price proposed ($41) from the Ecology Preliminary Regulatory Analysis, strikes a reasonable and appropriate balance between the cap and the floor, absent auction indicative price discovery that will be provided in the second phase of CAISO’s approach. The third phase, independent broker pricing, will likely price in the expectation of the market and future auctions more accurately than the prior auction price used in phase two.  

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

As stated above, PSE supports CAISO’s proposal to use real-time net negative imbalance energy transactions in WEIM entity settlement statements for the purposes of estimating WEIM “imports” into the state.

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

PSE does not object to CAISO’s classification of joint authority of the WEIM Governing Body and the CAISO Board of Governors over the tariff changes in this proposal.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

PSE recognizes the asymmetrical bid outcomes that may occur as a result of the Washington program and acknowledges that this asymmetry is not in all cases within the CAISO’s control. The company looks forward to CAISO convening a stakeholder process to develop a market design and associated settlement process to best address this asymmetric treatment.

Lastly, PSE supports the comments of the Public Generating Pool with respect to Ecology’s final rules for treatment of electricity delivered from a first jurisdictional deliverer to an energy imbalance market purchasing entity in Washington[1]. While it is not in the scope of this immediate proposal, PSE agrees further discussion with Ecology is warranted with respect to how to treat transfers from multi-state WEIM Entities with footprints partially in Washington (PacifiCorp, Avista, BPA) to WEIM Entities wholly within Washington. 

[1] WAC 173-446-040

1. Please provide a summary of your organization’s comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

WPTF appreciates the changes that CAISO has made in response to comments from WPTF and others to the draft final proposal on Washington WEIM Greenhouse Gas Enhancements. However, WPTF remains concerned about the approach proposed to support GHG reporting by Washington EIM entities in 2023 and beyond. Specifically, we are concerned that the policy does not align with the regulations regarding treatment of WEIM transactions.

2. Provide your organization’s comments on the initiative’s removal of modeling Washington borders and the demand forecast, as discussed in section 3.1:

No Comment.

3. Provide your organization’s comments on updating greenhouse gas reference costs, as described in section 3.2:

No Comment.

4. Provide your organization’s comments on WEIM greenhouse gas reporting, as described in section 3.3:

WPTF is concerned that the policy does not align with the Washington regulations with regards to the treatment of WEIM transactions. Specifically, in the draft final proposal the CAISO states that “…the CAISO will not separate what is served by a Washington or non-Washington BAA. The CAISO will calculate the WEIM market dispatches based upon instructed imbalance energy, the difference between the market real time market dispatch and base schedule of BAA generation and net schedule interchange. From a settlements perspective this is the net positive instructed imbalance energy quantity (Fifteen Minute Market Instructed Imbalance Energy + Real Time Market Instructed Imbalance Energy) which captures instances when a supply resource increased its output to serve load based on a forecast with a base schedule reference.”

During the September 29^th stakeholder call, CAISO staff reiterated the interpretation that Washington will treat all transactions in the WEIM used to serve load within Washington as imported energy.” As we have stated previously, this interpretation is incorrect.

Paragraph 2(g) of WAC 173-441-124 defines “Imported electricity” as “electricity generated outside Washington state with a final point of delivery within the state.” Paragraph 2(g)(i) further clarifies that “Imported electricity" includes electricity from an organized market, such as the energy imbalance market.” Paragraph 2(g)(i) does not however in any way negate the overriding principle that imported electricity must be generated outside the state. Thus, CAISO’s interpretation is in conflict with Washington’s GHG reporting requirement.

This conflict is more apparent in WAC 173-446-040 of Washington’s final cap and invest program rules (italics added): (iv) For the first compliance period the electricity importer for electricity derived from the energy imbalance market is the energy imbalance market purchasing entity located or operating in Washington that receives the delivery of electricity transacted through the energy imbalance market. For electricity transferred through the energy imbalance market that is generated by a first jurisdictional deliverer with a compliance obligation under this chapter, there is no compliance obligation for that same electricity if it is delivered to an energy imbalance market purchasing entity in Washington.

Given these provisions, WPTF sees potential problems with the CAISO’s proposed approach and seeks clarification on the treatment of wheel-throughs. First, by failing to separate what is served by a Washington or non-Washington BAA, CAISO’s approach could result in a compliance obligation for the WEIM purchasing entity for electricity generated within Washington, which is already subject to the cap and invest program at the generator level. Secondly, WPTF seeks clarification on the treatment of wheel-throughs. Specifically, we would appreciate clarification, and confirmation of our understanding, that the CAISO’s approach will not result in a Washington EIM entity having a compliance obligation by virtue of the fact that electricity imports are wheeled through its system to another Washington or non-Washington EIM entity. 

WPTF therefore urges CAISO to modify its approach to ensure that a) only electricity that originates in a BAA that is not located completely within Washington[1] is treated as an import, and b) EIM imports are not attributed to a Washington EIM entity for energy that is wheeled through that entity’s system.

[1] Electricity sourced from the BPA, Avista and Pac-West BAAs should be treated as EIM imports, because of how these entity systems are treated in the Washington Cap and Invest and Reporting rules.

5. Provide your organization’s comments on the proposed WEIM Governing Body role, as described in section 4:

No Comment.

6. Provide any additional comments on the Washington WEIM Greenhouse Gas Enhancements draft final proposal and September 29, 2022 stakeholder call discussion:

No Comment.