Comments on Phase 1 Draft Tariff Language

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

CESA appreciates the opportunity to provide feedback on the CAISO’s Draft tariff language relative to Phase 1 of the Resource Adequacy (RA) Enhancements initiative. As noted in comments previously filed under this initiative, CESA is generally supportive of the proposals encompassed by Phase 1. In particular, CESA supports the modifications ISO staff have made regarding the minimum state-of-charge (MSOC) proposal, as they minimize the material and financial impacts of said proposal.

In these comments, CESA requests the ISO to amend the Draft Tariff language relative to the MSOC requirement. Specifically, CESA notes the need to include a section that states the ISO will track and report on the use of MSOC when it is triggered. To this end, CESA recommends adding a section (40.5.3) which will detail the tracking responsibilities of the ISO and the usage of that data in a manner consistent with exceptional dispatch (ED).

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

CESA offers no comments at this time.

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

CESA offers no comments at this time.

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

CESA offers no comments at this time.

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

CESA offers no comments at this time.

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

CESA offers no comments at this time.

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

In the RA Enhancements Phase 1 Final Proposal, the ISO introduced a series of modifications to the MSOC proposal including a clear trigger condition, a provision to minimize the number of intervals affected by this requirement, and a sunset provision. Furthermore, the Final Proposal notes the ISO will report on how frequently the minimum state of charge is used, when it was triggered, and may report on the estimated impact that the requirement has on the storage resources on the system.[1] CESA expressed support for these modifications and considers the Draft Tariff language should reflect them as well.

The current Draft Tariff language does not include a consideration of the aforementioned reporting requirements the ISO highlighted in the Final Proposal. To amend this omission, CESA recommends including a section detailing reporting requirements on MSOC use in a manner consistent with ED, as recorded in Section 34.11.4. As such, CESA proposes the following changes to the Draft Tariff language:

            40.5.1  Operation of the MSOC Tool

For the first two years following the effective date of this Section 40.5, on any Trading Day that meets the requirements specified in Section 40.5.2, the CAISO enforces the MSOC Tool in the RTM on Non-Generator Resources that are RA Resources on that day.  The MSOC Tool limits RTM awards to a Non-Generator Resource providing RA Capacity such that, based on its registered operating parameters, the Non-Generator Resource will have sufficient charge to meet its discharge awards from its Day-Ahead Schedule. 

When reviewing market and system conditions on the Operating Day, the CAISO may choose not to apply the MSOC Tool for particular Trading Hours if its assessment of projected conditions reflects that the MSOC Tool is not necessary for system reliability in those Trading Hours. 

The CAISO will monitor the application of the MSOC Tool in order to report on how frequently it is used, the conditions that lead to its trigger, and the estimated impact that the requirement has on the storage resources on the system in line with the requirements specified in Section 40.5.3.

40.5.2  Determining an MSOC Event Day

The CAISO enforces the MSOC Tool for a Trading Day if there is at least one Trading Hour on that Trading Day for which, per Section 31.5.5, the RUC process initially cannot find a feasible solution without adjusting the constraints described in Section 31.5.4.  The CAISO notifies Market Participants in advance of applying the MSOC Tool.

40.5.3  [Not Used] Reporting MSOC Usage

On the fifteenth day of each month, the CAISO shall file with the Commission and post to the CAISO Website an initial report concerning the use of the MSOC tool over the two months prior to the month in which the report is filed. The report shall identify the frequency, volume, costs, and causes behind MSOC use during such period to the extent such data are available. On the thirtieth day of the month following the month in which the initial report is filed, the CAISO shall file with the Commission and post to the CAISO Website a revised and updated report for the same period.

[1] Final Proposal, at 25.

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

CESA offers no comments at this time.

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

LSA and SEIA are submitting comments on the first two items - Planned Outage Enhancements and Operationalizing Energy Storage/Minimum State of Charge.  Our general comments on these two topics are summarized below, and the attached mark-up includes specific suggested edits to implement these comments.  (Thus, our detailed comments are reflected in the attachment and not provided  in #2-8 below.)

COMMENT SUMMARY

• Planned Outage Enhancements, i.e., 100% RA Capacity substitution requirements for Planned Outages, starting with June 2021 going forward.  The draft LSA-SEIA comments include proposed modifications supporting the new elements in our Final Proposal comments, i.e.: (1) Clarification that no VER capacity substitution would be required for partial outages if the capacity left in service at least equals the NQC for that month; and (2) a placeholder for exemptions of small MW outage amounts.  (The comments also request clarification of some language specific to June and July 2021 outages.)

• Operationalizing Energy Storage/Minimum State of Charge (MSOC), a new CAISO market feature that would prevent storage resources from engaging in real-time market activity that could impair their ability to meet DA schedules when the DA market indicates that capacity may be tight the next day.  The draft LSA-SEIA comments include:  (1) Requesting clarification where the draft language seems to imply revision of the initiative proposal that would allow CAISO operators to apply the MSOC even where the market criteria for that application were not met; and (2) inserting clarification that the MSOC would not apply to Hybrid Resources (as the CAISO said in the stakeholder process).

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

Main highlights of PG&E’s comments:

Planned outage process enhancements

As explained in PG&E’s comments submitted to the CAISO on RA Enhancements Phase 1 – Final Proposal, PG&E has many concerns about the logistics of the CAISO substitution proposal, and requests modifications to the timeline that will not jeopardize CAISO’s objective, including:

• PG&E proposes the CAISO require substitution capacity for planned outages at T-30 rather than T-45, as currently proposed;
• PG&E proposes that planned outages emerging between T-30 and T-8 should maintain the current substitution rules, or be given three to five business days to provide substitution capacity, rather than 24-hours;
• PG&E requests the CAISO clarify the substitution types should remain unchanged (e.g., system RA can be used to substitute for local RA on planned outage);
• PG&E believes that the implementation of the proposal which requires new forced outage cards for planned outage extensions needs to be revised in order to minimize the operational burden on the CAISO’s operators and scheduling coordinators.

New local capacity technical study criteria and related capacity procurement mechanism authority

As submitted in comments to the RA Enhancements Phase 1 - Final Proposal, CAISO should examine other methods of evaluating resource insufficiency before implementing an approach that does not account for the resource’s contribution during different hours of the day. This needs to be clarified in the draft Tariff language section 40.3.1.1 Local Capacity Technical Study Criteria.

Process

PG&E believes that the CAISO should not be finalizing the draft tariff language while stakeholders are still working with CAISO on the policy development of the above topics. This draft tariff language is premature (it was published while stakeholders were still commenting on the RA Enhancements Phase 1 – Final Proposal). PG&E has expressed in its comments to the RA Enhancements Phase 1 – Final Proposal specific concerns with the implementation details of the proposal for the planned outage process enhancements, specifically PG&E proposed changes on the time when the Scheduling coordinators will have to provide substitution. This proposed changes that will not jeopardize CAISO’s objectives have not been reflected in the Draft Tariff Language.

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

See PG&E’s comments on the draft tariff language attached.

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

See PG&E’s comments on the draft tariff language attached.

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

See PG&E’s comments on the draft tariff language attached.

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

See PG&E’s comments on the draft tariff language attached.

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

As submitted in comments to the RA Enhancements Phase 1 - Final Proposal, PG&E believes more work is needed to improve the methodology that the CAISO has proposed for evaluating local capacity and energy needs and considering resource availability limitations. The CAISO’s proposed methodology will determine the hourly capacity needs by dispatching all resources including solar up to the latest available NQC at the time of the load in the local area. Applying a time duration curve to modify the dispatch of a solar resource that has already been adjusted for the ELCC methodology does not properly account for all of the energy production available during all hours of the day. The CAISO should examine other methods of evaluating resource insufficiency before implementing an approach that does not account for the resource’s contribution during different hours of the day.

This needs to be clarified in the draft Tariff language section 40.3.1.1 Local Capacity Technical Study Criteria.

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

PG&E requests clarification on “determining on the MSOC event day” (section 40.5.2), As written, it appears that an MSOC event day is only in DA. PG&E requests the CAISO to confirm that the RT option was stricken. PG&E also requests the CAISO clarifies how far in advance will the CAISO notify market participants of applying the MSOC tool.

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

No additional comments. 

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

See attachment for SDG&E's comments. Comments and edits are redlined.

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

SCE appreciates the opportunity to provide the comments on Phase 1 Draft Tariff Language[1]. SCE notes that the Draft Tariff Language contains details and changes that are not documented, nor fully addressed, in the Final Proposal. For example, the 48-hour deadline for outage substitution is new, which was not discussed in the Final Proposal posted on February 18, 2021[2]. In addition, certain aspects of the existing process can be impacted under the Draft Tariff Language, which apparently are not addressed in the Final Proposal. As such, SCE has a list of clarifying questions on those changes, as detailed below.

• 9.3.1.3.1. Is the process going forward that planned maintenance outages and approved planned outages will be automatically denied? Will the annual outage submittal/approval process requirement remain in place?  If the deadline to provide substitution is within 48 hours of the planned outage request, this would hinder early communication of outage to facilitate system planning and assessment.  Was this meant to state all planned outages require substitution and that the deadline to provide substitution is 48 hours prior to the outage event?
• If the 48 hours deadline prior to the outage event to provide substitution referenced above is the intent, is the delineation between planned outage and forced outage T – 48 hours?
• If the 48 hours deadline prior to the outage event to provide substitution referenced above is not the intent, note that under the previous (now deleted) 9.3.1.3.3.1 and 9.3.1.3.3.2, suppliers were allowed up to T-8 to provide substitution (as opposed to within 48 hours of the outage request). 
• 9.3.1.3.4. How does the CAISO inform an SC as to the reason why an outage was denied even with substitution provided?
• Deletion of 40.9.3.6.1.  With mandatory POSO, will outages still be populated in CIRA if they require substitution or how will CIRA change?
• Will Section 9.2 for Planned Outage Substitution of the BPM for Reliability Requirements (Version 54) remain in effect under this tariff change, where LCR for LCR substitution will not be required as in Section 9.3 for Forced Outage Substitution?
• Should substitute capacity match with the outage request exactly or should substitution always include the full day of the start date and the full day of the end date of the outage regardless of when the outage starts and ends in a day?
• Are current outage substitution exemptions for VER (wind & solar) and QF units whose QC is determined by historical outage remain applicable in RA enhancements?

[1] Available at http://www.caiso.com/InitiativeDocuments/DraftTariffLanguage-ResourceAdequacyEnhancementsPhase1.docx.

[2] Available at http://www.caiso.com/InitiativeDocuments/ResourceAdequacyEnhancements-Phase1FinalProposal.pdf.

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

Please see response to Question #1 above.

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

Please see response to Question #1 above.

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

Please see response to Question #1 above.

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

Please see response to Question #1 above.

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

Please see response to Question #1 above.

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

Please see response to Question #1 above.

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

Please see response to Question #1 above.

1. Provide a summary of your organization’s comments on the phase 1 draft tariff language:

Please see attached Vistra suggestions and comments.

2. Provide your organization’s comments on tariff amendments relating to the new substitution obligation for maintenance outages (sections 9.3.1.3.1 through 9.3.1.3.5):

Please see attached Vistra suggestions and comments.

3. Provide your organization’s comments on tariff amendments relating to the substitution process transition period covering June 2021 and July 2021 (section 9.3.1.3.9 and Appendix J, part 2):

Please see attached Vistra suggestions and comments.

4. Provide your organization’s comments on tariff amendments conforming existing tariff provisions on RAAIM to the new planned outage substitution process (section 40.9.3.6 and section 40.9.4):

Please see attached Vistra suggestions and comments.

5. Provide your organization’s comments on tariff amendments relating to requiring a new outage request when an existing outage is extended (section 9.3.3):

Please see attached Vistra suggestions and comments.

6. Provide your organization’s comments on tariff amendments relating to new local capacity technical study criteria and related capacity procurement mechanism authority (section 40.3.1.1 and section 43A.2.2):

Please see attached Vistra suggestions and comments.

7. Provide your organization’s comments on tariff amendments relating to the new minimum state of charge tool (section 40.5):

Please see attached Vistra suggestions and comments.

8. Additional comments on the Resource Adequacy Enhancements Phase 1 draft tariff language:

Please see attached Vistra suggestions and comments.