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Proposed Revision Request Detail Help
PRR Life Cycle*********Withdrawn
PRR Details
PRR #
1610
Title Stage 2 variable energy resource will be set to self-schedule only until the resource is a Stage 3 variable energy resource
Date Submitted 12/23/2024 8:49 AM
PRR Category B
Priority Normal
Owner Martin, Michael (CAISO)
Status Withdrawn
Status End Date 3/18/2025 11:59 PM
Related BPM Market Operations
BPM Section Market Operations Appendices A.12.1
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Existing Language
​See Attached
Proposed Language
​See Attached​
Reason For Revision
Once a VER becomes commercial, the CAISO must collect high quality production and meteorological data for a minimum of 30 consecutive days before the CAISO can produce a forecast. During this time and due to the lack a forecast, the Stage 2 VER must submit self-schedules and cannot economically bid.  The CAISO will set a flag in the Master File to ensure the Stage 2 VER can only submit self-schedules during this time. Stage 2 VERs must self-schedule and not submit economic bids to ensure accurate dispatch and avoid unwarranted Bid Cost Recovery payments.  ​​
Announcements
This PRR has been Withdrawn.  Should any new BPM language be proposed on this topic, a new PRR will be created.
Posted On - 3/31/2025 10:19 AM
This PRR is now On-Hold pending a review of all comments received and forthcoming response from the CAISO.
Posted On - 3/27/2025 8:59 AM
To allow additional commenting time and stakeholder review, this PRR will be in the initial phase for another month. We have extended the initial comment phase to Mar 18.
Posted On - 2/25/2025 2:48 PM
To allow additional commenting time and stakeholder review, this PRR will be in the initial phase for 2 months. We have extended the initial comment phase to Feb 19.
Posted On - 1/29/2025 9:50 AM
Impact Analysis
Impact Analysis not available.
Withdrawal Reason
Initial Comments
20250319 CPA Comments on PRR 1610_FINAL.pdf    
The ISO has received written comments on 3/17/2025 from Ben Gustafson from Clean Power Alliance.
3/19/2025 3:09 PM
Logged By - Williamson-Duffney, Joseph (CAISO)
BPM PRR 1610 CEG Initial Comment.pdf    
On 2/19 CAISO received written comments from Jack Watson at Clearway Energy.
2/19/2025 6:31 PM
Logged By - Hines, Nicole (CAISO)
LSA - PRR 1610 comms final 021925.docx    
Please see the attached comments from the Large-scale Solar Association (LSA).
2/19/2025 11:47 AM
Logged By - Susan R. Schneider (Phoenix Consulting)
Terra-Gen, LLC - Initial Comments on PRR 1610
Terra-Gen opposes PRR 1610 and concurs with the initial comments of NCPA and WPTF opposing the PRR. Terra-Gen owns and operates VER resources and would be faced with undue price risk if forced to self-schedule Stage 2 VERs and, similar to NCPA, has good experience providing forecast based economic bids for Stage 2 VERs.  Terra-Gen also highlights the WPTF feedback that this modification amounts to a policy change and is not appropriate for a PRR BPM change.  Such modifications should be developed through formal stakeholder proceedings and CAISO Board of Governor's consideration.

1/9/2025 4:45 PM
Logged By - Chris Devon (Terra-Gen, LLC)
WPTF opposes the CAISO proposed BPM language in PRR 1610, specifically the new requirement for VER resources to self-schedule while they are in Stage 2. Any bidding restrictions (in this case not allowing VERs to economically offer) directly impact rates, terms, and conditions and thus must be reflected in the Tariff. We not only oppose this from a market perspective, but also the fact that the change is being done through the BPM change process rather than a policy effort and subsequent FERC filing. Additionally, this language now creates a conflict between the CAISO Tariff and BPM as it relates to the bidding of VER resources.
1/9/2025 1:34 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
NCPA requests for CAISO to reconsider the self-schedule requirement for Stage 2 VERs proposed in PRR 1610. CAISO describes Stage 2 as the period between COD and issuance of the CAISO VER Forecast. CAISO reasons that the EIR must self-schedule due to the lack of a forecast. Counter to CAISO’s points, NCPA successfully bids in Stage 2 resources by utilizing non-CAISO VER forecasts. In an effort to formalize this practice, NCPA is currently working with CAISO staff to utilize ALFS for Stage2 VER Forecast submittals (see CIDI 00278958). NCPA strongly opposes any self-schedule requirements for an EIR due to extreme price risk associated with negative pricing. Economic bidding is an essential tool required to mitigate such price risk.
1/9/2025 9:25 AM
Logged By - Mike Whitney (NCPA)
Recommendation Comments
No Recommendation Comments available for this PRR.
Attachments