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Proposed Revision Request Detail Help
PRR Life Cycle*****Stakeholder Meeting on Recommendation****
PRR Details
PRR #
1690
Title Clarification on tagging megawatts back into CAISO BA from a non-contiguous portion of CAISO BA
Date Submitted 7/24/2026 12:19 PM
PRR Category A
Priority Normal
Owner Martin, Michael (CAISO)
Status Stakeholder Meeting on Recommendation
Status End Date 9/16/2026 11:59 PM
Related BPM Market Operations
BPM Section 8.4.4 Static Schedules or Normal E-Tags

Attachment H - Circular Schedule Rule

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Existing Language

​See Attached

Proposed Language

​See Attached​

Reason For Revision

​Clarification that separate tags are required for importing MWs back into CAISO BA from a non-contiguous portion of CAISO BA.  ​

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BPM PRR Submitter

Martin, Michael (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

​Approve the BPM PRR as submitted

Identification of the authorship of comments

Provided detailed response to questions attached to this PRR
Action

Approve the BPM PRR as submitted

Statement of apparent requirements of the BPM PRR

Priority and rank for any BPM PRR requiring a CAISO system change

Proposed effective date(s) of the BPM PRR

Other recommended actions

Announcements
No Announcements has been posted for this PRR.
Impact Analysis
PRR 1690 Impact Analysis Form.doc    
Notes:
Initial Comments
PRR 1690 - Response to 1690.docx    
PRR 1690 covers a narrow and well-defined scenario – moving power between non-contiguous portions of the same balancing authority area.  The PRR explains there is operational benefit from having such transactions reported on separate eTags.  Such schedules also do not pose the sort of operational and market risks as schedules FERC has deemed to be circular schedules in prior instances.  The CAISO understands PG&E’s concern that a market participant could cite the language from this PRR to justify breaking up the legs of a circular schedule into separate transactions and evade the impact of the settlement rule.  The CAISO addressed this concern when it proposed the circular scheduling settlement rule in 2012.  The CAISO explained that if “it believes that a market participant intentionally sought to circumvent the proposed settlement rules by submitting multiple e-Tags that “chop-up” the path of what is essentially a single transaction so as to avoid application of the proposed settlement rule, then DMM would consider referring that conduct as either potentially manipulative or involving the submission of false information.  The same would apply if there were reason to believe that a single scheduling coordinator sought to avoid the settlement rule by including a third party on the e-Tag where there was no legitimate arm’s-length transaction between the two parties.” (CAISO transmittal letter, p.15.  also review CAISO answer to protest and comments, pp.8-10).  The CAISO has been monitoring, and will continue to monitor, for transactions that seek to circumvent or evade the settlement rule.  As relates to PRR 1690,  this monitoring would include the use of separate eTags for a schedule sourcing and sinking in the same balancing authority area, unless the schedule was used to move power between non-contiguous portions of the same balancing authority area.
~Michael Martin
8/28/2026 10:37 AM
Logged By - Williamson-Duffney, Joseph (CAISO)
PG&E would like CAISO to explain how it would distinguish between legitimate and illegitimate uses of this circular scheduling exception. Scenario 1: an entity imports into CAISO from Sunzia in New Mexico, exports at Pinal, and then imports again into CAISO at Palo Verde. Scenario 2: an entity seeks to utilize a circular schedule to exercise market power and it splits its export and import schedules into two separate tags. How would CAISO distinguish between Scenarios 1 and 2? Under Market Operations BPM Section 8.4.4, would Scenario 2 dodge the circular scheduling settlement rule? What recourse, if any, does CAISO have against Scenario 2?
8/18/2026 5:01 PM
Logged By - alan.meck@pge.com (CAISO)
This PRR is related to PRR 1691 and should be considered in parallel. 
Based on the definitions in Tariff Appendix A, it appears that references in the language proposed for §8.4.4 to “BA” should be changed to “BAA.” 
More importantly, the Six Cities question whether references to the CAISO BAA, rather than to participating BAAs in general terms, are appropriate.  PacifiCorp submitted an Initial Comment on PRR 1691 expressing its understanding that the circular scheduling rule only applies to Scheduling Coordinators in the CAISO BAA, and the CAISO’s response agrees with that view.  The Six Cities do not agree that the circular scheduling settlement rule should apply only to Scheduling Coordinators in the CAISO BAA.  The circular scheduling settlement rule arose from determinations by the FERC following the 2000-2001 Energy Crisis that circular scheduling, as described in Attachment H, violates market conduct rules.  In an integrated market, there is no apparent reason why market conduct rules should be different for participating BAAs.  Appropriately defined exceptions for transactions between non-contiguous portions of a BAA should apply to all BAAs under comparable circumstances, but there should be no categorical limitation of the circular scheduling rule to CAISO Scheduling Coordinators alone.
8/18/2026 3:31 PM
Logged By - bblair@thompsoncoburn.com (CAISO)
Recommendation Comments
As noted previously, PRRs 1690 and 1691 are related and should be considered in parallel.  Both the Six Cities and PG&E submitted Initial Comments raising questions about the language proposed for PRR 1690 and, in the Six Cities’ Initial Comments, questioning CAISO’s response to the PacifiCorp Initial Comment on PRR 1691.  While the CAISO’s response to the Initial Comments suggests that the CAISO plans to continue enforcing the rule against circular scheduling, it does not expressly address the questions PG&E raised, and it does not clarify the meaning of the earlier response to PacifiCorp’s Initial Comment.  The Six Cities request express clarification that the CAISO will apply the rule against circular scheduling consistently for all BAAs participating in the Extended Day-Ahead Market, subject to any appropriately tailored exceptions explicitly detailed in the BPM.
9/16/2026 2:47 PM
Logged By - bblair@thompsoncoburn.com (CAISO)
Attachments