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Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
PRR #
1055
Title Update the pre-calculation metered subsystem deviation penalty quantity configuration to properly account for MSS instructed imbalance energy for a MSS load following resource with no day ahead award but dispatched in real time market
Date Submitted 5/3/2018 9:35 AM
PRR Category B
Priority Normal
Owner Kwong, Jennifer (CAISO)
Status Closed
Status End Date 7/19/2018 12:00 AM
Related BPM Settlements and Billing
BPM Section Pre-calculation MSS Deviation Penalty Quanitity
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Existing Language

See BPM attached to this PRR

Proposed Language

See BPM attached to this PRR

Reason For Revision

A Market Participant has entered a dispute over erroneous formula for MSS Load Following (LF) Deviation Penalty (DP) Non Dispatch Mode Energy Quantity.  The current equation is Max of zero and the Supplemental Energy Quantity less Minimum Ex Post Capacity Quantity.  This equation assumes the MSS LF resource has a DA Award.  In this scenario, IIE should be the Supplemental Energy Quantity.

The proposed solution is to first check for the DA position of the MSS LF resource.  If the DA Award is non-zero, the equation will work as is; however, if the DA Award is zero, then the MSS LF IIE will be equal to the Supplemental Energy Quantity.

 

The proposed revision will be applied retroactively, effective starting with Trading Day October 1, 2014 to capture all Trading Days over which the defect applies.

 

The ISO anticipates implementation of the BPM changes on or about June 25, 2018.

Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Kwong, Jennifer (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

The ISO proposes no modified BPM language beyond that proposed in the BPM PRR.
Identification of the authorship of comments

Comments were received from Mike Whitney, NCPA, on 5/18/18:

Thank you for submitting this PRR. One concern is that the max function in 3.6.1.22 does not allow for downward supplemental energy (aka supp dec bid/award) results and will continue to create DOPD IIE settlements that are inconsistent with FMM IIE, RTD IIE settlements and Expected Energy.

BAResource5MMSSLFDPNonDispatchModeEnergyQuantity BrtT’M'F’S’L’mdhcif = (1/12)*
   Max(0,(BAResourceDispatchSupplementalEnergyQty BrtT’M'F’S’c’L’mdhcif – BAResourceMSS5MMinimumExPostCapacityQuantity BrtT’M'F’S’L’mdhcif ))

CAISO ruled in dispute 174289 that a Metered Sub-system Aggregator (MSSA) resource cannot attempt to bid supp decs by changing Load Following Up and/or Load Following Down capacity from the Day Ahead Market to the Fifteen Minute Market process in the Real Time Market. NCPA is working with CAISO staff on developing a new PRR to remedy that limitation.
  
However, the gas fired resources that are the subject of dispute 202501 are typically not used for load following and thus LFU and LFD capacity is not typically bid in so under these circumstances, these resources should not be barred from supp dec bidding and awards. A similar resource received valid supp dec instructions on 5/11/2018 that settled correctly in charge code 6460 but 3.6.1.22 will return a value that is inconsistent with the energy settlements in the T+12 B statement which may trigger another, related, dispute.

Proposed modifications to 3.6.1.22 to address the dec issue and align DOPD supplemental energy with 6460, 6470, and Expected Energy:
1. Remove the max function from the formula referenced above
2. Replace BAResourceMSS5MMinimumExPostCapacityQuantity with BAHrlyResourceDAMSSGenerationScheduleQty
3. Remove this test:
       a. BAResource5MGeneratorDispatchOperatingTargetQty BrtT’M'F’S’L’mdhcif  > BAResourceMSS5MM      inimumExPostCapacityQuantity BrtT’M'F’S’L’mdhcif

Besides addressing the dec issue, please thoroughly test the result of the new formula, perhaps during a market sim to ensure any unintended results are addressed prior to release.

1) The scenario described for 5/11/2018 is actually hypothetical in nature. The unit was testing so LFD was involved but LF will not be present in economic bid stacks that are expected to be the norm going forward.

2) CAISO's system operating message dated 5/18/2018 announcing Oversupply conditions for 5/19/2018 is another reason CAISO should assign a higher priority for the resolution of the supp dec issue for all MSSA resources since they are at this time restricted from submitting Decremental Energy bids to help relieve Oversupply conditions:

 05/18/2018 13:04:08  The ISO has determined a potential for Oversupply conditions for the Operating Day 5/19/2018 during hours ending 1000 through 1600. The ISO is requesting decremental Energy bids and limited self-sch  edules in the Real Time market.

ISO response to NCPA submitted on 5/22/18:

The changes in this release (PRR1055) to the MSS DP Quantity PC is to address the IIE issue when an MSS LF resource has a Zero DA Award and yet is dispatched in RT.  This fix is to resolve SDS: 202501.  The Max function pointed out in the comments section by NCPA is an existing function on an existing formula.  The dec issue is a separate issue and is currently being assessed/evaluated.

Confirmed today (5/22/18) after the monthly call this morning, that we do not have a timeline on the dec issue, it will require a MSS contract change.
Action

Approve the BPM PRR as submitted

NA
Statement of apparent requirements of the BPM PRR

This BPM PRR contains basic language changes.
Priority and rank for any BPM PRR requiring a CAISO system change

There are system changes associated with this PRR. The system changes are planned for implementation on 6/25/2018 on a normal basis.
Proposed effective date(s) of the BPM PRR

The ISO proposes an effective date of 10/1/2014 for the BPM revisions.
Other recommended actions

The ISO does not recommend any other actions on this BPM PRR.
Click here to view the Final Decision for this PRR
Final Decision

The ISO adopts the BPM change as proposed in the recommendation.
Stakeholder Comment

No comments submitted.

Effective Date

10/1/2014
Action

Adopt the recommendation as originally issued

None
Announcements
No Announcements has been posted for this PRR.
Impact Analysis
IA - Impact Analysis Form for MSS Deviation Penalty Qty PC.doc    
Notes:
Initial Comments
Additional info for comment dated 5/18/2018 9:51 AM

1) The scenario described for 5/11/2018 is actually hypothetical in nature. The unit was testing so LFD was involved but LF will not be present in economic bid stacks that are expected to be the norm going forward.

2) CAISO's system operating message dated 5/18/2018 announcing Oversupply conditions for 5/19/2018 is another reason CAISO should assign a higher priority for the resolution of the supp dec issue for all MSSA resources since they are at this time restricted from submitting Decremental Energy bids to help relieve Oversupply conditions:

 05/18/2018 13:04:08  The ISO has determined a potential for Oversupply conditions for the Operating Day 5/19/2018 during hours ending 1000 through 1600. The ISO is requesting decremental Energy bids and limited self-sch  edules in the Real Time market.
 
5/18/2018 1:30 PM
Logged By - Mike Whitney (NCPA)
---------------------------------------------
The changes in this release (PRR1055) to the MSS DP Quantity PC is to addressed the IIE issue when an MSS LF resource has a Zero DA Award and yet is dispatched in RT.  This fix is to resolve SDS: 202501.  The Max function pointed out in the comments section by NCPA is an existing function on an existing formula.  The dec issue is a separate issue and is currently being assessed/evaluated.

Confirmed today (5/22/18) after the monthly call this morning, that we do not have a timeline on the dec issue, it will require a MSS contract change.
5/22/2018 3:05 PM
Responded By - Peacock, Bonnie (CAISO)
Thank you for submitting this PRR. One concern is that the max function in 3.6.1.22 does not allow for downward supplemental energy (aka supp dec bid/award) results and will continue to create DOPD IIE settlements that are inconsistent with FMM IIE, RTD IIE settlements and Expected Energy.

BAResource5MMSSLFDPNonDispatchModeEnergyQuantity BrtT’M'F’S’L’mdhcif = (1/12)*
   Max(0,(BAResourceDispatchSupplementalEnergyQty BrtT’M'F’S’c’L’mdhcif – BAResourceMSS5MMinimumExPostCapacityQuantity BrtT’M'F’S’L’mdhcif ))

CAISO ruled in dispute 174289 that a Metered Sub-system Aggregator (MSSA) resource cannot attempt to bid supp decs by changing Load Following Up and/or Load Following Down capacity from the Day Ahead Market to the Fifteen Minute Market process in the Real Time Market. NCPA is working with CAISO staff on developing a new PRR to remedy that limitation.
 
However, the gas fired resources that are the subject of dispute 202501 are typically not used for load following and thus LFU and LFD capacity is not typically bid in so under these circumstances, these resources should not be barred from supp dec bidding and awards. A similar resource received valid supp dec instructions on 5/11/2018 that settled correctly in charge code 6460 but 3.6.1.22 will return a value that is inconsistent with the energy settlements in the T+12 B statement which may trigger another, related, dispute.

Proposed modifications to 3.6.1.22 to address the dec issue and align DOPD supplemental energy with 6460, 6470, and Expected Energy:
1. Remove the max function from the formula referenced above
2. Replace BAResourceMSS5MMinimumExPostCapacityQuantity with BAHrlyResourceDAMSSGenerationScheduleQty
3. Remove this test:
       a. BAResource5MGeneratorDispatchOperatingTargetQty BrtT’M'F’S’L’mdhcif  > BAResourceMSS5MM      inimumExPostCapacityQuantity BrtT’M'F’S’L’mdhcif

Besides addressing the dec issue, please thoroughly test the result of the new formula, perhaps during a market sim to ensure any unintended results are addressed prior to release.

Respectfully,

Mike Whitney
Power Settlements Supervisor
 
Northern California Power Agency
A Public Agency
651 Commerce Dr.
Roseville, CA 95678-6411
(916) 781-4205 Office
(916) 297-1990 Cell
(916) 781-4255 Fax
www.ncpa.com

5/18/2018 9:51 AM
Logged By - Mike Whitney (NCPA)
---------------------------------------------
*Please refer to CAISO's response to your 'additional' comment from 5/18/18 at 1:30PM.*
5/21/2018 4:47 PM
Responded By - Peacock, Bonnie (CAISO)
Recommendation Comments
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