Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
PRR #
1122
Title Inappropriate reporting of forced outages
Date Submitted 1/10/2019 12:33 PM
PRR Category A
Priority Normal
Owner Woody, Kyle (CAISO)
Status Closed
Status End Date 4/16/2019 11:59 PM
Related BPM Outage Management
BPM Section 4.5
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Existing Language
 
Please refer to Reliability Requirements BPM section 9.2 for more information.
Proposed Language
 
If the CAISO initially approves a requested planned transmission or generation outage and the CAISO subsequently disapproves the outage or withholds final approval, it is generally not appropriate for the PTO or scheduling coordinator for the generator to resubmit the same (or substantially similar) outage as a forced outage. Resubmitting the outage could be viewed as submission of false information to the ISO and/or taking an outage not authorized by the ISO.  Resubmission in the forced timeframe may be appropriate where the physical circumstances surrounding the outage request changed between the planned and forced timeframes or where further delay to the outage poses imminent operational risk to the transmission or generation equipment. Similarly, it is not appropriate outage practice for a PTO or scheduling coordinator for a generator intentionally to refrain from submitting a planned outage until the forced outage timeframe. This is particularly so with RA resources, considering that some forced outage nature of work categories are exempt from RAAIM.
Where the CAISO determines that a PTO or scheduling coordinator for a generator may have reported outages inappropriately, the CAISO and/or the Department of Market Monitoring may investigate and inform FERC of such conduct.
Reason For Revision
 
Adding clarity to what is inappropriate behavior for reporting forced outages. This note was removed from the reliability requirements bpm, updated, and added to the outage management bpm.
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Woody, Kyle (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

The ISO is approving the PRR as submitted.
Identification of the authorship of comments

Comments submitted by SCE, Calpine, NCPA, PG&E, Six Cities
Action

Approve the BPM PRR as submitted

n/a
Statement of apparent requirements of the BPM PRR

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

N/A
Proposed effective date(s) of the BPM PRR

3/18/2019
Other recommended actions

n/a
Click here to view the Final Decision for this PRR
Final Decision

The original PRR language has been modified through discussions with the market participants. The updated language is being submitted as a Final Decision.
Stakeholder Comment

The ISO worked with stakeholders to modify the original language through the BPM comment and recommendation periods.

Effective Date

4/8/2019
Action

Adopt the recommendation as modified

Announcements
The Final Decision BPM redline language can be viewed under Attachments titled 'Outage Management BPM Version 17_redline_V1'.
Posted On - 4/1/2019 8:08 AM
Please see the attached excel file titled "PRR 1122 recommendation comment matrix" for responses to the Recommendation Comments.
Posted On - 3/25/2019 12:05 PM
The CAISO has posted its responses to all 'Initial Comments' in the attached word doc under Six Cities comments. The CAISO has made an update to its 'Recommendation Details' by updating the original proposed PRR language. This updated language has been attached to the PRR.
Posted On - 3/5/2019 9:29 AM
Impact Analysis
Impact Analysis not available.
Initial Comments
Six Cities' Comments on PRR 1122
2/12/2019 9:41 PM
Logged By - Rebecca Shelton (Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California)
---------------------------------------------
This attachment contains repsonses to all market participant questions.
3/5/2019 9:31 AM
Responded By - Woody, Kyle (CAISO)
2/12/2019 4:52 PM
Logged By - winichen (ISO & FERC Relations)
2/12/2019 8:59 AM
Logged By - Aditya Chauhan (SCE) (Southern California Edison)
NCPA appreciates the opportunity to comment on Proposed Revision Request 1122.  NCPA understands that some generators may have used outages to game markets in the past, but NCPA does not support PRR 1122 because it is too restrictive. While it purports to be an attempt to secure system reliability, it could actually be detrimental to system reliability.

First of all, CAISO appears to assume that once it approves a planned outage, the outage is set in stone, because after the approval, plans and schedules are put in place that cannot easily be adjusted.  While this is true in many cases, CAISO is ignoring the fact that the specialized contractors necessary to perform much generator work sometimes experience their own scheduling issues, which can include a demand to reschedule their work at the last minute. Specialized experts in high demand may not be able to reschedule planned work for days or months if their window of availability is missed, and by that time it could be too late for a unit in need of significant work.  When these scheduling issues arise, conversion of a planned outage to a forced outage will be necessary to complete the work. It is not always possible to say that failure of a resource is “imminent” (NCPA believes this word is too general for this context), but it is possible to predict that if the specialized expert needed to start the process of necessary repairs is delayed for a year, the chances of catastrophic failure sometime during that year increase dramatically.

Secondly, SCs submit planned outages in good faith and attempt to provide CAISO as much time as possible to plan around the outage.  Typically, when SCs submit planned outages in shorter term time frames, it is because there is an unforeseen issue that must be addressed immediately to preserve the long term availability of the unit, whether or not CAISO approves the outage. When CAISO rejects those requests because it cannot plan around the outage, and an SC cannot locate substitute capacity, the SC will have no choice but to resubmit the outage as a forced outage to prevent far greater harm in the future, such as the potential unavailability of the unit for months.  NCPA supports PG&E’s comments in PRR 1074 seeking to take a more holistic approach to the issue at hand and to improve the inflexible outage process by taking into account all the variables behind an outage rather than simply denying an outage and threatening SCs with consequences.

NCPA also disagrees with the implied premise that resubmitting a planned outage as a forced outage, on its own, is necessarily an indication of gaming. Tariff Section 9.3.10.6 identifies ten different factors that should be considered when determining if a forced outage was the result of gaming or other questionable behavior. While, the recent rejection of a planned outage for a resource may, when combined with other factors, be an indication that an operator has submitted a forced outage to gain some market benefit, those other factors, such as evidence that an operator has been deceptive or that the operator’s submission of a forced outage would financially benefit the operator in the markets, should be present before investigating that operator for gaming would be appropriate. FERC considers the purpose of an entity’s actions as a critical factor in determining whether conduct is fraudulent. See Order No. 670, 114 FERC ¶ 61,047, P 50 (2006) (fraud includes actions taken “for the purpose of impairing, obstructing, or defeating a well-functioning market”); Coaltrain Energy, L.P., 155 FERC ¶ 61,204, P 5 (2016) (“Respondents’ OCL Trades were manipulative because they were executed for the sole or primary purpose of targeting and garnering MLSA payments.”). When an entity submits a forced outage for operational or maintenance reasons, and accepts any RAAIM penalties associated with that outage, that entity should not be investigated without additional indicia of gaming.

Additionally, there are legitimate, non-gaming reasons why a resource owner might have to delay the reporting of a planned outage.  Consider, for example, a resource owner that knows that its transmission provider intends to declare a transmission outage that will impact its resource. The resource owner might plan to do maintenance on its unit during the transmission outage, but could not submit that planned outage until after the transmission provider commits to a date and submits its transmission outage to CAISO. Since the resource owner has no control over when the transmission provider submits an outage, the resource owner properly must delay reporting of its planned outage until the dates are certain.

NCPA respectfully requests that CAISO deny PRR 1122. Instead, CAISO should reviews its outage process and modify it such in a way that will result in fewer rejections of planned outages, thereby addressing this issue atits root cause and providing win-win solutions for both CAISO and its business associates. At a minimum, however, CAISO must allow for instances when an outage is necessary for the long-term viability and availability ofthe unit.
2/11/2019 2:43 PM
Logged By - Mike Whitney (NCPA)
Calpine continues to object to the language of this PRR -- regardless of its location in the BPM library.  Rather than edit the BPM, we offer an entirely revised version which we assert, models historic practice and represents a reasoned interpretation of the tariff obligations. 
2/4/2019 1:06 PM
Logged By - Mark at Calpine (Calpine)
Recommendation Comments
3/19/2019 3:23 PM
Logged By - winichen (ISO & FERC Relations)
3/14/2019 2:52 PM
Logged By - Mike Whitney (NCPA)
Click here to view the Appeals for this PRR
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# of Appeals In Progress - 2
# of Appeals Closed - 0
# of Appeals Abandoned - 0
#Appeal ReasonStatusResponseAppealed ByAppealed On
1Attached please find the Notice of Appeal of PRR 1122 and Opening Brief of the Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA the (“Six Cities”)

Rebecca L. Shelton
rshelton@thompsoncoburn.com
P: 202.585.6911
SubmittedPayton, Julia (CAISO)4/15/2019
2PG&E submits the attached Notice of Appeal for PRR 1122.

Thanks,

Wini Chen
Senior Analyst, Regulatory Relations
Pacific Gas and Electric Company
Office: 415-973-8801
wcce@pge.com
SubmittedPayton, Julia (CAISO)4/17/2019
Attachments