Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
Title Resourse Adequacy Availability Incentive Mechanism Exemption Updates
Date Submitted 4/22/2019 12:21 PM
PRR Category C
Priority Normal
Owner Woody, Kyle (CAISO)
Status Closed
Status End Date 8/20/2019 11:59 PM
Related BPM Reliability Requirements
BPM Section 9.2.2 and 9.3.3
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Existing Language
See attached BPM
Proposed Language
See attached BPM
Reason For Revision
Tariff filing
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

Please see attached "Revised" BPM.
Identification of the authorship of comments


Approve the BPM PRR as modified.

Based off comments from market participants the original BPM language has been modified and can be found under attachments as "Revised".
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

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Final Decision

The BPM has been approved as revised.
Stakeholder Comment


Effective Date


Adopt the recommendation as modified

The ISO posted a revised version of the redlined BPM and posted the response to comments and
Posted On - 7/16/2019 4:42 PM
The ISO has place PRR 1154 on hold pending the review and response to comments and posting of the Recommendation.  We anticipate the posting in a couple weeks.
Posted On - 6/20/2019 9:41 AM
The response to initial comments and recommendation posting will be delayed until mid-June, as this will
require further discussion.
Posted On - 5/29/2019 4:23 PM
The revised BPM updated the Forced nature of work for 'New Generator Test Energy' to not require substitution.
Posted On - 5/7/2019 8:07 AM
Impact Analysis
Impact Analysis not available.
Initial Comments
NRG Energy, Inc. Initial Comments on BPM CM 1154
5/16/2019 7:06 AM
Logged By - Brian Theaker (NRG Energy)
To the extent that there are concerns regarding the determined opportunity costs not binding for use limited resources, please refer to the “use limit reached” outage cards.  The “environmental restrictions” outage card is not intended to be a catch all outage card that provides substitution and RAAIM exemptions. 

In regard to this languag being in the bpm and not the tariff, FERC has approved several tariff provisions that allow the ISO to defer certain details to the relevant BPM. This is one of those provisions.
7/16/2019 1:59 PM
Responded By - Woody, Kyle (CAISO)
5/14/2019 1:44 PM
Logged By - winichen (ISO & FERC Relations)
The CAISO’s implementation of tariff section must be guided by the principle that the tariff does not guarantee a RAAIM exemption for every outage beyond the generator’s control. The RAAIM exemption, instead, is tied to specific nature of work categories. In identifying a nature of work as RAAIM exempt, the CAISO needs to be comfortable that every (or virtually every) outage reported in that category meets one of the three factors identified in section  The CAISO is not confident that the “environmental restrictions” nature of work meets this standard. PG&E’s example of condor curtailments conceivably could be framed as an outage outside the resource’s control but that is not relevant to a wind resource because they already are categorically exempt from RAAIM.  PG&E’s example of restrictions on burning diesel, however, is a case of an outage within the generator’s control.  An emissions limitation is not exogenous to the resource because those restrictions only curtail output to the extent a given resource emits.  In PG&E’s specific example, if the initial gas system outage falls within the scope of issues covered by the RAAIM-exempt “Ambient Not Due to Temp” nature of work, then once the diesel emission limitations foreclose further operations the resource could report the outage under that exempt nature of work for as long as the qualifying gas system limitations remain in place. Otherwise, the outage properly would be reported under either the “Environmental Restrictions” or “Ambient due to Fuel insufficiency” outage types.
7/16/2019 9:48 AM
Responded By - Woody, Kyle (CAISO)
Recommendation Comments
No Recommendation Comments available for this PRR.
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