Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
Title Attachment B changes to support Tariff Section 4.6.4
Date Submitted 8/22/2019 9:55 AM
PRR Category C
Priority Emergency
Owner Batakji, Jamal (CAISO)
Status Closed
Status End Date 11/12/2019 11:59 PM
Related BPM Market Instruments
BPM Section Attachment B
RSS Subscribe
Existing Language
See attached
Proposed Language
See attached
Reason For Revision
The CAISO is adding clarity to the process to support Tariff Section 4.6.4 Identification of Generating Units.
Effective date is once the PRR is published.
Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Batakji, Jamal (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

The ISO may modify the draft language to accommodate the comments provided by stakeholders
Identification of the authorship of comments

Comments were submitted by multiple entities

Approve the BPM PRR as modified.

We are still in the process of evaluating few comments provided by stakeholders. Recommendation with modified document will be available ASAP
Statement of apparent requirements of the BPM PRR

Attachment B changes to support Tariff Section 4.6.4
Priority and rank for any BPM PRR requiring a CAISO system change

Proposed effective date(s) of the BPM PRR

Fall 2019
Other recommended actions

No other recommended actions on this PRR.
Click here to view the Final Decision for this PRR
Final Decision

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

Comments were submitted, and CAISO responded accordingly.

Effective Date


Adopt the recommendation as originally issued

CAISO has received written communication dated 3/18/2020 from SCE that states:
"SCE would like to withdraw its appeal of 1181."
Posted On - 3/19/2020 3:40 PM
CAISO has received written communication dated 2/25/2020 from WPTF that states:
"Given the recent posting of PRR 1230, WPTF, and the parties, withdraw the appeal to PRR 1181."
Posted On - 2/26/2020 9:06 AM
Impact Analysis
Impact Analysis not available.
Initial Comments
ISO Response to stakeholder comments
10/2/2019 7:55 AM
Logged By - Payton, Julia (CAISO)
Brandon Gimper
Sr. Regulatory Compliance Analyst
Federal & Regional Policy | Puget Sound Energy
(P): 425-457-5421
355 110th Ave NE, EST 07W, Bellevue, WA 98004
9/24/2019 10:21 AM
Logged By - Payton, Julia (CAISO)
Comments of Portland General Electric on PRR 1181: Attachment B Revisions
9/18/2019 2:06 PM
Logged By - Ryan Millard (Portland General Electric Company)
9/18/2019 2:01 PM
Logged By - Brian Theaker (Middle River Power, LLC)
WPTF comments on proposed changes.
9/18/2019 1:03 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
9/18/2019 8:57 AM
Logged By - Aditya Chauhan (SCE) (Southern California Edison)
Attached are comments, questions on the original draft and suggested edits.  Three attachments.
9/17/2019 7:02 PM
Logged By - Mark at Calpine (Calpine)
Please see attachment for PG&E's comments.
9/17/2019 4:36 PM
Logged By - Mark Tiemens (PG&E)
Idaho Power Company comments:
With PRR 1181, CAISO is proposing to significantly increase the requirements for Master File change requests.  Idaho Power objects to the magnitude of these changes and the additional burden these changes place on EIM Entities.  CAISO has not provided justification or explanation for why these changes are necessary except to support Corporate Goal 4a. Please identify what Corporate Goal 4a is and how these changes are necessary for that objective.

Idaho Power does not support the changes and recommends the proposed language not be adopted for all SC’s in the market.  If CAISO adopts the proposed language for resources within the CAISO BAA, it should retain the existing current requirements, without these proposed changes, for resources in EIM Entity BAAs.  The additional information the proposed language would require is unduly burdensome and would materially increase the time required to make Master File changes and potentially increase the rejection rate of changes an EIM Entity needs on resources in its BAA.  Entities can discover that changes are necessary to how a resource is modelled in the normal course of business, and should be able to make those corrections without burdensome information requirements.  Moreover, the proposed required information is unnecessary for resources not in the CAISO BAA, and CAISO should not be in the position of verifying whether EIM Entities are modeling their resources correctly.  Entities are already required by section 4.6.4 of the CAISO Tariff to ensure that resources are modelled correctly.   In addition, incorrect modeling of resources in the EIM Entity’s BAA can lead to financial and reliability issues, a further incentive to ensure these are correctly represented in the model. The proposed changes should not be adopted, or if adopted, should be limited to resources internal to the CAISO BAA.

Thank you for the opportunity to comment.

Camille Christen
Idaho Power Company
9/17/2019 2:24 PM
Logged By - Camille Christen (Idaho Power Company)
Recommendation Comments
10/15/2019 4:14 PM
Logged By - Gridwell Consulting for WPTF (Western Power Trading Forum)
The concept of age-adjusted design capability is in the tariff today and is not part of this BPM revision.  The ISO fundamentally disagrees that it should not perform a due diligence review prior to implementing changes in the Master File.
10/24/2019 1:03 PM
Responded By - Batakji, Jamal (CAISO)
10/15/2019 4:11 PM
Logged By - elynor reyes (Calpine Corporation)
The ISO believes that OEM manuals are just one way that an entity could demonstrate an age-adjusted design capability.  The ISO has changed the language in the Recommendation phase to clarify that only an explanation for the change is required upon initial submittal of the change.  Only if the explanation does not adequately support the request would the ISO ask for additional supporting materials that the Scheduling Coordinator and Generator Owner would have used as a basis for their change request.  The ISO believes that this process provides an appropriate due diligence review for changes being implemented in the Master File.
10/24/2019 1:05 PM
Responded By - Batakji, Jamal (CAISO)
Click here to view the Appeals for this PRR
Click on the '+' icon to submit a New Appeal

# of Appeals In Progress - 2
# of Appeals Closed - 0
# of Appeals Abandoned - 0
#Appeal ReasonStatusResponseAppealed ByAppealed On
1Please see attached Joint Appeal document for reasons why the Parties are appealing the decision.
SubmittedGridwell Consulting for WPTF (Western Power Trading Forum)11/7/2019
2See attachedSubmittedAditya Chauhan (SCE) (Southern California Edison)11/12/2019