Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
PRR #
1345
Title Market operations BPM changes as it relates to scheduling priorities
Date Submitted 4/21/2021 3:19 PM
PRR Category C
Priority Emergency
Owner Batakji, Jamal (CAISO)
Status Closed
Status End Date 8/17/2021 11:59 PM
Related BPM Market Operations
BPM Section 6.6.5
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Existing Language
 
See attached
Proposed Language
 
See attached
Reason For Revision

This PRR is to address removing the higher priority that RUC exports are given in the real-time market.  We also provided additional descriptions of the import leg and export leg of wheel through self-schedules to provide additional clarity.  These BPM changes will only be effective pending FERC (ER21-1790) decision​.

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

No modifications to the original PRR are proposed.
Identification of the authorship of comments

Comments received, and responses were posted
Action

Approve the BPM PRR as submitted

N/A
Statement of apparent requirements of the BPM PRR

Market operations BPM changes as it relates to scheduling priorities
Priority and rank for any BPM PRR requiring a CAISO system change

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

Upon FERC decision by June 30th.
Other recommended actions

No other recommended actions on this PRR.
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Final Decision

Approve as submitted
Stakeholder Comment

No recommendation comments

Effective Date

Action

Adopt the recommendation as originally issued

Announcements
No Announcements has been posted for this PRR.
Impact Analysis
Impact Analysis not available.
Initial Comments
Portland General Electric Company (PGE) objects to the proposed revisions in PRR 1345.  The proposed changes are not appropriate to be made through a Business Practice Manual change, and moreover, are unduly discriminatory or preferential.
Consistent with the objections noted by previous commenters, PGE also maintains that the adoption of these business practice manual changes would result in a material change to the priority of curtailments for wheel-throughs which is a fundamental term or condition of service that must be filed with the Federal Energy Regulatory Commission (FERC) and included in the tariff under section 205(c) of the Federal Power Act and FERC’s “rule of reason” policy, which requires that practices that significantly affect rates, terms and conditions be filed with the FERC.
Moreover, because the revisions proposed in PRR 1345 would accomplish the same prioritization changes as the proposed tariff revisions in FERC Docket No. ER21-1790, it is not only imprudent to implement these BPM changes prior to any FERC approval of the related tariff revisions, but, as noted by Idaho Power, it creates additional and unduly discriminatory hurdles for wheel-throughs to be prioritized equally to CAISO load, and are not just and reasonable, nor are they consistent with or superior to FERC’s pro forma open access requirements, as described further in the joint protest filed by PGE and Idaho Power in that docket (filed May 19, 2021).
6/14/2021 9:56 AM
Logged By - Ryan Millard (Portland General Electric Company)
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Pending FERC decision. Please refer to tariff revision in ER21-1790
6/23/2021 2:07 PM
Responded By - Batakji, Jamal (CAISO)
Idaho Power Company objects to the proposed revisions in PRR 1345.  The proposed changes are not appropriate to be made through a Business Practice Manual change, and moreover, are unduly discriminatory or preferential.

The proposed BPM revisions in PRR 1345 significantly affect the rates, terms, and conditions of service.  The proposed revisions would change the penalty pricing parameters that dictate the priority of curtailments for wheel-throughs on CAISO’s system.  The priority of curtailments for wheel-throughs is a fundamental term or condition of service that must be properly filed with the Federal Energy Regulatory Commission (FERC) and included in the tariff under section 205(c) of the Federal Power Act and FERC’s “rule of reason” policy, which requires that practices that significantly affect rates, terms and conditions be filed with the FERC.  Thus, these changes are not appropriate for a Business Practice Manual change.

In addition, because the revisions proposed in PRR 1345 would accomplish the same prioritization changes as the proposed tariff revisions in FERC Docket No. ER21-1790, they create additional and unduly discriminatory hurdles for wheel-throughs to be prioritized equally to CAISO load, and are not just and reasonable, nor are they consistent with or superior to FERC’s pro forma open access requirements, as described further in Idaho Power’s protest in that docket (filed May 19, 2021).
6/4/2021 7:30 PM
Logged By - Camille Christen (Idaho Power Company)
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Pending FERC decision. Please refer to tariff revision in ER21-1790.
6/23/2021 2:08 PM
Responded By - Batakji, Jamal (CAISO)
Because CAISO’s BPM revisions significantly affect rates, terms, and conditions of service, they must be filed with FERC for review under section 205 of the Federal Power Act.  It is inappropriate to make these changes through the business practice manual.  FERC uses its “rule of reason” policy to identify “provisions that significantly affect rates, terms, and conditions” and must therefore be part of the tariff, rather than a business practice manual.  Midcontinent Indep. Sys. Operator, Inc., 158 FERC ¶ 61,003 at P 69 (2017) (citing Cal. Indep. Sys. Operator Corp., 119 FERC ¶ 61,076 at P 656 (2007); Order No. 890-A, 121 FERC ¶ 61,297 at ¶¶ 988, 990 (2007) (“. . . we reiterate that each ISO and RTO must include in its OATT all of the rules, standards and practices that significantly affect the transmission service provided by the ISO or RTO. . .”).  The proposed changes unquestionably have a significant effect on the terms and conditions of transmission service across the CAISO transmission system. With the adoption of these business practice manual changes, wheel-through transactions using firm transmission on the import and export legs would receive a lower level of priority when CAISO runs its day-ahead and real-time markets.  This has the effect of turning firm wheel-through transactions into non-firm transactions, which significantly alters CAISO’s longstanding practice, materially affects costs to entities scheduling on the CAISO system and affects how utilities will source power in Western energy markets.  CAISO cannot reasonably claim that these changes will not “significantly affect rates, terms, and conditions” of transmission service. 

Indeed, many of the BPM changes proposed here specify the terms and conditions of transmission service across the CAISO transmission system that are the subject of tariff changes currently pending before FERC in Docket No. ER21-1790 – this fact indicates that CAISO itself recognizes that tariff changes are necessary for these fundamental changes to CAISO markets and scheduling prioritization.  These market and scheduling rules should be implemented via amendment to CAISO’s tariff. It is contrary to FERC precedent to proceed with making these changes via the BPM.
5/18/2021 2:03 PM
Logged By - Marcie Martin (SRP)
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Pending FERC decision. Please refer to tariff revision in ER21-1790.
6/23/2021 2:08 PM
Responded By - Batakji, Jamal (CAISO)
Recommendation Comments
No Recommendation Comments available for this PRR.
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