The CAISO has identified three ways the tariff rules related to the enhanced 75 percent penalty do not implement the policies underlying the under/over delivery charge. The CAISO now proposes targeted tariff amendments to address these three issues.
The first issue is that the enhanced penalty does not apply to over-deliveries.
The second concern is the provisions on the enhanced penalty did not contemplate that in a fifteen-minute interval, a scheduling coordinator could deviate from its HASP award both because of a reliability curtailment and because it did not secure the energy needed for the intertie transaction.
The third concern is that the floor price in applying the enhanced penalty is the same as the standard penalty scenario.
The effective date of the changes is 6/1/2022.