Proposed Revision Request Detail Help
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PRR Details
PRR #
968
Title Clarification updates to BPM for resource adequacy availability incentive mechanism precalc
Date Submitted 2/10/2017 8:16 AM
PRR Category A
Priority Normal
Owner Caldwell, Elizabeth (CAISO)
Status Closed
Status End Date 4/18/2017 11:55 PM
Related BPM Settlements and Billing
BPM Section PC resource availability incentive mechanism
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Existing Language
See BPM attached to this PRR
Proposed Language
See BPM attached to this PRR
Reason For Revision

In the current BPM, Business Rule 1.5 defines the trade hours for flexible resource adequacy categories 2 and 3. The proposed revision removes the defined hours, and replaces with references to the ISO flexible capacity needs assessment which determines the five-hour period in alignment with tariff Section 40.10.6.1(a).

 

The proposed revisions ensures that when there is an update to the five-hour period as determined in the ISO flexible capacity needs assessment. This is a documentation only change as updates to the configuration are not required.

Click here to view the Recommendation Details for this PRR
BPM PRR Submitter

Caldwell, Elizabeth (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

The ISO proposes no modified BPM language beyond that proposed in the BPM PRR.
Identification of the authorship of comments

No comments were received.

Question received from SDG&E (during the 2/28/17 stakeholder call):
How are the formulas in the settlements BPM ensure that the RAAIM assessment hours are updated as the ISO changes the flexible category MOO hours?
ISO Response:
RAAIM assessment hours are mapped in an upstream system before data reaching the formulas in the Settlements BPM.  Hence as Flex Categories 2 and 3 hours change, an update of the hours mapped are implemented in the upstream system.
Action

Approve the BPM PRR as submitted

NA
Statement of apparent requirements of the BPM PRR

This BPM PRR contains basic language changes.
Priority and rank for any BPM PRR requiring a CAISO system change

There are no system changes associated with this PRR.
Proposed effective date(s) of the BPM PRR

The ISO proposes an effective date of 11/1/2016 for the BPM revisions.
Other recommended actions

The ISO does not recommend any other actions on this BPM 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 plus the additional content revisions proposed during the comment on recommendation period.
Stakeholder Comment

Comments were received from NCPA on 3/10/17 to note minor typos in Section 2.1, and on 3/16/17 to clarify the MAX function used for DayAheadUpperEnergyBidQuantity.  CAISO Responded on 3/22/17 by updating the BPM to fix the typos and to clarify which max function is being used.

Effective Date

11/1/2016
Action

Adopt the recommendation as modified

None.
Announcements
As PRR 1018 replaced PRR 968, the appeal on this PRR was withdrawn by the Joint Demand Response parties.
Posted On - 7/11/2018 9:31 AM
Impact Analysis
IA - Impact Analysis Form_RAAIM_PC_Updates_Mar_2017.doc    
Notes:
Initial Comments
No Initial Comments available for this PRR.
Recommendation Comments
Joint DR Parties Comments in Opposition to PRR 968_final.docx    
Comment of Joint Demand Response Parties (EnerNoc, Inc., CPower and EnergyHub).
3/16/2017 6:06 PM
Logged By - Payton, Julia (CAISO)
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ISO response to Joint Demand Response party comments:

1. The comments are outside the scope of the PRR process. Each subject area in a BPM is based on enabling language in the ISO tariff. The PRR process cannot be used to introduce changes that are not supported by existing tariff authority. Existing tariff authority allows the ISO to set the availability incentive hours as part of the annual Flexible Capacity Assessment. The proposed change is ministerial and does not modify any existing ISO tariff authority.
2. Legal issues are inapplicable to the PRR.
a. Section 40.1 of the tariff does not exempt CPUC-jurisdictional LSEs from the RA requirements in the tariff. The Joint DR Parties’ argument is that “Section 40.1 of the CAISO tariff clearly excludes LSEs regulated by the CPUC.” As the basis for this conclusion, the Joint DR Parties cite the following tariff language: “For purposes of Section 40, a Load Serving Entity shall not include any entity satisfying the terms of California Public Utilities Code Section 380(j)(3).” (emphasis added). Public Utilities Code Section 380(j)(3) only exempts “[c]ustomer generation located on the customer’s site or providing electric service through arrangements authorized by Section 218” from the definition of an LSE, it does not generally exempt CPUC-jurisdictional LSEs.
b. The Flexible Capacity Assessment process has been approved by FERC and therefore is just and reasonable. The Joint DR parties argue that PRR 968 would violate the Federal Power Act because the Availability Assessment Hours “significantly affect rates, terms and conditions of service” and therefore must be made via tariff amendment. As support for this statement, the Joint DR Parties cite FERC’s “rule of reason” which states that “provisions that ‘significantly affect rates, terms and conditions’ of service must be included in the tariff, while items better classified as implementation details may be included only in the business practice manual.” Case law notes that “The statutory directive must reasonably be read to require the recitation of only those practices that affect rates and service significantly, that are realistically susceptible of specification, and that are not so generally understood in any contractual arrangement as to render recitation superfluous.” (emphasis in the original). The Court further noted that “It is obviously left to the Commission [FERC], within broad bounds of discretion, to give concrete application to this amorphous directive.” In the present case, FERC has given concrete application to the rule of reason by approving the CAISO’s flexible resource adequacy criteria-must-offer obligation (FRAC-MOO) filing. In approving FRAC-MOO, FERC considered exactly what provisions were required to be included in the tariff. As a result, the tariff specifies the necessary parameters for the Flexible Capacity Needs Assessment consistent with FERC’s application of the rule of reason
4/10/2017 10:06 AM
Responded By - Payton, Julia (CAISO)
Please finish the max function from 3.6.11.6:

3.6.11.6 DayAheadUpperEnergyBidQuantity
DayAheadUpperEnergyBidQuantity BrtF’S’mdh =      Max(BAHourlyResDAMEnergyBidQty BrtubAA’pF’S’mdh,?)

The max of BAHourlyResDAMEnergyBidQty and what?

Thanks,
Mike
3/16/2017 12:00 PM
Logged By - Mike Whitney (NCPA)
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Updates to clarify which max function is being used, plus typos indicated in the 3/10/17 comment, will be addressed in the final posted version.  Attached BPM reflects these changes.
3/22/2017 5:08 PM
Responded By - Peacock, Bonnie (CAISO)
Typo.PNG    
Minor typos in 2.1
3/10/2017 9:04 AM
Logged By - Mike Whitney (NCPA)
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Typos will be addressed in the final posted version.
3/17/2017 12:56 PM
Responded By - Caldwell, Elizabeth (CAISO)
Click here to view the Appeals for this PRR
Click on the '+' icon to submit a New Appeal

# of Appeals In Progress - 0
# of Appeals Closed - 1
# of Appeals Abandoned - 0
#Appeal ReasonStatusResponseAppealed ByAppealed On
1The PRR 968 represents unreasonable market risk, supercedes jurisdiction expressly reserved for the Commission and represents non-tariffed changes to rates, terms and conditions of service.ClosedMona Tierney-Lloyd (Joint DR Parties)4/18/2017
Attachments