RSS Feed for Proposed Revision Request - 1104

PRR - 1104

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Initial Comment for PRR - 1104

Description: The BPM should also address confidentiality. That is, what data will be exchanged with other BAAs, and with what form of confidentiality protections? We understand that the RC will be "walled off" from the CAISO Dispatch Center, but what access to data will be granted to market participants, regulators or state entities?
-By Mark (Calpine) on Monday, November 5, 2018 12:32:53 PM

Response: The RCSA says that information will be treated in accordance with section 20 of the tariff or the applicable data sharing information agreement, which is as it is today, so there should not be concerns of confidentiality.
-By Katta, Gautham on Tuesday, November 27, 2018 1:16:20 AM

Initial Comment for PRR - 1104

Description: SRP suggests that any details that are covered by the RC Operating Procedures should not be duplicated in this BPM. As CAISO has acknowledged in its FERC filing, the NERC standards dictate the function and scope of RC services, and the CAISO is working with RC Customers to develop a series of detailed RC Operating Procedures covering all aspects of RC service. We have serious concerns about the details of those procedures being duplicated here, with a real likelihood that as the procedures evolve the terms may diverge with the BPM, create confusion for customers, CAISO staff and the public about what source should be looked to as the authoritative source. We also are concerned that this duplication will add needless administrative work to all parties to keep the documents aligned. In addition, the CAISO’s change process for BPMs creates an added layer of process and workload. We urge CAISO to review the RC Operating Procedures and remove all duplicative material from this BPM, using the BPM to cover only those areas that are not covered under the RC Operating Procedures. SRP makes suggested changes consistent with these comments in the attached redlined BPM. Thank you.
-By Nancy Saracino (Salt River Project) on Thursday, November 8, 2018 4:45:55 PM

Response: Please review the latest redline BPM attached to this PRR. This should address your concerns.
-By Katta, Gautham on Tuesday, November 27, 2018 1:18:34 AM

Initial Comment for PRR - 1104

Description: Bonneville Power Administration (BPA) has reviewed the Business Practice Manual for Reliability Coordinator Services (BPM) and comments submitted by the Salt River Project (SRP). BPA supports the comments submitted by SRP. In particular, BPA agrees that the BPM should not describe or summarize information already contained and approved in RC Operating procedures such as the Outage Coordination Process, System Operating Limit Methodology, IRO-010 Data Exchange requirements, Real Time and other operating procedures etc. To do otherwise creates an unnecessary risk for potential conflicts between the BPM and those operating procedures.
-By Young Linn BPA (Transmission Services) on Friday, November 16, 2018 12:06:08 PM

Response: CAISO agrees to the above feedback. Please review the latest redline BPM attached to this PRR.
-By Katta, Gautham on Tuesday, November 27, 2018 1:17:34 AM

Announcement for PRR - 1104

Description: New redline version attached please review.
-By Katta, Gautham on Thursday, November 29, 2018 4:31:36 PM

Recommendation Comment for PRR - 1104

Description: Section 5.1 has a table with the following line item (#14): "Net Energy for Load and Net Generation for settlements purposes will be obtained either through direct submission or optionally calculated if the RC customer is an EIM entity. Submission of Net Energy for Load and Net Generation will be through the MRI-Settlements application and be available through both user interface and CAISO standard web services. Settlements bill determinant files, statements, and invoices will be available through MRI-S via both the user interface and CAISO standard web services." The table discusses the “option” of having the Net Energy for Load calculated if the RC customer is an EIM entity. (I was expecting section 12 to further discuss specifics on how this would be done and the optionality provided.) Can the CAISO provide additional clarity in section 12 relating to the Net Energy for Load calculation when the RC customer is an EIM entity? Is this automatically done? Does it require a formal request for the CAISO to do this?
-By Christine Kirsten (PacifiCorp) on Monday, December 10, 2018 9:15:22 AM

Response: Please see the redline - version 3.
-By Katta, Gautham on Thursday, December 20, 2018 10:37:12 AM

Recommendation Comment for PRR - 1104

Description: Regarding section 12.1.1, does the CAISO anticipate that the Net Generation and annual Net Energy for Load will be consistent with the generation and load values that are submitted for EIM purposes (for an EIM entity)? To clarify, is it expected that the generation and load values submitted for RC purposes will be representative of the CAISO network model?
-By Christine Kirsten (PacifiCorp) on Friday, December 14, 2018 11:16:23 AM

Response: EIM entities need to submit their NEL/NG in accordance with WECC’s definitions of NEL/NG. The CAISO would not know whether or not an EIM entity’s (EIM) volumes match WECC’s definition of NEL/NG for that entity.
-By Katta, Gautham on Thursday, December 20, 2018 10:36:41 AM

Recommendation for PRR - 1104

Proposed Language:

SRP and BPA comments are addressed in the latest redline version. Please review the changes.

Apparent Requirement: NA
Priority: NA
Action: Approve the BPM PRR as modified.
Effective Date:
Other Actions: N/A

Final Decision for PRR - 1104

Final Decision: Adopt the redline as final BPM version for RC service.
Stakeholder Comment: ISO received comments from Calpine, BPA, SRP and PAC during the PRR process. All comments have been addressed in the redline document attached to this PRR.
Action: Adopt the recommendation as modified
Effective Date: 04/01/2019