RSS Feed for Proposed Revision Request - 1154

PRR - 1154

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Announcement for PRR - 1154

Description: The revised BPM updated the Forced nature of work for 'New Generator Test Energy' to not require substitution.
-By Woody, Kyle on Tuesday, May 7, 2019 8:07:45 AM

Initial Comment for PRR - 1154

-By winichen (ISO & FERC Relations) on Tuesday, May 14, 2019 1:44:59 PM

Response: The CAISO’s implementation of tariff section 40.9.3.4(d) must be guided by the principle that the tariff does not guarantee a RAAIM exemption for every outage beyond the generator’s control. The RAAIM exemption, instead, is tied to specific nature of work categories. In identifying a nature of work as RAAIM exempt, the CAISO needs to be comfortable that every (or virtually every) outage reported in that category meets one of the three factors identified in section 40.9.3.4(d). The CAISO is not confident that the “environmental restrictions” nature of work meets this standard. PG&E’s example of condor curtailments conceivably could be framed as an outage outside the resource’s control but that is not relevant to a wind resource because they already are categorically exempt from RAAIM. PG&E’s example of restrictions on burning diesel, however, is a case of an outage within the generator’s control. An emissions limitation is not exogenous to the resource because those restrictions only curtail output to the extent a given resource emits. In PG&E’s specific example, if the initial gas system outage falls within the scope of issues covered by the RAAIM-exempt “Ambient Not Due to Temp” nature of work, then once the diesel emission limitations foreclose further operations the resource could report the outage under that exempt nature of work for as long as the qualifying gas system limitations remain in place. Otherwise, the outage properly would be reported under either the “Environmental Restrictions” or “Ambient due to Fuel insufficiency” outage types.
-By Woody, Kyle on Tuesday, July 16, 2019 9:48:03 AM

Initial Comment for PRR - 1154

Description: NRG Energy, Inc. Initial Comments on BPM CM 1154
-By Brian Theaker (NRG Energy) on Thursday, May 16, 2019 7:06:54 AM

Response: To the extent that there are concerns regarding the determined opportunity costs not binding for use limited resources, please refer to the “use limit reached” outage cards. The “environmental restrictions” outage card is not intended to be a catch all outage card that provides substitution and RAAIM exemptions. In regard to this languag being in the bpm and not the tariff, FERC has approved several tariff provisions that allow the ISO to defer certain details to the relevant BPM. This is one of those provisions.
-By Woody, Kyle on Tuesday, July 16, 2019 1:59:09 PM

Announcement for PRR - 1154

Description: The response to initial comments and recommendation posting will be delayed until mid-June, as this will require further discussion.
-By Payton, Julia on Wednesday, May 29, 2019 4:23:54 PM

Announcement for PRR - 1154

Description: The ISO has place PRR 1154 on hold pending the review and response to comments and posting of the Recommendation. We anticipate the posting in a couple weeks.
-By Payton, Julia on Thursday, June 20, 2019 9:41:25 AM

Announcement for PRR - 1154

Description: The ISO posted a revised version of the redlined BPM and posted the response to comments and recommendation.
-By Payton, Julia on Tuesday, July 16, 2019 4:42:12 PM

Recommendation for PRR - 1154

Proposed Language:

Please see attached "Revised" BPM.

Apparent Requirement: n/a
Priority: n/a
Action: Approve the BPM PRR as modified.
Effective Date: 07/22/2026
Other Actions: n/a

Final Decision for PRR - 1154

Final Decision: The BPM has been approved as revised.
Stakeholder Comment: N/A
Action: Adopt the recommendation as modified
Effective Date: 08/06/2019