RSS Feed for Proposed Revision Request - 1181

PRR - 1181

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Initial Comment for PRR - 1181

Description: Idaho Power Company comments: With PRR 1181, CAISO is proposing to significantly increase the requirements for Master File change requests. Idaho Power objects to the magnitude of these changes and the additional burden these changes place on EIM Entities. CAISO has not provided justification or explanation for why these changes are necessary except to support Corporate Goal 4a. Please identify what Corporate Goal 4a is and how these changes are necessary for that objective. Idaho Power does not support the changes and recommends the proposed language not be adopted for all SC’s in the market. If CAISO adopts the proposed language for resources within the CAISO BAA, it should retain the existing current requirements, without these proposed changes, for resources in EIM Entity BAAs. The additional information the proposed language would require is unduly burdensome and would materially increase the time required to make Master File changes and potentially increase the rejection rate of changes an EIM Entity needs on resources in its BAA. Entities can discover that changes are necessary to how a resource is modelled in the normal course of business, and should be able to make those corrections without burdensome information requirements. Moreover, the proposed required information is unnecessary for resources not in the CAISO BAA, and CAISO should not be in the position of verifying whether EIM Entities are modeling their resources correctly. Entities are already required by section 4.6.4 of the CAISO Tariff to ensure that resources are modelled correctly. In addition, incorrect modeling of resources in the EIM Entity’s BAA can lead to financial and reliability issues, a further incentive to ensure these are correctly represented in the model. The proposed changes should not be adopted, or if adopted, should be limited to resources internal to the CAISO BAA. Thank you for the opportunity to comment. Camille Christen Idaho Power Company
-By Camille Christen (Idaho Power Company) on Tuesday, September 17, 2019 2:24:50 PM

Initial Comment for PRR - 1181

Description: Please see attachment for PG&E's comments.
-By Mark Tiemens (PG&E) on Tuesday, September 17, 2019 4:36:09 PM

Initial Comment for PRR - 1181

Description: Attached are comments, questions on the original draft and suggested edits. Three attachments.
-By Mark (Calpine) on Tuesday, September 17, 2019 7:02:00 PM

Initial Comment for PRR - 1181

-By Aditya Chauhan (SCE) (Southern California Edison) on Wednesday, September 18, 2019 8:57:16 AM

Initial Comment for PRR - 1181

Description: WPTF comments on proposed changes.
-By Gridwell Consulting for WPTF (Western Power Trading Forum) on Wednesday, September 18, 2019 1:03:04 PM

Initial Comment for PRR - 1181

-By Brian Theaker (Middle River Power, LLC) on Wednesday, September 18, 2019 2:01:18 PM

Initial Comment for PRR - 1181

Description: Comments of Portland General Electric on PRR 1181: Attachment B Revisions
-By Ryan Millard (Portland General Electric Company) on Wednesday, September 18, 2019 2:06:58 PM

Initial Comment for PRR - 1181

Description: Brandon Gimper Sr. Regulatory Compliance Analyst Federal & Regional Policy | Puget Sound Energy (P): 425-457-5421 355 110th Ave NE, EST 07W, Bellevue, WA 98004
-By Payton, Julia on Tuesday, September 24, 2019 10:21:54 AM

Initial Comment for PRR - 1181

Description: ISO Response to stakeholder comments
-By Payton, Julia on Wednesday, October 2, 2019 7:55:52 AM

Recommendation Comment for PRR - 1181

-By elynor reyes (Calpine Corporation) on Tuesday, October 15, 2019 4:11:42 PM

Response: The ISO believes that OEM manuals are just one way that an entity could demonstrate an age-adjusted design capability. The ISO has changed the language in the Recommendation phase to clarify that only an explanation for the change is required upon initial submittal of the change. Only if the explanation does not adequately support the request would the ISO ask for additional supporting materials that the Scheduling Coordinator and Generator Owner would have used as a basis for their change request. The ISO believes that this process provides an appropriate due diligence review for changes being implemented in the Master File.
-By Batakji, Jamal on Thursday, October 24, 2019 1:05:04 PM

Recommendation Comment for PRR - 1181

-By Gridwell Consulting for WPTF (Western Power Trading Forum) on Tuesday, October 15, 2019 4:14:04 PM

Response: The concept of age-adjusted design capability is in the tariff today and is not part of this BPM revision. The ISO fundamentally disagrees that it should not perform a due diligence review prior to implementing changes in the Master File.
-By Batakji, Jamal on Thursday, October 24, 2019 1:03:39 PM

Announcement for PRR - 1181

Description: CAISO has received written communication dated 2/25/2020 from WPTF that states: "Given the recent posting of PRR 1230, WPTF, and the parties, withdraw the appeal to PRR 1181."
-By Hines, Nicole on Wednesday, February 26, 2020 9:06:42 AM

Announcement for PRR - 1181

Description: CAISO has received written communication dated 3/18/2020 from SCE that states: "SCE would like to withdraw its appeal of 1181."
-By Hines, Nicole on Thursday, March 19, 2020 3:40:41 PM

Recommendation for PRR - 1181

Proposed Language:

The ISO may modify the draft language to accommodate the comments provided by stakeholders

Apparent Requirement: Attachment B changes to support Tariff Section 4.6.4
Priority: N/A
Action: Approve the BPM PRR as modified.
Effective Date:
Other Actions: No other recommended actions on this PRR.

Final Decision for PRR - 1181

Final Decision: The ISO will adopt the BPM change as proposed in the recommendation.
Stakeholder Comment: Comments were submitted, and CAISO responded accordingly.
Action: Adopt the recommendation as originally issued
Effective Date: 10/25/2019

Appeal for PRR - 1181

Reason for Appeal: Please see attached Joint Appeal document for reasons why the Parties are appealing the decision.
Status: Closed
-By Gridwell Consulting for WPTF (Western Power Trading Forum) on Thursday, November 7, 2019 3:35:11 PM

Appeal for PRR - 1181

Reason for Appeal: See attached
Status: Closed
-By Aditya Chauhan (SCE) (Southern California Edison) on Tuesday, November 12, 2019 8:43:08 AM