RSS Feed for Proposed Revision Request - 1345

PRR - 1345

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Initial Comment for PRR - 1345

Description: Because CAISO’s BPM revisions significantly affect rates, terms, and conditions of service, they must be filed with FERC for review under section 205 of the Federal Power Act. It is inappropriate to make these changes through the business practice manual. FERC uses its “rule of reason” policy to identify “provisions that significantly affect rates, terms, and conditions” and must therefore be part of the tariff, rather than a business practice manual. Midcontinent Indep. Sys. Operator, Inc., 158 FERC ¶ 61,003 at P 69 (2017) (citing Cal. Indep. Sys. Operator Corp., 119 FERC ¶ 61,076 at P 656 (2007); Order No. 890-A, 121 FERC ¶ 61,297 at ¶¶ 988, 990 (2007) (“. . . we reiterate that each ISO and RTO must include in its OATT all of the rules, standards and practices that significantly affect the transmission service provided by the ISO or RTO. . .”). The proposed changes unquestionably have a significant effect on the terms and conditions of transmission service across the CAISO transmission system. With the adoption of these business practice manual changes, wheel-through transactions using firm transmission on the import and export legs would receive a lower level of priority when CAISO runs its day-ahead and real-time markets. This has the effect of turning firm wheel-through transactions into non-firm transactions, which significantly alters CAISO’s longstanding practice, materially affects costs to entities scheduling on the CAISO system and affects how utilities will source power in Western energy markets. CAISO cannot reasonably claim that these changes will not “significantly affect rates, terms, and conditions” of transmission service. Indeed, many of the BPM changes proposed here specify the terms and conditions of transmission service across the CAISO transmission system that are the subject of tariff changes currently pending before FERC in Docket No. ER21-1790 – this fact indicates that CAISO itself recognizes that tariff changes are necessary for these fundamental changes to CAISO markets and scheduling prioritization. These market and scheduling rules should be implemented via amendment to CAISO’s tariff. It is contrary to FERC precedent to proceed with making these changes via the BPM.
-By Marcie Martin (SRP) on Tuesday, May 18, 2021 2:03:48 PM

Response: Pending FERC decision. Please refer to tariff revision in ER21-1790.
-By Batakji, Jamal on Wednesday, June 23, 2021 2:08:47 PM

Initial Comment for PRR - 1345

Description: Idaho Power Company objects to the proposed revisions in PRR 1345. The proposed changes are not appropriate to be made through a Business Practice Manual change, and moreover, are unduly discriminatory or preferential. The proposed BPM revisions in PRR 1345 significantly affect the rates, terms, and conditions of service. The proposed revisions would change the penalty pricing parameters that dictate the priority of curtailments for wheel-throughs on CAISO’s system. The priority of curtailments for wheel-throughs is a fundamental term or condition of service that must be properly filed with the Federal Energy Regulatory Commission (FERC) and included in the tariff under section 205(c) of the Federal Power Act and FERC’s “rule of reason” policy, which requires that practices that significantly affect rates, terms and conditions be filed with the FERC. Thus, these changes are not appropriate for a Business Practice Manual change. In addition, because the revisions proposed in PRR 1345 would accomplish the same prioritization changes as the proposed tariff revisions in FERC Docket No. ER21-1790, they create additional and unduly discriminatory hurdles for wheel-throughs to be prioritized equally to CAISO load, and are not just and reasonable, nor are they consistent with or superior to FERC’s pro forma open access requirements, as described further in Idaho Power’s protest in that docket (filed May 19, 2021).
-By Camille Christen (Idaho Power Company) on Friday, June 4, 2021 7:30:30 PM

Response: Pending FERC decision. Please refer to tariff revision in ER21-1790.
-By Batakji, Jamal on Wednesday, June 23, 2021 2:08:09 PM

Initial Comment for PRR - 1345

Description: Portland General Electric Company (PGE) objects to the proposed revisions in PRR 1345. The proposed changes are not appropriate to be made through a Business Practice Manual change, and moreover, are unduly discriminatory or preferential. Consistent with the objections noted by previous commenters, PGE also maintains that the adoption of these business practice manual changes would result in a material change to the priority of curtailments for wheel-throughs which is a fundamental term or condition of service that must be filed with the Federal Energy Regulatory Commission (FERC) and included in the tariff under section 205(c) of the Federal Power Act and FERC’s “rule of reason” policy, which requires that practices that significantly affect rates, terms and conditions be filed with the FERC. Moreover, because the revisions proposed in PRR 1345 would accomplish the same prioritization changes as the proposed tariff revisions in FERC Docket No. ER21-1790, it is not only imprudent to implement these BPM changes prior to any FERC approval of the related tariff revisions, but, as noted by Idaho Power, it creates additional and unduly discriminatory hurdles for wheel-throughs to be prioritized equally to CAISO load, and are not just and reasonable, nor are they consistent with or superior to FERC’s pro forma open access requirements, as described further in the joint protest filed by PGE and Idaho Power in that docket (filed May 19, 2021).
-By Ryan Millard (Portland General Electric Company) on Monday, June 14, 2021 9:56:19 AM

Response: Pending FERC decision. Please refer to tariff revision in ER21-1790
-By Batakji, Jamal on Wednesday, June 23, 2021 2:07:33 PM

Recommendation for PRR - 1345

Proposed Language:

No modifications to the original PRR are proposed.

Apparent Requirement: Market operations BPM changes as it relates to scheduling priorities
Priority: N/A
Action: Approve the BPM PRR as submitted
Effective Date:
Other Actions: No other recommended actions on this PRR.

Final Decision for PRR - 1345

Final Decision: Approve as submitted
Stakeholder Comment: No recommendation comments
Action: Adopt the recommendation as originally issued
Effective Date: 01/01/0001