RSS Feed for Proposed Revision Request - 1404

PRR - 1404

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Initial Comment for PRR - 1404

Description: 1. Since hybrid resources are not subject to mitigation, PG&E is confused as to the meaning of “resources comprised of multiple technologies that include Non-Generator Resources” which are subject to mitigation (Pages 2 and 11). If not hybrids, what are these resources? 2. What is the default DEB ranking since it is removed from the Market Operations BPM (Page 5)? (Note: Market Instruments Attachment D does not specify) 3. Could the CAISO please clarify the difference between an IFM commitment and a binding day-ahead commitment? (Page 10) 4. Footnote 6 on Page 14 is confusing; there is no section 2.8.5.2 in the Market Operations BPM 5. The term “daily SOC limits” (Pages 16, 17, and 20) should be changed to “upper and lower charge limits” to match the SIBR Business Rules terminology 6. The CAISO should update the reference on Page 17, which refers to the BPM for Market Instruments, Appendix Attachment A, since this attachment redirects to the SIBR Business Rules on the CAISO’s website. 7. PG&E asks whether footnote 8 on Page 17 should read the opposite: “the procurement of ancillary services will take precedence over satisfying the EOH SOC constraint 8. Aren’t the “critical hours” on Page 20 defined as those which generate a RUC infeasibility in the IFM? Has the CAISO changed the meaning of this term to be more general? 9. In Example 1 (Page 20), why would the CAISO prefer a lesser minimum EOH SOC as a binding constraint during critical hours? Here, PG&E would expect the constraint to be 30MWh, which was the biddable min EOH SOC.
-By MichaelVolpePGE (Pacific Gas & Electric Company) on Tuesday, February 15, 2022 4:02:02 PM

Response: 1. Will respond ASAP 2. The default rankings are noted in Market Instruments Attachment B, table B.2.1 (see RDT Column Names COST_RANK_LMPM, NEGO_RANK_LMPM, and PRC_RANK_LMPM). The default rankings are also specified in Tariff section 39.7.1. If no rank order is specified, the following default rank order applies: variable cost, negotiated, LMP. 3. ‘Binding’ refers to whether the commitment is operationally binding. For long start resources, IFM commitments are operationally binding. For short start resources they are not – the real-time market can re-optimize those commitments. 4. Will respond ASAP. 5. Agree that we are using inconsistent terminology in this section. Will change the term ‘daily SOC limit’ to ‘daily Lower and Upper Charge Limit bids’. 6. We should leave the reference alone. If the attachment A redirect ever changes, we would have to change references to more than one document. 7. The footnote is correct. If ancillary services have already been procured, then SOC will be maintained to respect those services. However, if a participant has submitted an EOH SOC constraint, it may affect the procurement of further ancillary services. 8. See footnote on previous page. 9. Critical hours may be those in which CAISO needs to serve the most load, thus will rely on battery discharge. If the higher biddable constraint of 30 MWh is allowed to prevail, the battery may not provide needed supply to the grid, and in some cases may even result in charging of the battery.
-By Batakji, Jamal on Tuesday, February 22, 2022 9:47:16 AM

Recommendation Comment for PRR - 1404

Description: 1. Since hybrid resources are not subject to mitigation, PG&E is confused as to the meaning of “resources comprised of multiple technologies that include Non-Generator Resources” which are subject to mitigation (Pages 2 and 11). If not hybrids, what are these resources? The text originates from Tariff section 31.2 and describes how mitigation is applied for resources under the Generic NGR model. The mitigation framework for hybrid resources is applied separately. 2. What is the default DEB ranking since it is removed from the Market Operations BPM (Page 5)? (Note: Market Instruments Attachment D does not specify) The default rankings are noted in Market Instruments Attachment B, table B.2.1 (see RDT Column Names COST_RANK_LMPM, NEGO_RANK_LMPM, and PRC_RANK_LMPM). The default rankings are also specified in Tariff section 39.7.1. If no rank order is specified, the following default rank order applies: variable cost, negotiated, LMP. 3. Could the CAISO please clarify the difference between an IFM commitment and a binding day-ahead commitment? (Page 10) ‘Binding’ refers to whether the commitment is operationally binding. For long start resources, IFM commitments are operationally binding. For short start resources they are not – the real-time market can re-optimize those commitments. 4. Footnote 6 on Page 14 is confusing; there is no section 2.8.5.2 in the Market Operations BPM This should read 7.8.5.2, we will make this correction. 5. The term “daily SOC limits” (Pages 16, 17, and 20) should be changed to “upper and lower charge limits” to match the SIBR Business Rules terminology We will revise the term “daily SOC limits” to “daily Lower and Upper Charge Limit bids.” 6. The CAISO should update the reference on Page 17, which refers to the BPM for Market Instruments, Appendix Attachment A, since this attachment redirects to the SIBR Business Rules on the CAISO’s website. This reference will be left as-is due to revision control considerations between documents. 7. PG&E asks whether footnote 8 on Page 17 should read the opposite: “the procurement of ancillary services will take precedence over satisfying the EOH SOC constraint The footnote is correct. If ancillary services have already been procured, then SOC will be maintained to respect those services. However, if a participant has submitted an EOH SOC constraint, it may affect the procurement of further ancillary services. 8. Aren’t the “critical hours” on Page 20 defined as those which generate a RUC infeasibility in the IFM? Has the CAISO changed the meaning of this term to be more general? See footnote on previous page. 9. In Example 1 (Page 20), why would the CAISO prefer a lesser minimum EOH SOC as a binding constraint during critical hours? Here, PG&E would expect the constraint to be 30MWh, which was the biddable min EOH SOC. Critical hours may be those in which CAISO needs to serve the most load, thus will rely on battery discharge. If the higher biddable constraint of 30 MWh is allowed to prevail, the battery may not provide needed supply to the grid, and in some cases may even result in charging of the battery.
-By Martin, Michael on Tuesday, March 22, 2022 11:46:40 AM

Recommendation Comment for PRR - 1404

Description: Attached are edits to the originally submitted MO BPM with edits to Items 4 and 5
-By Martin, Michael on Tuesday, March 22, 2022 11:49:51 AM

Recommendation for PRR - 1404

Proposed Language:

Edits to PRR1404 attached.

Remaining questions are also attached

Action: Approve the BPM PRR as submitted or modified and forward to CAISO senior management for consideration and possible approval, rejection or referral
Effective Date: 01/01/0001

Final Decision for PRR - 1404

Final Decision: Adopt recommendation as Modified
Stakeholder Comment: Additional examples were added for more clarity.
Action: Adopt the recommendation as modified
Effective Date: 01/01/0001