RSS Feed for Proposed Revision Request - 1568

PRR - 1568

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Recommendation Comment for PRR - 1568

Description: CAISO Received written comments from Sara Eaton at BPA on 4/23/24. BPA appreciates the opportunity to provide input on the G-FP Tagging BPM. In discussions with CAISO on the original BPM updates, back in May of 2023, it was highlighted that these G-FP tags would only be curtailed when CAISO was in an EEA 3 and the risk of shedding load was substantial. Further, the discussion highlighted that these tags would only be curtailed if they had cleared DA, cleared the HASP and then circumstances changed after the HASP – essentially that these tags would not clear the HASP if an EEA 3 is triggered and CAISO is arming firm load. Based on these previous discussions, we were expecting to see this distinction to be more explicit in the new BPM language. But in reviewing the below section from the BPM, along with the referenced section of the tariff, it reads as though CAISO is able to curtail these tags prior to an EEA 3. BPA would appreciate the CAISO BPM to more clearly identify that it will not be curtailing G-FP tags, unless the CAISO is in an EEA 3.  Provisions for G-FP Use In E-Tag Market Path “Product” field: As provided in Section 34.12.4, curtailment is to be effectuated consistent with good utility practice and operator judgement. The G-FP tag allows the CAISO to utilize its tariff authority to • restore contingency reserves following a contingency and deployment of existing contingency resources, where in the case where the re-procurement of contingency reserves is deficient. • maintain reliability, including in an EEA3 condition, where armed load is utilized to restore deficient contingency reserves in conjunction with E-Tag curtailments, in order to maintain required contingency reserves.
-By Hines, Nicole on Wednesday, April 24, 2024 3:20:05 PM

Recommendation Comment for PRR - 1568

Description: CAISO Response: Thank you for your comment in response to PRR 1568. While we agree and discussed that in almost all cases the CAISO will not curtail G-FP tags unless there is an EEA3, there may be a need in extenuating circumstances and timing where curtailment of GF-Ps tags are necessary while in an EEA2 and the EEA3 is expected forthcoming. We would need to strike that BPM language and the Tariff language below if we are limited to curtailment in only an EEA3. BPM language: “As provided in Section 34.12.4, curtailment is to be effectuated consistent with good utility practice and operator judgement” was meant to allow operator discretion and judgement as a factor in determining curtailment of G-FP tags. Tariff Language: 34.12.4 At its sole discretion, the CAISO may, after HASP, apply the market scheduling run priorities in Section 34.12.1 through manual operator intervention to curtail lower priority HASP hourly block export schedules even before the CAISO Balancing Authority Area is in an energy emergency alert. When the CAISO is in an emergency alert level 3 (EEA 3), subject to operator judgement and consistent with good utility practice, it will curtail in accordance with the priority specified below to prevent the need to arm Load, or reduce the amount of Load that is armed, and meet its operating reserve obligations
-By Martin, Michael on Thursday, May 2, 2024 5:54:58 PM

Recommendation for PRR - 1568

Proposed Language:

Approve as submitted

Apparent Requirement: See attached
Priority: NA
Action: Approve the BPM PRR as submitted
Effective Date: 01/01/0001
Other Actions: NA

Final Decision for PRR - 1568

Final Decision: Approve as submitted
Stakeholder Comment: noted addition clarification needed on re-tagging, which CAISO agreed and will submit in a separate PRR
Action: Adopt the recommendation as originally issued
Effective Date: 01/01/0001