RSS Feed for Proposed Revision Request - 1663

PRR - 1663

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Impact Analysis for PRR - 1663

-By Madrigal, Radha on Monday, March 2, 2026 10:19:11 AM

Announcement for PRR - 1663

Description: Please note updated PRR attachment posted 3/3/26
-By Madrigal, Radha on Tuesday, March 3, 2026 5:17:41 PM

Initial Comment for PRR - 1663

Description: Please see Southern California Edison's comments.
-By John Diep (Southern California Edison) on Tuesday, March 17, 2026 2:10:05 PM

Initial Comment for PRR - 1663

Description: The Six Cities have the following questions concerning revisions included in the indicated sections for PRR 1663 - - Re § 7.1.2(9) - - The Six Cities have been unable to locate any tariff section relating to the concept of overlapping RA capacity described in § 7.1.2(9), and the reference to a “true-up settlement” is unclear. What would be “trued-up” in the situation of overlapping capacity. The Six Cities request that the CAISO provide additional explanation regarding the purpose and mechanics for the described LSE-RA Resource True-up settlement, including an illustrative example. Re § 7.4, next to last paragraph - - The language stating that “[t]he SC will be able to adjust or cancel reassignment for future TDs that have not had the DAM run for that TD” appears to conflict with the requirement that reassignments be submitted and approved by 8:00 a.m. on the calendar day before the trading day. The Six Cities request that the CAISO clarify the timing for submission of an adjustment to or cancellation of a reassignment.
-By Bonnie Blair (Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, CA) on Tuesday, March 17, 2026 2:32:27 PM

Initial Comment for PRR - 1663

Description: PG&E’s comment: this section establishes an 8:00 AM Day Ahead Market reassignment deadline on the calendar day prior to the trading day. PG&E notes that this 8:00 AM deadline is not specified in the tariff, so this can be altered if the BPM review process determines that it should. In PG&E’s view, an 8:00 AM deadline impacts dependencies outside of the ISO. Notably, the EDAM entities that are being reassigned to will require the source information before the 8:00 AM deadline. Given current trading and scheduling practices, confirming a source (EDAM or non-EDAM) before 8:00 AM is difficult and often not possible. This could result in an increase in unspecified schedules being submitted to the ISO. The ISO should clarify the intended purpose of the 8:00 AM deadline and consider whether an adjusted reassignment timeline is necessary in light of the intertie scheduling realities and third party SC approval requirements.
-By Alan Meck (PG&E) on Tuesday, March 17, 2026 4:27:55 PM

Recommendation Comment for PRR - 1663

Description: We have received written comments from Jake McDermott on behalf of Terra-Gen on 4/7/26. Please see attached. In addition, the following notes were provided for context: There are redlines in the attached doc on page 89 relevant to the NGR (Non-REM) for the summary of bidding requirements for resources providing RA capacity. (See Sec 7.1.1.). Terra-Gen recommends these redlines as needed changes to PRR 1663 to account for the fuel-limited nature of hybrid resources participating as NGRs. Without those redlines, the CAISO would assume that resources are required to submit RUC/RCU/RCD bids during all hours of the day which may not be possible for hybrids overnight.
-By Madrigal, Radha on Tuesday, April 7, 2026 11:39:01 AM

Response: Thank you for your recommendation. The proposed recommendation to RUC Bidding requirements for NGRs aligns with section 40.6.1.1 (b) (B) of the Tariff. CAISO will adopt this recommendation. Please note that section 40.6.1.1(b)(B) and this part of the BPM applies to NGRs and not to hybrid resources. The proposed recommendation to RTM bidding requirements does not align with section 40.6.2(g)(B). The CAISO will not adopt this recommendation.
-By Bogen, Melanie on Tuesday, April 28, 2026 10:08:10 AM

Recommendation Comment for PRR - 1663

Description: We have received written comments from Cathleen Colbert on behalf of Vistra on 4/14/26. Please see attached.
-By Madrigal, Radha on Wednesday, April 15, 2026 9:03:04 AM

Response: Thank you for your recommendations. Based on the comments received during the PRR process, the CAISO does not believe another review cycle necessary. If additional comments or clarifications are needed after the PRR process is complete, please reach out. Section 7.1.1 – Storage Generic RCU MOO: To align with section 40.6.1.1(b)(B) of the Tariff, the CAISO will revise the RUC bidding requirements for Non-generator resources (Non-REM) to the following: “Submit RUC Availability Bids for RCU and RCD for all RA Capacity for all hours of the month the resource is physically available”. Section 7.1.1 – RTM MOO: The CAISO does not agree there are cases when generic RA converts to flexible RA. It is important to distinguish between an offer obligation arising because of status as RA capacity and offer obligations arising in the real-time from having been awarded reliability capacity or imbalance reserves. Resources must honor both sets of obligations. Section 7.3.3 – Flexible RCU MOO: The CAISO will accept this recommendation and add the following clarification to this section of the BPM: “The Scheduling Coordinator for a Flexible RA Capacity Resource must submit RUC Availability Bids for RCU to cover their Flexible RA Obligation, subject to otherwise applicable limits on bidding for reliability capacity.”. The CAISO will also update section 7.3.5 of the BPM to align with this recommendation. Section 7.3.3 – Flexible RCU MOO The table is correct when it states no RCU bid insertion for Flex RA. Per section 40.10.6.2 of the tariff, CAISO does not insert generated bids for flex RA. That doesn't change from DAME. If a resource is providing only flex RA, then there are no generated bids for RCU. But if they are providing generic and flex, then section 40.6.8 would still apply.
-By Bogen, Melanie on Tuesday, April 28, 2026 10:07:16 AM

Recommendation for PRR - 1663

Proposed Language:

See attached

Apparent Requirement: CAISO reply comments to initial comments are attached to PRR.
Action: Approve the BPM PRR as submitted
Effective Date: 05/01/2026

Final Decision for PRR - 1663

Final Decision: Adopt the recommendation as modified, see attached.
Stakeholder Comment: Requested clarifying language
Action: Adopt the recommendation as modified
Effective Date: 05/01/2026