Full Network Model Expansion Straw Proposal Comments Page 1 of 33 Full Network Model Expansion Straw Proposal Comments NRG Energy, Inc.............................................................................................................................4 NRG supports the CAISO’s proposal to expand its full network model (FNM) to: ....................... 4 Pacific Gas & Electric (PG&E) ......................................................................................................5 Opening Comments ............................................................................................................................... 5 1. The CAISO should immediately begin to track all loop flow data. Key information on loop flows should inform this initiative. ........................................................................................................ 5 2. CAISO loads should not pay for less efficient unit-positioning due to improper positioning or flows in external Balancing Areas (BAs)............................................................................................. 6 3. The CAISO should implement cost-allocation based on cost-causation for RTCIO ............... 7 4. The use of WECC tools is a good starting point, but the CAISO’s plan must also ensure reasonable modeling inputs to ensure reasonable market outcomes. .......................................... 8 a. The scope and formulations of the proposed system-to-system exchanges between the CAISO and WECC need review. ......................................................................................................... 8 b. The CAISO should address how it will manage flawed inputs or unreasonable model results....................................................................................................................................................... 8 c. The specific formulas and details involved in estimating loop flows, generation distribution factors, and external BAs’ load-distribution factors warrant high-level stakeholder review. ....... 9 5. The CAISO should review risks of pricing inconsistencies if unique constraints are used to simultaneously enforce a physical limit and a scheduling limit. .................................................... 10 6. The expanded FNM’s effects on market solution times need review to ensure the time leading up to a full market solution is used optimally. .................................................................... 10 Powerex ........................................................................................................................................ 11 Opening Comments ............................................................................................................................. 11
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Full Network Model Expansion Straw Proposal Comments Page 1 of 33
Full Network Model Expansion Straw Proposal
Comments
NRG Energy, Inc. ............................................................................................................................4
NRG supports the CAISO’s proposal to expand its full network model (FNM) to: ....................... 4
Pacific Gas & Electric (PG&E) ......................................................................................................5
Full Network Model Expansion Straw Proposal Comments Page 8 of 33
4. The use of WECC tools is a good starting point, but the CAISO’s plan must also ensure reasonable modeling inputs to ensure reasonable market outcomes.
PG&E supports the proposed idea of leveraging currently available WECC tools and data for the
CAISO’s FNM expansion through a phased approach. Generally, this plan will help the CAISO
to better consider loop flows and reliability needs.
Changes to the FNM, however, will affect market outcomes and so require several checks on
reasonableness.
ISO Response
The ISO agrees. WECC data will serve as a guide to the ISO for day-ahead conditions but it
will not be the only source. The ISO will also have historical flow data and it remains within our
discretion to adjust data received from WECC to reflect those real-time flows considering the
expected conditions. This serves as a reliable check on reasonableness of the WECC data.
See also discussion in Section 11.
a. The scope and formulations of the proposed system-to-system exchanges between the CAISO and WECC need review.
As PG&E understands it, the CAISO intends to calculate state-estimations and flows for
neighboring BAs for each market run by pulling information from the WECC, e.g. from the
WECC’s exchange tool. How frequent will these transactions occur? How often should the
CAISO “drop” new versions of its expanded FNM? With respect to sequencing the information
exchanges, when and how will WECC-wide information in the Day-Ahead (DA) feed into the
Integrated Forward Market, particularly if e-tags detailing the DA WECC interchanges are not
submitted to WECC until 3pm? The CAISO should thus provide step-by-step details on how its
market optimization will access and use information from the WECC. A general assessment of
this information technology work should show that the proposed plan is feasible.
ISO Response
See discussion in Section 11.
Updates to the expanded FNM are not expected to be any more frequent than current practices,
which is periodic and typically occurs on a 30-60 day cycle.
b. The CAISO should address how it will manage flawed inputs or unreasonable model results.
How will the process include new and relevant information such as major outages on a key BA
to BA intertie? What if the exchange process fails and market results become unreasonable?
What if RAS schemes are activated in external BAs, dramatically effecting transfer capabilities
Full Network Model Expansion Straw Proposal Comments Page 9 of 33
or resource loading and invalidating the CAISO’s assumed flows? The CAISO must develop a
process for addressing problems that may result from an expanded FNM which is out of the
CAISO’s control and perhaps also visibility.
ISO Response
The ISO appreciates PG&E’s comments. The goal of the FNM expansion is to model and
include as much up-to-date information as possible for the day-ahead and real-time to ensure
reliability. The issues PG&E points out are some of the concerns that have led the ISO to
pursue this initiative. For example, the current day-ahead schedules ignore loop flows from
external transactions (e.g., next day operating conditions of external systems, including
generation schedules and transmission outages). Consequently, the ISO takes several actions
in the real-time to mitigate such loop flows such as transmission limit reductions on power flow
constraints, the use of compensating injections account for the loop flow, and exceptional
dispatch. We believe an expanded FNM will provide us more visibility and options to manage
the system than today. See also discussion in Section 11.
c. The specific formulas and details involved in estimating loop flows, generation distribution factors, and external BAs’ load-distribution factors warrant high-level stakeholder review.
The CAISO should provide these formulas mathematically as seen by the market optimization.
Will the CAISO use the expanded FNM for all market runs? To support stakeholder
engagement, the CAISO should provide an example of a stylized optimization model with the
new constraints.
ISO Response
In response to PG&E, the ISO has provided several examples in Section 10 of the revised straw
proposal.
d. Lastly, if the CAISO plans to include more detailed topologies or elements of external areas, information sharing rules should be developed.
More detailed information may require direct BA to BA coordination and information sharing.
PG&E believes such activities should be fair and equitable among transmission owners and
BAs. To pursue more detailed models based on BA–to-BA information sharing, the CAISO
would need to transparently detail which pieces of information it seeks and how it would obtain
the data beyond or outside of the WECC tools. The Universal Data Sharing Agreement, the
non-disclosure agreement that BAs and others have signed with the WECC RC, may not be
sufficient to address concerns from the affected entities in a BA-to-BA sharing approach.
To develop further BA-to-BA information sharing ideas or rules, the CAISO should consider a
Full Network Model Expansion Straw Proposal Comments Page 10 of 33
“FNM Expansion Working Group” which would support collaboration, detailed discussion, and
problem solving among the BAs and other stakeholders. This group could review the data
confidentiality concerns, communication protocols, network and outage data needs, and other
relevant information required to allow more detailed network model sharing, potentially
producing recommendations or roadmaps with approximate milestones to guide the effort.
ISO Response
The ISO appreciates PG&E’s comments and will consider such a working group. In this first
phase, the ISO has worked closely with the external balancing authorities involved in the
September 8th event and such collaboration can also serve as a blueprint for future cooperation
with other entities.
5. The CAISO should review risks of pricing inconsistencies if unique constraints are used to simultaneously enforce a physical limit and a scheduling limit.
The CAISO’s design should ensure pricing consistency. To the extent that the CAISO enforces
two incongruous flow constraints at an intertie, it seems possible for multiple prices to result.
This issue, as PG&E understands it, may be akin to the “dual constraint” issue discussed in the
Intertie Pricing and Settlement5 initiative where the optimization produced multiple LMPs at a
single node. Pricing disparities can produce illogical awards and potentially other market
inefficiencies.
The CAISO should further study how the added enforcement of physical limits may or may not
create disparities and related issues. To this end, PG&E recommends the CAISO provide an
example of the stylized optimization model, in line with 4c.
Full Network Model Expansion Straw Proposal Comments Page 15 of 33
“There also may be potential unintended consequences that result from strict enforcement of
earlier e-tag requirements. An earlier requirement may reduce day ahead market liquidity by
reducing the time market participants have to secure energy and transmission to meet their day
ahead awards. Additionally, an earlier e-tag timing requirement may conflict with the timing of
when transmission routinely becomes available in other balancing authority areas. In
considering whether it is appropriate to implement earlier e-tagging requirements in the ISO’s
markets, it is important to assess the potential adverse impacts as well as the benefits.”
Powerex believes this viewpoint illustrates two important perspectives of the CAISO:
1. The CAISO believes it is consistent with its market efficiency and reliability objectives for
physical interchange awards in its IFM market to be backstopped merely by prospective
purchases of energy and/or transmission outside the CAISO in real-time – IFM awards do not
need to be backstopped by day ahead physical delivery capabilities.
2. The CAISO believes it is appropriate for the CAISO’s rules to ensure that “unused” firm
transmission rights that are released by external transmission providers as non-firm
transmission rights (after next-day e-tagging industry timelines) can be prospectively relied upon
by participants for performing on CAISO’s IFM physical interchange awards.
Powerex, respectfully, strongly disagrees with both of these perspectives, and provides an
alternative perspective as follows:
1. IFM physical interchange supply offers to CAISO, representing prospective purchases of
energy and/or transmission in external markets, must be treated as financial offers in the
CAISO’s IFM market.
Powerex agrees with the CAISO that prospective real-time interchange supply should be
encouraged to participate in CAISO’s markets. However, Powerex strongly disagrees with the
CAISO that prospective real-time interchange supply should be treated as physical supply in the
CAISO's day ahead markets- prospective real-time supply simply cannot be reliably relied upon
to meet firm load obligations in the next day window. Only when a participant has secured the
necessary rights to generation output and transmission, as represented by an implemented e-
tag, can the CAISO reasonably rely on such supply to meet its firm load obligations.
Full Network Model Expansion Straw Proposal Comments Page 16 of 33
Accordingly, it is prudent, consistent with reliability objectives and efficient market outcomes,
and consistent with rules developed across eastern ISOs/RTOs, for prospective real-time
interchange supply, (including un-tagged physical interchange awards) to be treated as financial
awards in the CAISO’s IFM and RUC processes.
The appropriate mechanism for enabling prospective real-time interchange supply to participate
in CAISO markets, thereby increasing IFM liquidity, is through the implementation of
convergence bidding on the interties, and settling un-tagged IFM physical awards consistent
with intertie convergence supply awards. Importantly, treating prospective real-time interchange
supply in this manner (i.e. as financial, not physical supply transactions) in the next day
timeframe would ensure that the CAISO could procure accurate quantities of RUC , with the
costs of this RUC capacity allocated to these supply offers, consistent with cost causation. This
alternative treatment would both protect reliability of the western grid, by directly addressing the
recommendations of the FERC/NERC Joint Staff Report on the September 8th Event, and be
consistent with efficient market outcomes.
In contrast, the CAISO’s current approach, which fails to treat prospective real-time interchange
supply as financial in the next-day timeframe, undermines the CAISO’s RUC process and thus
its reliability objectives, while inefficiently lowering marginal clearing prices in CAISO’s markets.
This price depression effect results from participants with prospective real-time supply being
able to avoid, and hence exclude from their offer prices, the increased dispatch of RUC capacity
necessary to backstop their prospective supply offers. In effect, the CAISO’s incorrect treatment
of prospective real-time interchange supply as physical supply results in “quality” supply under-
scheduling in the CAISO’s IFM physical markets, through the avoidance of day ahead
generation and/or transmission capacity commitments behind the un-tagged day ahead supply
offer. Put another way, the inappropriate co-mingling of un-tagged prospective real-time
interchange supply with physical supply that includes unit commitment (as represented by
implemented e-tags) as equivalent products, distorts CAISO's market clearing prices while
undermining the CAISO’s reliability objectives.
2. The CAISO’s efforts to access “unused” firm transmission to support IFM awards directly
subverts transmission investments and transmission priorities external to CAISO markets,
inappropriately shifting the value to CAISO transmission rights.
Full Network Model Expansion Straw Proposal Comments Page 17 of 33
Under the pro-forma open access transmission tariff (OATT) prevalent across western markets
outside the CAISO, priority access to use the transmission system is granted under tariff rules
set forth by the Federal Energy Regulatory Commission. Under these rules, investors in long-
term firm transmission rights receive priority access to utilize the transmission system ahead of
all non-firm transmission customers. On transmission paths that are fully subscribed on a long-
term firm basis, such as the transmission paths that enable deliveries from the Pacific Northwest
to serve demand in California, non-firm transmission is generally only available for sale during
hours when the firm transmission customer chooses not to utilize its priority rights. Importantly,
this "choice" appropriately rests with the transmission customer, granted by the respective
transmission provider, not with external entities such as CAISO.
It is important to note that this priority access for firm transmission investors is achieved largely through:
(i) transmission providers monitoring the utilization of firm and non-firm transmission rights on e-tags
(ii) transmission providers limiting the release of unused firm transmission rights as non-firm transmission rights based on path scheduling limits and firm transmission rights utilization as represented on e-tags
(iii) transmission providers curtailing non-firm transmission rights ahead of firm transmission rights during hours where scheduled use exceeds scheduling limits, via implementation of e-tag curtailments. For example, Bonneville Power Administration, the largest OATT transmission provider in the
region, attempts to ensure firm transmission rights holders are given priority access to
transmission on its southern interties in the day ahead markets, via designing the release of
unused firm transmission rights (offered as non-firm transmission rights) only after next-day e-
tagging timelines in western markets have expired. This release timeline attempts to ensure
that:
(i) non-firm transmission customers cannot “step ahead” of firm transmission customers as a
result of seams issues with neighboring jurisdictions
(ii) non-firm transmission rights are available to be utilized if the firm transmission rights-holder
chooses not to utilize its transmission rights in the day ahead timeframe, ensuring efficient
utilization of the transmission network
Full Network Model Expansion Straw Proposal Comments Page 18 of 33
The CAISO’s lack of a day ahead e-tagging requirement has the effect of nullifying BPA’s
transmission priority framework, enabling non-firm transmission customers to compete directly
with firm transmission customers, for use of the respective transmission path not only on the
CAISO transmission system, but on the BPA transmission system as well. This directly and
severely undermines transmission investment and transmission priorities under BPA’s open
access transmission tariff framework. In effect, this results in the CAISO allocating transmission
awards both on its transmission system and on the BPA system, directly inconsistent with the
BPA’s authority under its OATT and various statutes. In other words, the CAISO chooses which
participants utilize BPA's transmission system. This significantly undermines the value of
transmission investment in the BPA transmission system, by increasing the physical liquidity in
the CAISO’s day ahead physical energy markets potentially beyond the transmission capacity of
the BPA transmission system. Economically, this increases the value of CAISO transmission
rights through increased intertie congestion, at the direct expense of lowering the value of BPA’s
transmission rights, while undermining FERC/NERC’s and the CAISO's reliability objectives, as
previously discussed.
To be clear, Powerex is not seeking to resolve the seams issues between the CAISO and
adjacent transmission providers in a manner which seeks to disproportionately transfer value to
external transmission customers, such as Powerex. Powerex believes there are market design
solutions available which result in efficient market outcomes, are consistent with reliability
objectives, respect both the CAISO and external transmission providers open access
transmission rules and authorities, and result in equitable proportionate allocations of
transmission value to both CAISO transmission customers and external transmission
customers. The CAISO does not, and should not, need to sacrifice the transparency and
coordination objectives sought by FERC/NERC, via continued omission of a day ahead e-tag
requirement, in order to achieve its liquidity objectives and efficient market outcomes. Powerex
hopes such results will be achieved through open and transparent transmission market and rate
design and seams discussions, perhaps as part of the CAISO's EIM stakeholder process, within
the context of the CAISO’s desire to represent wider regional interests beyond California's
transmission customers and ratepayers.
Powerex does, however, oppose the CAISO’s current implementation of its e-tagging timing
rule, which, in its view, results from the pursuit of increased liquidity in its markets at the
expense of efficient market outcomes, equitable allocation of transmission value to both CAISO
Full Network Model Expansion Straw Proposal Comments Page 19 of 33
and external transmission customers, and reliability objectives. This viewpoint should not be
misinterpreted to suggest that Powerex opposes increased liquidity in CAISO markets. To the
contrary, Powerex generally supports the CAISO’s pursuit of liquidity in its markets but believes
this pursuit should not go beyond the CAISO’s reliability and market efficiency objectives, and
certainly shouldn’t transcend to the inequitable or confiscatory treatment of transmission rights
outside CAISO markets. Importantly, in the context of this stakeholder process focused on
reliability objectives, the pursuit of economic value for CAISO's transmission customers, via
omission of a day ahead e-tag requirement, runs directly counter to the reliability objectives of
FERC/NERC.
ISO Response
The ISO appreciates Powerex’s comments. Current WECC tagging rules only require tagging
20 minutes before flow.
The CAISO should ensure it has accurate information on the quality of day ahead and real-time physical interchange offers
The CAISO should ensure it has accurate information on the quality of day ahead and real-time
physical interchange offers The CAISO currently has three energy product codes applicable to
interchange transactions which are designed to reflect the “quality” of interchange deliveries
from a generation perspective – firm, unit contingent and non-firm. Each of these three products
carries different delivery requirements and different settlement treatment.
Conceptually, firm energy can be relied upon to meet CAISO’s firm load obligations, without the
need for additional CAISO generation capacity commitments to backstop potential failures to
deliver. Unit contingent energy can also be relied upon to meet CAISO’s firm load obligations;
however, additional operating reserves need to be carried by the CAISO in order to backstop
failures to deliver resulting from qualifying contingency events (i.e. unit trips or de-rates, which
can be backstopped by the activation of Contingency Reserves). Non-firm energy products
cannot be relied upon to meet CAISO’s firm load obligations, and hence must be fully coupled
one-for-one with operating reserves to serve firm demand. CAISO’s operating reserve costs
associated with these energy product types are allocated based on these differing requirements
for operating reserves, consistent with cost causation.
In practice, however, the CAISO has poorly defined the differing delivery requirements
associated with each of these energy products in its tariff. Moreover, although these differing
Full Network Model Expansion Straw Proposal Comments Page 20 of 33
energy products have different settlement and reliability implications, the CAISO takes little, if
any, direct action to ensure that participants utilize the appropriate energy product type to
represent their energy offers, in either its day ahead and/or hour ahead markets. It should not
be surprising, therefore, that deliveries of interruptible energy products to CAISO represented as
firm and unit contingent products appear to be increasing, as more entities become comfortable
with the CAISO’s lack of clarity in its tariff. This trend is exacerbated by the widespread
installation of VERs outside the CAISO and the cost pressures associated with VER integration.
In Powerex’s view, the representation of interruptible interchange supply as firm and/or unit
contingent products, results in “quality” under-scheduling of supply, which undermines efficient
market outcomes in both the CAISO and external markets, and more importantly, seriously
jeopardizes reliability.
To understand the impacts of quality under-scheduling of supply, Powerex believes it may be
helpful to consider the impacts of a similar activity - quantity-based under-scheduling of
demand. It is well documented that under-scheduling of demand from a quantity perspective
distorts efficient market outcomes, lowering day ahead energy prices and raising real-time
prices. It is also well documented that under-scheduling of demand can have serious reliability
implications unless the respective system operator both identifies the under-scheduling activity
and commits additional generation capacity day ahead.
FERC has taken significant steps to both prevent and counter the ability and consequences of
under-scheduling demand practices. For example, the standard design of the Residual Unit
Commitment process in RTOs ensures sufficient capacity is procured from a reliability
perspective to prevent under-commitment of capacity day ahead resulting from load-serving
entities under-scheduling their expected quantity of demand, in pursuit of lower day ahead
prices. Similarly, convergence bidding is a market design mechanism that nullifies the ability for
load-serving entities to benefit from under-scheduling demand through utilizing their monopsony
power to depress day ahead prices and thereby distorting efficient market outcomes.
In Powerex’s view, the CAISO’s failure to differentiate and/or enforce the delivery requirements
of different energy products results in under-scheduling supply from a quality perspective, with
the same troubling consequences as quantity-based under-scheduling of demand. By tolerating
delivery of a portion of its IFM aggregate firm and unit contingent interchange energy awards
from resources and/or balancing authorities that supply energy subject to interruption (outside of
Full Network Model Expansion Straw Proposal Comments Page 21 of 33
events that can be backstopped by Contingency Reserves) the CAISO IFM (and HASP)
markets run with an over-statement of supply “quality”. This has two undesirable consequences,
similar to those identified with quantity-based demand under-scheduling. First, it artificially
lowers day ahead energy prices for firm energy resources below efficient market outcomes, as
entities offering such supply do not have to include RUC costs in their offer prices. Second, it
increases the reliability risk to the western interconnect since insufficient residual unit
commitments may take place to backstop this quality shortfall.
Powerex urges the CAISO to re-examine and re-define energy product types in its tariff, and
develop sufficient prospective preventative procedures to ensure differing qualities of day ahead
and real-time interchange energy deliveries are treated appropriately from both a reliability and
cost causation perspective. To be clear, Powerex is not seeking a framework which penalizes,
or over-charges, participants that have elected to purchase insufficient capacity reserves to
deliver energy that can be reliably relied upon to serve firm demand, including interruptible
energy deliveries from VERs. To the contrary, Powerex urges the CAISO to identify and
differentiate such interruptible energy products from firm and unit contingent supply offers,
thereby enabling the efficient, reliable and transparent procurement of sufficient capacity
resources in the CAISO day ahead and real-time markets, with the associated costs allocated
consistent with cost causation and efficient market outcomes.
Powerex believes the additional information that would be provided by both a day ahead e-tag
requirement and by well-defined energy product types that are adhered to would go a long way
to increasing the CAISO’s situational awareness of operations in external balancing authorities
both next-day and in real-time. These steps would enhance CAISO reliability while helping
achieve efficient market outcomes. Additional steps such as modeling of external transmission
systems and potential loop flow, layered on top of this important foundation of a robust day
ahead e-tagging and energy product type framework, would go a long way to achieving the
Recommendations of the FERC/NERC Blackout Report.
ISO Response
The ISO appreciates Powerex’s comments. Please see the HASP reversal rule under the ISO’s
The CAISO should combine its physical and scheduling limits on each intertie into a single value that is coordinated with adjacent transmission providers
Powerex does not object to the CAISO’s proposal to attempt to calculate physical limits, in
Shell Energy wishes to make the following comments to the proposal as described in the
stakeholder presentation on June 18, 2013 to incorporate impacts of neighboring BAA’s into the
ISO dispatch process.
Shell Energy requests that when creating Transaction ID’s that the ISO retains and uses the
existing Resource ID’s and does not require SC’s to modify or change the existing Resource
ID’s which were created during MRTU and have been incorporated extensively into existing
scheduling systems.
The CAISO proposes to create a new “Transaction ID” which would be broader than the current
resource ID’s presently used by SC’s. These Transaction ID’s would provide a broader input to
the CAISO model, to indicate load and supply in external BAA’s.
Shell Energy supports the ISO’s work to implement recommendations associated with the
September 8, 2011 blackout and the modeling work that is proposed. However, as part of the
implementation of Transactions ID’s, it would be very helpful to begin thinking about how these
would be created. It is anticipated that these are an internal tool which the ISO could use to
evaluate the feasibility of the DA schedule relative to external BAAs.
It would be very helpful if the ISO could use the existing Resource ID’s which were set up by all
SC’s in 2008 with the implementation of MRTU, in the creation of the ISO’s Transaction ID’s and
that SC’s would not be required either create new Transaction ID’s or to modify their existing
Resource ID’s.
Full Network Model Expansion Straw Proposal Comments Page 27 of 33
Resource ID’s can be numerous and in particular, were greatly expanded with the
implementation of MRTU to be very specific to the transaction and location, of, for example
imports and exports. It would be a substantial effort to modify these Resource ID’s. They are
used extensively in both ISO systems and SC’s internal systems to move transaction quantities
of energy to scheduling points, associate with energy sales and deliveries, and properly
schedule daily quantities of energy into and out of the CAISO.
We request that as the ISO contemplates how the implementation of external BAA’s daily
load/supply/import/export schedules are set up and evaluated within a new broader view to be
created by the ISO, that the ISO could allow the existing Resource ID’s to remain intact, and to
use them to create the new Transaction ID’s and that any changes to schedules could then be
fed backwards to the appropriate Resource ID’s, so as to not require SC’s to make a whole new
set of Resource ID’s.
ISO Response
The ISO appreciates Shell’s comments and will consider these points as we move into the
implementation stage.
Company Date Submitted By
Southern California Edison 6/25/2013 Wei Zhou (626) 302-3273
Opening Comments
Southern California Edison (SCE) appreciates the opportunity to comment on the California
Independent System Operator (CAISO), June 11, Straw Proposal on Full Network Model
Expansion1. Full Network Model (FNM) plays an important role as it provides a foundation for
the CAISO to run the day-ahead market and the real-time market.
In general, SCE supports the CAISO efforts on improving modeling accuracy to better reflect
physical conditions. As noted by the CAISO, expanding the FNM has the potential to increase
Full Network Model Expansion Straw Proposal Comments Page 28 of 33
the modeling accuracy and minimize the impact of loop flows2 on the market outcomes.
However, the FNM expansion is a major step and should be carefully evaluated to avoid
adverse impacts to the current system, the CAISO market, and commercial trading around the
CAISO’s markets. Therefore, SCE’s support on this stakeholder process is contingent upon its
further review of details of the CAISO proposal.
Below, SCE provides comments on specific items on:
CAISO Proposed Activity 1: New scheduling point and load aggregation point definitions
CAISO Proposed Activity 2: Enforcing constraints for both scheduled and physical flow
CAISO Proposed Activity 3: Include variables in high voltage direct current transmission
modeling
Impacts to CRRs
Impacts to the LMP calculation
____ 1
ISO Straw Proposal on Full Network Model Expansion: http://www.caiso.com/Documents/StrawProposal-FullNetworkModelExpansion.pdf 2 Page 6 of the straw proposal
ISO Response
The ISO appreciates SCE’s comments and questions. Please see ISO’s responses below.
(1) CAISO Proposed Activity 1: New scheduling point and load aggregation point definitions
The CAISO should clarify any impacts to today’s practice of submitting bids and scheduling
power on interties, including the timeline to submit intertie bids, the mapping between today’s
intertie points and expanded intertie points and the bid validation process. For example, parties
currently schedule power to the CAISO at Palo Verde, will they have to change the way they
scheduled (possibly to different or multiple scheduling points) under the CAISO proposal? The
CAISO should clarify whether it intends to price in its market optimization all of, or a part of, the
set of new scheduling points and load aggregation points outside the CAISO, and how a bid
placed at a new generation aggregation point will get cleared and whether that requires the
disaggregation of the bid involving generation distribution factors?
Regarding the CAISO statement on
“The expanded model will also allow scheduling coordinators to submit physical or virtual import
or export bids at each of the new scheduling points”3,