Renewables integration market and product review phase 1 and Bid cost recovery mitigation measures
California Independent System Operator Corp.
Party / Comment / ISO ResponsePG&E / 39.6.1.4 Minimum Bid Price for Energy Bids
The draft tariff language in this section is inconsistent with the language approved by the CAISO Board of Governors. Specifically, the draft language states:
For the twelve (12) months following the effective date of this Section, the minimum Energy Bid price shall be negative $150MWh. After the twelfth month following the effective date of this Section, the minimum Energy Bid price shall be negative $300/MWh.
The Memorandum to the CAISO Board of Governors stated:
Management proposes to set the bid floor level at -$150/MWh for one year and then evaluate the impact of this change. If there are no significant unanticipated negative effects, then Management will propose to lower the bid floor to -$300/MWh.1
PG&E requests the CAISO revise the draft tariff language to better reflect what the Board of Governors approved and ensure that a future change in bid floor level from -$150/MWh to -$300/MWh occurs only after the impacts of the initial change to -$150/MWh has been thoroughly analyzed.
To maintain consistency with the Board’s approval, PG&E also expects that a second, brief stakeholder process addressing the change and providing the Board with the final approval of lowering the bid floor from -$150/MWh to -$300/MWh will occur in advance of the 12-month timeline in order to evaluate and trigger this second adjustment to the Energy Bid floor. / The ISO intends to maintain its commitment to evaluate the impact of lowering the bid floor to negative $150 after one year. The language indicating a reduction to negative $350 is removed from the proposed tariff language for this filing.
PG&E / Section 11.8 The second sentence in this section reads: “In any Settlement Interval a resource is eligible for Bid Cost Recovery payments only if it is On”. This sentence is inconsistent with the approved policy changes that allow a generator to recover IFM Bid Costs when that unit is first committed under the Day-Ahead market run and is then de-committed during the Real Time market, as outlined in updated Tariff section 11.8.2.1.2. PG&E feels that this section creates an ambiguity in the Bid Cost Recovery process and requests that the sentence be changed to maintain consistency with the approved policy changes, as outlined in later Tariff sections. / The sentence is modified to address the comment.
PG&E / 11.8.4.1 RTM Bid Cost Recovery Amount
In the posted Table for Draft Tariff Language, the CAISO stated a plan to “add to 11.8.4.1 reference that real-time bid cost recovery payments are subject to real-time performance metric.”2 Language addressing the real-time performance metric has not been added to the section. / The reference was added.
PG&E / 11.8.5 Unrecovered Bid Cost Uplift Payment and Performance Metrics
The CAISO indicated its intention to “add to 11.8.5 new sections to indicate how the unrecovered bid cost recovery uplift may be affected by the application of the day-ahead metered adjustment factor.”3 As written, the CAISO has omitted any reference to the day-ahead metered adjustment factor in the draft tariff section. / The ISO considered this and it believes the reference to the day-ahead metered energy factor in this not necessary given that the day-ahead metered energy factor is applied to the IFM energy bid cost and market revenue calculations and not directly to the unrecovered uplift payments. The ISO will correct the table explaining the changes.
PG&E / In section 11.5.5 and in numerous other sections, the CAISO introduces the term “re-rate” (alternating using “rerate”). This term, though undefined in the Fifth Replacement Tariff Master Definition Supplement, appears to have different definitions in the various places the term is used. In one instance in this section, “re-rate” appears to describe the period of time during which a generating resource is returning to normal dispatch range following a derate. In another instance, “rerate” describes moving to or away from Minimum Load. In section 11.8.2.1.5 the term “re-rate” is applied to a Minimum Load position that was scheduled in the Day-Ahead Market. Finally in section 11.8.4.1.5 “re-rate” applies to moving up or down from a Minimum Load position scheduled in the Real-Time Market.
PG&E finds both the spelling and implied definitions of this term inconsistent and unclear. For these reasons, we request that the term be removed from the draft tariff and replaced with descriptive language using the term “derate” and consistent with the CAISO’s definition of “derate energy” which may be produced above or below the previously scheduled value.4 / PG&E’s comment regarding the inconsistent use of the term re-rate is accepted. The term re-rate was described as an increase in the resource’s minimum load through SLIC. The energy that is re-rated in this manner is classified as Derated Energy.
PG&E / / The proposed edits as well as other clarifying changes were made.
SCE / / The proposed change is not within the policy approved by the board prior to this tariff amendment.
SCE / / Accepted.
SCE / / Accepted.
SCE / / Accepted.
SCE / / Accepted.
SCE /
/ Accepted.
SCE /
/ Accepted.
SCE /
/ Accepted. Additional changes were made to this section to clarify treatment of start-up costs in the real-time.
SCE / / Accepted.
SCE / / Accepted.
SCE / / The last sentence was removed because it was redundant and therefore not necessary. The ISO references the Real- Performance metric where it is applied and discussed its application in 11.8.5.5. Therefore, the proposed change to the last sentence is no longer necessary.
SCE /
/ Accepted.
SCE / / Accepted.
Six Cities / / Clarifications made to this section.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / This new sub-section was removed because the ISO determined this rule was not intended to apply to RUC.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
Six Cities / / Accepted.
CDWR / 11.8.4.1.2
CAISO could clarify this by adding “MSG” before “RTM Minimum Load Costs will be equal…” / Section was clarified.
CDWR / 11.8.4.4
Term “respectfully” highlighted / Accepted.
NRG / 11.5.5
“Adjacent to” or “contiguous with?” / Accepted.
NRG / 11.5.5
Added term “re-rated” / The use of the term re-rated was clarified to mean an increase in the minimum load. Energy associated with such a re-rated is classified as Derated Energy.
NRG / 11.8
Added term “described” / Accepted.
NRG / 11.8.1.3 (1) (a)
“and” instead of “less”? / Proposed change seems to change the meaning. Not accepted.
NRG / 11.8.2
Added term Energy in Day-Ahead Metered __ Adjustment Factor / Accepted.
NRG / 11.8.2.1.1
(h)For Short Start Units, the BCR Eligible Resource’s IFM Start-Up Cost will be qualified for the IFM Commitment Period instead of qualified for the RTM Commitment Period, when the Short Start Unit is started up in the Real-Time Market after the start of and before the end of the IFM CommitmentPeriod. The Start-Up Costs for aAny subsequent Start-Ups pursuant to a Shut-Down Instruction the Short-Start Unit receives in the Real-Time Market that falls within the IFM Commitment Period, the Start-Up Costs will be qualified as an RTM Start-Up Cost. / Clarifying changes were made to this section.
NRG / 11.8.2.1.2 IFM Minimum Load Cost
(c)If a BCR Eligible Resource receives a Day-Ahead Schedule and is subsequently decommitted by the CAISO in the Real-Time Market, the IFM Minimum Load Costs are subject to the Real-Time Performance Metric pursuant to the rules specified in Section 11.8.4.4.
(d)The IFM Minimum Load Costs for a Multi-Stage Generating Resource that receives a Day-Ahead Schedule and issubsequently committed to a lower [WHAT IS A “LOWER” CONFIGURATION? ONE THAT CAN PRODUCE FEWER MW?] MSG Configuration in the Real-Time Market are subject to the Real-Time Performance Metric pursuant to the rules specified in Section 11.8.4.4.
(e)If the conditions in (c) and (d) do not apply, then:
(i)the IFM Minimum Load Cost for any Settlement Interval is zero if the Bid Cost Recovery Eligible Resource is determined to benot actually On during the applicable Settlement Interval. / Accepted.
The use of the use of the terms “lower MSG configuration” were clarified to mean to be a lower configuration evaluated by the lower minimum load.
NRG / 11.8.2.1.5 IFM Energy Bid Cost
For any Settlement Interval, the IFM Energy Bid Cost for Bid Cost Recovery Eligible Resources, except Participating Loads, shall be the integral of the relevant Energy Bid used in the IFM, if any, from the higher of the registered Bid Cost Recovery Eligible Resource’s Minimum Load and the Day-Ahead Total Self-Schedule up to the relevant MWh scheduled in the Day-Ahead Schedule, divided by the number of Settlement Intervals in a Trading Hour. For Settlement Intervals for which the BCR Eligible Resource is ramping up to andor down from a Minimum Load re-rate submitted into the Day-Ahead Market, the IFM Energy Bid Cost will be based on the applicable Locational Marginal Price. / Accepted.
NRG / 11.8.2.5IFM Market Revenue and Energy Bid Cost Adjustments
The CAISO will adjust for each BCR Eligible Resource the IFM Energy Bid Cost and IFM Market Revenue calculations by multiplying the Day-Ahead Metered Energy Adjustment Factor with the amounts derived as specified in Sections 11.8.2.1.5 and 11.8.2.2, respectively. In all cases, regardless of the rules specified below, the application of the Day-Ahead Metered Energy Adjustment Factor shall never increase a BCR Eligible Resource’s Unrecovered Bid Cost Uplift payments. In the event that the CAISO discovers that there has been an increase in the Unrecovered Bid Cost Uplift payment due to the application of the Day-Ahead Metered Energy Adjustment Factor, the ISO will adjust the payment to recover the overpayment in a subsequent billing cycle as permissible under Section 11.29. / Accepted.
NRG / 11.8.2.5.5If for any given Settlement Interval, the absolute value of the resource’s Metered Energy less its Regulation Energy less the minimum of the Day-Ahead Schedule Energy and Expected Energy, is less than or equal to the Performance Metric Tolerance Band, then the CAISO will not apply the Day-Ahead Metered Adjustment Factorto the IFM Energy Bid Cost or the IFM Market Revenue. / Accepted.
NRG / 11.8.3.1.1
(g)For Short Start Units, the BCR Eligible Resource’s RUC Start-Up Cost will be qualified for the RUC Commitment Period instead of qualified for the RTM Commitment Period, when the Short Start Unit is started up in the Real-Time Market after the start of and before the end of the RUC Commitment Period. The Start-Up Costs for aAny subsequent Start-Ups that follow a Shut-Down Instruction the Short-Start Unit receives in the RTM that falls within the RUC Commitment Period, the Start-Up Costs will be qualified as an RTM Start-Up Costs.
This sentence was difficult to follow; the proposed changes are intended to try to make it less difficult to follow, not to change the intent. / Sub-section was removed because it does not apply to RUC.
NRG / 11.8.3.1.2RUC Minimum Load Cost
The Minimum Load Cost for the applicable Settlement Interval shall be the Minimum Load Cost of the Bid Cost Recovery Eligible Resource divided by the number of Settlement Intervals in a Trading Hour. For each Settlement Interval, only the RUC Minimum Load Cost in a CAISO RUC Commitment Period is eligible for Bid Cost Recovery. The RUC Minimum Load Cost for any Settlement Interval is zero if: (1) the Bid Cost Recovery Eligible Resource is manually pre-dispatched under an RMR Contract or the resource is flagged as an RMR Dispatch in the Day-Ahead Schedule in that Settlement Interval; (2) the Bid Cost Recovery Eligible Resource is not actually On in the applicable Settlement Interval; or (3) the applicable Settlement Interval is included in an IFM Commitment Period. For the purposes of determining RUC Minimum Load Cost for, a Bid Cost Recovery Eligible Resource, recovery of the RUC Minimum Load Costs is subject to the Real-Time Performance Metric. except for a Multi-Stage Generating Resource, is assumed to be On if its metered Energy in a Settlement Interval is equal to or greater than the difference between its Minimum Load Energy and the Tolerance Band. Otherwise, such non-Multi-Stage Generating Resources are determined to be Off. / Clarifying changes were made to this section.
NRG / 11.8.4.1 RTM Bid Cost Calculation
For each Settlement Interval, the CAISO shall calculate RTM Bid Cost for each Bid Cost Recovery Eligible Resource, as the algebraic sum of the RTM Start-Up Cost, RTM Minimum Load Cost, RTM Transition Cost, RTM Pump Shut-Down Cost, RTM Energy Bid Cost, RTM Pumping Cost and RTM AS Bid Cost. For Multi-Stage Generating Resources, in addition to the specific RTM Bid Cost rules described in Section 11.8.4.1, the rules described in Section 11.8.1.3 will be applied to further determine the applicable MSG Configuration-based CAISO Market Start-Up Cost, Transition Cost, and Minimum Load Cost in given Settlement Interval. For Multi-Stage Generating Resources, the incremental RTM Start-Up Cost, Minimum Load Cost, and Transition Cost to provide RTM committed Energy or awarded Ancillary Services capacity for an MSG Configuration other than the self-scheduled MSG Configuration are determined by the RTM optimization rules in specified in Section 34. For any BCR Eligible Resources that is ramping up to or down from an Exceptional Dispatch, the relevant Energy Bid cost related to the Energy caused by ramping will be the same relevant Energy Bid used in the Settlement of the Exceptional Dispatch that led to the ramping. / Accepted.
NRG / 11.8.4.1.1
(f) The Real-Time Market Start-Up Cost shall be qualified if an actual Start-Up occurs within that Real-Time Market Commitment Period. An actual Start-Up is detected between two consecutive Settlement Intervals when the relevant metered Energy in the applicable Settlement Intervals increases from below the Minimum Load Energy and reaches or exceeds the relevant Minimum Load Energy in the Settlement Interval that falls before, after, or during the Settlement Interval(s) that fall within the IFM Commitment Period. The Minimum Load Energy is the product of the relevant Minimum Load and the duration of the Settlement Interval. The CAISO will determine the Minimum Load Energy for Multi-Stage Generating Resources based on the CAISO-committed MSG Configuration. / Accepted.
NRG / 11.8.4.1.2RTM Minimum Load Cost
… A resource’s RTM Minimum Load Costs for Bid Cost Recovery puprposes are subject to the Real-Time Preformance Metric as specified in Section 11.8.4.4. For the purposes of RTM Minimum Load Cost, a Bid Cost Recovery Eligible Resource, other than a Multi-Stage Generating Resource, is determined to not actually be On if the metered Energy in that Settlement Interval is less than the Tolerance Band referenced by the Minimum Load Energy. . For Multi-Stage Generating Resources, the commitment period is determined based on application of section 11.8.1.3. If application of section 11.8.1.3 dictates that the RTM is the commitment period, then the calculation of the RTM Minimum Load Costs will depend on whether the metered MSG Configuration is equal to or different from the RTM committed MSG Configuration. If the metered MSG Configuration is equal to the RTM committed MSG Configuration, then the RTM Minimum Load Costs will be based on the Minimum Load Costs of the RTM committed MSG Configuration. If the metered MSG Configuration is different from the RTM committed MSG Configuration, then the RTM Minimum Load Costs will be based on the lower of the Minimum Load Costs of the metered MSG Configuration and the Minimum Load Costs of the RTM Committed configuration. The metered MSG Configuration is determined based on the highest MSG Configuration submitted to the Real-Time Market for which the Metered Data is within or above the three (3) percent (or 5 MW) Tolerance Band of the PMin of that highest MSG Configuration submitted to the Real-Time Market. Between two (2) (or more) MSG Configurations, the highest MSG Configuration is the MSG Configuration with the PMin value that is the greatest MW value. For Settlement Intervals that contain two (2) Dispatch Intervals with two (2) different MSG Configurations, the CAISO will determine the Transition Costs, and Minimum Load Costs based on the sum of the two (2) applicable Dispatch Intervals. For all BCR Eligible Resources that the CAISO commits down to Off in the Real-Time, either through an Exceptional Dispatch or an Economic Dispatch through the Real-Time Market, from its Day-Ahead Schedule that was also from a CAISO commttment, the RTM Minimum Load Costs will include negative Minimum Load Costs for Energy between the Minimum Load and zero (0) MWhs. In addition, for all Multi-Stage Generating Resources that the CAISO commits down to a lower MSG Configuration, either through an Exceptional Dispatch or an Economic Dispatch through the Real-Time Market, from its IFM MSG Configuration that was also from an CAISO commttment, the RTM Minimum Load Costs will be equal to the Real-Time Minimum Load Cost less the IFM or RUC Minimum Load Cost, as applicable.