California ISO Comments Template for Commitment Costs Initiative
Stakeholder Comments Template
Subject: Changes to Bidding and Mitigation of Commitment Costs
Submitted by / Company / Date SubmittedPlease fill in name and contact number of specific person who can respond to any questions on these comments. / Please fill in here / Please fill in here
This template has been created for submission of stakeholder comments on the following topics covered in the March 19 meeting of the Market Surveillance Committee (MSC) and on the March 24 Stakeholder Conference Call regarding Commitment Costs and the ISO Straw Proposal on this topic. Upon completion of this template please submit (in MS Word) to . Submissions are requested by close of business on Friday, April 2, 2010.
Please submit your comments to the following questions for each topic in the spaces indicated.
1. Is the ability to independently specify registered or proxy cost for start-up and minimum load costs an enhancement that is desirable to you?
(Submit Comments Here)
2. Do you anticipate that you would take advantage of the proposed enhancement that would enable proxy start-up and proxy minimum load values to be bid into the ISO markets on a daily basis provided that the bid-in values are below the calculated proxy cost values?
(Submit Comments Here)
3. Is the ability to submit to the ISO detailed operations and maintenance (O&M) data a desirable enhancement from your perspective? AND, is this feature desirable given that it would supplant the option of negotiating an O&M adder with the Independent Entity?
(Submit Comments Here)
4. Does adding the SoCal CityGate and Malin natural gas delivery points for the purposes of the start-up and minimum load proxy cost options improve the proxy cost option’s ability to approximate your costs? AND, would you support this enhancement if the areas that would be linked to the CityGate prices were defined by the PG&E gas distribution network in the north (NP15) and by the SoCal gas distribution network in the south (SP15)?
(Submit Comments Here)
5. Please provide comments on the extent to which you support the methodology offered in the Straw Proposal for adding opportunity costs as a component of proxy start-up costs.
(Submit Comments Here)
6. If you have a use-limited resource, does the methodology offered in the Straw Proposal for adding opportunity costs as a component of proxy start-up costs meet your needs? OR, does the independent election of start-up and minimum load costs to the registered and proxy cost options suffice for the purpose of capturing opportunity costs?
(Submit Comments Here)
7. If you support the methodology offered in the Straw Proposal for adding opportunity costs as a component of proxy start-up costs, and if you would plan to use this enhancement, would you prefer to rely on monthly updates to the annual use limitation plan, or would you prefer to submit the monthly update with use information for the weeks of the month broken out?
(Submit Comments Here)
8. Out of concern that a use-limited resource could be doubly compensated for its opportunity costs, the ISO is considering that once the unit is committed, the opportunity cost value only be considered for the purposes of bid cost recovery if the unit is not dispatched above its Pmin. Please comment on the extent to which you would support use-limited opportunity costs with this condition.
(Submit Comments Here)
9. Please comment on the extent to which you feel that the design of the MSG transition cost validation rules meet the design principals of guarding against economic withholding while providing MSG unit owners with flexibility in defining transition costs.
(Submit Comments Here)
10. If you would like to provide the ISO with additional comments, or express concerns or support for the Straw Proposal, please do so here.
(Submit Comments Here)
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