SDG&E

SDG&E has five primary recommendations for the proposed changes in PRR 787.

First, SDG&E recommends that all affidavits for 2016 and forward to be executed by senior management of the scheduling coordinator if the nature of the use-limitation for the next trade year has not changed since the current trade year. Submitting a brand new affidavit from the generator owner is creates unnecessary work if no changes occur. Since the generator owner must communicate through its scheduling of all changes anyways, the scheduling coordinator should be able to sign an affidavit when there have been no changes.

  • ISO will update BPM language to require the affidavit be executed by an executive officer of the Scheduling Coordinator on behalf of the generator owner.

Second, SDG&E would like the ISO to confirm that a change of nature of the use limitation during intra-year does not require an affidavit to be submitted with the monthly updates of the use limited plan. This means that the nature of the use limitation could change within the year and revert to the original nature of the use limitation for the beginning of the following trade year and thus not require the Scheduling Coordinator to submit new documentation in the annual affidavit process. Section 6.1.4.1 seems to be disconnected from section 6.1.4.2 where the nature of the use limitation changes intra-year while the affidavit process is expected only for the following trade year.

  • ISO will clarify that no affidavit is required for the monthly update of a use plan.

Third, SDG&E believes section 6.1.4.2 should be updated to read as follows:

ISO discusses the proposed annual use plan with the Scheduling Coordinator and suggests potential revisions to meet reliability needs of the system. If revisions are agreed upon, the Scheduling Coordinator then submits its final annual use plan in accordance with the schedule in Exhibit A-1. The Scheduling Coordinator is able to update the projections made in the annual use plan in optional monthly updates to the annual Use use Plansplans.

SDG&E notes that Exhibit A-1 does not have a set schedule for registering use-limited resources or a date to resubmit the final annual use plans. Exhibit A-1 only has a date for submitting the annual use plan with the affidavit. The term “use plans” was capitalized as if it were defined in the BPM definitions list. Did the ISO want to define this term?

  • ISO will update BPM language as proposed by SDG&E.
  • ISO will update BPM with the Submittal Date for the Registration of Use-Limited Resources.

Fourth, it seems that the proposed language in section 6.1.4.2 supersedes proposed language in section 6.1.4.1. SDG&E has also made certain revisions to ISO’s proposed language.

Once the ISO receives a valid annual Uuse Pplan or updated monthly Uuse Pplan, the ISO will apply the use-limitations indicated in that use-plan for the time period(s) shown in that use-plan.

  • ISO will update BPM language as proposed by SDG&E.
  • ISO will clarify that 6.1.4.2 does not supersede 6.1.4.1: Use Limited Resource Registration and annual affidavit is a pre-condition to the ISO’s acceptance of valid use plans. The ISO will not accept use plans from resources that do not have a current registration as a Use Limited Resource unless the SC is submitting the use plan as a part of the registration process in order to achieve use limited status.

This language seems to not require the need for an annual affidavit for the ISO to begin applying a new use-plan. SDG&E would like to confirm that an affidavit is required in order for a resource to qualify as a use-limited resource, however use-limited resources are considered to be available 7x24 unless an approved use-plan Is submitted to the ISO.

  • Annual affidavits are required for a use limited resource to maintain its use limited status and maintain its eligibility to provide use plans to the ISO.
  • Any use limited resource that has kept its use limited status current by providing an annual affidavit will still be considered to be available 24x7 unless an approved use plan is submitted to the ISO. The ISO will apply the use limitations indicated in the valid use plan for the time period(s) shown in that plan.

Finally, SDG&E recommends the ISO send out an annual market notice to market participants as a reminder for the affidavit.

  • A known published due date in the BPM should be sufficient notice of annual requirements.