Download Western Area Power Administration Sierra Nevada Region

Western Area Power Administration Sierra Nevada Region
Comments on CAISO Draft Tariff Language - Pricing Enhancements - Existing
Transmission Contracts Priority
Western Area Power Administration Sierra Nevada Region (Western) as a federal agency is
responsible for marketing federal hydropower generated by the Central Valley Project (CVP) and
serving load in both the Balancing Authority of Northern California and the CAISO. Western
owns, operates and maintains an extensive high voltage transmission network extending to the
load center of Northern California. Western has Existing Transmission Contracts (ETC) with
PG&E and a transmission exchange agreement on Pacific AC Intertie (PACI) with PG&E and
CAISO. Western uses Transmission Ownership Rights (TOR) and the ETC to schedule power on
the CAISO grid.
The CAISO’s pricing enhancements stakeholder initiative attempted to address some of the
issues concerning the effective utilization of the Transmission Ownership Rights (TOR) and
ETC. The CAISO draft final proposal states:
“The ISO intends to modify his logic in SIBR so that if a scheduling coordinator submits
an erroneous contract reference number (CRN) or fails to pass the SIBR validation rules
due to a zero entitlement, the ETC/TOR self-schedule will be rejected rather than being
passed through like a regular self-schedule. … Going forward, the new procedure
would reject the ETC/TOR self-schedule if either that CRN is misused or if the maximum
amount for the applicable contract is exceeded.”
The draft final proposal stops short on elaborating what action will be taken if the ETC/TOR
self-schedule is not balanced. Western understood the CAISO’s preference was that CAISO’s
SIBR system should reject the ETC/TOR self-schedule and notify the market participant
immediately if the ETC/TOR self-schedule is invalid for whatever reasons including incorrect
CRN, unbalanced source-sink pairs, exceeding maximum resource capacity or transmission right
under the ETC/TOR. The market participant, instead of the CAISO, can then address the
situation by resubmitting the ETC/TOR self-schedule with correction information. By doing so,
the CAISO would be able to minimize uncertainty and potential settlement disputes and truly and
adequately meet the objective of this stakeholder initiative.
Western finds the CAISO’s draft tariff language still requires CAISO to replace ETC/TOR selfschedule with regular price-taker schedule when the CAISO’s SIBR finds that ETC/TOR selfschedule is unbalanced. Rather than replacing unbalanced schedules with a price-taker schedule,
the CAISO should reject such schedules.
Western has edited the CAISO’s draft tariff language included the edited version in a separate
attachment.
1