UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) ) MOTION TO INTERVENE AND COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY

Transcription

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION California Independent System Operator Corp., Docket No. ER MOTION TO INTERVENE AND COMMENTS OF Pursuant to Rules 211 and 214 of the Rules and Regulations of the Federal Energy Regulatory Commission ( Commission or FERC, 18 C.F.R , 214 (2014 and the Combined Notice of Filings, issued March 13, 2015 in the above-captioned docket, Southern California Edison Company ( SCE hereby respectfully submits its Motion to Intervene and Comments on the California Independent System Operator Corporation s ( CAISO Tariff Amendment to Modify Bid Cost Recovery Provisions to Ensure Appropriate Treatment of Minimum Load Compensation for Multi-Stage Generators ( Amendment. I. MOTION TO INTERVENE SCE, a wholly owned subsidiary of Edison International, is an investor-owned utility, subject to the Commission s jurisdiction. SCE s principal place of business is 2244 Walnut Grove Avenue, Rosemead, California SCE is a Participating Transmission Owner in the California Independent System Operator Corporation ( CAISO, and thus is affected by the outcome of this proceeding, as it proposes modifications to the CAISO s tariff. As such, SCE has an immediate interest in the outcome of this proceeding. SCE s interest cannot be represented by any other party and, consequently, SCE respectfully requests that the Commission - 1 -

2 grant SCE permission to intervene in this proceeding. SCE hereby reserves its rights to raise substantive issues regarding all aspects of this proceeding, and to file additional comments, as warranted by the proceeding. SCE designates the following person for service on the Commission s service list in this proceeding: Erin K. Moore Southern California Edison Company Rosemead, CA ( erin.moore@sce.com II. COMMENTS On March 12, 2015, the CAISO made an emergency tariff filing identifying a tariff gap where Multi-Stage Generators ( MSG can receive over-recovery for Minimum Load Costs ( MLC in Real-time Bid Cost Recovery ( BCR calculations. The CAISO s filing requested that the tariff change be effective as of March 13, The CAISO s filing states that it now realizes that under certain scenarios, multi-stage generating resources that are self-committed also have the potential to receive excessive bid cost recovery payments. Therefore, it is appropriate to calculate minimum load costs for these resources based on the incremental difference between the costs associated with the resource s day-ahead and real-time committed configurations. 1 The minimum load cost settlement impact from such excessive BCR payments has amounted to $2.54 million in less than a year. This issue has arisen with MSG units only because of multiple Minimum Costs associated with different MSG configurations. With Order 764 implementation on May 1, 2014, CAISO has separated BCR the Day Ahead ( DA and Real Time ( RT markets. Along with this, CAISO has implemented an Incremental/Decremental MLC cost concept for MSG units. 1 Amendment at p

3 This issue was not present when all commitment costs were netted together between DA and RT markets. (Shortly after the bifurcation of DA and RT bid cost recovery, CAISO DMM had reported the issue of MLC over-payment for MSG units, but CAISO did not feel the overpayment amount was significant at the time. With EIM implementation on Nov. 1, 2014, this issue was further extended to the PacifiCorp MSG units that are committed in the DA as part of the base schedules. The Real-time Bid Cost Recovery today will compensate them for full minimum load costs when dispatched in real-time. SCE supports the CAISO s efforts to make a correction to prevent the over-recovery for MLC. CAISO s filing has provided examples of different scenarios demonstrating how its proposed formula will work, and SCE believes that these demonstrate that the proposal is reasonable. CAISO has made corresponding changes to its EIM Tariff on RT BCR (section f.2, changing the language from stating that non-zero EIM Base Schedule is a selfschedule and not eligible for recovery of Start-Up Costs (SUC and MLC, to simply stating that non-zero EIM Base Schedule is an Integrated Forward Market Self-Schedule. However, this new language is not sufficiently specific. It lacks necessary specifics on implementation details, and lends great discretion for calculation formula designs, which has led to many unintended payment calculations. As part of CAISO initiative to revamp BCR, some of the key implementation details should be incorporated as part of the tariff to ensure consistent BCR calculation outcome. SCE urges the Commission to accept the CAISO filing and the requested effective date of March 13. III. CONCLUSION For all of the foregoing reasons, SCE respectfully requests that the Commission allow SCE to intervene in this proceeding and be accorded full party status therein. SCE further respectfully requests that the Commission accept the CAISO s filing

4 Respectfully submitted, ANNA J. VALDBERG ERIN K. MOORE By: Erin K. Moore Attorneys for Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Dated: April 2,

5 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing MOTION TO INTERVENE AND COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Rosemead, California, this 2 nd day of April, Case Analyst Post Office Box 800 Rosemead, California