Business Requirements Specification

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1 Business s Specification Commitment Cost Default Energy Bid Enhancements (CCDEBE) Doc ID: GNFDMDEHU6BB Page 1 of 53

2 Revision History Date Version Description Author 1/18/ BRQ117: Added note for which intervals this applies to. BRQ121: Clarification on startup points. BRQ053: Remove verbiage pertaining to replacing ex-ante adjustments. This information is found in other requirements. Added BRQ214: for a market rate authority. Added BRQ215: Validation requirement for ex-ante. Added BRQ216: Validation requirement for ex-ante. Added BRQ217: Validation requirement for ex-ante. Added BRQ218: Scenario when operator blocks a commitment. Added BRQ219: UI for fuel region specific volatility scalar. Added BRQ to cover Integration requirements associated with Cleanbid set and Minimum load BRQ050: Reworded for clarity. BRQ041: Reworded for clarity. BRQ028: Reworded for clarity. BRQ033: Removed, duplicate information found in other requirements. BRQ014: Removed due to wording that was in BRQ008. Since BRQ008 was removed this wording no longer has meaning. BRQ016: Duplicate requirement, removed BRQ026: Removed because imports won t have to submit into the ex-ante tool. BRQ022: Removed Participating load and NGR because they aren t modeled as having commitment costs. BRQ201: Removed because feedback loop scalar should not be visible within the RDT (per Policy). BRQ207: Modified verbiage per Policy/Legal review of document. BRQ130: Clarified the impacted market runs BRQ093: Removed the word default BRQ205: Removed participating load and NGRs Andrew Owens Doc ID: GNFDMDEHU6BB Page 2 of 53

3 Date Version Description Author BRQ008: Removed BRQ008, ex-ante tool will not perform this function. Already captured within the rule section. BRQ010: Changed from requirement to Master File. BRQ030: Removed BRQ because BRQ010 is moved to Master File. BRQ200: We will use a flag not calendar. BRQ085: Needed to be reworded for clarity BRQ086: Removed the word default BRQ105: Impacted system changed from PCA to IFM/RTM based on Siemens discussion. Reworded requirement based on change. BRQ123: Removed final default. BRQ127: This is a BPM requirement not a core requirement (adjusted accordingly) BRQ132: Removed default from requirement BRQ134: Removed default and replaced updated with potentially mitigated 1/18/ Per CR 2: New s: Andrew Owens Added BRQ223 to make change to IFM/RTM related to minimum load costs. Added BRQ224 for broadcasting to downstream systems for DA and RTM. Added BRQ211 for fuel region and market (DA/RT) as fields to broadcast. Added BRQ225 for ineligibility for manual consult. Removal of s: Removed BRQ062 as team feels this is covered by other requirements. Removed BRQ110 as team feels this is covered by other requirements. Clarifications: BRQ061: Moved this requirement to the retention section. Doc ID: GNFDMDEHU6BB Page 3 of 53

4 Date Version Description Author 1/18/ Clarifications: BRQ079: Updated requirement for MSG resources. Andrew Owens BRQ210: Added implementation note to specify ability to adjust resource-level scalar. Defines what feedback loop is based on. BRQ214: Changed resource to BAA. Removed RDT reference. BRQ111: Specifies which market runs requirement would apply to. BRQ116: Specifies this requirement is for purposes of commitment cost migitation. BRQ121: Adds note to not consider Pmin rerates. BRQ124: Changes integration requirement from hourly to interval basis. BRQ131: Specifies which number will apply to energy bid mitigation vs. commitment bid mitigation. Appendix A/B: Updates to Reference level calculations and Reasonableness Threshold calculations. Simplified equation examples and defined variables. Removed: BRQ219 BRQ070 Added: BRQ227 Doc ID: GNFDMDEHU6BB Page 4 of 53

5 Table of Contents PURPOSE... 8 BUSINESS IMPACTS... 9 HIGH LEVEL DESCRIPTION OF BUSINESS PROCESS... 9 BUSINESS PRACTICE MANUAL (BPM)... 9 OTHER BUSINESS REQUIREMENTS BUSINESS PROCESS: MANAGE MARKETS & GRID (MMG) Business s BUSINESS PROCESS: MANAGE MARKET & RELIABILITY DATA & MODELING (MMR) -MASTER FILE Business s BUSINESS PROCESS: MANAGE OPERATIONS SUPPORT & SETTLEMENTS (MOS) -MARKET QUALITY SYSTEM (MQS) Business s BUSINESS PROCESS: RETENTION REQUIREMENTS Business s BUSINESS PROCESS: SUPPORT CUSTOMERS & STAKEHOLDERS (SCS) - CIDI Business s BUSINESS PROCESS: MANAGE MARKETS & GRID (MMG) - CMRI Business s BUSINESS PROCESS: IFM/RTM Business s BUSINESS PROCESS: REGULATORY & BUSINESS PRACTICE IMPACTS Business s APPENDIX A: REFERENCE LEVEL CALCULATIONS APPENDIX B: PROPOSED GUIDELINES FOR EX ANTE ADJUSTMENT REQUESTS AND VERIFICATION PROCESSES B.1 PROPOSED REFERENCE LEVEL ADJUSTMENT CALCULATIONS B.2 PROPOSED REASONABLENESS THRESHOLD B.3 PROPOSED EX POST VERIFICATION AND AUDITING APPENDIX C: DETAILS ON LOCAL MARKET POWER MITIGATION C.1 POTENTIALLY PIVOTAL OR FRINGE COMPETITIVE SUPPLIER C.1.1 Binding constraint calculations WC Doc ID: GNFDMDEHU6BB Page 5 of 53

6 C.1.2 Critical constraint calculations WC C.2 COUNTERFLOW SUPPLY FROM POTENTIALLY PIVOTAL SUPPLIERS C.3 COUNTERFLOW SUPPLY FROM FRINGE COMPETITIVE SUPPLIERS C.4 DEMAND FOR COUNTERFLOW C.4.1 Binding constraint calculations DCF C.4.1 Critical constraint calculations DCF C.5 DCPA FORMULAE C.5.1 Notation C.5.2 Resource DCPA contributions for Energy mitigation C.5.3 Resource DCPA contributions for Commitment Cost mitigation C.6 RESIDUAL SUPPLY INDEX C.6 LMPM MITIGATION CRITERIA C.6.1 Binding constraint calculations mitigation criterion C.6.2 Critical constraint calculations mitigation criterion C.7 MITIGATED VALUES C.8 APPLYING MITIGATION TO COMMITMENT COST BIDS Doc ID: GNFDMDEHU6BB Page 6 of 53

7 Disclaimer All information contained in this draft Business s Specification (BRS) as provided by the California Independent System Operator Corporation (ISO) is prepared for discussion and information purposes only. The draft BRS is provided as is without representation or warranty of any kind, including, without limitation, a representation or warranty as to accuracy, completeness, or appropriateness for any particular purpose. The draft BRS shall be revised as the development and review of the business requirements progresses. The ISO assumes no responsibility for the consequences of any errors or omissions. The ISO may revise or withdraw all or part of this information at any time at its discretion without notice. Doc ID: GNFDMDEHU6BB Page 7 of 53

8 Purpose The purpose of this document is to capture and record a description of what the Users and Business Stakeholders of the project wish to obtain by providing high-level business requirements. This document establishes the basis for the agreement between the initiators and implementers of the project. The information in this document serves as input to determining the scope of projects and to all Business Process Modeling and System s Specifications efforts. Business requirements are what must be delivered to provide value for the Users and Business Stakeholders. Systems, software, and processes are the ways (how) to delivery, satisfy or meet the business requirements (what). The Initial BRS will provide sufficient information to determine the scope of the project and will provide the functional business requirements so that the Architecture Decision can be made. Following the Architecture Decision, the remaining non-functional business requirements, such as data, performance, web services, and security can be added to complete the Final BRS. Due to Stakeholder concerns, there has been increasing need for the ISO to enhance its market rules to support Bidding Flexibility and also comply with FERC order 831. Based on the Second Revised Draft Final Proposal posted on 3/2/2018, the following are the major scope items for this initiative: Support integration of renewable resources through incentivizing flexible resources participation during tight fuel supply Account for costs of flexible resources (gas and non-gas) to reduce risk of insufficient cost recovery Encourage participation of non-ra and voluntary EIM resources ISO needs to comply with FERC Order 831 Requires supporting verified costs of energy bids above $1,000/MWh Doc ID: GNFDMDEHU6BB Page 8 of 53

9 Business Impacts High Level Description of Business Process Related Business Process (Level II) Impact Description Maintain Major Maintenance Adders (MMG LIII) Maintain Negotiated Default Energy Bids (MMG LIII) Maintain Negotiated O_Ms (MMG LIII) Manage Day Ahead Market (MMG LII) Manage Market Billing Settlements (MOS LII) Manage Real Time Hourly Market (RTPD) (MMG LII) Manage Real Time Operations Maintain Balance Area (MMG LII) Yes Yes Yes Yes Yes Yes Yes Business Practice Manual (BPM) BPM Description of Impact(s) Managing Full Network Model Congestion Revenue Rights Market Instruments Outage Management Reliability Market Operations Compliance Monitoring Metering Scheduling Coordinator Certification & Termination Rules of Conduct Administration BPM Change Management Yes Yes Doc ID: GNFDMDEHU6BB Page 9 of 53

10 Definitions & Acronyms Settlements & Billing Credit Management Candidate CRR Holder BPM Description of Impact(s) Transmission Planning Process Direct Telemetry Distributed Generation for Deliverability Energy Imbalance Market (EIM) Generator Interconnection Procedure (GIP) Generator Interconnection and Deliverability Allocation Procedures Generator Management Managing Full Network Model Other Impact: Market Simulation Market Participant Impact User Acceptance Testing (UAT) Internal Training External Training Policy Initiative Vendor Architectural Framework and Roadmap Description: (optional) Yes Yes Yes- Price Corrections, Market Services Production Yes Yes Yes Yes- Siemens Yes Doc ID: GNFDMDEHU6BB Page 10 of 53

11 Business s The sections below describe the Business Processes and the associated Business s involved in the project. These may represent high level functional, non-functional, reporting, and/or infrastructure requirements. These business requirements directly relate to the high level scope items determined for the project. Business Process: Manage Markets & Grid (MMG) - Business s ID# Business Feature Type Potential Application(s) Impacted BRQ001 BRQ002 BRQ205 BRQ003 BRQ004 BRQ005 BRQ006 System shall receive negotiated reference levels for default commitment bids (DCB), DEB values (can be either variable, negotiated, or LMP), and reasonableness threshold DEB values, and gas price indices (existing) and a field to indicate whether the gas price index is current. For each set of values, system shall receive the origin information (negotiated, LMP, proxy, manual consult). These values shall be received daily for the DAM and for RTM. System currently obtains a set of resource specific default commitment bid options, either variable or registered. A third option shall be added: negotiated. System shall be able to support market based commitment cost bids from Generating Units, Reliability Demand Response Resources, or Proxy Demand Resources. Note: Transition bids are only available to MSG resources. An external facing system shall perform an ex-ante validation of market participant requests to adjust reference level cost (default start up bids, default minimum load bids, and default energy bids). System shall store ex-ante default bid adjustment requests for auditing. This data includes requested cost component, approved cost, timestamp, market type, SCID, login ID, and reasonableness threshold cost (upper bound). This shall include all requests if there are multiple requests for the same market and time period. System must have a UI for SCs to submit default start up bid, default minimum load bid, and default energy bid adjustments. System must have an automated interface for market participants to submit default commitment bid and default energy bid adjustments. BPM Market Instruments Doc ID: GNFDMDEHU6BB Page 11 of 53

12 ID# Business Feature Type Potential Application(s) Impacted BRQ007 System shall be capable to handle adjustments for resources with existing reference level costs (e.g. generators, tiegenerators, and NRS-RAs). BPM Market Instruments BRQ212 BRQ011 BRQ012 System shall consume ineligibility list from Master File. Note: This list shall be used to prevent users from submitting ex-ante adjustment requests. System shall allow submission of reference level adjustments only for resources associated with the Market Participant (including EIM Entity) user. Market participants with active ineligible status shall not be allowed access to display. All resources shall be provided collectively as a list. ISO users shall have access to all resources. User shall be able to select a resource from the list and be presented with a list of data entry fields giving an opportunity to enter the following: Default start up bids adjustment BPM Market Instruments Market Instruments BPM o Start Date o End Date o Adjustment Values (for hot, medium, and cold starts, separately) o Market Type (DA, RT) Default minimum load bids adjustment o Start Time (hourly granular) o End Time (hourly granular) o Adjustment Values (may vary by hour throughout trade day) o Market Type (DA, RT) Energy Cost Adjustment (Variable, Negotiated, LMP) o Start Time (hourly granular) o End Time (hourly granular) o Adjustment Values for each bid segment (may vary by hour throughout trade day) o Market Type (DA, RT) Doc ID: GNFDMDEHU6BB Page 12 of 53

13 ID# Business Feature Type Potential Application(s) Impacted BRQ013 System shall apply basic validation rules to reference level cost adjustment entry, such as: date verification start time must be prior to end time adjustment values must be non-negative energy bid values shall be subject to existing basic validations BRQ015 BRQ017 BRQ018 BRQ019 BRQ208 Opportunity to adjust Day-Ahead and Real-Time default bids will be allowed for any open market. Once default bids have been calculated for a given time period and market, the adjustment request shall be validated. For gas resources - volatility scalar (Appendix 2, D.2 Scaled Gas Price Index in Reasonableness Threshold) shall be set at 125% (configurable) for days for which a next day index is not published the day before (e.g. the day after a holiday) and 110% (configurable) for other days. Volatility scalar is multiplied by the next day gas commodity price index to get a scaled gas commodity price index. For non-gas resources - volatility scalar shall be set at 110% (configurable). Volatility scalar. For default minimum load bids - volatility scalar is multiplied by the Master File average cost field at segment 1 and the min_load_cost to get scaled fuel equivalent cost. For default start up bids - volatility scalar is multiplied by the Master File strt_startup_cost field to get scaled fuel equivalent cost. System must have the ability to support resource-specific scalars (feedback loop scalar). These scalars will be set to 100% for every resource. CAISO will have the ability to adjust the resource-level scalar based on need to tune the fuelregion volatility scalars to better approximate the resourcespecific cost expectations. Note: Feedback loop is based on systematic positive differences between resources actual incurred costs (verified through ex post review) versus the fuel-region volatility scalars. Doc ID: GNFDMDEHU6BB Page 13 of 53

14 ID# Business Feature Type Potential Application(s) Impacted BRQ021 BRQ215 BRQ216 BRQ217 BRQ022 BRQ023 BRQ024 BRQ025 Validation shall consist of comparing the submitted cost to the calculated cost and the reasonableness threshold cost. Values that are less than the default bids shall be rejected. Values that are greater than the reasonableness threshold shall be capped at the reasonableness threshold cost. The capped values shall then be considered as accepted. Values between these two costs shall be accepted. For default startup bid adjustment requests, system shall validate that the down time breakpoints submitted by the SC match those in the originally calculated default startup bid. For default energy bid adjustment requests, system shall validate that the megawatt breakpoints submitted by the SC match those in the originally calculated default startup bid. For default energy bid adjustment requests, system shall validate that the bid submitted by the SC is monotonically increasing. System shall calculate reasonableness threshold default commitment bids. System shall calculate reasonableness threshold default commitment bids for all Generating Units, Reliability Demand Response Resources, or Proxy Demand Resources that have chosen either the negotiated or variable default commitment bids option. For gas-fired resources, system shall calculate reasonableness threshold default commitment bids in accordance with policy requirements using the appropriate volatility scalar for each resource and time period. See Appendix 2, D.2 Scaled Gas Price Index in Reasonableness Threshold equation. System will replace the scaled gas price index in the variable cost formula for energy reasonableness threshold. Note: No reasonableness threshold for transition costs. For non gas-fired resources, system shall calculate reasonableness threshold default commitment bids in accordance with policy requirements using the appropriate volatility scalar for each resource and time period. See Appendix 2, D.2 Scaled Variable Energy Fuel Equivalent Cost in Reasonableness Threshold. System will replace the scaled fuel equivalent costs in the proxy cost formulas for minimum load reasonableness threshold and the start-up reasonableness threshold. Note: No reasonableness threshold for transition costs. System shall perform a segment by segment validation of exante adjustments for DEBs. Doc ID: GNFDMDEHU6BB Page 14 of 53

15 ID# Business Feature Type Potential Application(s) Impacted BRQ027 BRQ028 BRQ202 Ex-ante adjustment validation shall be rejected for all costs with an origin of manual consult. Requests shall not be allowed for ex-ante adjustments of default commitment bids for resources that have selected the registered bids option. These same resources shall be eligible for adjustment of their DEBs however. Requests shall not be allowed for ex-ante adjustments for any costs for RMR resources. BRQ029 Reference level adjustment results shall be displayed to users after completion of validation. Displays must clearly indicate the amount accepted and the amount rejected. BRQ031 BRQ032 BRQ034 For approved adjusted DEBs, when replacing the original DEB values, the entire bid stream must be replaced. If the ISO does not approve a submitted reference level adjustment, the ISO shall use the default reference level. System shall calculate reference level default commitment bids for the Day-Ahead Market based on the gas price indices for the day of the market close. Implementation Note: There will be minor changes to the reference level default commitment bids formula and the resources types that are to be considered. See Appendix 1. BPM Needs Tom review Doc ID: GNFDMDEHU6BB Page 15 of 53

16 ID# BRQ035 BRQ036 BRQ037 BRQ038 BRQ039 BRQ040 BRQ041 BRQ042 BRQ043 BRQ044 Business Feature Type System shall calculate reference level default commitment bids for the 15- and 5-minute real-time markets based on the gas price indices for the hour of the market close. Implementation Note: There will be minor changes to the reference level default commitment bids formula and the resources types that are to be considered. See Appendix 1. Reference level default commitment bids formulas shall include a uniform configurable headroom scalar. The headroom scalar shall be initialized at 125% System shall must have the ability to calculate default minimum load bids costs for resources with zero Pmin. This shall include a new value which shall be added to the existing default minimum load bids cost formula for both gas and non-gas resources. System business rules must be changed to use default energy bids received from upstream systems in lieu of system generated bids. Notes: This does not impact existing bid insertion rules. In the event that the gas price is not available system shall fall back to the last real time gas price (normally the evening prior). CAISO shall implement a configurable uniform multiplier which will be used in the cap for market based commitment bids. The multiplier will be applied to each default commitment bid (as adjusted) to create a circuit breaker hard cap. The multiplier shall be initially set at 150%. The existing real-time market re-bidding rules for Existing commitment costs shall remain in place. The CAISO shall have a resource type based energy bid cap. Potential Application(s) Impacted BRQ045 The energy bid cap on convergence bids and non-resource specific system resources shall be configurable. BRQ046 BRQ047 BRQ048 For convergence bids and non-resource specific system resources, the energy bid cap shall be set to uniform hard cap. For other resources, the energy bid cap shall be in the form of min (max (soft cap, reference level), hard cap). The initial value of the soft cap shall be set to $1000/MWh and the hard cap shall be set at $2000/MWh. Doc ID: GNFDMDEHU6BB Page 16 of 53

17 ID# Business Feature Type Potential Application(s) Impacted BRQ049 BRQ050 BRQ051 BRQ052 BRQ053 BRQ206 System shall apply cap to EIM SCs without market-based rate authority so that market-based energy and default commitment bids are capped to DEB or reference level default commitment bids (including adjustments as applicable). System shall calculate transition cost reference level on upward transition cost bids as the difference between the to configuration default start up bids cost reference level (excluding the opportunity cost adder) and the from configuration default start up bids reference level (excluding the opportunity cost adder), plus the default transition opportunity cost adder applicable to that transition. Currently, the minimum load costs are a daily value in dayahead. The minimum load bids and default minimum load bids submitted as reference level adjustments shall be changed to an hourly value. The hourly value can vary throughout the day. This applies to both the day-ahead and real-time markets. If a resource has chosen the negotiated option for default commitment bids and for the current market a negotiated cost is not available system shall use the variable option to calculate and broadcast the cost. Default commitment bids and DEBs that are replacing the original default commitment bids and DEB values shall be specifically identified within the payload. System shall broadcast resource-specific default commitment bids and default energy bid values to downstream systems for each Day-Ahead and Real-Time Market. Doc ID: GNFDMDEHU6BB Page 17 of 53

18 Business Process: Manage Market & Reliability Data & Modeling (MMR) -Master File Business s ID# Business Feature Type Potential Application(s) Impacted BRQ078 BRQ079 BRQ210 BRQ081 BRQ082 The cost basis type for default minimum load bids and default start up bids shall include negotiated option along with the existing options of registered or variable cost option. System must have a field for variable default proxy minimum load bids cost adder for resources that will be independent from the Pmin level. For MSG resources, this field must apply to the configuration level and shall not apply to the plant level. Note: This field may be used by variable cost for all resources to reflect costs associated with run hours unassociated with costs for providing energy up to a minimum load level. This will be available to Generating Units, Participating Load, Reliability Demand Response Resources, or Proxy Demand Resources regardless of their registered Pmin levels. SCs will submit this value. System must provide means of maintaining resource specific scalars (feedback loop scalar). These scalars shall be initially set to 100% for every resource. Note: CAISO must have the ability to adjust the resource-level scalar based on the need to tune the fuel-region volatility scalars to better approximate the resource-specific cost expectations. Feedback loop is based on systematic positive differences between resource s actual incurred costs (verified through ex post review) versus the fuel-region volatility scalars. System shall retain the registered cost option for historical review. Market participants shall only be able to select negotiated DEB as rank one if they have accepted NDEB in effect. Existing RDT Master File, RDT Master File Master File Master File Note: A related business process will document the request process to change their ranking. Doc ID: GNFDMDEHU6BB Page 18 of 53

19 ID# Business Feature Type Potential Application(s) Impacted BRQ010 BRQ214 BRQ227 System shall provide means of maintaining an ineligibility list of market participants not allowed to make adjustments (either ex-ante or ex-post) to reference level costs. Ineligibility status shall have an associated effective date range. Example: Ineligibility SCID ABD which is tied to caisoresource1070 shall be ineligible from 5/1/17 to 6/30/17 (60 day case) or 5/1/17 to 10/31/17. System shall provide means to indicate whether a BAA resource has market rate authority. System must include the proxy minimum load cost adder as part of the Minimum Load Cost calculation (at Resource and Config levels) for registered cost. BPM Market Instruments Master File Master File, RDT Master File New MLC formula = 1.5 * [MLC + (Segment1_heat_rate * Pmin * GPI) + OM_cost + GMC_cost + GHG_cost] + MLC_MMA MLC = new attribute Doc ID: GNFDMDEHU6BB Page 19 of 53

20 Business Process: Manage Operations Support & Settlements (MOS) -Market Quality System (MQS) Business s ID# Business Feature Type Potential Application(s) Impacted BRQ083 BRQ084 BRQ085 BRQ086 In the event of an after-the-fact exceptional dispatch where the original issuance time is unavailable, the issuance time is assumed to be the start time of the dispatch. If an ED spans multiple trade dates, subsequent dates shall use the higher of the reference level (subsequent day s reference level) or original bid post mitigation. For a given resource, contiguous nonconflicting exceptional dispatch time periods shall be considered as a single time period for default minimum load bids cost distribution of EDs. For purposes of pre-qualification of bid cost recovery, unless otherwise noted in this document, system shall use commitment bids components provided by the market (i.e. use mitigated costs whenever they have been mitigated by LMPM. Otherwise, system shall use the original cost). MQS MQS MQS MQS BRQ087 System shall create a default competitive path assessment list for critical constraints for Day-Ahead and for Real-Time. Note: This will be a separate list that is created per trade date and market type (only applies to IFM and RTPD). This will be similar to the primary list structure. List will reflect the most recent 60 days of trade dates available at the time of testing and will be updated at least every 7 days. MQS Doc ID: GNFDMDEHU6BB Page 20 of 53

21 BRQ088 For ED Default Commitment Bids Mitigation Only: Second list shall deem paths competitive base on the following thresholds: MQS Congestion Threshold: Critical flow in 10 hours or more under the current time window in any unit commitment run, and Competitive Threshold: Deemed competitive 75 percent or more of the instances where the constraint was critical and tested. An exception to the thresholds described above will apply to Path 15 and Path 26. Each of these two paths will be considered competitive unless the Transmission Constraint was congested in 10 or more hours in the test period and was deemed competitive less than 75 percent of the time. This exception allows these major inter-zonal interfaces to remain competitive even when they have not been binding in the past 60 days. System will create separate lists of competitive transmission or corrective capacity constraints in the critical list for the Day-Ahead and Real-Time processes, based on data relevant to each market. For the Real-Time Market, if the transmission or corrective capacity constraints in the critical list was binding during any 15-minute interval during an hour, then the transmission or corrective capacity constraints in the critical list will be deemed to be binding for the entire hour. If the transmission or corrective capacity constraints in the critical list was determined to be non-competitive during any 15- minute interval during an hour, then the transmission or corrective capacity constraints in the critical list Doc ID: GNFDMDEHU6BB Page 21 of 53

22 ID# Business Feature Type Potential Application(s) Impacted will be deemed to be noncompetitive for the entire hour. BRQ089 BRQ090 BRQ091 Note: Second list will deem path uncompetitive otherwise. Default commitment bids pre-qualification process shall qualify scenario where resource with zero Pmin is online and has non-zero default minimum load bids costs. System shall receive reference level default commitment bids from upstream system. System shall mitigate default commitment bids (start up, minimum load, and transition) under the following circumstances (for both verbal and non-verbal EDs): MQS MQS MQS 1. Addressing reliability requirements related to non-competitive Transmission Constraints (constraints on the second list see requirements above). 2. Ramping resources with Ancillary Services Awards or RUC Capacity to a dispatch level that ensures their availability in Real-Time. 3. Ramping resources to their Minimum Dispatchable Level in Real- Time. 4. Addressing unit-specific environmental constraints not incorporated into the Full Network Model or the CAISO s market software that affect the dispatch of Generating Units in the Sacramento Delta and are commonly known as "Delta Dispatch. Note: Default commitment bids mitigation will only apply to RTPD, however, it may be triggered by RTD ED if the RTD ED comes first. This applies to ED only (not EIM manual dispatches). Doc ID: GNFDMDEHU6BB Page 22 of 53

23 ID# Business Feature Type Potential Application(s) Impacted BRQ092 If mitigated, the existing default commitment bids in applicable intervals shall be replaced as follows: MQS Mitigate default minimum load bids to the higher of default minimum load bids energy revenues and the lower of the market-based bid and the reference level o max[lmp from RTPD*Lower Operating Limit (LOL), Min(reference level, bid)] Mitigate default start up bids and transitions to the lower of the market-based bid and the reference level BRQ093 BRQ094 BRQ095 BRQ096 min(reference level, bid) System shall process interval without a minimum load bids value from the market that resulted in market dispatch based on its default minimum load bid. Note: For MSG resources this applies to the configuration level. System shall process an interval without startup/transition value from the market (e.g. exceptional dispatch commitment) for an ISO commitment period by using the start up and transition cost reference levels. Note: For MSG resources this applies to the configuration level. When using reference level default start up bids, system shall determine whether to use hot/warm/cold reference level default start up bids. Implementation note: Can leverage existing initial conditions table. In the event of a default commitment bids (start-up, min load, and transition) is unavailable, system shall use a value of $0. MQS MQS MQS MQS Doc ID: GNFDMDEHU6BB Page 23 of 53

24 ID# Business Feature Type Potential Application(s) Impacted BRQ097 A residual imbalance energy type rule shall be implemented for default minimum load bids. MQS For a period of one or more contiguous RTPD intervals where RTPD dispatch results indicate a) that a resource is uneconomic to operate at that schedule, b) the economic point of operation is below the schedule, and c) the resource schedule is less than the initial condition, and that period either starts at the beginning of a trade hour or crosses hours, then for BCR qualification purposes the system shall consider the default minimum load bids and transition cost bid components applicable to the reference interval (interval prior to the start of the period) and apply it to all intervals within the period. For a period of one or more contiguous RTPD intervals where FMM dispatch results indicate a) that a resource is uneconomic to operate at that schedule, b) the economic point of operation is below the schedule, and c) the resource schedule is greater than the initial condition, and that period either ends at the end of a trade hour or crosses hours, then for BCR qualification purposes the system shall consider the default minimum load bids and transition cost bid components applicable to the reference interval (interval after the end of the period) and apply it to all intervals within the period. If the reference interval falls within an hour in which a resource is self-committed, the reference level default minimum load bids cost shall be considered in lieu of the default minimum load bids and transition cost bid components. Doc ID: GNFDMDEHU6BB Page 24 of 53

25 ID# Business Feature Type Potential Application(s) Impacted BRQ098 Means shall be provided to clearly indicate to CAISO personnel (both database and UI) the intervals in which a resource s default commitment bids bid component was replaced by the reference interval default commitment bids bid component for purposes of BCR qualification. This applies to: MQS 1. Residual type replacements 2. ED type replacements 3. Mitigation type replacements BRQ099 Means shall be provided for system to receive and store the resource specific initial condition from each RTPD run. MQS; EIDE Note: To implement this, will need the current RTPD horizon schedule to include all market resources for all intervals, filtering may need to be added to the EIDE adapter if using the existing RTPD Horizon Schedule payload. BRQ100 BRQ101 System shall receive the issuance time of an exceptional dispatch from upstream system. The default commitment bids for resources subject to binding exceptional dispatch shall be set at the default commitment bids components of the bid applicable when the ISO issued the ED. For MSG resources that transition due to an ED instruction, the default minimum load bids cost used shall be applicable to the configuration that the resource is dispatched in throughout the ED horizon. This applies to EDs in CAISO BAA and not EIM MDEs. MQS/PCA MQS/PCA Doc ID: GNFDMDEHU6BB Page 25 of 53

26 Business Process: Retention s Business s ID# Business Feature Type Potential Application(s) Impacted BRQ103 BRQ104 System shall retain ex-ante data for auditing purposes for minimum of 36 months. The data may be purged after T+10 years. Note: Ex-ante adjustment requests include requested cost, approved cost, timestamp, market type, SCID, login ID, and reasonableness threshold cost (upper bound). This shall include all requests if there are multiple requests for the same market. System shall retain data used in determining default commitment bids mitigation similar to data used for energy bid cost mitigation. EDR EDR Doc ID: GNFDMDEHU6BB Page 26 of 53

27 Business Process: Support Customers & Stakeholders (SCS) - CIDI Business s ID# Business Feature Type Potential Application(s) Impacted BRQ106 BRQ107 System must have the ability for SCs to submit request for manual consultation along with the supporting documentation as defined within the Market Instruments BPM. System must provide the ability for the user to enter the following information for the manual consultation or for ex-post verification: BPM Market Instruments Market Instruments CIDI CIDI Resource ID Trade date Market Adjustment parameters Adjustment value Field to describe change BRQ108 Manual consultation or ex-post verification System must allow for the user to attach supporting documentation to the manual consultation or ex-post adjustment request. Note: Sufficient documentation shall be spelled out within the Market Instruments BPM. BPM Market Instruments CIDI Business Process: Manage Markets & Grid (MMG) - CMRI Business s ID# Business Feature Type Potential Application(s) Impacted BRQ109 System shall receive resource-specific reference level cost values for each Day-Ahead and Real-Time Market. CMRI Doc ID: GNFDMDEHU6BB Page 27 of 53

28 ID# Business Feature Type Potential Application(s) Impacted BRQ111 BRQ112 BRQ113 System shall display the default commitment bids for resources that were mitigated by MPM in DA and RTPD runs. Note: System performs this functionality currently for energy bids that were mitigated. Reference level costs shall be retained for external reporting in accordance with CMRI standards. System shall display the origin of DEBs and default commitment bids. This includes original, adjusted ex-ante, and manual. Existing CMRI CMRI CMRI Doc ID: GNFDMDEHU6BB Page 28 of 53

29 Business Process: IFM/RTM Business s ID# Business Feature Type Potential Application(s) Impacted BRQ114 BRQ115 System shall test constraints to assess if they are competitive or non-competitive and mitigate energy bids and market commitment bids. Note: Refer to the Appendix C. CAISO will test resources on non-competitive non-binding critical transmission or corrective contingency constraints and mitigate default commitment bids of resources with dispatch/schedule that exceeds the constraint limit minus the scheduled flow. Note: DOT (limit-flow). If a resource fails the non-competitive commitment criterion in any interval in day-ahead or real-time, mitigation will apply to the impact window. For the purpose of testing for mitigating start-up or transition bids, the impact window is the entire optimization horizon (T). I.E. if any interval failed in T mitigate start-up and transition bids. For the purpose of testing for mitigating minimum load bids, the impact window is the range of intervals from the interval failed (i) through the remainder of its minimum up time (i+mut). This assessment is performed for each failed interval and the resource could have overlapping impact windows depending on the results of their noncompetitive commitment mitigation criteria across intervals. o For example in day-ahead, if a resource failed the non-competitive commitment mitigation criterion in hour ending 5 and has a 3 hour minimum up time, the resource would be mitigated in hour ending 5, 6, and 7. o For example in real-time, if a constraint is noncompetitive in 15-minute interval 1 and the resource being tested has a 60 minute minimum up time, the impact window will be interval 1 interval 4. Similarly, if constraint failed in interval 3, the window will be interval 3 interval 6 etc. System will assess the impact window and apply mitigation if: LMPM applies mitigation to minimum load bids by: Day-ahead market: bids mitigated for the hour the resource failed. IFM/RTM IFM/RTM Doc ID: GNFDMDEHU6BB Page 29 of 53

30 ID# Business Feature Type Potential Application(s) Impacted BRQ115 (continued) BRQ116 BRQ117 Real-time market: bids mitigated for the range of intervals tested (impact window) if the criteria are met in any interval within the impact window LMPM applies mitigation to start-up and transition cost bids by: Day-ahead market: bids mitigated for the set of intervals of the optimization window T if the criteria are met in any interval within the horizon T. Real-time market: bids mitigated for the set of intervals of the optimization window T if the criteria are met in any interval within the horizon T. For purposes of commitment cost mitigation, CAISO will mitigate all units constrained by an MOC as defined by a static list and determined via advanced studies. The minimum load energy, start up, and transition costs of a resource that can start up within the optimization time horizon of the unit commitment process shall be included in the Dynamic Competitive Path Assessment (DCPA) calculation. IFM/RTM IFM/RTM IFM/RTM The supply of counterflow from fringe competitive supplier (SCFFCS) will include the minimum load energy, start up, and transition cost from off-line resources if in that unit commitment process the market would consider the resource(s) startable. BRQ118 Note, this applies for all intervals of the time horizon. System shall change current DCPA method on binding constraints (preventive and corrective transmission constraints and EIM BAA Power Balance Constraint (PBC)) to account for ability of generators to shut down. Applies conditional logic in RTM if it can ramp to Pmin in interval based on ramping from initial condition to the interval within horizon and has fulfilled its minimum run time and does not have a self-schedule or AS award. Impacts real-time calculations for withheld capacity (WC) and supply of counter flow from potentially pivotal suppliers (SCFPPS). Reference Appendix C for exact calculations. IFM/RTM Doc ID: GNFDMDEHU6BB Page 30 of 53

31 ID# Business Feature Type Potential Application(s) Impacted BRQ119 System shall perform another DCPA for mitigating default commitment bids on all critical constraints (preventive and corrective transmission constraints and EIM BAA Power Balance Constraint (PBC)) IFM/RTM CAISO will not default net buyers to fringe competitive suppliers in this calculation Includes enhancement to capture ability to shutdown Applies conditional logic in RTM if the resource can ramp to Pmin in an interval based on ramping from initial condition to the interval within horizon and has fulfilled its minimum run time and has no self-schedule or AS award. Impacts real-time calculations for withheld capacity (WC) and supply of counter flow from potentially pivotal suppliers (SCFPPS) Modify existing logic in RTM to determine ramp capable movement in real-time relative to initial condition not the prior interval s DOT for the binding interval only. BRQ120 Subtract unloaded capacity on the constraint from demand for counter flow on preventive and corrective transmission constraints but not on EIM BAA PBC. Test for resource mitigation need based on non-competitive preventive or corrective transmission constraints using noncompetitive commitment mitigation criterion: IFM/RTM Non-competitive commitment mitigation criterion is met if resource has negative shift factor to a non-competitive binding constraint, or Non-competitive commitment mitigation criterion is met if resource has negative shift factor to a non-competitive critical constraint and schedule/dispatch that is greater than or equal to the unloaded capacity on the constraint. Doc ID: GNFDMDEHU6BB Page 31 of 53

32 ID# Business Feature Type Potential Application(s) Impacted BRQ121 BRQ122 BRQ123 BRQ124 BRQ125 BRQ126 BRQ127 Minimum load bids will be mitigated at higher of the market revenues for minimum load energy (product of the competitive LMP and the lower operating limit(i.e. not considering Pmin rerates)) and the lower of the minimum load cost bid or the minimum load reference level. For startup and transition cost bids default commitment bids mitigated by the market shall be mitigated to the lower of the market-based bid and the approved adjusted reference level for each segment of the curve. System shall apply mitigation to all resources within MOCs (only if activated). Any default commitment bids mitigated due to MOCs will be mitigated to the lower of their bid or adjusted reference level. System shall provide the commitment bids (bid or reference level) used in the optimization to downstream systems. Commitment data used by the market shall be transmitted to downstream systems on an hourly interval basis. Commitment horizon transmitted to downstream systems shall reflect the actual horizon committed by the market. System shall calculate a scaling factor defined as the bid used in the market (mitigated as applicable) divided by the reference level bid. For a market run, if there is any Pmin rerate market will apply the scaling factor to the calculated DEB value (integrated DEB between Pmin and Lower Operating Limit - LOL), add it to the market bid MLC, use the sum in the optimization and publish that value downstream. CAISO shall re-calibrate the existing penalty price parameters around the $2,000/MWh hard cap in the dayahead and real-time markets. BPM Market Instruments IFM/RTM IFM/RTM IFM/RTM IFM/RTM IFM/RTM IFM/RTM BRQ227 BRQ128 BRQ129 BRQ130 Any changes to the penalty price parameters shall be incorporated into future patch releases as default values. System shall receive resource-specific reference level cost values for each Day-Ahead and Real-Time Market. System shall perform MPM on energy bids, same as today, except for the enhancement of considering shutdown in DCPA. System shall perform market power mitigation on default commitment bids in each market where commitment may take place (DA, RTUC, and STUC). IFM/RTM IFM/RTM IFM/RTM IFM/RTM Doc ID: GNFDMDEHU6BB Page 32 of 53

33 ID# Business Feature Type Potential Application(s) Impacted BRQ131 System shall test the following constraints for competitiveness: IFM/RTM 1. Any binding transmission or corrective capacity constraint 2. Any critical transmission or corrective capacity constraint (binding/nonbinding) 3. An EIM BAA power balance constraint with a positive shadow price BRQ203 Items 1 and 3 shall be tested for energy bid mitigation, items 1, 2, and 3 shall be tested for commitment bid mitigation. System shall continue to publish the MPM Outcome data. It shall publish a value of Y anytime mitigation occurs, whether for commitment, for energy, or both. IFM/RTN BRQ132 BRQ133 BRQ134 BRQ135 BRQ218 Energy mitigation occurred Commitment mitigation occurred Flag Y Y Y Y N Y N Y Y N N N System shall store data used in determining commitment bids mitigation similar to data used for energy bid cost mitigation. System shall include a market power mitigation run in STUC (there is no MPM run in STUC currently) for energy bids and commitment. Advisory commitments with commitment bids that were mitigated in prior unit commitment runs shall continue to be tested and potentially mitigated until receiving binding commitment. Binding commitments in STUC for default commitment bids that have been mitigated shall remain mitigated for RTUC. In the event of an operator block (i.e. they are cancelling the binding startup) of a binding commitment, the commitment shall not be considered a binding commitment for purposes of MPM. The resource that was to be committed shall be re-evaluated in subsequent runs. This shall apply to both RTUC and STUC Update business process flow IFM/RTN RTM RTM RTM RTM Doc ID: GNFDMDEHU6BB Page 33 of 53

34 ID# Business Feature Type Potential Application(s) Impacted BRQ223 System shall consider minimum load costs in the optimization that vary by hour. IFM/RTM Note: Currently, the market system optimizes minimum load costs as a single value for the time horizon. Doc ID: GNFDMDEHU6BB Page 34 of 53

35 Business Process: Regulatory & Business Practice Impacts Business s ID# Business Feature Type Potential Application(s) Impacted BRQ146 BRQ147 BRQ148 BRQ149 BRQ150 BRQ151 BRQ152 BRQ153 Extend filing right to MPs at FERC for fuel procurement costs in its incremental energy costs. The CAISO shall continue to send D+2 RUC report to SCs. The tariff plans to make this provision permanent. The ISO shall use the webice Volume Weight Average Price (VWAP) pull between 8-9AM (ICE calculated midpoint made available prior to official index publication) in the CAISO's day-ahead gas price index formulation. If no webice value is submitted, the System will fallback to the most recent gas price index available that is based on the average of the published commodity price indices available the night prior to the day-ahead market. Note: Tariff change will make this provision permanent. If flagged verified, MVQA shall send a correction request to revise costs in uplift calculations which will be at resource and supply offer component level (resource id, energy cost; resource id, default minimum load bids cost; resource id, default start up bids; resource id, transition cost). If flagged unverified, CAISO will notify the MP that the reference level adjustment was rejected for levels above the soft cost cap for each component. MVQA will identify if rejected requests failed to follow any of the guidelines for submitting the request. If yes, MVQA will add resource to list of ineligible resources for a period of 60 days (BPM). If no, then no additional action is needed. MVQA would audit to verify that the ex-ante submissions were a reasonable reflection of cost expectations at the time submitted given available information to the SC. If flagged unverified, MVQA shall submit correction request to Market Service Production. MVQA will send a correction request to revise costs in uplift calculations will be at resource and supply offer component level (resource id, energy cost; resource id, default minimum load bids cost; resource id, default start up bids; resource id, transition cost). Tariff Tariff BPM- Market Instruments Tariff Business Process BPM Market Instruments Business Process BPM Market Instruments Business Process BPM Market Instruments Business Process BPM Market Instruments Business Process BPM Market Instruments Doc ID: GNFDMDEHU6BB Page 35 of 53

36 ID# Business Feature Type Potential Application(s) Impacted BRQ154 BRQ155 BRQ156 MVQA shall identify if a SC fails its audit. If yes, MVQA shall add the resource to list of ineligible resources for a period of 60 days. Approved ex-post cost updates shall be communicated to Settlements in a file for uploads to PCA. Negotiated default commitment bids shall be filed with FERC. Business Process BPM Market Instruments Business Process Business Process Tariff Doc ID: GNFDMDEHU6BB Page 36 of 53

37 Appendix A: Reference Level Calculations This section provides proposed formulations for the calculation of start-up and minimum load cost reference levels. The gas price index is the delivered gas price estimate based on next day gas commodity price indices, transportation rates, cap-and-trade credits, etc. California ISO calculates day-ahead and real-time GPIs. Gas Price Index Transportation Rate is the approved gas pipeline shipping company rates on the company s electric supplier rate for that region. Cap & Trade Credit (neg. value) is the approved CARB-jurisdictional gas pipeline shipping company rates on the company s electric supplier rate for that region that are only eligible to resources on the CARB covered entities list or to those who opt-in to the CARB list. Miscellaneous costs will be defined specific to the fuel region. Minimum load costs are costs incurred per hour to maintain the resource at the minimum operating point as specified by the minimum load value in the Master File. These costs do not require having a minimum operating point above zero since it could include short-term fixed costs incurred for a run hour or variable costs for power production at minimum load. Doc ID: GNFDMDEHU6BB Page 37 of 53

38 Minimum Load Cost Reference Level Minimum Load Cost Reference Level = (Minimum Load Fuel Cost + VOM + GMC Adder +GHG Cost + MMA) * Headroom scalar + OC Adder If Gas Resource: Minimum Load Fuel Cost = Min_Load_Cost + (Unit Conversion * Incremental heat rate * Pmin * GPI) Where: Headroom scalar = MIN_LOAD_Cost is a new Master File attribute ($ value). See BRQ079. If non-gas resource: Minimum Load Fuel Cost = Average Cost * Pmin 1 Start-up (or shutdown) cost is a cost incurred per start-up event that is the cost of bringing the resource into a mode by which it can operate hourly and to a given dispatch level. The cost does not vary with the number of hours the resource is kept online Start-up Cost Reference Level: Start-up Cost Reference Level = (Start-up Fuel Cost + Start-up Energy Cost + GMC Adder + GHG Cost + MMA) * Headroom Scalar + OC Adder. If gas resource: Where Start-up Fuel Cost = STRT_STARTUP_FUEL * GPI If non-gas resource: Start-up Fuel Cost = STRT_STARTUP_COST 2 31 California ISO will revise the definition of this field to make clear that for variable cost units the registered values should only be the run hour costs expected outside of energy production costs up to Pmin First segment in the average heat rate field in Master File where segment 1 must be the Pmin (i.e. minimum load). 2 Doc ID: GNFDMDEHU6BB Page 38 of 53

39 Inputs: Transition cost is a cost incurred per event of the resource that is the cost of moving from one state of operation ( From Configuration ) to another state of operation ( To Configuration ). The cost does not vary with the hours the resource is called on or at what dispatch level. California ISO views these costs as similar to starting up a higher configuration and is the difference in startup costs between the two configurations. See Tariff section Transition Cost Reference Level: Transition Cost Reference Level = [Proxy Startup Costs (ToConfig) Proxy Startup (FromConfig)] * Headroom Scalar + OC Adder Where headroom scalar is equal to Doc ID: GNFDMDEHU6BB Page 39 of 53