The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) regarding proposed revisions to EIM market governance documents. These comments are in response to the November 17, 2017, CAISO Issue Paper that proposes changes to the Selection Policy for the EIM Governing Body (“Selection Policy”) and the Guidance for Handling Policy Initiatives within the Decisional Authority or Advisory Role of the EIM Governing Body (“Guidance Document”). The proposed revisions to the Selection Policy are designed to address the situation where a Governing Body Member seeks to be nominated for a new term. The BOSR assigns a high priority to the dual objective of maintaining the independence and discretion of the Nominating Committee and conducting an open and transparent selection process. The BOSR has recommended changes to the CAISO proposal that support this dual objective.
The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) regarding the Regional Integration and EIM Greenhouse Gas (GHG) Compliance Initiative. The purpose of this Initiative is to address concerns that the EIM GHG market design is not capturing the impact on the atmosphere that occurs in connection with EIM transfers into the ISO to serve ISO load. This has been referred to as the secondary dispatch effect. After initially reviewing several potential design changes and stakeholder comments, the ISO focused on developing a two-pass market design to identify the amount of each non-California resource used to serve ISO load. In the third quarter of 2017, some serious and credible concerns regarding the two-pass solution were brought to the CAISO’s attention. In light of these concerns, the CAISO is re-evaluating the two-pass proposal. The BOSR submitted comments that enunciate some key principles that should be applied to any option being considered for a market design change. The BOSR will apply these principles to evaluate any proposal offered by the CAISO that impacts the EIM market design.