EIM-BOSR Library

On November 22, The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) on the Extending the Day-Ahead Market to EIM Entities (EDAM)  Issue Paper.  The BOSR supports  joint authority by the EIM Governing Body and CAISO Board of Governors over all aspects of any proposed EDAM market design.  The BOSR articulates some high level principles to guide the development of two of the market design components proposed in the Issue Paper:  GHG accounting and the day-ahead resource sufficiency test, and encourages CAISO to seek robust stakeholder input by structuring  forums to allow for effective participation from the full range of interested EDAM stakeholders.

On June 14, 2019, the Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the EIM Governing Body on the Draft Final Proposal for Formation of an EIM Governance Review Committee (GRC) and the Draft Final Proposal Governance Review Committee Charter.  The BOSR objects to the proposed change to the voting status for the BOSR member on the GRC and includes guidelines, established by the BOSR, for the BOSR’s participation on the GRC. 

The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) has developed draft principles on two key governance topics: EIM BOSR Membership and the EIM Governing Body’s Authority.
The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) on the EIM Governance Issue Paper and Straw Proposal. The BOSR supports the CAISO straw proposal to incrementally add a “motivation test” to the process for determining which market changes the EIM Governing Body is assigned primary or advisory decision authority. However, the BOSR recommends that the California ISO begin to consider moving towards a simplified process that nonetheless equitably shares decisional authority between the CAISO Board of Governors and the EIM Governing Body. In addition, the BOSR provided comments on the broader EIM Governance Review regarding the timing and scope.

The Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) regarding the Third Revised Draft Final Proposal for the EIM Greenhouse Gas Enhancements 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.  Under the Third Revised Draft Final Proposal, the amount of generation dispatched by an EIM participating resource that can be attributed to California (deemed to serve California load), is limited to a resource’s maximum output minus its base schedule.  As stated in prior comments, the BOSR supports a market design that is robust and unbiased and the BOSR makes the following observation:  the current proposal may create incentives for EIM participating resources to change their base schedules to maximize GHG revenues.

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.

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.