On November 22, 2022, the Western Energy Imbalance Market (WEIM) Body of State Regulators (BOSR) submitted comments to the California ISO on the EDAM Draft Final Proposal, focusing on Transmission Availability in the EDAM. The BOSR supports the three pathways proposed by the CAISO for making unscheduled transmission available in the EDAM. The BOSR supports this framework because it maximizes the transmission made available in the EDAM, while providing flexibility that is consistent with existing Open Access Transmission Tariff (OATT) rights. The BOSR also supports the concept of historical transmission revenue recovery through EDAM as financial incentives for market participation. However, the BOSR recommends redesigning Component 2 to eliminate the recovery of a return on transmission investment and recommends a re-evaluation of Component 3 to avoid double recovery of transmission revenues associated with wheel-through transactions. Lastly, the BOSR encourages CAISO to consider an eventual phaseout of the historical transmission revenue recovery through EDAM, acknowledging that the benefits of the market will outweigh the potential decrease in transmission revenues as the market matures.
