EIM-BOSR Comments on CAISO Initiative: EIM Greenhouse Gas Enhancements Initiative Third Revised Draft Final Proposal | June 22, 2018

EIM-BOSR Library

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.