On June 20, 2022, the Western Energy Imbalance Market (EIM) Body of State Regulators (BOSR) submitted comments to the California Independent System Operator (CAISO) regarding their Extended Day-Ahead Market Straw Proposal (Straw Proposal). The WEIM-BOSR applauds the efforts of all the participants in this initiative. Many of the market design elements discussed in the proposal are detailed and complex and are best addressed by participants actively engaged in the WEIM. Not all of the proposed design elements are fully formed and the discussion included in the Straw Proposal is often intended to elicit new and improved proposals. It is also clear that much can and will change from this first straw proposal to the Final EDAM Proposal.
The WEIM-BOSR specifically recommends the following components of the straw proposal be discussed further in the technical workshops:
- Transmission Commitment:
- Bucket 3 compensation
- Resource Sufficiency Evaluation:
- The impact of a penalty price on the market price from a financial consequence perspective
- Provide specific criteriea for incentivizing accurate demand forecast
- GHG Accounting:
- Both the Resource Specific and Zonal Approaches, but more details on theunspecified resource component and the calculation of hurdle rates.