The Western Energy Imbalance Market (WEIM) Body of State Regulators (BOSR) submitted comments to the GRC on the EDAM Revised Governance Proposal. Overall, the BOSR generally supports the revised proposal as an appropriate incremental step reflective of the deeper interdependence inherent in EDAM. The BOSR offered the following comments: 1) the BOSR believes the use of the parity principle brought forward during the GRC’s stakeholder process is one reasonable tool to support determining what rules fall under joint authority; 2) it would be helpful for the GRC to provide additional clarity about how this concept of parity will apply to differently situated entities and whether there may be conflict with including in joint authority proposals that may directly establish or change locational marginal prices; 3) the BOSR continues to support the GRC’s proposal to retain the current process for designating the decisional classification for initiatives and the iterative remand process for resolving disagreements between the California ISO Board of Governors and the WEIM Governing Body on whether to approve a proposal within their shared approval authority; 4) the BOSR supports the enhancements proposed for the existing advisory input process – the BOSR concurs that these enhancements will complement the WEIM Governing Body’s oversight of rules that fall under joint authority with an appropriate forum to address critical issues that may affect EDAM Entities but fall outside joint authority; 4) the BOSR supports the GRC’s proposal of EDAM governance becoming effective once FERC has conclusively accepted the CAISO’s filing for the EDAM market design, i.e., FERC’s approval of the EDAM market design proposal.
