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EIM Resource Sufficiency Evaluation MetricsReport covering July and August 2021September 23, 2021Prepared by: Department of Market MonitoringCalifornia Independent System Operator

Department of Market Monitoring – California ISO1September 2021Report overviewAs part of the Energy Impact Market (EIM) resource sufficiency evaluation stakeholder initiative, DMMhas agreed to provide additional information and analysis about resource sufficiency evaluationperformance, accuracy, and impacts in regular reports.1 This report highlights existing metrics andanalysis covering July and August 2021. Future reports will provide additional metrics and analysis on amonthly basis.This report is organized as follows: Section 2 provides an overview of the flexible ramping sufficiency and bid-range capacity tests. Section 3 provides existing summary metrics. Section 4 provides existing metrics for key time periods.DMM is seeking feedback on existing or additional metrics and analysis that EIM entities and otherstakeholders would find most helpful. Comments and questions may be submitted to DMM via email atDMM@caiso.com.1EIM Resource Sufficiency Evaluation Enhancements Straw Proposal, August 16, s.pdfResource Sufficiency Evaluation in the EIM2

Department of Market Monitoring – California ISO2September 2021Overview of the flex ramp sufficiency and capacity testsAs part of the energy imbalance market, each area, including the California ISO, is subject to a resourcesufficiency evaluation. The evaluation is performed prior to each hour to ensure that generation in eacharea is sufficient without relying on transfers from other balancing areas. The evaluation is made up offour tests: the power flow feasibility test, the balancing test, the flexible ramping sufficiency test, andthe bid range capacity test. Two of these tests have the same outcome of constraining transfercapability following a failure: The flexible ramping sufficiency test (sufficiency test) requires that each balancing area has enoughramping flexibility over an hour to meet the forecasted change in demand as well as uncertainty. The bid range capacity test (capacity test) requires that each area provide incremental bid-incapacity to meet the imbalance between load, intertie, and generation base schedules.If an area fails either the flexible ramping sufficiency test or bid range capacity test in the upwarddirection, energy imbalance market transfers into that area cannot be increased.2 Similarly, if an areafails either test in the downward direction, transfers out of that area cannot be increased.Flexible ramping sufficiency testThe flexible ramping sufficiency test requires that each area has enough ramping resources to meetexpected upward and downward ramping needs in the real-time market without relying on transfersfrom other balancing areas. Each area must show sufficient ramping capability from the start of the hourto each of the four 15-minute intervals within the hour.Equation 1 shows the different components and mathematical formulation of the flexible rampingsufficiency test. As shown in Equation 1, the requirement for the flexible ramping sufficiency test iscalculated as the forecasted change in load plus the uncertainty component minus two components:(1) the diversity benefit and (2) flexible ramping credits.Equation 1. Flexible Ramping Sufficiency Test FormulationThe diversity benefit reflects that system‐level flexible ramping needs are typically smaller than the sumof the individual balancing area flexible ramping needs because of reduced uncertainty across a larger2If an area fails either test in the upward direction, net EIM imports during the hour cannot exceed the more lenient ofeither the base transfer or optimal transfer from the last 15-minute interval prior to the hour.Resource Sufficiency Evaluation in the EIM3

Department of Market Monitoring – California ISOSeptember 2021footprint. As a result, balancing areas receive a prorated diversity benefit discount based on thisproportion.The flexible ramping credits reflect the ability to reduce exports to increase upward ramping capabilityor reduce imports to increase downward ramping capability.Finally, as shown in Equation 1, the reduction in the sufficiency test requirement because of anydiversity benefit or flexible ramping credit is capped by the area’s net import capability for the upwarddirection, or net export capability for the downward direction.The uncertainty component currently used in the flexible ramping sufficiency test is calculated from thehistorical net load error observation. The 2.5th percentile of historical net load error observations is usedfor the downward requirement and the 97.5th percentile if used for the upward requirement.3 As part ofthe flexible ramping product refinements stakeholder initiative, the uncertainty component is expectedto be enhanced in Spring 2022 to scale and account for net load currently in the system.4Bid range capacity testThe bid range capacity test requires that each area provide incremental (or decremental) bid‐in capacityto meet the imbalance between load, intertie, and generation base schedules. Equation 2 shows thedifferent components and mathematical formulation of the bid range capacity test. As shown inEquation 2, the requirement for the bid range capacity test is calculated as the load forecast plus exportbase schedules minus import and generation base schedules.Equation 2. Bid Range Capacity Test FormulationAs also shown in Equation 2, two additional components are added to the requirement in order toaccount for both (1) historical intertie deviations and (2) net load uncertainty (beginning June 16).5If the requirement is positive, then the area must show sufficient incremental bid range capacity tomeet the requirement and if the requirement is negative, then sufficient decremental bid range capacitymust be shown.3Net load error in the 15‐minute market is calculated from the difference between binding net load forecasts in the5-minute market and the advisory net load forecast in the 15‐minute market. Weekdays use data for the same hour fromthe last 40 weekdays. For weekends, the last 20 weekend days are used.4Flexible Ramping Product Refinements Final Proposal, August 31, Net load uncertainty is reduced by the diversity benefit similar to the sufficiency test. Unlike the sufficiency test, credits(net EIM exports in the upward test and net EIM imports in the downward test) are not used in the capacity test. This is toprevent double counting of internal capacity. For example, net EIM exports are supported by internal capacity, which isalready accounted for in the capacity test by the generation base schedules and bid range.Resource Sufficiency Evaluation in the EIM4

Department of Market Monitoring – California ISOSeptember 2021The bid range capacity used to the meet the requirement is calculated relative to the base schedules.For the ISO, the “base” schedules used in the requirement are the advisory schedules from the lastbinding 15-minute market run. For all other energy imbalance market areas, the export, import, andgeneration schedules used in the requirement are the base schedules submitted as part of the hourlyresource plan.Since the bid range capacity is calculated relative to the base schedules, the upward capacity test cangenerally be expressed as follows:6Incremental bid‐in generation capacity is calculated as the range between the generation base scheduleand the economic maximum, accounting for upward ancillary services and any de-rates (outages). Otherresource constraints including start‐times and ramp rates are not considered in the capacity test.15-minute dispatchable imports and exports are included as bid range capacity.6DMM has identified cases when the existing incremental approach for the capacity test relative to base schedules does notequal maximum capacity expected under a total approach. The incremental bid-range capacity can be positive only. Ifmaximum capacity at the time of the test run is below base schedules, this difference will not be accounted for in the test.For more information see DMM’s comments on EIM resource sufficiency evaluation enhancements straw 0Resource Sufficiency Evaluation in the EIM5

Department of Market Monitoring – California ISO3September 2021Summary metricsThis section provides existing summary metrics on the resource sufficiency evaluation.7 DMM is in theprocess of developing additional metrics including coverage of the uncertainty component used in thetests, analysis of unloaded capacity, test comparisons to actual availability, and counterfactual analysisof changes proposed in the resource sufficiency evaluation enhancements initiative.Frequency and size of bid-range capacity test and flexible ramping sufficiency test failureFigure 1 through Figure 4 shows the percent of intervals in which each EIM area failed the upwardcapacity or sufficiency tests as well as the average shortfall of those test failures. Figure 5 through Figure8 provides the same information for the downward direction. The dash indicates the area did not fail thetest during the month. The flexible ramping sufficiency test and bid-range capacity test failures reportedbelow reflect results independent of the other test.Figure 9 summarizes the overlap between failure of the upward capacity and sufficiency tests betweenJuly and August. The black horizontal line (right axis) shows the number of 15-minute intervals witheither a capacity or sufficiency test failure for each energy imbalance market area. The areas are shownin descending number of failure intervals. The bars (left axis) show the percent of the failure intervalsthat meet the condition.Figure 10 shows the same information for the downward direction. Areas that did not fail either thecapacity or sufficiency test during this period were omitted from the figure.7Results in this section exclude known invalid test failures. These can occur because of a market disruption, software defect,or other errors. Data on invalid test failures may be included in future reports if sufficient interest exists.Resource Sufficiency Evaluation in the EIM6

Department of Market Monitoring – California ISOSeptember 2021Figure 1. Frequency of upward capacity test failures (percent of intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock unJulAug Sep Oct Nov Dec Jan Feb Mar Apr May 5381636——7412147Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunJulAug20202021Figure 2. Average shortfall of upward capacity test failures (MW)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock �JunJul2020Resource Sufficiency Evaluation in the EIM1387 2325 �——4938—120217

Department of Market Monitoring – California ISOSeptember 2021Figure 3. Frequency of upward sufficiency test failures (percent of intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock unJulAug Sep Oct Nov Dec Jan Feb Mar Apr May 1836—3319——2453——Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunJulAug20202021Figure 4. Average shortfall of upward sufficiency test failures (MW)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock ID———17——1115— 232 5652815710 1031 87219——60—516—71618——913 ��—4747820—584727—6JunJul2020Resource Sufficiency Evaluation in the EIM20218

Department of Market Monitoring – California ISOSeptember 2021Figure 5. Frequency of downward capacity test failures (percent of intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock unJulAug Sep Oct Nov Dec Jan Feb Mar Apr May �————————————88Aug Sep Oct Nov Dec Jan Feb Mar Apr May JunJulAug20202021Figure 6. Average shortfall of downward capacity test failures (MW)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock Resource Sufficiency Evaluation in the EIM20219

Department of Market Monitoring – California ISOSeptember 2021Figure 7. Frequency of downward sufficiency test failures (percent of intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock unJulAug Sep Oct Nov Dec Jan Feb Mar Apr May ��2970———44——25—4JulAug20202021Figure 8. Average shortfall of downward sufficiency test failures (MW)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock 4—47—674———38——65—7JunJulAug Sep Oct Nov Dec Jan Feb Mar Apr May Jun2020Resource Sufficiency Evaluation in the EIM26——202110

Department of Market Monitoring – California ISOSeptember 2021Figure 9. Upward capacity/sufficiency test failure intervals by concurrence(July – August, 2021)Only capacity test failedOnly flex sufficiency test failed100%Both tests failedTest failure intervals250Percent of failures80%20070%60%15050%40%10030%20%50Number of 15-minute intervals90%10%0%0Figure 10. Downward capacity/sufficiency test failure intervals by concurrence(July – August, 2021)Percent of failures100%Both tests failedTest failure 0%4010%200%Number of 15-minute intervalsOnly capacity test failedOnly flex sufficiency test failed0NEVPNWMTResource Sufficiency Evaluation in the EIMPWRXSCLTIDCAZPSSRP11

Department of Market Monitoring – California ISOSeptember 2021Impact of adding uncertainty to the capacity testOn June 16, the ISO added net load uncertainty to the requirement of the bid range capacity test as partof a package of market enhancements for Summer 2021 readiness. The uncertainty component is net ofthe diversity benefit, similar to that already in effect for the flexible ramping sufficiency test.8Figure 11 shows the impact of this change by showing actual capacity test failure intervals that wouldhave passed the test without the additional uncertainty component. Figure 12 shows the sameinformation, except without intervals in which the sufficiency test also failed in that interval. Since theoutcome of failing either the capacity or the sufficiency test is the same, this figure thereforesummarizes additional intervals in which energy imbalance market transfers were capped.Figure 11. Additional capacity test failures with implemented uncertainty (15-minute intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock ��———————1Jun*JulAugJun*JulAugUpward capacity testDownward capacity test*June 16-30, 2021 only (implementation of uncertainty in the capacity test)8The diversity benefit reflects that system‐level flexible ramping needs are typically smaller than the sum of the individualbalancing area flexible ramping needs because of reduced uncertainty across a larger footprint. The diversity benefit is aprorated discounted based on this proportion.Resource Sufficiency Evaluation in the EIM12

Department of Market Monitoring – California ISOSeptember 2021Figure 12. Additional capacity test failures with implemented uncertaintyexcluding sufficiency test failures (15-minute intervals)Arizona PSBANCCalifornia ISOIdaho PowerLADWPNorthWesternNV EnergyPacifiCorp EastPacifiCorp WestPortland GEPowerexPSC New MexicoPuget Sound EnSalt River Proj.Seattle City LightTurlock ��———————1Jun*JulAugJun*JulAugUpward capacity testDownward capacity test*June 16-30, 2021 only (implementation of uncertainty in the capacity test)Transfer consequences of failing resource sufficiency evaluationThis section summarizes current consequences of failing the bid-range capacity or flexible rampingsufficiency tests in terms of the import limit that is imposed when a balancing area fails either of thesetests in the upward direction. As part of the stakeholder initiative on resource sufficiency evaluationenhancements, the ISO is considering additional or alternative consequences for failing these tests.When either test is failed in the upward direction, imports will be capped at the greater of (1) the basetransfer or (2) the optimal transfer from the last 15-minute market interval. If both the base transfer andthe last 15-minute transfer are in a net export position, the cap will be imposed on the export side (i.e.the balancing area cannot export less than the cap).Figure 13 summarizes the import limits that were imposed after failing either test by balancing area andcap position (i.e. import or export). The black horizontal line (right axis) shows the number of 15-minuteintervals with either a capacity or sufficiency test failure. The energy imbalance market areas are shownin descending number of failure intervals. The bars (left axis) show the percent of the failure intervalsthat meet the condition. Figure 14 summarizes the same information with the import limit categorizedby various levels of import limits.Figure 15 summarizes whether the import limit that was imposed after failing either test in the upwarddirection ultimately impacted market transfers. It shows the percent of failure intervals in which theresulting transfers are right up against the limit imposed after failing the test. These results areseparated between energy imbalance market transfers in the 15-minute (FMM) and 5-minute (RTD)markets.Resource Sufficiency Evaluation in the EIM13

Department of Market Monitoring – California ISOSeptember 2021Figure 13. Upward capacity/sufficiency test failure intervals by import limit position(July – August, 2021)100%Capped on export sideCapped on import sideCapped at zeroTest failure intervals250Percent of failures80%20070%60%15050%40%10030%20%50Number of 15-minute intervals90%10%0%0Figure 14. Upward capacity/sufficiency test failure intervals by import limit amount(July – August, 2021)100%-1,000 to -500 (net exp.)0 to 500 (net imp.)2,000 to 3,000 (net imp.)-500 to 0 (net exp.)500 to 1,000 (net imp.)3,000 to 4,000 (net imp.)25090%Percent of rce Sufficiency Evaluation in the EIMNumber of 15-minute intervals-2,000 to -1,000 (net exp.)01,000 to 2,000 (net imp.)Test failure intervals014

Department of Market Monitoring – California ISOSeptember 2021Figure 15. Percent of upward test failure intervals with market transfers at the imposed cap(July – August, 2021)012345678910Total failure intervals11121314151625090%Percent of MRTDFMMRTDFMMRTDFMMRTDFMMRTDFMMRTDFMMRTD0%Number of failures (15-minute intervals)Transfers at test-failure imposed limit (percent)100%SRP NWMT PGE NEVP IPCO PSEI TIDC PWRX PNM CISO AZPS PACE PACW BANCLADWP SCLBalancing test failures and penaltyThe resource sufficiency evaluation includes a balancing test applied each hour to all non-ISO energyimbalance market areas. Here, areas that elect to use the ISO-generated load forecast must show baseschedules to be within 1 percent of the forecast. Areas that fail the balancing test are subject topotential over-scheduling or under-scheduling penalties. The penalty is then applied if the final areametered load is 5 percent more or less than the base schedules. There are then two tiers of penaltyprices depending on whether the under/over scheduling is above 5 percent or above 10 percent.Figure 16 and Figure 17 show under-scheduling and over-scheduling balancing test failures by area forApril 2021. The failure amounts are shown both as a number of hours (left axis) and a percent of hours(right axis). The categories summarize the final calculation between base schedules and metered loadand whether the penalty is ultimately applied. Results are based on ISO settlement data, and are laggedto include only the most recent month beyond the last required statement.9Powerex is not included in these charts because they do not use the ISO-generated load forecast. EIMentities that elect to use their own forecast are not subjected to the initial balancing test but are insteadsubject to potential under-scheduling or over-scheduling penalties in all hours.9Market Settlements Timeline Transformation, Rashele Wiltzius, Manager, Customer Readiness, July 20, fResource Sufficiency Evaluation in the EIM15

Department of Market Monitoring – California ISOSeptember 2021Figure 16. Under-scheduling balancing test failures(April 2021)2015Underscheduled 20% (tier 2 penalty)Underscheduled 10% to 20% (tier 2 penalty)Underscheduled 5% to 10% (tier 1 penalty)Underscheduled 2.5% to 5% (no penalty)Underscheduled 0% to 2.5% (no penalty)Overscheduled 0% to 5% (no penalty)Overscheduled 5% cheduling balanging test failures(percent of hours)Under-scheduling balancing test failures(number of hours)25Figure 17. Over-scheduling balancing test failures(April 2021)2015Overscheduled 20% (tier 2 penalty)Overscheduled 10% to 20% (tier 2 penalty)Overscheduled 5% to 10% (tier 1 penalty)Overscheduled 2.5% to 5% (no penalty)Overscheduled 0% to 2.5% (no penalty)Underscheduled 0% to 5% (no penalty)Underscheduled 5% e Sufficiency Evaluation in the EIMOver-scheduling balancing test failures(percent of hours)Under-scheduling balancing test failures(number of hours)2516

Department of Market Monitoring – California ISOSeptember 2021Imbalance conformance in the energy imbalance marketOperators in every EIM balancing area, including the California ISO, can manually adjust the loadthrough imbalance conformance adjustments. These adjustments are not used directly in either the bidrange capacity or flexible ramping sufficiency tests. However, they can impact test results indirectly in atleast two ways. The flexible ramping sufficiency test measures ramping capacity from the start of the hour (i.e. lastbinding 15-minute interval) against the load forecast. Here, imbalance conformance adjustmentsentered prior to the test hour can impact internal generation at the initial reference point andramping capacity measured from that point. Further, the penalty for failing either the upward capacity or sufficiency test is that EIM transfers arecapped by the greater of the optimal transfer in the last 15-minute interval prior to the hour or baseEIM transfers. Due to this, a higher imbalance conformance adjustment entered prior to the hourcan increase EIM transfers into the balancing area resulting in higher transfer limits following afailure than would have occurred otherwise.In the EIM resource sufficiency evaluation enhancements initiative, the ISO does not propose toincorporate load conformance into the tests but plans to revisit this in a second phase.10Figure 18 summarizes average 15-minute market imbalance conformance entered by operators in theISO between July and August. Figure 19 shows the same information for each of the EIM entities withsubstantial imbalance conformance.11 Table 1 summarizes the average frequency and size of 15-minuteand 5-minute market imbalance conformance for all balancing authority areas.10EIM Resource Sufficiency Evaluation Enhancements Straw Proposal, August 16, s.pdf11EIM entities with an average absolute 15-minute market imbalance conformance of less than 1 MW were omitted fromthe chart.Resource Sufficiency Evaluation in the EIM17

Department of Market Monitoring – California ISOSeptember 2021Figure 18. Average hourly ISO 15-minute market imbalance conformance(July – 200123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24Figure 19. Average hourly non-ISO 15-minute market imbalance conformance(July – 1050-5-10-15-201234567Resource Sufficiency Evaluation in the EIM89 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2418

Department of Market Monitoring – California ISOSeptember 2021Table 1. Average frequency and size of imbalance conformance(July – August)Positive imbalance conformancePercent ofintervalsAverageMWArizona Public Service15-minute market3%5-minute market16%BANC15-minute market1%5-minute market3%California ISO15-minute market34%5-minute market28%Idaho Power15-minute market7%5-minute market16.0%Los Angeles Dept. of Water and Power15-minute market11%5-minute market33%NorthWestern Energy15-minute market77%5-minute market77%NV Energy15-minute market2%5-minute market10%PacifiCorp East15-minute market0.3%5-minute market21%PacifiCorp West15-minute market0%5-minute market2%Portland General Electric15-minute market0%5-minute market18%Public Service Company of New Mexico15-minute market0%5-minute market1%Puget Sound Energy15-minute market0%5-minute market2%Salt River Project15-minute market0%5-minute market4%Seattle City Light15-minute market0%5-minute market2%Turlock Irrigation District15-minute market0%5-minute market0%Resource Sufficiency Evaluation in the EIMNegative imbalance conformancePercent of Percent oftotal load intervalsAverageMWPercent oftotal loadAverage %2.6%-3-1521174.5%3.5%0%0%N/A-25N/A7.8%0019

Department of Market Monitoring – California ISO4September 2021Metrics for key time periodsThe following section highlights test results and outcomes during specific periods of interest. Themetrics below shows resource sufficiency evaluation results and outcomes for the California ISO on July9, around the Stage 2 Energy Emergency. As previously noted, DMM is seeking input on (1) thresholds toproduce similar period specific and area specific metrics and (2) additional metrics to include.Figure 20 shows 15-minute and 5-minute market energy imbalance market imports coming into theCalifor

Sep 23, 2021 · DMM is seeking feedback on existing or additional metrics and analysis that EIM entities and other . to each of the four 15-minute intervals within the hour. . calculated as the forecasted change in load plus the uncertainty component minus two components: (1) the diversity benefit and (2) flexible ramping credits.

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