A new paper from Powerex is likely to reignite the debate between supporters of CAISO’s Extended Day-Ahead Market (EDAM) and SPP’s Markets+ just as the competition between the two markets approaches critical junctures.
Chief among them: the pending introduction of legislation in California to allow CAISO to relax its oversight over its Western markets; the Bonneville Power Administration’s impending draft decision on a day-ahead market choice; and an expected continuation of participant commitments to both markets.
The paper, which Powerex published Feb. 11, contends that EDAM contains a “design flaw” that could saddle non-CAISO participants with $1 billion in unjustifiable charges that effectively would be conveyed as payments to participants operating within the ISO.
Powerex contends EDAM’s treatment of firm transmission rights and congestion would leave the market’s non-CAISO participants exposed to charges for constraints occurring outside their systems while not providing them adequate ability to recover or hedge against those costs — what the company calls an “aberration” among organized markets.
“The PacifiCorp, NV Energy and Idaho Power transmission systems are the most exposed to this outcome, including when the utilities use their own transmission systems to deliver their own generation to their own load,” Powerex wrote in the paper.
The potential “transfer of value” could have a “wide range of harmful consequences” in those service territories, including: raising costs for retail ratepayers; eliminating incentives for third parties to invest in transmission service; shifting the benefits of non-CAISO transmission expansion projects to ISO customers; and “undermining the proper functioning of other regional programs and markets,” such as the Western Resource Adequacy Program and Markets+.
Powerex’s assertions prompted a sharp response from CAISO and PacifiCorp, the first utility to commit to joining EDAM and whose recent tariff filing apparently prompted the concern.
“Powerex, a primary funder of Markets+, continues to publish hyperbole and unsupported assertions, with economic impact estimates that defy market logic,” CAISO Director of Communications Jayme Ackemann and PacifiCorp spokesperson Omar Granados said in a joint statement to RTO Insider.
Ackemann and Granados called the paper “misinformed and inflammatory” and said it represents “an attempt to derail” EDAM “rather than improve it.”
Vancouver, Canada-based Powerex is the marketing subsidiary of BC Hydro, the Canadian Crown corporation that provides power for most of British Columbia and operates about 11,680 MW of hydroelectric capacity. Through a trading operation that spans the Western Interconnection, Powerex owns transmission rights on multiple systems throughout the sprawling region.
The company currently participates in CAISO’s Western Energy Imbalance Market (WEIM) but has been a key backer of SPP’s Markets+ in its competition with EDAM for day-ahead participants and, in that capacity, a vocal critic of CAISO and its EDAM. Powerex recently committed to joining Markets+ and providing a substantial share of funding for Phase 2 implementation stage of the market. (See Powerex Commits to Funding, Joining SPP’s Markets+.)
On the other hand, PacifiCorp — along with Portland General Electric — is scheduled to begin trading in EDAM next year, while NV Energy and Idaho Power are heavily leaning in favor of joining the CAISO market.
Parallel Flows
The complexity of Powerex’s argument mirrors that of how energy flows on the electricity grid — and how those flows are reflected in the rules and processes of organized wholesale electricity markets.
Powerex notes that under FERC’s Open Access Transmission Tariff (OATT) framework of transmission rights, “entities that invest in firm OATT transmission service obtain the right to deliver generation from lower-price locations to load in higher-price locations.”
The company also points out that — as in other markets — EDAM will be “layered” on top of that framework, requiring a resource to sell its supply at one locational marginal price, while an end user will pay a different LMP at the point of consumption.
And as in other markets, EDAM electricity deliveries will be subject to a “net financial settlement” that reflects the difference between the prices at the two locations — which can include charges stemming from the congestion on the lines between those points.
The assessment of congestion charges is complicated by the fact that flows of energy associated with a scheduled delivery do not always follow the “contract path” but often are channeled through a neighboring system, producing “parallel” flows on that system.
In EDAM, Powerex contends, this means a delivery scheduled between PacifiCorp’s East and West balancing authority areas, for example, could produce a parallel flow that causes congestion in the CAISO BAA. EDAM then would apply the charge for that congestion to the PacifiCorp transaction.
Powerex contends EDAM deviates from “all other” U.S. markets because it does not provide “a financial hedge that returns the day-ahead congestion charges on a delivery path back to the entities with firm transmission rights on that delivery path” — as required by FERC.
“Instead, EDAM will allocate congestion revenues based on the modeled locations of congestion ‘bottlenecks,’” the paper says.
Powerex says WEIM data show that the “most prevalent” of those bottlenecks occur in CAISO’s system.
“Under the EDAM design, this means the California ISO’s customers can be expected to receive the vast majority of the flow-based congestion charges collected from activity on other transmission systems throughout the EDAM footprint,” the paper says.
Powerex contends that in every electricity market in the U.S. but EDAM, customers using service from one transmission service provider (TSP) are either not liable for the cost of parallel flows on other systems, or able to mitigate that cost through specific market mechanisms, such as hedging instruments like financial transmission rights. In the case of Markets+, congestion charges will be returned to the firm rights holder.
“This EDAM market design flaw will have the greatest impact on those adjacent transmission systems outside of California that also provide significant north-to-south and south-to-north connectivity: namely, PacifiCorp, NV Energy and Idaho Power,” Powerex wrote. “If each of these utilities join EDAM under its current design, it will be … [CAISO’s] own customers that will collect the vast majority of the locational price difference from activity on the PacifiCorp, NV Energy and Idaho Power transmission systems.”
‘Completely Meaningless’
Powerex said the issue came to light in January when PacifiCorp filed with FERC its EDAM tariff, which noted the utility could offer its firm transmission customers only a “partial hedge” against congestion charges. That hedging option would reverse only the portion of congestion related to transmission constraints modeled within PacifiCorp’s system, “even though the schedules would pay congestion charges that also include parallel flows on other transmission systems,” Powerex contended.
In November, Powerex announced it would cancel a large portion of its transmission rights on the PacifiCorp system in response to the expected OATT changes. (See Powerex to Cancel Rights on PacifiCorp Tx System over EDAM Changes.)
Powerex said its experience in the WEIM “shows unambiguously” that the transmission constraints that most often limit physical flows between locations throughout that market are in CAISO.
“Since the EDAM design distributes congestion charges based on the location of the constraints that cause LMPs to separate, and data shows these constraints will predominantly be located in … [CAISO’s] transmission system, once EDAM commences, customers that use PacifiCorp transmission service will pay large new congestion charges that will go almost entirely to … [CAISO’s] own customers,” Powerex said.
Under one scenario modeled to show heavy solar penetration in the Southwest, Powerex found the “value transfer” from non-CAISO BAAs to CAISO to reach $1 billion annually, a figure not reflected in production cost modeling studies that repeatedly have shown that most Western entities will realize greater economic benefits from participating in EDAM than in Markets+, including a series of studies performed by The Brattle Group.
“All of the EDAM benefits studies to date have completely missed this important market design issue, and given its magnitude, the results of these studies are completely meaningless,” Powerex said.
‘Feigned Concern’
“Focusing narrowly on one aspect of market design, in isolation, conveys an intentionally distorted picture,” CAISO and PacifiCorp said in their joint statement. “As a power marketer, Powerex is simply attempting to force changes to the EDAM market design that have already been approved by FERC for its own economic interest.”
They also contend that, based on the assumed EDAM market footprint, it is “illogical” to estimate that the three cited BAAs would be forced to pay $1 billion in congestion revenues for congestion occurring in CAISO.
“Such claims, which Powerex attempts to cloak in feigned concern for NV Energy, Idaho Power Co. and PacifiCorp customers, are not supported by the analysis from the very entities that are responsible for providing service to those customers,” they said.
They said the FERC docket (ER25-951) for PacifiCorp’s EDAM tariff is the “appropriate venue” for Powerex to air its concerns about the market.
“While we appreciate Powerex’s continued engagement in Western energy market design, its approach continues to be counterproductive,” CAISO and PacifiCorp said.
In an email to RTO Insider, Brattle Group principal John Tsoukalis said his company’s EDAM benefits studies “have repeatedly found results that are consistent with the actual experience in WEIM over the last 10 years”: that ISO customers “in fact receive less benefits on a load-ratio-share basis than other market participants due to the fact that CAISO already has a day-ahead market in place.”
He said the allocation of congestion revenues “is necessarily simplified in our studies, which means that real-world congestion revenue allocations may differ from our estimates,” adding that those revenues are only one metric examined in the studies.
“Of course, it is possible that EDAM implementation might uncover some revenue allocation issues that will need to be addressed, just as PacifiCorp’s filing addresses some items that have come up and CAISO stakeholder processes have addressed issues in the past,” Tsoukalis told RTO Insider.
Tsoukalis additionally contended that Powerex’s paper did not provide enough detail to replicate its analysis and “vet its conclusions” and that it failed to cover several aspects of EDAM that will differ from the WEIM, including expectations that:
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- EDAM participants will contribute significantly more transmission than they do in WEIM, thereby reducing congestion;
- major new transmission projects under development are likely to “significantly reduce” and change the pattern of congestion; and
- optimized day-ahead unit commitment and dispatch “will further increase the effectiveness of how the existing grid is used.”
Tsoukalis also pointed out that EDAM will disaggregate price differences between areas into congestion revenues and “transfer” revenues collected when a transfer constraint results in differentials between two BAAs.
“The [Powerex] memo does not discuss the transfer revenue portion of the EDAM design, which means that EDAM congestion revenues will be more limited than the price differences that [Powerex] uses in its illustrations,” he said.