Comment Log Display

The Western Power Trading Forum offers the following comment on
staff proposed changes the Mandatory Reporting Regulation. 

Clare Breidenich
WPTF, GHG Committee Director
1.206.697.4946


At the June 5th workshop on potential changes to the Mandatory
Reporting Regulation, staff proposed modification to the regulation
to provide clarification of the calculation by which importers
would report  the lesser of scheduled power or metered generation
in an hour. WPTF supports inclusion of this calculation in the
regulation, and the proposal that this calculation be required only
from specified imports with an emission rate of zero, or resources
that are eligible for the California Renewable Portfolio Standard
program. However, WPTF believes that additional changes are
needed:
 
•         First, the Air Resources Board’s practice, as explained
at in an Electric Power Entities workshop in July 2013, has been to
accept hourly allocation data in lieu of meter data for specified
imports from the Mid-Columbia hydro-electric resources. 
•         Second, the ‘lesser-of’ calculation should not be
required for out-of-state resources that are physically connected
to the California Independent System Operator (CAISO) system and
for which no NERC-tag is created.  Electricity generated from these
resources and injected into the CAISO is physically metered at a
CAISO busbar. Thus, the quantity of generation will always match
the quantity of power imported.
 
WPTF therefore requests CARB to amend the proposed changes to the
lesser-of calculation to include these exceptions.