As Nevada regulators consider NV Energy’s request to join CAISO’s Extended Day-Ahead Market, the debate over the independence of EDAM’s governance has reached a critical point.
EDAM proponents and opponents shared their views during a Public Utilities Commission of Nevada hearing March 10. The parties also sounded off in written testimony and rebuttal comments filed with the PUCN in February. The commission is expected to vote April 3 on NV Energy’s EDAM request.
“I recommend that the commission prioritize the independence of the market’s governance over most other factors,” David Patton, president of Potomac Economics, an independent market monitor for four RTOs/ISOs, said in written testimony filed on behalf of Powerex and Wynn Las Vegas, a luxury resort and NV Energy customer. Powerex has committed to joining SPP’s Markets+, a competing day-ahead market.
Through the West-Wide Governance Pathways Initiative and California Assembly Bill 825 of 2025, governance of EDAM and CAISO’s Western Energy Imbalance Market is being shifted to a Regional Organization for Western Energy (ROWE). Some see the ROWE as a means to alleviate concerns among potential market participants that CAISO, whose governing board is appointed by the California governor, plays too large a role in the markets’ governance.
Patton said the ROWE is “a very positive step” in the governance of EDAM and WEIM. But he said the entity is proposed to have minimal staff and that “critical roles,” including market operation, would remain with CAISO.
Lively Hearing
During the March 10 hearing, NV Energy representatives and intervenors in the case presented witnesses for questioning by the other parties in attendance. PUCN Chair Hayley Williamson presided over the session.
Attorney Curt Ledford with Davison Van Cleve grilled Stacey Crowley, CAISO’s vice president of external affairs, about EDAM governance. Ledford represents Powerex and Wynn Las Vegas.
Ledford asked Crowley to read aloud Section 345.5(a) of the California Public Utilities Code, which directs CAISO to “conduct its operations … consistent with the interests of the people of the state.”
“When you read ‘the state,’ do you understand [that to mean] the state of California, not the state of Nevada?” Ledford said.
“Correct,” Crowley responded.
Ledford asked Crowley about the steps needed to establish the ROWE. While the ROWE has an interim board, it doesn’t yet have staff. A consumer advocate office must be established, and a service agreement needs to be drawn up between the ROWE and CAISO. That agreement must be reviewed by the California Public Utilities Commission for conformance with AB 825 and likely will need FERC approval.
CAISO wants to wait until the permanent ROWE board is in place before negotiating the service contract, Crowley said.
“Would it be fair to say that this entire ROWE exercise could be for naught if CAISO doesn’t pursue it?” Ledford asked.
Crowley disagreed.
“The [ROWE] could exist without California participation,” she said, later clarifying that the ROWE “could take on other Western services if they so choose.”
In response to Ledford’s questioning, NV Energy attorney Roman Borisov asked Crowley whether the Pathways Launch Committee has the most control over the Pathways Initiative at this time. Crowley said yes, noting that the committee has broad representation from across the West and industry sectors.
Until the ROWE takes over governance, EDAM and WEIM are being overseen by the Western Energy Markets Governing Body, which has shared authority with the CAISO Board of Governors.
EDAM Choice Explained
NV Energy announced in May 2024 its intention to join EDAM rather than Markets+. The market choice requires PUCN approval, and NV Energy filed an application with the commission in October. (See NV Energy Confirms Intent to Join CAISO’s EDAM and NV Energy Files Request to Join EDAM.)
Without NV Energy, EDAM would lose a large and central piece of its footprint.
David Rubin, NV Energy’s federal energy policy director, said Section 345.5 of the California Public Utilities Code was adopted before CAISO was running a regional market. He noted that AB 825 added Section 345.6, which allows California utilities to participate in a CAISO market that has independent governance if the FERC tariff for the market includes a requirement to respect the authority of each participating state. That authority includes setting procurement, resource adequacy, environmental, reliability “and other public interest policies.”
The language “reflects a clear recognition that the regional markets — including the EDAM — must accord equal respect to the policy interests of all participating states,” Rubin said in written rebuttal testimony.
Rubin said market participants and regulators must have confidence in the overall fairness of a market’s governance.
He said other key reasons why NV Energy chose EDAM are the company’s positive experience in the WEIM; expected costs of day-ahead market implementation; EDAM’s expected market footprint and interconnectivity of participants; and transmission work within the footprint that will enhance interconnectivity and supply diversity.
Additional reasons are EDAM’s market design and projected financial, reliability and environmental benefits.
“These factors favor the EDAM over Markets+,” he said.
