By Robert Mullin

LAS VEGAS — The West-wide forum created by CAISO to foster discussion about Energy Imbalance Market-related issues outside the ISO’s normal stakeholder process is worth preserving — and developing further.

That was the general consensus of stakeholders and EIM Governing Body members who gathered at The Palazzo hotel last week to discuss the fate of the Regional Issues Forum (RIF), which was established in 2015 as the ISO began to build momentum for “regionalization” — the push to expand into other parts of the West.

“We all value what the RIF has been doing,” Governing Body Chair Christine Schmidt said during a Feb. 28 joint meeting that included fellow body members, RIF representatives, industry participants and interest groups. “We value the promise of what the RIF can do going forward.”

‘Learning a Lot’

Speaking in her capacity as a Washington state utility commissioner, Ann Rendahl — chair of the EIM’s Body of State Regulators — voiced her support for the RIF as someone “who is coming into this market new and learning a lot.”

“The Regional Issues Forum discussions have been very helpful, because you are all participating in the market and you have experiences that are helpful for us to learn and hear, in addition to the formal stakeholder processes that the ISO puts on,” Rendahl said.

Accolades notwithstanding, uncertainty still looms about the future role for the forum, what formal structure it should assume and how it should interact with the Governing Body.

Doug Howe, the body’s vice chair, referred to it as “the existential question of ‘What’s the RIF?’”

RIF representatives, called “sector liaisons,” have committed to answering that question and developing an operating framework for the group in time for the Governing Body’s July meeting.

“The liaisons don’t see a lot of barriers to getting this done in an expedited way,” said Tony Braun, RIF chair and a liaison representing the publicly owned utilities sector.

Informal Body

The RIF was conceived under the EIM charter as an informal body to enable industry stakeholders and the public to discuss wide-ranging issues related to the West’s only real-time energy market. (See PacifiCorp Offers Lessons for Future EIM Participants.)

The forum is organized by 10 liaisons representing five industry sectors: independent power producers and power marketers; transmission-owning utilities; publicly owned utilities; consumer advocates; and balancing areas neighboring the EIM — the last of which is a diminishing group as the EIM grows, Braun joked. CAISO planned for the RIF to meet about three times a year but required no set schedule.

According to the ISO, “The forum may produce documents or opinions for the benefit of the EIM Governing Body, ISO Board of Governors and the ISO,” but it sits firmly outside established stakeholder processes.

The EIM’s governance documents call for the RIF’s role to be re-evaluated by next month, which was the primary reason for the Feb. 28 joint meeting.

Re-evaluation Process

A key question in the re-evaluation: How should the RIF run the process to re-evaluate itself?

“Should this be an ISO-run stakeholder process in the traditional fashion?” asked Braun. “Is this something that the liaisons should take ownership of? What should be the liaisons’ role in putting together the recommendations and things like that, if any?”

Schmidt said she didn’t think the RIF’s evaluation was ever intended to become part of an ISO stakeholder process.

“I think the general consensus [among CAISO and EIM leaders] is that the Regional Issues Forum is the Regional Issues Forum,” Schmidt said. “However the re-evaluation needs to take place, this is in your control and is in your span of control and authority, and you should actually go through that process as a Regional Issues Forum issue.”

Speaking on behalf of her company, RIF liaison Sara Edmonds, general counsel at PacifiCorp Transmission, supported the general independence of the RIF, but she noted that the group has no funds or processes to post material coming out of its meetings.

“We’re happy as the liaisons to kind of be the muscle to pull together the substance [of the re-evaluation], but we’re still going to need the ISO vehicle to get the information out [and] help us with the meetings,” Edmonds said.

Ellen Wolfe of Resero Consulting, representing the Western Power Trading Forum (WPTF), backed Edmonds’ view. The WPTF sees “a lot of value” in the continuation of the RIF and agrees with the bottom-up approach to re-evaluation, she said.

‘Grass-Rootsy’

“We do like the idea of the RIF being very ‘grass-rootsy,’ so to speak, but also appreciate the ISO providing the infrastructure for posting comments and market notices and so forth,” Wolfe said.

Howe sought more clarity on the process the RIF would adopt in its re-evaluation.

“So we know that is not going to be a formal ISO stakeholder process — which means a few things, but among them is that you’re not going to start with an issue paper that’s going to be delivered to you by the staff of the ISO,” Howe said.

“So, to some extent, either you’re going to have to deliver the issue paper, or you’re going to have to take in the comments, perhaps write a strawman proposal, and send that out for another round of comments.”

Howe wondered whether ISO staff would ultimately be charged with writing the strawman based on what RIF liaisons heard during the Feb. 28 meeting.

“In my mind, we’re either fish or fowl,” Braun responded. “So if this is a process that the RIF liaisons are going to take ownership of, then my colleagues as the liaisons need to pick up the pens and craft the issue paper of the first straw proposal.”

“We’re all devoting our time and energy to this because we think it’s important,” said RIF liaison Matt Lecar, principal at Pacific Gas and Electric. “But there is a lack of formal structure, and therefore a lack of funding and resources to do things like write the extensive issue papers and straw proposals that the CAISO staff otherwise would in a CAISO stakeholder process.”

Hands Off

On the question of who should be responsible for approving the RIF’s proposal for a framework, Governing Body members advocated a mostly hands-off position.

“I am not seeking to have authority over what the RIF does,” said Governing Body member Valerie Fong, adding that she wouldn’t want to be cut out of the RIF’s activities because of the forum’s educational value. “I won’t be offended if [RIF members] decide that the EIM Governing Body does not have a decision in this process.”

Howe seconded Fong’s sentiments, saying he didn’t see a role for the Governing Body to put its “blessing” on the RIF’s final proposal.

“The primary purpose of this [process] is to construct an organization that helps you all to be effective, and I just want to thank you for including us in that,” Governing Body member Carl Linvill said. “But as far as any kind of formal approval, I’m with what everybody else has said: I don’t think we need that.”

Fellow body member John Prescott said it was important for the RIF to be transparent.

“What I want is access to the knowledge,” Prescott said.

Schmidt reminded her fellow body members that the RIF is embedded in the EIM’s governing documents, meaning that decisions around the RIF will still be subject to some CAISO oversight.

“If there’s a resource impact, or any other impact on the ISO or the ISO’s Tariff, those are matters that will have to be decided by the EIM’s Governing Body and ultimately the [ISO’s] Board of Governors,” Schmidt said.

RIF as Author?

Another key issue facing the RIF: whether it will produce papers on issues coming before the EIM Governing Body.

On that subject, Braun said stakeholder comments ranged from “no, that’s not what the RIF is for” to “yes.”

Howe said the question must be preceded by what issues the RIF will undertake.

“Are you going to take on issues in the stakeholder process?” Howe asked. He added that the RIF will “need to decide how you’re going to decide.”

Fong noted that operating guidelines are “somewhat silent” on a lot of RIF issues.

“If I were you, I would keep my options open,” she said.

‘Happy to Help’

Lecar wondered if there would be resources available to the RIF to take on larger written work projects.

Stacey Crowley, CAISO vice president for regional and federal affairs, affirmed that ISO staff would be willing to take down comments from a RIF meeting.

“We’re happy to help,” Crowley said, adding that it would be up to the RIF, however, to craft substantive policy recommendations.

Howe emphasized the need for the RIF to document the views arising within its discussions. “If you don’t turn this into a written product, these are conversations that get lost in the dark,” he said.

Jennifer Gardner, staff attorney with Western Resource Advocates, asked whether the RIF could play the role of flagging issues for the Governing Body that are not already being addressed in CAISO’s stakeholder process.

“Is there value, from the Governing Body’s perspective, in having something a little bit more formalized with the RIF?” Gardner asked. A more formal process would entail producing written comments, rather than just “casual dialogue” among RIF participants.

“Does the RIF have to come to consensus on everything?” Fong asked. “Does it have to be giving us an overall perspective from a RIF level? I’d say ‘no.’ I’m OK with the individual input” from RIF participants.

Howe agreed with his colleague and added his own perspective.

“For me, the value is the eyes and ears out in the field to flag issues which may not have risen to the level [of] the ISO yet,” Howe said. “What doesn’t have value for me would be for the RIF to try to turn itself into a formal stakeholder process, because we’ve already got that [within the ISO]. And that just wouldn’t provide additional value.”