11. Reporting and Process Requirements
As discussed in the July 1 Ruling, it is unclear what the eventual effects will be of a utility's convergence bidding participation in the CAISO markets.77 In order for the Commission to eventually make such an assessment, the IOUs must meet certain reporting and process requirements.
Because we are only granting interim authority for IOU participation in convergence bidding, these reports will provide the Commission with the information necessary to make any changes to IOU convergence bidding authority in any subsequent decision extending or modifying such authority.
11.1. Parties' Position
With regards to the Commission's regulatory oversight, DRA recommends that each IOU be required to provide monthly reports of convergence bidding activities on a common reporting template.78 In their reply comments, PG&E states no objection this recommendation.79 Similarly, SCE agrees with DRA that monthly reporting using a common reporting template for the first year was acceptable.80 In addition, both PG&E and SDG&E recommend filing these data in the QCR.81 Specifically, SDG&E proposes tracking gains and losses on a weekly basis, and include the information accordingly in SDG&E's QCR filings.82
Regarding PRG consultation, Reid recommends that the IOUs be required to meet with the PRG every two weeks for the first six months of convergence bidding.83 However, both SCE and SDG&E oppose Reid's recommendation as overly burdensome upon the IOUs and PRG participants.84 Instead, SCE proposes reviewing convergence bidding with its PRG on a quarterly basis, including information on bid quantity, rationale for the bid, and amount received or paid for each bid.85
With regards to public disclosure of the IOUs' convergence bidding activities, PE recommends that convergence bidding data should be presented quarterly, and be made public.86
11.2. Discussion
In response to parties' concerns regarding proper Commission oversight of the IOUs' convergence bidding activities, we conclude that it is reasonable to direct the IOUs to provide a set of information for each calendar month, no later than two weeks from the end of each month, to the Energy Division. The IOUs shall provide this information monthly for a period of one year after the CAISO convergence bidding market becomes active. At the end of one year, absent further direction from the Commission, this information shall be reported in the QCR filings beginning with the Q1 2012 filings and presented to the PRGs on a quarterly basis.
In response to parties' concerns regarding proper PRG consultation, we conclude that it is reasonable to direct each IOU to provide to PRG participants review of its convergence bidding strategies, performance, and market analysis in the quarterly PRG meetings, beginning with the first quarter in which convergence bidding activities commence.
At a minimum, the IOUs shall include in their monthly reports:
1) A list of each cleared convergence bid, containing the hour, location, volume, and justification for the transaction;
2) A list of the Day-Ahead and Hour Ahead prices corresponding with each convergence bid;
3) For each day the gains or losses, in dollars, as a result of convergence bidding;
4) For that month, and any past months during the calendar year in which convergence bids were transacted, a monthly total of volume, gains or losses (in dollars), the number of times each strategy was employed, and the number of bids conducted outside of that IOU's service territory;
5) The approved convergence bidding strategies utilized during that time period; and
6) Qualitative analysis of convergence bidding impacts upon other related products, such as CRRs; and
7) A list of any affiliates who have or are registered with the CAISO to participate in convergence bidding.
In light of parties' comments on the need for a common reporting template, we conclude that it is reasonable to direct the IOUs to use a common template when reporting the summary of convergence bids for each month. The Energy Division is directed to develop the reporting template, with inputs from all parties, and to modify it as appropriate.
77 July 1 ALJ Ruling at 2.
78 DRA August 30, 2010 Comments at 9.
79 PG&E September 7, 2010 Reply Comments at 7.
80 SCE September 7, 2010 Reply Comments at 11.
81 PG&E September 7, 2010 Reply Comments at 7; SDG&E September 7 Reply Comments at 3.
82 SDG&E September 7 Reply Comments at 3.
83 Reid August 31, 2010 Comments at 2.
84 SCE September 7, 2010 Reply Comments at X; SDG&E September 7, 2010 Reply Comments at 8.
85 SCE September 7, 2010 Reply Comments at 11.
86 PE August 30, 2010 Comments at 6.
