Interaction with MRTU and Wholesale Markets

SCPPA views the impact of a deliverer approach on the real-time or forward markets as a "direct interference" that would increase the cost of the GHG reduction program. However, the CAISO Market Surveillance Committee strongly favors a deliverer approach due to what it sees as reduced interference in the efficient operation of its markets. SCE asserts a related advantage with respect to imported energy, that an entity that delivers power to California must take responsibility for that energy before it is bid into the CAISO market. In SCE's view, this addresses the attribution challenge of market bids from imports.

SCPPA is concerned that this approach may discourage importers from selling into the California market, "thereby reducing California electricity market liquidity, increasing wholesale electricity prices, and decreasing reliability."