Summary of NERC Penalties
Quarter 2 - April 2023
Section 126.96.36.199 of CAISO’s Tariff
Ohm’s bids exceeded the registered metered load of all its customers
Ohm is a demand response provider participating in the CAISO market. Demand response providers do not generate electricity themselves but instead contract with individual customers to reduce the amount of electricity they would otherwise use. In California, demand response providers then aggregate this demand response under the California Public Utilities Commission’s (CPUC) Demand Response Auction Mechanism (DRAM) pilot program.
Under the DRAM pilot program, demand response providers contract with Load-Serving Entities (LSEs) to provide a given amount of demand response. Each month, demand response providers tell the LSEs how much demand response they would provide 90 days later, and those load reductions become part of the LSEs’ supply plans. The LSEs, in turn, submit their supply plans (including demand response) to CAISO to substantiate the Resource Adequacy capacity contracted by the LSE.
Under this program, Ohm, a California demand response provider, bid the same amounts of demand response each day as it had contracted with the LSEs into CAISO’s day ahead (DA) energy market. A substantial majority of the bids Ohm made into the DA market in the first six months of 2018 exceeded the registered metered load of the individual customers whose potential demand response was aggregated into Ohm’s bids. Consequently, between January and June 2018, Ohm submitted bids into the DA market that it could not fulfill with registered load.
In May and June 2018, Ohm received Resource Adequacy Availability Incentive Mechanism (RAAIM) payments that it would not have received if it had made accurate bids.
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