high prices were set by demand response and other resources not subject to mitigation

Was this impact of demand response anticipated?

"I place this observation in the category of Practice trumping theory.'"

I place CAISO's observation in the category of "Another Smoke-And-Mirrors Excuse Invented by California Regulators to Distract From the Inept Failure of Their State's 'Renewable Portfolio Standard.'"

"....resources that may be subject to mitigation were generally infra-marginal in re-runs of the day-ahead market using cost-based bids blah blah..."

Either that, or..."CAISO didn't have enough reliable power when it was needed by the people who were paying for it"?

What caused outages in mid-August isn't nearly as complicated as CAISO would like to make it seem.

Richard,

I went and looked into the Market Monitoring and Mitigation Business Practice Manual (BPM) of MISO on Demand Response Resources. Here is what our BPM says, section 9.2 of BPM 09:

"It is difficult, if not impossible in some cases, to determine appropriate Reference Levels for DRRs and apply mitigation to them using the conduct and impact approach. Therefore, in order to monitor DRRs for potential market power, the IMM will:
1) Monitor DRRs in a manner comparable to Generation Resources;
2) Notify FERC of any behavior by a DRR that the IMM has reason to believe has violated applicable market rules;
3) Assess and report on uplift charges associated with any make-whole payments paid to these DRRs; and
4) Assess and report on the market effects of DRRs in MISO’s markets, including any market benefits and perceived market power risks, as part of its annual State of the Market Report."

DRRs are demand response resources at MISO. We have DRR Type I, which is a block load and DRR Type II, which is a range.

I am wondering with this piece of information, whether we are setting up market monitoring and mitigation for failure if it is already difficult to start with - monitoring and mitigating demand response?