PacifiCorp staff described how EDAM will require each market participant to satisfy a day‑ahead Resource Efficiency Evaluation (RSE) before the market runs and explained the penalty structure for shortfalls.

Danny (surname not specified in the transcript), a PacifiCorp market presenter, said the RSE is a daily test that checks whether a participant’s forecasted load, variable resource uncertainty and ancillary‑service obligations are covered by committed resources for each hour of the next day. He said the RSE exists to give market participants and transfer recipients confidence that scheduled transfers will be supported in real time.

PacifiCorp explained the penalty framework: failures below a de minimis threshold (less than 10 megawatts) carry no surcharge. For larger shortfalls, the tariff applies tiered multipliers on an estimated cure cost. PacifiCorp gave two examples: if a failure is less than 50% of an entity’s imbalance obligation the surcharge multiplier is 1.25; if a failure exceeds 50% it is treated as a severe failure and the multiplier is 2. The surcharge calculation is intended to approximate the cost of curing the deficiency in the bilateral market (for example a 16‑hour block purchase) and to deter participants from intentionally relying on market cures instead of forward procurement.

Commission staff asked whether the RSE and associated surcharges would change PacifiCorp’s hedging and forward‑procurement policies. Mike Wilding and other PacifiCorp staff said the company is updating hedging policies and planned a stakeholder presentation in October on hedging proposals. PacifiCorp also emphasized that participants receive advisory RSE runs multiple times in the morning, giving several opportunities to modify schedules before the final day‑ahead run.

Speakers warned that relying on surcharges rather than forward procurement could be risky if the market has limited capacity during extreme peak days. PacifiCorp said other penalties and operational consequences beyond the RSE surcharge would discourage gaming; the company said the RSE also benefits from a diversity advantage across a larger footprint, which lowers the overall uncertainty requirement compared with acting alone.