1.
Please provide your organization’s overall comments on the 2024 and 2028 Local Capacity Requirements Technical Study Draft Results.
Vistra Corp. respectfully submits these comments on the CAISO’s 2024 and 2028 Local Capacity Technical Study (“LCT Study”) Draft Report and Study Results (“Draft Reports”) posted on March 7, 2023 and discussed at a public stakeholder call on March 9, 2023.[1] Vistra comments will cover the following four topics:
- South Bay – Moss Landing LCR subarea continues to underrepresent the amount of batteries in the local area expected to be operating in 2024 and beyond
- Oakland LCR subarea continues to fail to show there is a need to procure storage in local area to complete the Oakland Clean Energy Initiative
- LCT Study results do not adopt needed methodology changes to recognize the reality that local Resource Adequacy in forward years can be met by new resources with deliverability and that use limited resources are meeting these needs
- LCT Study results do not allow planned resources that are viable to achieve commercial operations to offset the need to reduce the requirements in deficient areas
- LCT Study results do not specify the minimum energy (MWh) needed to meet the local area requirements
South Bay – Moss Landing LCR subarea continues to underrepresent the amount of batteries in the local area expected to be operating in 2024 and beyond[2]
Vistra is concerned that the Moss Landing Battery Energy Storage Facility Phase III, Moss 350, that is Q1540 project is not being included in the generation assumptions even though it is under construction with a target commercial operation date of June 1, 2023. This is well in advance of 2024 commercial operation date listed in the CAISO’s overall summary of findings when describing its assumptions and methods.
We believe this because the 2022-2023 TPP Portfolios transmitted to CAISO do not include these 350 MW in the in-development column. Further, the numbers support this because the 2022 NQC resources list showed 678 MW of storage of which the first two phases including VISTRA_5_DALBT1, VISTRA_5_DALBT2, VISTRA_5_DALBT3, and VISTRA_5_DALBT4 amounting to 400 MW and there were an additional 278 MW of new units with MW that do not map to the Vistra Q1540 project with 350 MW.[3] There should be an additional 350 MW shown in the Battery assumptions.
We respectfully request the CPUC and CAISO coordinate to provide an update to its transferred portfolio that would reflect the 350 MW as in development resources so that the 2024 LCR and 2028 LCR results are more accurate.
Oakland LCR subarea continues to fail to show there is a need to procure storage in local area to complete the Oakland Clean Energy Initiative[4]
CAISO assumptions show a 55 MW market resource and a 55 MW battery at the Oakland Sub-area, Vistra is not aware of any planned resource meeting the relevant inclusion criteria that would support this assumption for 2024 and 2028. The generation assumptions are inconsistent with the CPUC transferred portfolio which do not show any existing or planned resources at the Oakland substation for the 2022-2023 TPP. Vistra also requests the CAISO make clear that the local need cannot be met by the 48 MW of Muni/QF.
Vistra believes the correct assumptions based on the CPUC transferred portfolios, which are consistent with current state of development efforts while assuming CTs are retired in future years, are shown below.
|
Generation Assumption
|
CAISO Draft
|
Appropriate Assumptions Assuming Oakland Jet-Fuel CTs are retired after 2025
|
|
|
|
2024
|
2028
|
|
Market/Net Seller MW
|
55
|
110[5]
|
0[6]
|
|
Battery MW
|
55
|
0
|
0[7]
|
Further, Vistra believes the CAISO LCT Study Oakland results should be similar to those below.
|
Load (MW)
|
Generation MW)
|
Aug 2024-2025 NQC
|
Aug 2026-2028 NQC
|
|
Gross Load
|
177-185
|
Market
|
110
|
0
|
|
AAEE
|
-1
|
Battery
|
0[8]
|
0
|
|
Behind the Meter DG
|
-1
|
Muni/QF
|
0[9]
|
0
|
|
Net Load
|
175-184
|
Solar
|
0
|
0
|
|
Transmission Losses
|
0
|
Existing 20-minute DR
|
0
|
0
|
|
Pumps
|
0
|
Mothball
|
0
|
0
|
|
Load + Losses + Pumps
|
175-184
|
Total
|
110
|
0
|
Below, Vistra illustrates one way the LCR requirements could show that there is a deficiency in forward years.
|
Year
|
Category
|
Limiting Facility
|
Contingency
|
LCR (MW)
(Deficiency)
|
LCR (MWh)
(Deficiency)
|
|
2024
|
P6
|
Oakland C-X #2 115 kV cable
|
Oakland C-X #3 & D-L #1 115 kV lines
|
31
|
~176[10]
|
|
2025
|
P6
|
Oakland C-X #2 115 kV cable
|
Oakland C-X #3 & D-L #1 115 kV lines
|
31
|
~176
|
|
2026
|
P6
|
Oakland C-X #2 115 kV cable
|
Oakland C-X #3 & D-L #1 115 kV lines
|
31 (-31)[11]
|
~176 (~-176)
|
|
2028
|
P6
|
Oakland C-X #2 115 kV cable
|
Oakland C-X #3 & D-L #1 115 kV lines
|
40 (-40)
|
~176 (~-176)
|
Based on our practical experience with previous LCT Study results, we are concerned that failure to modify the LCT study assumptions will produce results that do not send the appropriate signal to address local capacity deficiencies in the Oakland local area. Specifically, energy storage will not be developed and achieve commercial operations to complete the Oakland Clean Energy Initiative and facilitate the retirement of the Oakland Power Plant Jet-Fired Combustion Turbines if the LCT study assumes energy storage will be in operation in 2024.
LCT Study results do not adopt needed methodology changes to recognize the reality that local Resource Adequacy in forward years can be met by new resources with deliverability and that use limited resources are meeting these needs
Vistra provided comments on the 2024 LCR methods on November 22, 2022.[12] We respectfully asked the CAISO to revise its methodology to allow the LCT Study to keep pace with the changing RA fleet and RA program by 1) specifying requirements in terms of capacity and energy and 2) only reducing the local requirement in areas with resource deficiency for the binding year and require CPE to cure the resource deficiency in forward years. We repeat that request out of fear that reluctance to do so restricts developers’ ability to rely on these results to help inform our activities in a manner that best supports local reliability in the near and mid-term horizons. We urge the CAISO to address this oversight and to make these changes to its 2024 and 2028 results in the final version.
LCT Study results do not allow planned resources that are viable to achieve commercial operations to offset the need to reduce the requirements in deficient areas
Vistra strongly believes the three-year forward local RA requirements established through the LCT Study must be revised to allow for new resources that can achieve commercial operations in a forward year to facilitate curing area(s) with resource shortfalls for the forward-year requirements. This change is needed to better align the LCR requirements to respect that the local RA program has evolved to require procurement of local RA on a three-year forward basis where new resources are able to be procured to meet those needs.
Vistra again requests that the CAISO change its assumptions to allow resources with commercial operation dates in 2025 and 2026 that are viable to achieve COD, such as by already receiving TPD allocation or by utilizing deliverability retained at the point of interconnection for repower or Independent Study Project.[13] We are concerned that failure to modify this assumption makes it more difficult for procurement arms and developers to work together through existing procurement mechanisms to cure needs with sufficient lead time. For example, PG&E Central Procurement Entity (“CPE”) could better plan and track progress on its efforts to cure local area deficiencies through procuring new resources under its existing CPE authority to execute long-term agreements with new resources.
Vistra urges the CAISO to update its methodology and produce 2024 and 2028 study results that will send the appropriate forward signal for use in the forward years.
LCT Study results do not specify the minimum energy (MWh) needed to meet the local area requirements
California fleet has evolved to include a greater concentration of use limited resources where providing the installed capacity requirement is insufficient to capture the energy requirement necessary to meet the LCT need. The LCT Study should evolve to recognize that the local needs will increasingly come from non-conventional resources and adopt changes for 2024.
By not specifying the local needs in both terms of capacity and energy, the CAISO is unintentionally confusing procurement arms that are considering meeting their local needs from non-conventional resources. Load Serving Entities or Central Procurement Entities need to understand that there is a MWh requirement in some areas where the 4-hour Resource Adequacy obligation may not be sufficient.
Vistra urges the CAISO to enhance its final results to include this needed level of detail to its LCT Study. CAISO should revise the LCT Study to identify both a minimum capacity (MW) and minimum energy (MWh) requirement for each LCR area(s). Additionally, we request the CAISO specify in its methods whether the energy requirement is (1) non-continuous hours requirement or (2) continuous hours requirement[14].
[1] 2024 & 2028 Overall Summary of Findings – Draft 2024 and 2028 Local Capacity Requirements, http://www.caiso.com/InitiativeDocuments/Presentation-Draft-2024-and-2028-LCR-Bay-Area-Local-Area-Mar92023.pdf; Draft 2024 and 2028 LCR Bay Area Local, http://www.caiso.com/InitiativeDocuments/Presentation-Draft-2024-and-2028-LCR-Bay-Area-Local-Area-Mar92023.pdf.
[2] Draft 2024 and 2028 LCR Bay Area Local, Slide 13, http://www.caiso.com/InitiativeDocuments/Presentation-Draft-2024-and-2028-LCR-Bay-Area-Local-Area-Mar92023.pdf.
[3] Attachment A – List of Physical Resources Accounted for in the 2023 and 2027 Local Capacity Technical Studies, South Bay – Moss Landing sub-area, https://www.caiso.com/InitiativeDocuments/AttachmentA-ListofPhysicalResourcesAccountedforinthe2023and2027LocalCapacityTechnicalStudies.xls.
[4] Draft 2024 and 2028 LCR Bay Area Local, Slide 17, http://www.caiso.com/InitiativeDocuments/Presentation-Draft-2024-and-2028-LCR-Bay-Area-Local-Area-Mar92023.pdf.
[5] Consistent with Vistra’s identifying that it is the future years that need the assumptions revised, Vistra suggests for the different generation assumptions that CAISO acknowledge the actual operating conditions for 2024.
[6] Consistent with the goal to complete the Oakland Clean Energy Initiative, CAISO should assume the existing Jet-Fuel fired CTs are retired in 2026-2028 but no earlier.
[7] Consistent with the pressing need for CAISO results to show that there is a need for new resource in Oakland sub-area, it is detrimental to procurement activities to assume any batteries in Oakland sub-area unless it is for forward years where a new resource could feasibly achieve commercial operations.
[8] No battery project in development, should be 0 MW.
[9] Muni/QF cannot meet local need. Please clarify this somehow so that the generation available to meet Oakland local need does not appear that the Muni/QF can.
[10] Please confirm that our understanding that the MWh need has not changed is correct, preferably by including this in the requirement as MWh requirement.
[11] Illustrative and intending to represent that there is a full deficiency starting in 2026 assuming CTs are retired to send the signal that additional procurement is needed to cure local needs in this area with projects that achieve COD in 2025 that have deliverability rights but have yet to be procured.
[12] Vistra Corp. Comments on the 2024 Local Capacity Technical Study Criteria, Methodology, and Assumptions, November 22, 2022, https://stakeholdercenter.caiso.com/Comments/AllComments/3e2c6d79-eb22-4d85-a14b-ed93e2dbdb6a#org-57df6a1d-445e-432e-ae3b-8b6d5e583fb9.
[13] 2024 & 2028 Overall Summary of Findings – Draft 2024 and 2028 Local Capacity Requirements, Slide 3, http://www.caiso.com/InitiativeDocuments/Presentation-Draft-2024-and-2028-LCR-Bay-Area-Local-Area-Mar92023.pdf.
[14] For example, in the 2023 LCT Study CAISO identified a local need for Oakland sub-area of 35 MW. However, there is also an energy requirement of 176 MWh based on Vistra’s review of the studies. This means to meet the need there needs to be resource(s) that provide either 35MW with at least a ~5 hour continuous output or 44MW with at least a ~4 hour continuous output. Vistra requests CAISO specify the requirements with both MW (35 MW) and energy (176 MWh) for all areas going forward to address the changing RA fleet various capabilities.
