Comments on Capacity Procurement Mechanism Enchancements - Revised draft final proposal

1. Please provide a summary of your organization’s comments on the CPM Enhancements Track 1 revised draft final proposal

The California Community Choice Association (CalCCA) thanks the California Independent System Operator (CAISO) for adopting its recommendation to allow conversions of exceptional dispatch or significant event Capacity Procurement Mechanism (CPM) capacity to Resource Adequacy (RA) capacity if a resource enters into an RA contract with a California Load Serving Entity (LSE) after being designated as CPM capacity. This will ensure the CAISO backstop does not usurp LSEs’ abilities to meet their RA obligations, while also ensuring the capacity retains its must-offer obligation (MOO) and remains available to serve CAISO load.

CalCCA supports the CAISO’s Revised Draft Final Proposal.

2. Please provide specific comments (if applicable) on proposal 4.1

CalCCA has no additional comments.

3. Please provide specific comments (if applicable) on proposal 4.2

CalCCA has no additional comments.

4. Please provide specific comments (if applicable) on the proposed classification of the stakeholder initiative as described in chapter 6

CalCCA has no additional comments.

1. Please provide a summary of your organization’s comments on the CPM Enhancements Track 1 revised draft final proposal

PG&E requests additional clarity on how new capacity obligations will be made during the significant event and exceptional dispatch CPM timeline.

2. Please provide specific comments (if applicable) on proposal 4.1

PG&E requests the CAISO clarify Proposal 1 and explain how new obligations would be made during the significant event and exceptional dispatch CPM timeline. CAISO’s proposal will allow significant event and exceptional dispatch CPM designated capacity to take on new RA obligations. However, CAISO has also indicated that “new RA obligations” must be shown to the CAISO as RA capacity through the regular showing process. This proposed change should be considered within the context of the following:

• The regular showing process locks RA and Supply Plans at T-30.
• Significant event and exceptional dispatch CPMs typically occur after the T-30 deadline.
• During the stakeholder call, CAISO indicated designated capacity could not be used for outage substitution.

Considering this, PG&E requests the CAISO provide examples of how this flexibility could be used. Is CAISO’s proposal for LSEs and SCs to leverage a good cause request (BPM page 35) to enable an SC to take on a new RA obligation? 

3. Please provide specific comments (if applicable) on proposal 4.2

PG&E has no additional comments on proposal 4.2 at this time.

4. Please provide specific comments (if applicable) on the proposed classification of the stakeholder initiative as described in chapter 6

PG&E has no comments at this time.

1. Please provide a summary of your organization’s comments on the CPM Enhancements Track 1 revised draft final proposal

Vistra supports the CAISO’s proposals to enhance its Capacity Procurement Mechanism (CPM) processes included in Track 1.

Vistra is concerned that there is an increased risk of an annual CPM being triggered as result of a collective local or collective system deficiency as result of Central Procurement Entity solicitation failing to meet its local procurement obligations in the Pacific Gas & Electric area. We support the CAISO proposal to clarify that significant event CPMs, similar to existing authority for exceptional dispatch CPMs, can have its CPM capacity reduced in future months if the CPM resource is shown for RA. We believe the same flexibility needs to be afforded to annual CPM designations for collective deficiencies if the resource can be contracted for Resource Adequacy during the year. Vistra does not find it compelling or appropriate that the CAISO should prohibit this practice for RA showing deficiencies. Vistra requests the CAISO remove the prohibition to apply this to RA showing deficiencies from its proposal, and allow it be applied to annual CPM designations cured intra-year.

Vistra again reiterates its request for CAISO to pair its proposal to extend the market notice deadline for CPM designations with a revision to its Operating Procedure 2330[1] to include a step that the CAISO Generation Desk issues a market notice prior to issue a significant event exceptional dispatch. This is different than the proposed market notice with a CPM designation but consistent with the OP 2330 step that has the CAISO Gen Desk, “Sends Market Notices prior to dispatching Legacy RMR units for reasons other than local area mitigation through an ED.”[2]

Looking forward, we are excited to move to Track 2 of this effort to begin to look more holistically at CPM enhancements. We strongly support Track 2 scope considering enhancements to the CPM soft offer cap and CPM FERC cost recovery review eligibility for offers above the soft offer cap. In addition, we also request the CAISO include in Track 2 scope additional flexibility to reduce CPM volume or the CPM term after a CPM designation has been accepted even for collective deficiencies if it declines to adopt this change in Track 1.

[1] See Operating Procedure 2330, Real-Time Exceptional Dispatch, http://www.caiso.com/Documents/2330.pdf.

[2] Id at Page 2.

2. Please provide specific comments (if applicable) on proposal 4.1

See above.

3. Please provide specific comments (if applicable) on proposal 4.2

See above.

4. Please provide specific comments (if applicable) on the proposed classification of the stakeholder initiative as described in chapter 6

Vistra supports the CAISO proposed designation as California RA issues are out of scope of joint authority.