Comments on final proposal

1. Please provide a summary of your organization’s comments on the Variable Operations and Maintenance Cost Review 2023 stakeholder meeting.

SRP appreciates CAISO’s efforts in incorporating stakeholder comments into the final proposal, including proposing to use a more recent inflation adjustment reference point as proposed by SRP.

However, CAISO declined to adopt the forward-looking indicator due to the uncertainty of future inflation rates, and declined to review default VOM adders more frequently, noting that the negotiated option exists if default values are inadequate.  SRP requests clarification and assurance regarding the use of the negotiated option for inflationary adjustments.

The negotiation process for inflationary adjustments is not a full negotiations process that requires extensive documentation for cost support.  SRP would like to understand that if SRP deems an inflation adjustment is necessary on a default VOM adder, that SRP can request such adjustment based off the inflation calculations from the Bureau of Economic Analysis.

In short, SRP would simply like to provide information supporting an inflation of the default VOM adders in between triennial reviews which would be unrelated to the renegotiation of a particular resource.  SRP would deem the default value from the triennial review adequate but due to the amount of time in-between reviews, an inflation increase may be needed on the Default value(s).

2. Please provide your feedback on the CAISO’s proposed default variable and operations maintenance adder values, as described in the final proposal.

No comment

3. Please provide any redline changes and embedded comments your organization may have on the Variable operations and maintenance cost review 2023 draft tariff language as an attachment to this comment template, and provide any additional comments in the text box below.

No comment