Comments on Draft final proposal

1. Please provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme (RAS) guidelines update draft final proposal, draft ISO Planning Standards (with RAS guideline updates), and December 15, 2022 stakeholder call discussion.

?AES Clean Energy appreciates the CAISO revisiting the RAS guidelines.  AES Clean Energy largely supports the revisions that eliminate redundancy with NERC PRC-012-1 standards and refine existing RAS guidelines as long as they are not applied to Centralized RAS systems.  Moreover, AES Clean Energy requests further clarification on the proposed ISO G-RAS4E as it is overly restrictive when combined with the proposed ISO G-RAS 3B.  Finally, AES Clean Energy requests CAISO to provide further information on implementing these guidelines as generation in the queue may be impacted.  More importantly, it is unclear to AES Clean if the proposed guidelines apply to Centralized RAS systems. 

2. Please provide your organizations comments on the proposed refinements to existing RAS guidelines, as discussed in section 3.2, as well as the draft ISO Planning Standards.

AES Clean Energy’s comments focus on the proposed revisions to existing guidelines and implementation for RAS systems.  The CAISO should provide further justification for the proposed ISO G-RAS4E that only allows RAS to monitor facilities no more than 1 substation beyond the first point of interconnection. During the December 15, 2022 stakeholder call, CAISO staff stated that the driving factor for this guideline is based on simplicity and communication.  However, AES Clean Energy believes that as the proposal reads, this proposed guideline is limiting and may substantially and unnecessarily increase network upgrades for interconnection projects.  The draft final proposal also proposes ISO G-RAS 3B that establishes a 10% effectiveness factor requirement for the RAS to trip load and/or resources.  Since ISO G-RAS 3B already proposes guidelines for what the RAS should monitor, adding an additional requirement is overly restrictive.   

AES Clean Energy also requests further detail on the implementation of the proposed guidelines. For example, what happens when there are more than 6 contingencies? The draft final proposal states that during the transition period, the CAISO may relax the RAS requirements to bridge long term system reinforcement.  However, it is not clear how these proposed guidelines would apply to both existing RAS and new RAS in the interconnection process. Specifically, if CAISO moves forward with ISO G-RAS4E, the CAISO should clarify if the guidelines will limit the expansion of existing RAS schemes.  AES Clean Energy continues to be concerned with the rising costs of area delivery network upgrades assigned to cluster projects.  Given that the new RAS guidelines will likely impact interconnection projects, AES Clean Energy respectfully requests the CAISO to conduct an analysis of the expected impacts of the new RAS guidelines on interconnection and delivery network upgrade costs.  The results of the analysis should be presented to the stakeholders for feedback before CAISO brings the final proposal for Board approval in February 2023. 

Importantly, the CAISO should clarify whether these guidelines would apply to Centralized RAS (CRAS) in addition to RAS.  AES Clean Energy strongly opposes applying the proposed guidelines to CRAS as its design and function are different from a RAS system. The proposed guidelines when applied to CRAS systems would result in different consequences than RAS systems.  For example, applying the proposed rule that states, “A RAS should not include logics to dynamically arm and trip various generation levels to achieve transmission facility flow objectives¹,” would directly go against the CRAS principle of being a “smart” system that mitigates a problem at a single central processor, rather than within the relays of individual RAS systems.  Instead, the CAISO should articulate the trigger point for CRAS conversion from RAS within this initiative. The CAISO should then initiate a new policy initiative to discuss CRAS implementation and potential guideline updates. 

1. Draft Final Proposal, p. 8 

3. Provide any additional comments on the Planning Standards – RAS guidelines update draft final proposal, draft ISO Planning Standards and December 15, 2022 stakeholder call discussion.

?AES Clean Energy has no further comments. 

1. Please provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme (RAS) guidelines update draft final proposal, draft ISO Planning Standards (with RAS guideline updates), and December 15, 2022 stakeholder call discussion.

San Diego Gas & Electric Company (SDG&E) appreciates the opportunity to provide comments on the California Independent System Operator (CAISO) “Planning Standard - Remedial Action Scheme (RAS) Guidelines Updates” draft final proposal.  

SDG&E is generally supportive of some of the updates proposed by the CAISO. SDG&E believes that most of these updates (1) align and complement the North American Electric Reliability Corporation (NERC) Reliability Standards (2) will make RASs less complex to design and operate, (3) and will also make RAS design criteria more transparent to stakeholders. SDG&E would like to also commend the CAISO for refining its latest proposal with the inclusion of “monitoring facilities no more than one substation beyond the first point of interconnection” as well as the inclusion of the “maximum interconnection service capacity”.  

However, SDG&E notes that the proposal is still missing key aspects that are making it challenging for SDG&E to support the approval of the proposal by the CAISO Board of Governors. SDG&E offers the following specific comments to help CAISO further refine its latest proposal and gain broader support from stakeholders and the Board:

2. Please provide your organizations comments on the proposed refinements to existing RAS guidelines, as discussed in section 3.2, as well as the draft ISO Planning Standards.

1. CAISO needs a RAS Standard and not Guidelines.  

CAISO asserts that RAS guidelines G-RAS3, G-RAS4, and G-RAS6 need to remain guidelines because “RAS implementation is a complex process that requires consideration of many factors, thus designating those as standards is not appropriate at this time”. SDG&E finds CAISO’s response to stakeholders’ feedback here to be unclear and concerning. First, CAISO’s proposal can only become meaningful if the CAISO makes guidelines G-RAS3, G-RAS4, and G-RAS6 standards. The reason some of the current RASs in service in the CAISO system do not follow CAISO’s previously established guidelines is because they were guidelines and not standards. Second, SDG&E believes that the CAISO has had robust technical discussions, over the past 18 months, with stakeholders and has built enough record in the public space that warrants the change of the proposed guidelines to standards as it is customary in other technical forums such as NERC or IEEE. In other words, SDG&E is not aware at this stage of critical unknowns that should prevent the proposed guidelines from becoming standards. As such, SDG&E encourages the CAISO to further vet SDG&E’s recommendation as part of its final proposal to move G-RAS3, G-RAS4, and G-RAS6 to standards. Finally, to the extent the CAISO and stakeholders find it necessary to deviate from the standard on rare occasions, the CAISO will have broad authority under G-RAS7 to make exceptions when needed.  

3. Provide any additional comments on the Planning Standards – RAS guidelines update draft final proposal, draft ISO Planning Standards and December 15, 2022 stakeholder call discussion.

2. A list of RASs that do not meet current and future CAISO requirements should be published annually.  

CAISO should maintain a tracking system of which RAS, both Pre and Post standard update, meet the Standards and Guidelines. This list will help CAISO and stakeholders ensure that requirements are applied in a consistent fashion across the CAISO footprint, and it will also help identify if future enhancements to the Standard are needed. 

3. G-RAS 7 should include a defined timeline.  

G-RAS7 should have language added which instates a timeline for relaxing the RAS requirements. As an example, relaxing of the RAS requirements as a “bridge” to system reinforcements should have a defined timeline. The timeline should meet a reasonable project schedule to reinforce the transmission system, but shall not exceed 10 years. This will ensure that interim measures do not inadvertently become permanent solutions. 

4. G-RAS 4 number of contingencies should be further reduced.  

SDG&E would also like to see the acceptable amount of monitored contingencies (P1-P7) reduced from 6 down to 4, which would coincide with the allowable number of system elements. To date the CAISO has been unclear on why more elements (6) is better than (4) elements when the goal is to make RASs less complex. Furthermore, if more contingencies are needed, under G-RAS7 the CAISO will have broad authority to recommend more elements on a case-by-case basis. 

5. A grandfather clause should be included in the CAISO Planning Standard. 

SDG&E continues to suggest that the CAISO includes a grandfather exemption for existing RASs as part of the Standard. This will make it clear to stakeholders that the new or updated requirements will only apply to new RASs moving forward.