Comments on Discussion paper

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

Brightline Defense Project (“Brightline”) is an environmental justice organization which supports equity in California’s energy and transmission development process and procedures. Brightline has been deeply involved in avoiding adverse impacts to California’s disadvantaged, low-income, and frontline communities. 

In response to the Greenhouse Gas (GHG) Coordination working group discussion paper, we offer the following high-level comments regarding principles and issues to consider for problem statement formation: 

Equity through procedural and transformational decision-making

The ISO should expressly adopt environmental justice as a key principle in the GHG Coordination working group. This includes procedural equity protections that can be included in the transparency principle as well as in the formulation of problem statements. Clear policy direction not only informs utilities, but also advocates. Procedural equity can also support advocates engaging in other related ongoing policy initiatives at the ISO and other state programs.

Furthermore, the equity considerations should aim to bring transformational change and benefits to California’s disadvantaged, low-income, and frontline communities in accordance with SB100’s mandate and CAISO’s adoption of this mandate into its Strategic Plan and Values Statement. GHG emission tracking and accounting should consider the disproportionate impacts borne on historically disadvantaged communities. This focus should especially highlight communities identified by state air regulators as disproportionately impacted due to proximity to air polluting facilities. 

Complexity of bringing new renewable energy sources should be considered in problem statement formation

Brightline understands the intention of the proposed non-discrimination principle but urges the ISO to consider and balance California’s renewable energy goals, non-monetary costs of GHG pricing policies, and upcoming renewable energy development. The complexity of new renewable energy sources, such as offshore wind, will need to be balanced in the GHG Coordination working group problem statement and principles. Offshore wind and other new renewable energy sources have the potential to power over 25 million California homes but have intrinsic complexities in market design, energy delivery, transmission infrastructure planning, and interconnection. The scope of discussion should weigh mechanisms and linkages between bringing new renewable energy sources online, other compliance obligations, and current GHG pricing policies. 

Brightline appreciates the opportunity to submit comments in response to the GHG Coordination working group discussion paper. With consideration of these high-level comments, Brightline looks forward to further engagement with the ISO on this matter.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

Brightline does not have any comments regarding deliverables and action plans at this time but reserves the right to comment at a later time.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

See Brightline’s response to previous comment sections.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

See Brightline’s response to previous comment sections.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The California Municipal Utilities Association (CMUA) supports the California Independent System Operator (ISO) undertaking this pre-initiative working group process. The ISO has an important role that extends beyond serving as the electricity market operator. We anticipate that as new policies are developed, states will look to the ISO to evaluate the impact of considered policies on grid reliability, resource adequacy, and the electricity market. CMUA encourages the GHG Coordination Working Group (Working Group) to explore additional potential roles within the working group process.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

CMUA supports the high-level process as outlined in the Discussion Paper and looks forward to further engaging with the Working Group.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

CMUA welcomes the opportunity to review ISO market operations and the current GHG market design. CMUA encourages the Working Group to address improved coordination with the California Air Resources Board (CARB) to promote efficient dispatch that accurately recognizes the GHG emissions of dispatched resources and proper attribution of actual GHG value. CMUA is concerned that this is not currently always the case. To this point, CMUA supports a discussion around the load-based accounting proposal as suggested in greater detail in the comments submitted by the Los Angeles Department of Water & Power. 

There is a need for greater information transparency to inform market participation and for verification of market data by market participants and state regulators. Ensuring accurate and transparent integration of GHG emissions with electricity market design will become increasingly important as California shifts into a new market design with increased transaction volumes and increased use of energy storage technologies.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

CMUA agrees that these principles provide a good starting point. CMUA suggests that the Working Group consider how the principles coordinate. For example, non-discrimination is key to market efficiency. Transparently incorporating all information into market prices is key to non-discriminatory market behavior. Additionally, while market efficiency is often considered paramount, irrespective of a market design’s efficiency, if the market solution is not feasible then it is unreasonable to pursue.

Additionally, the Working Group should include GHG accounting accuracy as a principle. Inaccurate GHG accounting can increase costs for California’s electricity customers and can also create incentives that are inconsistent with both the state’s clean energy policies and optimal resource allocation.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

CMUA looks forward to further engaging with the Working Group throughout this stakeholder initiative.

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

We have comments on how the working group topics and 6 proposed principles incorporate avoiding double counting of emissions generation attributes, achieving accurate and exclusive retail GHG claims, and maintaining the integrity and impact of existing REC systems and programs.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

None

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

Regarding topic 4 (beyond GHG pricing policies), what types of non-priced policies will be included? Are there certain types of programs or programs with certain elements that are assumed not to be affected or outside of the scope? For example, other venues have limited conversations about solutions/approaches for non-priced policies to “GHG cap” programs without pricing (or "source-based” or “generation-based" GHG programs), as oppsoed to "load-based" programs that require tracking emissions from generation to load. In that case, those approaches would not apply to certain clean energy programs in WA or CA. One reason provided for excluding these load-based programs is that they tend to have an "out-of-market solution” already, e.g. RECs. Will this working group consider solutions and market design elements to support load-based GHG policies, including those that use RECs? We recommend that it should. The distinction between programs that regulate emissions from electricity delivered to load or the state (that require tracking and allocation) and those that just regulate emissions from sources (as a rate or mass, within a geographic boundary), is important with respect to whether and how they’re accommodated in the market. 

In the previous survey, we suggested the following topics for discussion. We see them as generally falling under "emissions tracking and accounting" to "acknowledge the role of contract accounting" and also "out-of-market solutions," instruments, claims, etc., as well as under "beyond GHG pricing policies," and specifically "load-based programs," and "state coordination," specifically "regional coordination."

o    How to avoid double counting of emissions generation attributes and maintain exclusive retail claims with GHG attribution in ISO markets.
o    The effect of GHG attribution in ISO markets on existing REC systems and state programs.
o    Dissemination or data coordination with WREGIS regarding resource-specific GHG attributions to states/zones in ISO markets for resources registered in WREGIS.
o    How RECs could be used to report specified market purchases.
o    How entities with obligations under state programs to deliver specified power to customers or to report emissions associated with power delivered to customers (particularly where state rules account for delivered energy, tie attributes to energy, or require “bundling”) can participate in the market.
o    Potential benefits of all-generation certificate tracking and uses for reporting transacted power in ISO markets.
o    Generally, calculating the emissions to assign to market purchases by different entities.
o    Generally, how tools and information for tracking and verifying the delivery of specified power to state or utility load can be used and harmonized to maintain credible retail transactions and claims, avoid double counting, and facilitate achievement of regional and state goals.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

We recommend that "simplicity" and "feasibility" both include using existing systems and instruments for tracking generation and emissions where available.

We recommend that "transparency" include providing emissions data, not limited to overall system emissions, in different temporal and geographic granularities to the extent possible/practical, as well as different emissions metrics (dispatched vs. purchased generation, residual vs. average, reflecting resource-specific attributions vs. not). Transparency also includes explanations of emissions data and metrics and what they represent for consumers, how they can be used by consumers, and how they can be reported to consumers by utilities. Importantly, transparency also includes data sharing about resource-specific attribution in the market, e.g. sharing with the WREGIS, i.e. transparency about what emissions/generation have been/are being attributed in the market, so that state and other programs can use that information for their programs to avoid double counting and consider that in the context of their own accounting rules. Finally, transparency includes providing information about how attribution solutions work and relate to other mechanisms/instruments for attribution of generation to load (e.g. REC tracking systems). 

We recommend that "non-discrimination" include accurate residual mix emissions accounting.

We recommend that "jurisdictional roles and responsibilities" include market design to support, or in alignment with state policy, e.g. state-recognized compliance and tracking instruments and accounting rules. CAISO’s role is providing data and facilitating coordination/sharing to support harmonization of accounting/attribution across the region. But it is also market design to facilitate state and utility goals and tracking and reporting requirements. That means resource-specific attribution mechanisms and rules in particular that do not harm or undercut “harmonization” or create inconsistency in terms of accounting and attribution, e.g. by attributing in different ways to different regions or by attributing in a way that ignores or makes it difficult to use existing market instruments (e.g. RECs and other certificates).

Other pricinples were discussed at the Aug 16 working group meeting as well, including "minimizing leakage" as its own principle. Since leakage is relative to an individual state’s policy or accounting, this additional principle could be more broadly envisaged as comprehensive regional emissions accounting that does not double count, so that leakage of emissions (with respect to any individual state’s policy or emissions attribution) can be measured and located, and then the state’s policy can address that leakage if deemed necessary and determined to be cost effective. This may represent a new "accuracy of attribution" principle, but it also potentially fits under transparency, non-discrimination, and jurisdictional roles principles. Now that wholesale markets are doing resource-specific attribution to state or zonal load in the market, there may be a need for a principle about or that includes the accuracy of attribution, i.e. no double counting generation/emissions; do no harm to existing markets and market instruments; and maintaining exclusive resource-specific retail usage/delivery claims.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

LADWP appreciates CAISO forming the GHG Coordination Working Group, surveying the stakeholders, preparing the discussion paper, and hosting the working group meetings.

LADWP was encouraged to see the statement in the discussion paper regarding “focus on possible future GHG accounting design(s) evolution including potential enhancements to the current EDAM design”. LADWP presented an alternate approach to GHG emission accounting during the 2022 EDAM design stakeholder process, and looks forward to discussing our proposal as a possible future GHG accounting design for the market.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

The working group process should include discussions with state regulators. Exploring alternate approaches to market GHG emission accounting would help identify regulatory changes needed to enable more accurate GHG emission quantification/reporting and reduce compliance costs.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

LADWP agrees with the proposed topics listed above for the working group to address. Compatibility of the market design with the environmental policies and rules of different states, such as GHG emission reporting, cap-and-trade compliance, GHG emission reduction goals, renewable energy portfolio standards, and clean energy standards, is especially important.

LADWP recommends the working group also focus on the cost of electricity in the market, since maintaining a reliable and affordable electricity supply is essential for public safety and to support electrification, which will help states achieve their GHG emission reduction goals.

In addition, LADWP recommends the working group focus on how to eliminate GHG emissions leakage (secondary dispatch) associated with electricity transfers from a non-GHG zone (state/jurisdiction without GHG regulation) into a GHG zone (state/jurisdiction with GHG regulation).

• Currently California electricity ratepayers bear two GHG costs associated with purchasing electricity from the EIM market: 1) $/MWh in the price of electricity (intended for the generator to purchase and retire GHG emission allowances for cap-and-trade compliance), and 2) California Carbon Allowances withheld from California Electrical Distribution Utilities’ allocation and retired to satisfy the EIM Outstanding Emissions compliance obligation. The purpose of the EIM Outstanding Emissions is to account for GHG emissions leakage due to secondary dispatch that is not included in the EIM deemed-delivered imports to California, in order to maintain the environmental integrity of California’s GHG emission cap-and-trade program. Paying GHG cost in the price of electricity purchased from the market plus losing allowances to cover leakage drives up the price of electricity in California. Eliminating GHG emissions leakage would reduce GHG costs to California ratepayers by eliminating the need for the EIM Outstanding Emissions compliance obligation.

• Evaluate the feasibility and benefits of alternative approaches to market GHG emissions accounting such as the LADWP proposal. A load-based rather than generator-based approach to GHG emissions reporting and compliance could provide comprehensive accounting of GHG emissions associated with electricity imports to a GHG zone and eliminate emissions leakage. Eliminating emissions leakage would enable GHG regulators to eliminate leakage back-stop measures such as CARB’s EIM Outstanding Emissions calculation and its additional GHG compliance cost to retail electricity customers.

• Load-based accounting seeks to solve the leakage issue and provide comprehensive and accurate GHG emissions accounting by capturing GHG emissions from the incremental dispatch of non-GHG zone generating resources to support the transfer of electricity into a GHG zone. A GHG intensity factor for the aggregate of dispatched generating resources can be calculated after-the-fact and applied to the electricity imported into a GHG zone.

• Load-based accounting seeks to eliminate incorrect deeming that does not capture GHG emissions from the actual dispatch of generating resources to support the transfer of electricity into a GHG zone.

• Load-based accounting proposes to shift the First Jurisdictional Deliverer (FJD) GHG emissions reporting and compliance responsibility from the non-GHG zone generator to the GHG zone electricity purchaser (load serving entity). 

• GHG emissions should not be treated as a market commodity. GHG compliance is a carbon tax on GHG emissions, not something that market participants should profit from. LADWP recommends that the market operator insert a GHG bid adder for each participating generating resource for dispatch purposes only, not for settlement. With the larger volume of transactions for a day-ahead market, allowing market participants to profit from the GHG price could significantly impact the cost of electricity to customers in the GHG zones. Maintaining affordable electricity is important to help the GHG zones achieve their emission reduction goals.

• All generating resources should have separate energy bids and GHG bids so that GHG revenue collected can be distributed to entities that have an actual GHG emission compliance obligation, including load serving entities that purchase electricity from the market to serve their customers.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

LADWP recommends adding a principle to strive for accuracy in GHG emissions accounting.

Transparency in GHG emissions accounting is important for verification of data by market participants and state regulators. Monthly invoices should include MWh sold by generating resource and MWh purchased at each load node for transparency and GHG emission reporting and verification purposes.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

LADWP looks forward to participating in the working group process, and discussing our ideas to improve the accuracy of market GHG emission accounting and reduce GHG costs to our retail electricity customers.

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The Oregon Public Utility Commission and Oregon Department of Environmental Quality (the “Oregon Agencies”) respectfully offer these comments on the CAISO Extended Day-ahead Market (EDAM) GHG Coordination Working Group Discussion Paper dated August 3, 2023. The Oregon Agencies are responsible for protecting the public interest and ensuring the effective implementation of Oregon’s GHG emissions reduction mandate.

Need to accommodate non-price GHG regulation

The Oregon Agencies very much appreciate that CAISO has established this GHG Coordination Working Group (“Working Group”) to follow up on its commitment to explore how EDAM can evolve to accommodate the array of western climate policies. It is appropriate that CAISO has focused early EDAM design efforts on accommodating California and Washington’s price-based GHG regulations. It is now appropriate for CAISO and prospective EDAM participants to explore how EDAM can accommodate non-price-based GHG regulation in the near future. Four western states, including Oregon, have adopted non-price-based GHG regulation that requires utilities to reduce GHG emissions by increasing amounts over time. Oregon statute requires Portland General Electric and PacifiCorp to serve their Oregon electric load with 100 percent zero-emission electricity by 2040. These utilities will need to be able to demonstrate to the Oregon Agencies their compliance with the emissions reduction mandate while participating in a day-ahead market.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

The Oregon Agencies agree with the comments submitted by the Washington Agencies that support the proposed working group process and encourage a cadence appropriate for stakeholders and regulatory agencies:

[W]e encourage CAISO to ensure sufficient time for discussion at each step in the process, particularly during the analysis component. Stakeholders and regulatory agencies may need to revisit problem statements and principles in light of new information. ... It is our experience that it takes significant time to illustrate, discuss, and iterate problem statements on an issue as complex as GHG accounting.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

“Beyond GHG Pricing Policies” topic area is of high importance

The Oregon Agencies support the four discussion topic areas described in the Discussion Paper:

1. Review of ISO Market Operations and GHG Design
2. State Coordination
3. Emissions Tracking and Accounting
4. Beyond GHG Pricing Policies

At the August 16 Working Group meeting, stakeholders were asked in an online poll to prioritize these four topic areas. The fourth topic, “Beyond GHG Pricing Policies”, was ranked with the lowest priority. The Oregon Agencies are concerned that CAISO may interpret that low priority ranking as the topic being of low importance to stakeholders. We caution against that. It is clear from the survey results presented in the Discussion Paper’s Appendix that addressing non-price-based emissions reduction policies (a subtopic under the “Beyond GHG Pricing Policies” topic) is of great importance to the stakeholders. We believe that stakeholders prioritized the first three topics because they are educational in nature and will help establish common understanding of how GHG policies interact with market design. This common understanding will then help stakeholders work collaboratively to explore and review market design options to accommodate market participants’ compliance with state non-price GHG regulation.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

Principles should emphasize benefits to end-use customers

The Oregon Agencies offer the following comments on the draft principles, as described in the August 16 Working Group meeting presentation. We recommend that the descriptions of the principles be added to the Discussion Paper for clarity.

• The Oregon Agencies emphasize the first principle, “Efficiency”, because it relates to optimizing dispatch to minimize production cost. Reducing costs paid by electricity customers is a priority for state regulators. Reducing costs becomes even more important for Oregon as our climate policies drive new and expanded uses of electricity.
• The principle of “Simplicity” should be eliminated and instead incorporated into the principle of “Feasibility”. While we agree that the workgroup should avoid unnecessarily over-complicating the market design, the complexity of a design solution needs to be weighed against its potential benefits, particularly to end-use electricity customers. Maintaining a principle of simplicity could be used as a rationale not to explore more complex solutions that may be needed to accommodate states’ various GHG policies. Such solutions should be explored, and their complexity should instead be considered as an element of feasibility.
• The “Transparency” principle should include ensuring that sufficient information is provided for market participants to comply with state GHG regulation.
• The description of the “Non-discrimination” principle should be edited to include the regulatory principle of cost causation: “No inappropriate or unacceptable GHG or cost impact on a non-GHG regulation area or resource.”

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

During the EDAM design process, the CAISO dedicated a process to stakeholders to further enhance the EDAM GHG design after operational experience is gained after implementation. As noted in the Brattle study, the EDAM design paved a way for peak reductions of GHG emissions not only within the EDAM footprint, but ultimately across the entire Western interconnect. As a multijurisdictional entity, PacifiCorp recognizes the willingness of the CAISO to host an array of workshops aiming to reach a level of understanding of coordination across the West. PacifiCorp is differently situated with a set of six regulators with varying compliance programs. It is PacifiCorp’s understanding that these workshops will be part of an iterative process. Given that, throughout the workshop series, PacifiCorp recommends the CAISO obtain regulator engagement to aid in tackling the essential “chicken-and-egg” problem that naturally has come to light in the GHG space. Regulatory attendance at these workshops will move the ball forward as we embark on tackling the complex issues that occur from compliance frameworks that exist both within and outside of the market.

Specifically, PacifiCorp urges the CAISO to include air regulators in California and Washington (California Air Resource Board and Washington Department of Ecology) along with air and utility regulators, such as Washington Utilities and Transportation Commission, in states that have a non-price based GHG/clean energy policy (i.e., Oregon’s House Bill 2021) as air regulators and Oregon Public Utility Commission are both involved in ensuring Oregon emissions reduction policies are enabled. Additionally, PacifiCorp finds value in the potential for CARB to present the thought process regarding EIM treatment that is in place today. PacifiCorp believes doing so would be consistent with the Federal Energy Regulatory Commission’s Policy Statement, Carbon Pricing in Organized Wholesale Electricity Markets (issued April 15, 2021), 175 FERC ¶ 61,036[1]. Moreover, as a multijurisdictional entity, PacifiCorp is subject to six sets of regulators and would greatly appreciate a level of guidance or thought process as to how the compliance framework will work and how the cost-based, allocation-based, compliance framework will be affected. PacifiCorp echoes sentiments made at the working group where the community shouldn’t let perfect be the enemy of the good and that evolution and enhancement should be expected within regulatory parameters that exist today.

PacifiCorp comments on the following:

• Overall support for the deliverables and action plan while noting PacifiCorp’s view on what the problem statement is.
• Supports the working group topics and further refinement of stakeholder understanding of the complex compliance frameworks in California, Washington, and Oregon.
• Generally supports the working group principles.

[1] https://www.ferc.gov/media/ad20-14-000-041521

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

PacifiCorp supports the GHG Coordination working group process which is organized by undertaking problem statements and principles, prioritization, and analysis. It is important to spend time crafting problem statements so there can be a better solution regarding market mechanics and clean energy compliance. Each utility may define problem statements differently. PacifiCorp spoke to what we believe the problem statement to be within our submission for the CAISO GHG survey that was due June 30, 2023, which read the following:

Multi-state utilities with BAAs that overlap GHG zones can pose challenges to accounting for total GHG attributed to states with and without GHG programs. Focusing on energy flow between load in a state and resources located geographically in the state may oppose GHG and clean energy accounting otherwise adopted by state regulators. Can market data be informative to existing accounting schemes without creating a new accounting framework that is disjointed from existing practices?

PacifiCorp is very appreciative of the CAISO’s dedication to host additional workshops and potentially altering the market design to accommodate future enhancements with appropriate data and input from the regulators and stakeholders. 

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

PacifiCorp supports the ISO market operations and existing market design as written and extends gratitude for the flexibility to host additional sessions on this technical issue and the topics that are outlined during the GHG Coordination working group. As far as State Coordination is concerned, PacifiCorp recommends the CAISO include a walkthrough of the differing GHG reporting and compliance requirements in all states impacted within this topic (i.e., California, Oregon and Washington). Regarding emissions tracking and accounting, PacifiCorp views this topic to be consistent with the transparency principle. From a compliance reporting perspective, PacifiCorp would like additional clarity as to what data will be provided, the cadence of said data, and to whom the data will be provided. Is reporting emissions “beyond what is available for the purposes of reporting and compliance with state regulations” feasible? Is this a policy related to wants beyond compliance needs? PacifiCorp questions the amount of administrative burden and potential of reporting delivery data that is not reflective of the compliance framework. Lastly, on the topic that is beyond GHG pricing policies, PacifiCorp views this topic to be extremely valuable to level set as the CAISO’s potentially subject to supply data to support House Bill 2021 and Clean Energy Transformation Act.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

PacifiCorp generally supports the working group principles so long as there is a common understanding between participants and further refinement from the stakeholder community.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

 No additional comments.

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

PGP supports the overall framework proposed and appreciates the CAISO’s institution of the GHG working group in response to stakeholder feedback as a good way to begin to address specific issues on a proactive basis.  PGP suggests some additional refinement on the scope of the data needs and ‘beyond GHG pricing policies’ issues.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

PGP supports the overall framework proposed.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

PGP supports the topics identified and does not have any other topics to suggest.  PGP recommends that the working group tackle these topics sequentially beginning with data needs (referred to as emissions tracking and accounting above) followed by review of ISO market operations and existing GHG market design. 

With respect to the data needs topic, PGP suggests that the focus of the working group should be on the development of more robust and granular emissions related data so that market participants and stakeholders can have a better view of emissions and emissions trends within the EIM/EDAM footprint.  PGP recommends that the CAISO explore the potential benefits of and development of hourly marginal and average emissions rate data as is provided in other RTOs such as PJM.

With respect to the “Beyond GHG Pricing Policies” topic, PGP recommends careful consideration of scoping and phasing of this issue. Though supportive of discussion on reporting issues and unspecified rate development, PGP’s perspective is that this topic is likely to raise issues beyond the currently suggested problem statement. In the context of the development of the Southwest Power Pool’s Markets+, it has been suggested that a market design solution is needed to reflect non-pricing programs into the market dispatch.  If such a market design element is applied broadly, it could significant impacts to the market in terms of dispatch and price formation and could raise novel issues before the Federal Energy Regulatory Commission. The working group should focus its efforts on an initial scoping and discussion of this issue but recognize that it is likely to ultimately need a separate stakeholder process.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

PGP supports the suggested principles. 

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

PSE supports the procedural approach outlined in the August 2, 2023 Discussion Paper, and suggests the CAISO update the discussion paper and post clean versions to the website to reflect the key decisions and action items made in working group meetings. CAISO should consider options on how to bring action plans developed in working groups before the joint governing bodies.

The topic of state coordination is woven throughout each of the other three topics -

Review of ISO Market Operations and Existing GHG Market Design, Emissions Tracking and Accounting, and Beyond GHG Pricing Policies. PSE suggests rather than having state coordination as a separate topic, CAISO look at each topic through the lens of state coordination and include a subtopic within each topic to capture what coordination is necessary within that topic, what information, data, or guidance would CAISO need to provide the state, and what information, data, or guidance would it need in return.

PSE suggests that the working group should consider additional sub topics to emissions tracking and reporting that build up as parts of the whole topic including: the state policies of western market participants, market optimization and GHG attribution, and reporting and metrics.

The CAISO should add “durability” to the list of GHG coordination working group principles to prompt consideration of future market evolutions.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

PSE supports the procedural approach proposed by CAISO in its August 2, 2023 Discussion Paper of memorializing working group notes, key decisions, and action items in an ongoing Discussion Paper document. In order to maintain a document that is clean and readable, the CAISO might consider posting a clean version of the Discussion Paper after each meeting with items from that meeting integrated, and maintaining prior versions on the working group site so stakeholders can refer to prior versions, if needed. The CAISO should consider summarizing the changes made from the previous version of the discussion paper in an appendix to create a clear record of how discussion and decisions have impacted the paper.

PSE also supports the development of an Action Plan reflecting the final outcome of the working group process.

Absent a formal governance structure, the CAISO should clarify how it will measure and reflect stakeholder consensus on issues in the Discussion Paper and Action Plan. CAISO should also clarify how and where the Action Plan fits into the joint governance model. As this issue pertains broadly to both WEIM and CAISO market participants – as well as future EDAM participants – PSE does not see an obvious existing forum for bringing these issues before the joint governing bodies. CAISO should consider what options are available within the current joint governance model for a WEIM-EDAM-CAISO stakeholder body with advisory authority to bring this Action Plan and future Action Plans developed in CAISO’s enhanced stakeholder process before the joint governing bodies.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

The discussion paper’s proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies. PSE provides these comments on the working group topics:

PSE agrees with the need to review ISO market operations and existing GHG design so the working group is all starting from the same understanding.

The topic of state coordination is woven throughout each of the other three topics - Review of ISO Market Operations and Existing GHG Market Design, Emissions Tracking and Accounting, and Beyond GHG Pricing Policies. PSE suggests rather than having state coordination as a separate topic, CAISO look at each topic through the lens of state coordination and include an action item within each topic to capture what coordination is necessary within that topic, what information, data, or guidance would CAISO need to provide the state, and what information, data, or guidance would it need in return. This practice would also provide flexibility on when and how state agencies engage with this group as they may be limited at times in how they can engage. Additionally, this approach would allow stakeholders and CAISO to work together to determine the ISO’s role with respect to the state agencies.

With respect to emissions tracking and accounting, PSE sees this as having various subtopics that build upon each other:

Cataloging state policies of western market participants

This topic should include a discussion and catalog of the various state clean energy and emissions programs with which the EIM/EDAM entities must comply. This will help stakeholders understand the various constraints under which market participants will evaluate a market solution.

Market optimization and GHG attribution

This topic should address how resources may be attributed to serving load in and out of a GHG zone and how GHG transfers are settled. This topic should also include a discussion about the unspecified emissions rate. The working group should consider the application of various factors such as average, default, marginal, and residual market emissions.

Beyond GHG pricing policies

With respect to the beyond GHG pricing policies topic, PSE believes this subtopic belongs under the emissions tracking and accounting topic as well, as it is one flavor of an emissions-reduction program the market design should consider.

Reporting and metrics

This topic should address the data the ISO currently provides or is able to calculate as well as additional data or calculations that may be necessary for compliance or may provide transparency benefits to the market and states. The ISO’s “Today’s Outlook” page contains a view of the emissions deemed to serve ISO load. Similar data could be made available for the emissions associated with energy serving other EIM or EDAM entity load, emissions rate of the marginal resource, and emissions associated with exported energy. PSE also agrees with the August 16 comments from the Sacramento Municipal Utility District that look-ahead data regarding resources that are already committed vs. data about residual supply in the market will be important for market participants. This data can provide visibility into the reasonableness of GHG attribution, help utilities develop operational strategies for meeting clean energy mandates, and may also provide opportunities for clean technologies to participate in the market and support utility and customer decarbonization objectives. As a group, we should discuss and consider the appropriate time and locational granularity that appropriately balances these benefits with the need to ensure information does not create anti-competitive outcomes.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

The discussion paper’s proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

Efficiency, simplicity, transparency, and feasibility are important core principles against which the working group can very likely evaluate solutions for most of the issues at hand. PSE believes the Jurisdictional roles and responsibilities principle may be a misnomer and suggests renaming this principle to “congruency with state policy”. This principle can be reflected, as mentioned above, by including state coordination as an element in each of the working group topics.

With respect to non-discrimination, PSE prefers a principle of “competitive participation of resources inside and outside a GHG zone”. As mentioned by the Regulatory Assistance Project in the August 16 meeting, state policies implicitly create constraints on how resources may participate in the market, but within those constraints the CAISO’s GHG design should strive to preserve competition.   

PSE believes the EDAM “durability” principle should be added to this list. This working group should consider opportunities to build in flexibility for future evolutions of the market or regulations, when possible.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

None at this time.

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The paper and the Aug 16 meeting have sufficiently established the goals and guiding principles for accommodating various state GHG-emissions policies as a part of the larger EDAM effort.  In the meeting, it was clear that CAISO should focus it near-term efforts on establishing a baseline level of understanding of the process WEIM currently employs to handle current state-level GHG-emissions policies including the tracking and accounting of those emissions.

Additionally, SCE appreciates CAISO’s prioritization of ensuring cost-optimization to achieve minimized actual system costs with a priori transparency of actual all-in costs for market participants.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

The identified deliverables and details of the GHG Action Plan contents are sufficient.  It could be considered whether to include proactive engagement with regional/state GHG regulators as a part of the action plan prior to finalization of the straw proposal.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

SCE suggests that there be discussion about the methods of emissions tracking and accounting employed by states other than WA and CA.  Specifically, a review of the differences between states and whether CAISO can provide information required for the accounting across the various states.  CA and WA have market-based systems that likely can interact well with the CAISO’s electricity market, but it is not apparent that this will be the case for potential non-market mechanisms in other states – are (will) those systems compatible with the CAISO system?

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

SCE has no further suggestions.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The Six Cities recommend a phased approach for further activities in the GHG coordination initiative and outline their recommendations for structuring the first two phases, consisting of (1) data collection and analysis and identification of problem statements, and (2) evaluation of the impacts of identified problems and prioritization of efforts to develop solutions. 

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

The Six Cities recommend that the GHG Coordination process move forward in phases, as opposed to attempting to create a comprehensive action plan at this stage.  The initial phase should focus on data gathering and analysis and, to the extent analysis of data identifies problems that may prevent successful implementation of and compliance with state GHG programs, development of problem statements.  The second phase should evaluate the potential impact of identified problems and develop priorities for addressing those problems.  The CAISO should approach subsequent phases based on the priorities for addressing any identified and documented problems.

The cadence for working group meetings should be once per month, at least initially, and should accommodate comment periods between meetings.  Longer stretches between meetings may be appropriate if data gathering and/or analysis require additional time.

The format for meetings should be virtual only or hybrid.  Virtual participation should be accommodated for all meetings, and all meetings should be recorded.  Two hours generally should be sufficient for meetings.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

In the Six Cities’ view, the initial phase of data gathering, analysis, and development of problem statements falls within the scope of Topics 1 and 3.  The Six Cities recommend that the next working group meeting (which the Cities suggest deferring until early October) focus on the process for identifying data to be collected and analyzed, including consideration of any practical limits on data collection or publication (e.g., cost, resource limitations, confidentiality concerns).  It would be helpful to establish a date for stakeholders to identify data they would like to have available and for the CAISO to identify (1) concerns with providing requested data, and (2) potential alternative sources or forms of data that may be more accessible.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

The six suggested principles adequately identify high level metrics for evaluating any proposed market design changes that may emerge from the GHG Coordination initiative.  At this time, the Six Cities do not see value in further efforts to define or prioritize overarching principles, as their application to as yet undeveloped proposals for market design changes would be entirely speculative and premature.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The Six Cities have no additional comments at this time.

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

The Washington Utilities and Transportation Commission (UTC), Washington Department of Ecology (Ecology), and Washington State Energy Office (Energy Office), collectively known as the Washington Agencies, appreciate the opportunity to comment on questions posed in the August 30 comment survey.

The Washington Agencies offer these comments as the state agencies responsible for protecting the public interest and ensuring the effective implementation of Washington’s principal climate and clean energy laws.

These laws include the state’s comprehensive cap-and-invest program, the Climate Commitment Act (CCA), and 100 percent clean electricity law, the Clean Energy Transformation Act (CETA). Individually, the UTC regulates Washington’s three investor-owned electric utilities and ensures that rates and services are fair, just, and reasonable for Washington households and businesses served by those utilities. Ecology regulates the greenhouse gas emissions of electricity generation and imports under the CCA. The Energy Office, within the Department of Commerce, is responsible for developing and monitoring energy policy. It authored Washington’s 2021 State Energy Strategy, which calls for the development of regional wholesale energy markets. Additionally, the Energy Office developed the rules for, and monitors the implementation of, CETA by Washington’s consumer-owned utilities. 

The Washington Agencies commend the California Independent System Operator (CAISO) for its recent efforts to work collaboratively with stakeholders and regulatory agencies to explore how GHG accounting functionality could evolve after the ISO gains experience with the Extended Day Ahead Market (EDAM). Given the state and regional imperatives to decarbonize the electricity sector, the Washington Agencies appreciate CAISO’s collaborative efforts to focus on a future GHG policy initiative to support GHG design(s) that are durable and can reflect an array of western climate policies. It is our hope the GHG Coordination Working Group process yields a GHG plan that prioritizes efficient market outcomes for Washington households and meets the data requirements needed for Washington utilities to participate in the market and comply with Washington’s GHG laws and regulations.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

The Washington Agencies commend CAISO for its recent efforts to work collaboratively with stakeholders and regulatory agencies and its commitment to meet stakeholders where they are by offering a venue and cadence appropriate for stakeholders and regulatory agencies.

The Washington Agencies believe the process described in the August 16 CAISO presentation will ensure an opportunity for interested stakeholders to present or discuss relevant issues. However, we encourage CAISO to ensure sufficient time for discussion at each step in the process, particularly during the analysis component. Stakeholders and regulatory agencies may need to revisit problem statements and principles in light of new information. For example, as Ecology currently has a rulemaking underway that may impact issues discussed in the Working Group. It is our experience that it takes significant time to illustrate, discuss, and iterate problem statements on an issue as complex as GHG accounting.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

Review of ISO market operations and existing GHG market design

A review of ISO market operations and existing GHG market design is a worthwhile effort, but could likely occur through a recording from CAISO staff followed by a Q&A session at a subsequent GHG Coordination Working Group meeting.

The Washington agencies would prioritize the following areas for review:

• The optimized attribution process
• Market GHG price signals and GHG marginal revenue allocation
• The benefits and drawbacks of the current CAISO GHG emissions counterfactual method and alternatives considered during the initial EDAM market design process

Stakeholders suggested the development of GHG rules to account for dispatch from storage resources. Tracking and accounting of GHG emissions specific to storage resources is not a requirement in Washington law or regulations, and should not be a priority of this effort, as the GHG attributes of energy stored and dispatched from storage resources is dependent on the GHG attributes of the energy resource used to charge the storage unit.

State coordination

State coordination should highlight the GHG requirements in the respective laws and regulations across states with cap-and-invest programs, and non-price GHG policies, and the data states will need from CAISO to implement their respective laws.

The Washington agencies support the following topics suggested by discussion from stakeholders:

• The role of the ISO in facilitating consistency between GHG emissions reporting programs
• The role of the ISO in addressing the double counting of GHG emissions between state programs

The market’s ability to accommodate linkage between state GHG emissions programs, and consideration of the prospective impact.

Emissions tracking and accounting

This topic is likely to provide the greatest immediate benefit to Washington as it works to appropriately assign emissions to market transactions in its current markets rulemaking. Emissions tracking and accounting should focus on the process of tracking and accounting for GHG emissions in a manner compliant with state laws and regulations. This includes discussion of how the market design could result in and address leakage, while not inappropriately impacting customers in states that have not adopted carbon regulations.   

Beyond GHG pricing policies

Addressing states with non-price GHG programs in a market design is important for regional participation in a market. Washington’s Cap and Invest program is addressed in the CAISO’s EDAM proposal, and will be further addressed through this Work Group. The Washington Agencies also find addressing non-price GHG programs beneficial, as well as the non-price requirements of CETA. The market’s ability to handle both priced and non-price GHG programs within a state simultaneously will be important for Washington’s participation.

Environmental attributes and renewable energy credits

While Commerce and the UTC have sought to adopt rules to facilitate participation in regional electricity markets, while ensuring compliance with the CETA’s “use” requirements, any day-ahead or real-time market will need to include procedures that preserve the ability for state utilities to use RECs for CETA compliance. This may not require that the market design transfer RECs associated with the electricity used to serve Washington customers. This topic needs to be addressed to ensure Washington utilities are able to meet their legal obligations under CETA.

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

Efficiency

The Washington Agencies support a design that optimizes dispatch to minimize production cost. Reducing costs paid by electricity customers is a priority for the Washington Utilities and Transportation Commission and State Energy Office.

Simplicity

The Washington Agencies agree with Oregon’s assessment of the principle of “simplicity” and the idea of incorporating it into the principle of “feasibility”:

The principle of “Simplicity” should be eliminated and instead incorporated into the principle of “Feasibility”. While we agree that the workgroup should avoid unnecessarily over-complicating the market design, the complexity of a design solution needs to be weighed against its potential benefits, particularly to end-use electricity customers. Maintaining a principle of simplicity could be used as a rationale not to explore more complex solutions that may be needed to accommodate states’ various GHG policies. Such solutions should be explored, and their complexity should instead be considered as an element of feasibility.

Transparency

The “Transparency” principle should include ensuring that sufficient information is provided for market participants to comply with state GHG regulations, and make clear any costs market participants may incur beyond the GHG price required for importing electricity into states with price-based programs.

Non-discrimination

The Washington agencies request that CAISO modify this principle to reflect that non-discrimination means no inappropriate or unacceptable GHG emission or cost impact on a non-GHG regulation area or resource, and no penalty under a GHG pricing requirement through unreasonable uplift charges or any dispatch decision that unreasonably increases costs to customers in states with price-based programs.

Jurisdictional roles and responsibilities

Market design should align with state greenhouse gas regulation and clean electricity policies, to the extent practicable.

Feasibility

As discussed above, the Washington Agencies agree with Oregon’s assessment of the principle of “simplicity” and the idea of incorporating it into the principle of “feasibility.”

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

1. Please provide a summary of your organization’s comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

WRA supports the aims of the GHG Coordination working group. In particular, the working group should develop proposed solutions to address emissions tracking and reporting, as well as address the regulatory compliance needs of states with non-pricing GHG reduction policies. Both topics are essential for market operability and efficiency and maximizing participation across the West.

2. Provide your organization’s comments on the GHG Coordination working group process, including the deliverables and action plan:

WRA supports the plan to meet for ~2 hours virtually every month for the foreseeable future to develop the “GHG Action Plan.” The GHG Action Plan should include timelines and tangible targets for evaluation and implementation to support the ISO initiative process. Additionally, we appreciate the work of the ISO to post notes, key decisions, and action items as soon as possible following each meeting.

WRA requests meeting details and registration links be posted on both the CAISO calendar and individual Policy Initiative webpages, to facilitate stakeholder access and participation in this process. WRA notes that as of today (8/30), it appears the 8/30 EDAM stakeholder meeting and 9/13 GHG Coordination working group meeting may be found on the CAISO calendar but are not referenced on their respective Initiative homepages. This could result in stakeholders missing meetings.

3. Provide your organization’s comments on the proposed GHG Coordination working group topics, and include any other topics that should be considered:

Proposed topics include: 1) review of ISO market operations and existing GHG market design, 2) state coordination, 3) emissions tracking and accounting, 4) beyond GHG pricing policies.

WRA emphasizes the need to address each of these four topics in the GHG Coordination working group. #3, emissions tracking and accounting, is essential to measure market performance and address the needs of stakeholders. We urge the development of a robust tracking and accounting framework, with identified reporting metrics, in conjunction with other aspects of GHG design and prior to market go-live. EDAM emissions tracking and accounting should demonstrate the impact of the market on decarbonization and renewable curtailment, as well as provide requisite data for market participants, state regulatory compliance programs, and energy buyers. WRA also supports the proposal to identify “a methodology to more accurately track the emissions from generating resources dispatched both to serve a GHG and non-GHG areas.”

Per #4, WRA recommends prioritizing methods to incorporate the needs of states with non-pricing GHG reduction policies in the market design. Coordination with state regulators is critical. We encourage conversations with the “Western Climate PUC Group" and Doug Howe, who have identified a potential “emissions constraint” solution to support non-pricing state compliance. As noted in the proposed GHG Design Objectives, the market must have durable GHG design “including but not limited to allowing for future policy designs and potential linkage.”

4. Provide your organization’s comments on the proposed GHG Coordination working group principles, and provide any additional principles that should be considered:

Proposed principles include: 1) efficiency, 2) simplicity, 3) transparency, 4) non-discrimination, 5) jurisdictional roles and responsibilities, 6) feasibility.

WRA supports these principles for the GHG Coordination working group. “Transparency” should include transparency of market design and performance via robust reporting of dispatch, renewable curtailment, and emissions. “Feasibility” should include frequent feedback from CAISO and the DMM on the workability of proposed solutions, including modeling and example scenarios where applicable. As mentioned in our response to Question 3, “jurisdictional roles and responsibilities” must include coordination with state regulators and other stakeholders to identify design and reporting needs for maintaining state regulatory compliance.

5. Provide any additional comments on the Greenhouse Gas (GHG) Coordination working group discussion paper, and Aug 16, 2023 working group meeting:

WRA supports the continued use of in-meeting polls and post-meeting comments to supplement discussion and gauge support for proposals. For awareness, WRA has submitted a request to present to the working group on post-dispatch reporting metrics for EDAM and managing the impact of GHG seams in the West.