Comments on Issue paper/straw proposal

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

CEERT's comments are confined to the proposed affected system study process. The CAISO proposes to not reimburse a generator located in the other Balancing Authority seeking to serve load in CAISO that causes a network upgrade in the CAISO BA. The reasoning appears to be that the other Balancing Authority does not reimburse the interconnecting generator for network upgrades in the other Balancing Authority, and, therefore, CAISO should afford "comparable treatment" and not reimburse the generator intending to serve CAISO load for network upgrades in CAISO. CEERT believes that this is an innappropriate comparability standard. Instead, the same reimbursement standard for generators who finance construction of network upgrades should be comparable whether the generator is located in the CAISO BA or in the affected system BA and pseudo tied or dynamically scheduled into CAISO.      

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

3. Provide your organization’s comments on the initiative scope, as described in section 3:

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

See summary comments

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

14. Provide your organization’s comments on Appendix A:

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

 EDF-R Renewables appreciates the opportunity to comment on the CAISO’s Contract management enhancements 2021 (COMA) initiative. As described elsewhere in these comments, EDF-R respectfully requests the CAISO move the Market Quality/ Frequency response item to a separate initiative. 

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

As described elsewhere in these comments, EDF-R respectfully requests the CAISO move the Market Quality/ Frequency response item to a separate initiative.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

EDF-R is concerned that the description of the Market Quality item in Section 3. Scope has not been sufficient to attract the whole of the appropriate stakeholder audience for considering this change. “Revise droop and dead-band requirements in generator interconnection agreements.” Under a “Contract Management” header may not have garnered the attention that frequency response stakeholder initiative previously did and would have again.

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

 None at this time.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

 None at this time.

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

 EDF-R supports the CAISO modifying its tariff to reflect timelines that reasonably reflect actual delivery timelines, but suggests that completely removing the timeline for tendering the study plan removes any forward schedule planning or certainty for interconnection customers seeking repower. EDF-R respectfully requests CAISO change the tendering timeline to something more realistic (example: “not to exceed 30 Business days”) rather than remove it entirely. It is unclear how CAISO or interconnection customers could even identify a rough estimate study result delivery without any firm framework.

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

 None at this time.

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

 None at this time.

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

 None at this time.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

 EDF-R supports the CAISO modifying its tariff to reflect timelines that reflect efficient and actual observed delivery timelines.

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

  EDF-R supports the CAISO modifying its tariff to reflect timelines that reflect efficient and actual observed delivery timelines.

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

EDF-R supports CAISO efforts to further the integration of renewable generation and consider solutions to reduce curtailment, and respectfully requests the CAISO descope this topic form the COMA initiative and seek stakeholder engagement on this topic in the Frequency Response Phase 2 stakeholder initiative, which was previously planned for 2020 and was expected to address this exact topic.

 In the 2016 Frequency Response initiative the CAISO specifically decided not to pursue the changes for asynchronous resources with modern inverters that are now proposed in the COMA initiative. In the FERC transmittal letter for Phase 1 Tariff changes CAISO committed that if it were to pursue changes for asynchronous facilities, it would do it in “phase 2 of its initiative as part of long-term compliance strategy with BAL-003-1.” Also, at that time the CAISO committed to consider designing and implementing a market constraint or market product defined in a technology-neutral way that would allow all certified resources, including non-conventional resources, to provide primary frequency response. Moving forward with this topic in the COMA initiative may disincentivize the CAISO from ever reopening the Frequency Response initiative due to other issues being higher priority once a quasi-effective solve is in place to blunt the issue.

EDF-R agrees with stakeholders that a more through empirical review of the data CAISO used to support this proposal would be appreciated, and asks the CAISO to share that analysis. Specifically EDF-R requests CAISO provide more information on how often the 0.036Hz deadband is violated. EDF-R suggests that the 0.017Hz violation will happen much more frequently.

EDF-R also notes that on a technical level, this change is not a “all benefit” proposal.

CAISO indicated on the call that this new requirement would only come forward for asynchronous generators making inverter changes, however it is the experience of EDF-R that historically the CAISO and PTO have seeked to update any and all contract language to meet “current standards” regardless of the primary driver for the particular amendment. These new requirements will likely affect existing plants’ operation.  The degree to which they will be affected is unknown until these changes are studied: modeling, experimenting, and tuning will need to be a part of the process of these changes’ implementation. Considerations for older plants that EDF-R thinks are worthy of further discussion are:

1. The P-f droop is a necessary characteristics of generation plant output interface ensuring different resources can share power without a central controller (autonomously)
   1. It is sort of “natural” characteristic of a thermal plant governor driven system. (increase in a generator’s load proportionally slows down the rotational speed of the turbine, and thus, generator’s electrical frequency)
   2. Inverters don’t have this build in characteristics; the “speed” doesn’t exist and the frequency is independently adjusted of power level
   3. For inverter interfacing/controlled plants, the Power-frequency droop characteristics needs to match that of the rest of the interconnected system for
      1. Sharing power statically
      2. Sharing power Dynamically – so the power flow during load changes is properly coordinated
      3. Support restoration of frequency oscillations that may lead to stability problems (after sudden overloading or underloading happens on the grid)
2. The “droop” coefficient is defined (usually) as Df/DP.  However, the way the power plant operates, it responds with a change of Power (DP) to the measured change in frequency (Df).  So:
   1. The change of droop from 5% to 4% will result in 25% increase of the DP/Df regulation slope
   2. As a consequence, the dynamics of the plant control changes and potentially leading to
      1. Reduction of system stability (increase in nuisance trips, power oscillations, mechanical stress increase on pitch motors (trying to compensate), blades
      2. Increase power oscillations due to change in wind speed, switching conditions, close proximity of different plant technologies
      3. Increased average curtailment levels
   3. It is, therefore, potentially necessary to re-commission the older plants (tuning controllers)
   4. Operation of the existing infrastructure including other system components (pitching systems, drive train, CCUs) under these faster response requirements may result in increased rate of wear and/or failures
3. Effectively, narrowing of the dead-zone range could result in constant operation in droop-mode even when the actual frequency at POI doesn’t fluctuate.  This will likely contribute to negative effects similar to those mentioned in 2.d. above

There are also considerations for new plants coming online. Due to the nature of equipment procurement, it is quite common for generators to have to make inverter changes very close to COD, and placing a “new to them” requirement on these soon-to-be-online generators adds an additional complication on the already complex timelines and requirements of implementing a new resource.

Finally, as mentioned in item three above, EDF-R is concerned that the description of this change has not been sufficient to attract the whole of the appropriate stakeholder audience for considering this change. “Revise droop and dead-band requirements in generator interconnection agreements” under a “Contract Management” header may not have garnered the attention that the frequency response stakeholder initiative previously did and would have again.

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

None at this time.

14. Provide your organization’s comments on Appendix A:

None at this time.

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

 EDF-R respectfully requests the CAISO move the Market Quality/ Frequency response item to a separate initiative.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

3. Provide your organization’s comments on the initiative scope, as described in section 3:

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

IEP appreciates the opportunity to comment on the 2021 Contract Management Enhancement Initiative. IEP has narrow comments specific to Section 4.1, which states:

 “Unlike for CAISO interconnection customers, The CAISO proposes that Participating TOs will not reimburse external interconnection customers for network upgrades. The practice is consistent with neighboring utilities’ practices for CAISO interconnection customers” (pg.6)

While this may be true, it is time to revisit this practice between the CAISO and neighboring Balancing Authorities (BA). The regional grid is becoming more interdependent. There are resources available in neighboring BAs that can provide Resource Adequacy (RA) and generation to CAISO participants. Given that interconnections will be required to access these resources to benefit CAISO customers, distinguishing between CAISO interconnection Customers and interconnection Customers in other BAs serving CAISO load for reimbursement purposes seems unnecessarily parochial and self-defeating. The CAISO, in conjunction with neighboring BAs, should consider a process that would permit reimbursement for Network Upgrades made by external interconnection customers that are necessary to deliver electricity into the CAISO grid. This is fair, non-discriminatory, and likely to lead to additional capital investments in facilities necessary to meet the needs of CAISO customers.

In the alternative, the CAISO should consider providing Congestion Revenue Rights to secure firm transmission so that generation from the project is deliverable. Further, a process to provide MIC allocations to a Load Serving Entity that has executed a PPA with in interconnected external generator will need to be addressed.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

14. Provide your organization’s comments on Appendix A:

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

The comments of LSA and SEIA are summarized in the table below, and then explained in more detail in the subsequent sections.

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

LSA and SEIA have no objection to the schedule as proposed.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

LSA and SEIA have no objection to the proposed initiative scope, with one exception: the “revise droop and dead-band requirements in GIA topic.” 

Unlike the other process-driven changes in this initiative, this is a serious technical issue.  A fair examination of the proposed changes requires focused attention by technical experts familiar with WECC and other operating requirements, as well as past studies in this area by CAISO and others. 

In other words, just because “it’s in the GIA” doesn’t make it properly included in the scope of this limited initiative.  This topic should be broken out in a separate effort that includes technical workshops, thorough consideration of the need for the change, and examination of other options.

(See substantive comments in #12 below.)

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

LSA and SEIA support the CAISO’s proposals for the draft pro forma CAISO as an Affected System Study Agreement (CASSA), the $75K Study Deposit and required Financial Security postings. 

However, LSA and SEIA believe that the CAISO should further consider whether cost reimbursements are justified for funding of CAISO BAA Network Upgrades.  CAISO-area generators are entitled to reimbursement because, once built, the upgrades reinforce the CAISO grid, and the capacity is available for use by any transmission user (i.e., the generators have no priority or exclusive right to use the capacity).  A similar argument can be made for Network Upgrades funded by projects interconnecting outside the CAISO, i.e., that the upgrades are no less usable by CAISO grid entities for having been funded by projects elsewhere. 

Thus, it would be reasonable to consider refunds, for these Network Upgrades, either in general or perhaps where there is a commitment or high likelihood that the interconnecting project will serve CAISO load, e.g., where the project has a long-term PPA (above the 5-year refund period) or has established (and maintained) a Pseudo Tie arrangement with the CAISO.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

LSA and SEIA support the CAISO’s proposal for Interconnection Service (ISC) retention.  However, it was clear from the stakeholder meeting discussion that the “start date” for the three-year retention period is not clear, for either deliverability or ISC retention.  (The Proposal implies that the start date for both would be the same.

The BPM for Generator Management, Section 12, p.74 states that:

The effective date of Deliverability retention is the last day the Generating Unit was capable of operating.

This date is the earliest:

1. 1. 1. 1. the Generating Unit was forced out and not able to return to service, or
         2. the Generating Unit was removed from service and not able to return to service, or
         3. the SC disassociated from the Generating Unit in CAISO Masterfile, or
         4. the Generating Unit requested retirement by notice to Regulatory Contracts.)

LSA and SEIA support using these criteria for ISC retention.

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

LSA and SEIA oppose this proposal, as proposed.  While the 10 BD requirement is routinely violated (plans can take 3-4 months), the tariff time limits are the only leverage Interconnection Customers have to acquire a study plan in any reasonable time.  It is certainly not acceptable to completely eliminate the time limits.

We do agree that it makes sense to start any study-plan timeline once the request is validated.  Then, 30 Calendar Days (CDs) should be sufficient to issue a study plan. 

Lengthy times to gather system information (e.g., “current system outages and topology”) are not justified.  The CAISO and PTOs are constantly performing interconnection studies, reassessments, and TPP studies, so system data should be readily available for this purpose.

Thus, LSA and SEIA support: (1) Starting the study-plan timeline at the point when the repowering request is validated; and (2) providing a small amount of additional time (from the current 10 BDs to 30 CDs) for the study plan to be provided.

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

LSA and SEIA have no comments on this topic at this time.

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

LSA and SEIA see this issue as two potentially conflicting tariff provisions and agree that the primacy of one over the other should be clarified. 

The current tariff language:

• Limits COD extensions for projects with a Category 3 allocation.  GIDAP Section 8.9.2.2 states: 

If an Interconnection Customer receives TP Deliverability on the basis that it is proceeding without a power purchase agreement, it may not request suspension under its GIA, delay providing its notice to proceed as specified in its GIA, or modify its Commercial Operation Date beyond the earlier of (a) the date established in its Interconnection Request when it requests TP Deliverability or (b) seven (7) years from the date the CAISO received its Interconnection Request. Extensions due to Participating TO construction delays will extend these deadlines equally. Interconnection Customers that fail to proceed toward their Commercial Operation Date under these requirements and as specified in their GIA will be converted to Energy Only.)

• Allows projects to extend CODs to align with executed PPAs. GIDAP Section 6.7.5 states:

An Interconnection Customer with an executed GIA and an executed, regulator-approved power purchase agreement may request to automatically extend the GIA Commercial Operation Date to align with its power purchase agreement for that Generating Facility, including any extension or amendment…Requests to align the Commercial Operation Date with power purchase agreements are not exempt from the commercial viability criteria provisions in Section 6.7.4, where applicable.)

The disucssion at the stakeholder meeting indicated that the CAISO has been assuming that the first tariff provision above has priority over the second, offering as an explanation only that “our lawyers tell us this.”  With all due respect, this does not appear to be a very good explanation.

In any case, LSA and SEIA agree that the second provision should take priority over the first, i.e., that projects with a Category 3 TPD allocation should be allowed to delay their GIA CODs to align with the CODs of PPAs they later acquire.  The rationale for using PPAs as TPD award criteria for Category 1 and 2 TPD allocations, and for allowing COD delays for TPD awards under any other category, is that the PPAs are strong indicators of project viability.  This is true also for projects with Category 3 awards, and therefore those projects should have the same alignment ability.

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

LSA and SEIA strongly support this proposal generally.  The need for the current tariff restrictions on complete conversion to storage was never adequately explained, and the vagueness of the current tariff provisions is confusing.

However, we do not see any reason why such an MMA request should be evaluated using different criteria than other MMA requests.  The proposed requirement that the electrical characteristics of the projects remain substantially unchanged is the same as for other requests with executed GIAs, and it should apply to such projects.  For projects still in the study process, prior to GIA execution, the otherwise-applicable MMA assessment criteria of lack of adverse impacts on other projects in the queue should apply to capacity-conversion requests.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

LSA and SEIA have no comments on this topic at this time.

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

LSA and SEIA have no comments on this topic at this time.

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

LSA and SEIA oppose this proposal, mainly on process grounds at this time. 

As noted above, we object to inclusion of this very technical proposal in this the scope of this initiative, since it requires deeper consideration and does not fit with the other, largely process-driven topics here.

In addition:

• The CAISO has not justified tightening standards for inverter-based resources but not others.  

• The CAISO has not justified tightening standards for grid-connected resources before considering other ways to address roof-top solar issues.  The CAISO should consider other potential solutions instead of automatically moving to increase burdens on grid-connected resources.  For example, one stakeholder meeting participant proposed that the CAISO work with aggregators to acquirement information it needs to improve CAISO forecasting and data acquisition for rooftop solar projects.

• The CAISO should more fully justify the elements of this proposal, e.g., the specific rationale for the two revised technical parameters it has proposed.  This justification should tie directly the new proposed settings to the mitigation it needs.

• The CAISO should more fully explore how its needs will change in the future, and develop an overall long-term strategy for meeting those needs, instead of making piecemeal fixes like this one.

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

LSA and SEIA have no comments on this topic at this time.

14. Provide your organization’s comments on Appendix A:

In addition to adding the proposed terms, the CAISO should revise the Aggregate Capability Constraint definition in Appendix A to reflect the ability to use multiple ACCs for a single Generating Facility, as shown below.

A constraint that reflects the combined maximum and the combined minimum capability of Generating Units configured as Co-located Resources that comprise a single Generating Facility or portion thereof, so that the capability does not exceed the Generating Facility’s Interconnection Service Capacity or charging capacity specified in its Generator Interconnection Agreement. A single Generating Facility may have multiple Aggregate Capability Constraints as long as the sum of the Interconnection Service Capacity does not exceed the limit for the Generating Facility.  In the case of EIM Participating Resources, a constraint that reflects the combined maximum and the combined minimum capability of individual EIM Participating Resources or non-participating resources that comprise a single resource.

These changes are needed to clarify that: (1) ACCs are needed for Co-located Resources and not other project configurations; and that (2) multiple ACCs per Generating Facility are allowed.

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

The revised droop and dead-band requirements, as described in section 7.1, is a significant issue that would be better addressed in its own stakeholder initiative.

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

No comment at this time.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

No comment at this time.

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

No comment at this time.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

No comment at this time.

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

No comment at this time.

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

No comment at this time.

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

No comment at this time.

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

No comment at this time.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

No comment at this time.

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

No comment at this time.

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

Changing the droop and dead-band requirements is a significant issue that would be better addressed in its own stakeholder initiative. MCE agrees with the comments made during the August 17, 2021 CAISO stakeholder call in this initiative highlighting the seriousness of this issue. MCE understands the change would apply to new projects entering a Generator Interconnection Agreement (GIA) in the future as well as a subset of existing projects seeking amendments to GIAs. This may materially impact the costs of existing resources and should be examined more fully. MCE recommends establishing a separate stakeholder initiative to explore this issue.

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

No comment at this time.

14. Provide your organization’s comments on Appendix A:

No comment at this time.

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

No comment at this time.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

Please see below.  

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

The proposed schedule is reasonable.   

3. Provide your organization’s comments on the initiative scope, as described in section 3:

MRP has no comment on this topic. 

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

MRP has no comment on this topic. 

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

MRP has no comment on this topic. 

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

While MRP finds reasonable the CAISO’s concern about the current ten-day requirement for the CAISO to release a draft study plan after receiving an affidavit requesting repowering, MRP does not believe that there should be no timeframe for releasing the draft study plan.  MRP requests that, instead of eliminating any time frame, the CAISO propose an alternate (longer) time frame for releasing the draft study plan. 

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

MRP supports this proposed change.  

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

MRP has no comment on this topic. 

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

MRP supports the CAISO’s proposal to allow projects to request a 100% conversion to energy storage through the Material Modification Assessment process or repower request if the electrical characteristics of the plan, other affected projects, or the transmission system remain substantially unchanged.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

MRP has no comment on this topic. 

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

MRP has no comment on this topic. 

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

At this time, MRP does not object to the CAISO’s proposal to change the droop setting from 5% to 4% and decrease the frequency dead-band from 0.036 Hz to 0.0167 Hz for “asynchronous generators”, but requests two things: first, that the CAISO state whether inverter-connected battery energy storage system resources are “asynchronous generators”, and second, that the CAISO provide some technical support as to why it is proposing those specific changes, and not some other changes, to droop and dead-band settings. 

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

MRP has no comment on this topic. 

14. Provide your organization’s comments on Appendix A:

MRP has no comment on the proposed “CAISO as An Affected System Study Agreement”. 

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

MRP has no other comments.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

PG&E is appreciative of its efforts on this Contract management enhancements 2021 stakeholder initiative.  PG&E sees these changes as primarily administrative in nature and is generally in support of the issue paper and straw proposal.  PG&E asks for clarification on the issues of droop and deadband.

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

 PG&E is supportive of the proposed scheduled and goal of implementation in 2022.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

 PG&E requests clarification on which projects would be required to meet the revised droop and dead-band requirements. 

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

14. Provide your organization’s comments on Appendix A:

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

Shell Energy appreciates the opportunity to comment here.

Shell Energy was surprised to learn changes to frequency response is included in this stakeholder initiative.  Shell Energy requests frequency response be removed from the scope of COMA, and addressed in a separate, more aptly named stakeholder process to ensure a wider audience of stakeholders. 

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

3. Provide your organization’s comments on the initiative scope, as described in section 3:

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

14. Provide your organization’s comments on Appendix A:

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

In general, the Six Cities do not oppose the CAISO’s proposals as outlined in the Issue Paper/Straw Proposal.  The Six Cities have identified a limited number of proposed revisions to the CAISO’s draft pro forma “CAISO as an Affected System Study Agreement” (“CASSA”), including, among other suggested edits, new language related to the assignment of cost responsibilities under the agreement.  Additionally, with respect to the CAISO’s proposal to align the deliverability allocation retention period and the applicable period for retention of interconnection service rights, the Six Cities have no conceptual opposition, although, as outlined below, it would be appropriate to consider whether a three year retention period following resource retirement remains appropriate. 

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

 The Six Cities do not have comments on these elements of the Issue Paper/Straw Proposal. 

3. Provide your organization’s comments on the initiative scope, as described in section 3:

The Six Cities do not have comments on the initiative scope; the scope appears to be reasonable in light of an interconnection process enhancements initiative commencing later this year. 

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

The Six Cities have identified a limited number of comments and proposed revisions to the draft CASSA.  Please refer to these comments in the accompanying redline.  In addition to editorial revisions, the Six Cities’ comments include a new proposed provision to clarify the scope and extent of the Generation Project Owner’s cost responsibilities under the CASSA. 

The Six Cities support what they understand to constitute the CAISO’s proposal for assignment of cost responsibilities under the CASSA – namely, that the CAISO intends to require Generation Project Owners to pay for the CAISO to perform any necessary affected system studies and also for any mitigation that those studies identify may be required.  The Six Cities relatedly support the CAISO’s proposal that Participating Transmission Owners in the CAISO will not provide reimbursement for network upgrades that are needed in connection with Affected System mitigation. 

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

The Six Cities have not identified any concerns with the CAISO’s conceptual proposal that the deliverability allocation and interconnection service retention periods should be aligned following the retirement of a Participating Generator.  However, as noted by the CAISO, the existing Business Practice Manual (“BPM”) provision (Reliability Requirements BPM at section 6.1.3.4) relating to deliverability allocation retention provides for deliverability to be retained for a period of three years post-retirement (or, to use the terminology in the cited BPM provision, three years after a unit becomes “incapable of operating”).  The Six Cities request that the CAISO provide information regarding the original policy rationale for the three-year retention period.  Depending on the reasons for this three-year period, the Six Cities are concerned that permitting a retired resource to retain its deliverability allocation and interconnection service rights for three years (absent some commitment to return to service or repower) is unreasonably long and results in the underutilization of deliverability and interconnection service.  This is especially inefficient at a time when the CAISO footprint is in need of additional capacity resources that may be able to come online more quickly were deliverability and interconnection capacity more readily available.  Permitting resource owners to retain these rights for three years following retirement of the corresponding resources may inappropriately restrict deliverability and interconnection service (and possibly increase costs) for other resources under development. 

There is also an interrelationship between deliverability and availability of Maximum Import Capability (“MIC”), which a number of stakeholders have advised the CAISO must be expanded to improve the ability of CAISO load serving entities to use external resources to meet their Resource Adequacy obligations.  Again, unused or underutilized deliverability held by resources within the CAISO could be put to use to facilitate import RA. 

The Six Cities are not, at this time, taking an affirmative position on the existing retention period for deliverability allocations and interconnection services, but instead are seeking information to better understand the basis for the existing rules.  It is possible that the original policy rationale for the three year retention period is no longer appropriate in light of the needs to facilitate the development of new resources and/or improve access to external resources.  In the event that this topic is beyond the scope of this initiative, the Six Cities request that this issue be included within the scope of the next interconnection process enhancements initiative. 

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal. 

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal. 

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal. 

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal. 

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal.   

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal.   

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal.   

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

 The Six Cities do not have comments on this element of the Issue Paper/Straw Proposal.   

14. Provide your organization’s comments on Appendix A:

 Please refer to the accompanying redline. 

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

 The Six Cities do not have additional comments on the Issue Paper/Straw Proposal at this time.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

SCE appreciates the opportunity to comment on the COMA Enhancements 2021 issue paper and generally supports the CAISO’s proposed revisions and clarifications. 

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

SCE believes the proposed schedule allows ample time to adequately vet the issues which are mostly contract and administrative in nature and without much anticipated contention amongst stakeholders.  Thus, SCE supports the CAISO’s consideration of possibly revising the schedule if a step in the process is no longer necessary (i.e. bypassing a revised straw proposal and directly issuing a draft final proposal after the CAISO receives comments on the issue paper/straw proposal).  The possibility of truncating the COMA process is also more desirable in order to reduce or eliminate the overlap period with other generator interconnection enhancements, given the CAISO affirms in the COMA issue paper/straw proposal that it will initiate an IPE initiative later this year which would seemingly run in parallel to some extent with COMA 21.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

SCE supports the scope of the COMA 21 initiative.  Although four of the five major initiative categories – Affected Systems; Retirements & Repowers; Modification; and Interconnection Request & Study Agreement – address predominantly contractual and administrative matters, SCE believes it is also appropriate to include the more technical issues concerning droop and dead-band requirements contained in generator interconnection agreements.   

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

SCE supports the CAISO’s proposal to develop a defined process for conducting affected system studies and mitigating the impacts of the increasing volume of resources interconnecting to neighboring BAAs with impacts on the CAISO grid.  SCE also supports the CAISO proposal that PTOs will not reimburse external interconnection customers for network upgrades.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

SCE supports the CAISO’s proposal to clarify that interconnection service to the CAISO-controlled grid is maintained concurrent with deliverability retention.  This would be consistent with the CAISO’s policy regarding deliverability retention which expires exactly three years from the retirement date of a generator resource.

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

SCE does not oppose the CAISO’s proposal to remove the ten business days requirement for the CAISO to issue a draft study plan to a generating unit owner withing ten days of receipt of the affidavit requesting repowering.  The CAISO will instead coordinate with the PTO to validate the interconnection request and subsequently draft and tender a study plan as soon as practical following the validation on the repower interconnection request.

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

SCE supports the CAISO’s proposal to clarify and add specificity to the repowering section by modifying the language that refers specifically to the repowering process.

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

SCE conditionally supports, subject a project undergoing an MMM review to ensure other projects are not adversely impacted, the CAISO’s proposed clarification on allowing a project to extend its COD if they had received TPD allocation based on proceeding without a PPA but then receive a PPA and want to align their COD.

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

SCE supports the CAISO’s proposal to request a 100% conversion to storage via a Material Modification Assessment or a repower request provided the electrical characteristics of the plant, other projects or the transmission system will remain substantially unchanged.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

SCE supports the CAISO’s proposal to reconcile an existing tariff inconsistency regarding the process for serial projects to request modifications prior to achieving their Commercial Operations Date by deleting Section 4.4.4 of Appendix U in its entirety and retaining the language in Section 4.4 combined with Section 4.4.6.

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

Appendix U, Section 6.4 is predicated on System Impact Studies and Facility Studies which have been replaced with Phase I and Phase II studies.  As such, SCE supports the CAISO’s proposal to delete Sections 6.4 and 7.6 of Appendix U in their entirety to align the timing for the restudy to be consistent with the Appendix DD study process. The result changes the timeline from 45 calendar days to 60 calendar days.

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

SCE supports the overall direction to reduce governor droop and frequency dead-band for inverter-based resources, though would be interested to understand what studies have been conducted to-date on the changes associated with reducing governor droop from 5% to 4% and frequency dead-band from +/- 0.036 Hz to +/- 0.017 Hz.  We also recognize that there is a degree of uncertainty associated with establishing a change for all future entities, which will result in two populations of generators behaving differently with respect to frequency response, and the overall consequences of this are not presented.  The aggregated differences in response may result in some system response to a large frequency excursion that may be unexpected, possibly resulting in greater MW flows out of pockets of new generators (those adhering to the new requirement) along with a relatively lower response from pockets of “legacy” generators.

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

SCE supports the CAISO’s proposal to change the effective date of the GISPA to the date the interconnection request package is deemed complete and moves to the validation process following section 3.5.1 of GIDAP.

14. Provide your organization’s comments on Appendix A:

SCE has no comment.

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

SCE has no comment.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

Vistra appreciates the CAISO launching a stakeholder process to pursue improvements to its contracts management processes. Vistra specifically supports the proposed items in Section 5.1, retention of interconnection service; Section 6.2, whole project conversions to storage, and Section 8.1, Generator Interconnection Study Process Agreement (Appendix 3) effective date. These elements specifically will bring improvements to the CAISO’s processes. The remaining elements in Section 4, Section 5, and Section 6 seem largely uncontroversial and likely provide incremental benefits as well with a single caveat. Vistra proposes that the CAISO provide more flexibility to address Section 5.2, clarification of study plan timing requirements for repowers, by relaxing the Tariff deadline to issue a draft study plan to up to 30 business days after receiving the repowering request rather than removing the CAISO deadline completely. We believe this balances need for greater flexibility to complete the draft studies while protecting developers from increased risks of longer timelines.

While Vistra is very supportive of the CAISO improvements being pursued described above, we do not support the inclusion of the frequency response scope item in this initiative. Vistra respectfully requests the CAISO remove the frequency response inverter requirements element from the initiative scope. There is a planned policy project to explore whether additional frequency response is needed to better support grid reliability and CAISO ability to meet its applicable NERC and WECC reliability requirements – Frequency Response Measures.

The Frequency Response Measures initiative scope “consists of a comprehensive examination of mechanisms for the CAISO balancing authority areas to continue to meet NERC/WECC frequency response requirements. This initiative is in response to an observed degradation in frequency response performance, potentially related to a changing resource mix within the CAISO BA area.”[1] As a part of this initiative the CAISO will be providing the necessary analysis to support any proposed changes, the policy catalog states that this initiative will include:

• “complete an analysis of its current frequency response capabilities”
• “it will quantify the response of each individual governor-enabled resource”
• “In addition, CAISO plans to review the capability of variable energy and storage resources in meeting these reliability needs.”

Vistra believes the CAISO current plan to evaluate the operational challenges teed up in this initiatives Section 7 under the Frequency Response Measures initiative is the appropriate place to discuss these challenges. Based on the results of this analysis, the CAISO plans to explore an array of solutions to ensure the CAISO can observe the additional frequency response it needs to maintain reliability and meet those reliability criteria. This is the appropriate venue for the discussion introduced in Section 7 and we look forward to engaging in that effort once launched. 

[1] CAISO 2021 Final Policy Initiatives Catalog, Section 5.13, http://www.caiso.com/InitiativeDocuments/2021FinalPolicyInitiativesCatalog.pdf.

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

Assuming the CAISO revises the scope to remove the frequency response inverter requirements in Section 7 from scope, the schedule seems realistic and feasible given that the remaining elements are largely uncontroversial. If that element remains, the complex nature of the issue and broad array of potential solutions would require a longer schedule, which would delay these other useful enhancements.

3. Provide your organization’s comments on the initiative scope, as described in section 3:

Vistra cautions the CAISO against pursuing the Section 7, Market Quality Updates in the scope of this effort. This element is controversial, requires additional analysis to support the increased performance requirements, and stakeholder vetting currently planned for beginning of 2022 in the Frequency Response Measures project.

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

None at this time.

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

Vistra supports this proposal.

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

Vistra sympathizes with the CAISO desire to relax the 10 business day timeline in the Tariff for the CAISO to issue a draft study plan within a set number of days after receiving the repowering request affidavit. However, an unbounded timeline for the CAISO to provide draft study plan after receiving a repowering request affidavit would expose developers to uncertainty and increased risk of delays to its repowering. Vistra proposes that relaxing this deadline rather than removing the deadline would be a preferable route to provide CAISO more flexibility while retaining some protections and clarity on timing for the repowering asset. Vistra respectfully proposes the CAISO revise Section 25.1.2.3 to allow up to 30 business days to increase CAISO flexibility. 

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

None at this time.

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

None at this time.

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

Vistra supports this proposal.

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

None at this time.

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

None at this time.

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

As previously described, Vistra requests the CAISO remove this item from scope and pursue frequency response enhancements in the scheduled Frequency Response Measures project.

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

Vistra supports this proposal.

14. Provide your organization’s comments on Appendix A:

None at this time.

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal:

None at this time.

1. Provide a summary of your organization’s comments on the COMA Enhancements 2021 issue paper/straw proposal:

WPTF appreciates the opportunity to submit these brief comments on the CAISO’s Contract Management Enhancements 2021 (COMA) Issue paper and Straw proposal. WPTF was surprised to see the CAISO addressing Frequency Response within this stakeholder effort. While we appreciate the CAISO revisiting this very important topic, we believe the topic is misplaced within this effort and should be addressed in its own stakeholder initiative. WPTF is concerned that several market participants will not have an opportunity to engage with the CAISO on this topic simply because the title of this initiative does not lend one to believe frequency response would be within scope. Thus, the CAISO could be missing a large section of stakeholder feedback, thoughts, and insights on this energy market topic. Furthermore, an initiative focused on contract management is likely to have a significantly different group of stakeholders engaging with the CAISO than what would be engaged on an initiative focused on Frequency Response.

WPTF would also like to take this opportunity to note that in the last Frequency Response stakeholder process (Frequency Response Phase 2) the CAISO announced it will resume this topic in 2020. The latest message to the stakeholder community regarding this topic was to wait for the Frequency Phase 2 initiative to be re-opened, not look for frequency response as a sub-topic being addressed in a stakeholder effort focused on contract management.

Thus, WPTF respectfully requests that the CAISO move the topic of frequency response from the COMA initiative to its own separate initiative. Creating a separate initiative for frequency response will also provide the CAISO and stakeholders sufficient time to discuss the topic and potential solutions without having to compromise the solution due to scheduling limits. Not only will this then allow ample time to discuss the issue, but still provide the CAISO the ability to move forward with the contract topics according to the current schedule.

2. Provide your organization’s comments on the stakeholder process and proposed schedule, as described in section 2:

3. Provide your organization’s comments on the initiative scope, as described in section 3:

4. Provide your organization’s comments on the CAISO as an Affected System process update topic, as described in section 4.1:

5. Provide your organization's comments on the retention of Interconnection Service Following Retirement Approval topic, as described in section 5.1:

6. Provide your organization’s comments on the clarification of study plan timing requirements for Repowers topic, as described in section 5.2:

7. Provide your organization’s comments on the Clarify Repower language in Section 2 topic, as described in section 5.3:

8. Provide your organization’s comments on the TP Deliverability allocation Group 3 usage of COD extensions and alignment with PPA topic, as described in section 6.1:

9. Provide your organization’s comments on the whole project conversions to storage topic, as described in section 6.2:

10. Provide your organization’s comments on the Appendix U, Modifications topic, as described in section 6.3:

11. Provide your organization’s comments on the Appendix U, Re-study timeline alignment with other studies topic, as described in section 6.4:

12. Provide your organization’s comments on the revise droop and dead-band requirements in GIA topic, as described in section 7.1:

13. Provide your organization’s comments on the Generator Interconnection Study Process Agreement (Appendix 3) Effective Date topic, as described in section 8.1:

14. Provide your organization’s comments on Appendix A:

15. Additional comments on the COMA Enhancements 2021 issue paper/straw proposal: