Comments on 2022 draft final policy initiatives roadmap

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

APS appreciates the opportunity to comment on the 2022 draft final policy roadmap. APS would like to advocate for the continuation of the stakeholder process related to Resource Sufficiency Evaluation immediately after the conclusion of Phase 1. This will allow stakeholders and the CAISO to continue discussions surrounding the use of load conformance, and advisory EIM imports supporting HASP exports. Along with these two items APS requests the scope include corrections to the uncertainty calculation. The net load and inter-tie deviation uncertainty calculations were removed from the Resource Sufficiency Evaluation in Phase 1, APS supports further development of the correct calculations for these components in the next phase of the initiative. The quantile regression methodology for net load uncertainty has been delayed in implementation as part of the Flex Ramp Product Enhancements Initiative, and APS would support development of an interim calculation for this uncertainty component in case of further delays. Inter-tie deviation uncertainty was removed as an uncertainty component from the flex and capacity test in Phase 1, and no current replacement methodology is proposed, APS would request this component be discussed in the next phase of the Resource Sufficiency Evaluation Initiative.

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

The Bonneville Power Administration (Bonneville)[1] appreciates the opportunity to submit comments on CAISO’s 2022 Draft Final Policy Initiatives Roadmap dated January 19, 2022. Bonneville’s comments are limited to the EIM Resource Sufficiency Evaluation (RSE) Enhancements initiative.

Phase 1 of the EIM RSE Enhancements initiative was intended to increase the transparency of the EIM RSE and make enhancements that would ensure the EIM RSE is accurately reflecting the operating capability and obligations of each EIM Entity and the CAISO BAA for the time period being evaluated. The EIM RSE Enhancements Revised Draft Final Proposal dated December 16, 2021 that will be taken to the EIM Governing Body and ISO Board of Governors for joint decision on February 9, 2021 does not achieve those objectives. There are significant inaccuracies of the EIM RSE that remain and that need resolution urgently. Given the foundational nature of the EIM RSE and its importance in EIM Entities’ ability to have trust and confidence that the EIM, as a voluntary market, is producing reliable and equitable results, we urge the CAISO to prioritize addressing these remaining items in a Phase 1b and not delay work until July 2022.

Phase 1b should be focused on analysis and enhancements needed to enhance transparency and ensure that the EIM RSE is accurately evaluating the operating capability and obligations of each BAA being tested for the period being tested. This should include:

• Analysis of counting capacity made available in the STUC that was not actually available in real-time
• Method for calculating intertie uncertainty
• Testing of the quantile regression approach to calculating net load uncertainty, including working with EIM Entities to be able to re-create the test.
• A holistic examination of the uncertainty calculation that includes intertie and net load uncertainty
• Appropriate incorporation of significant and systemic adjustments made to a BAA’s load forecast, including load conformance used by the real-time market, into the EIM RSE.

Phase 2 should be focused on the effectiveness of the EIM RSE at achieving its objective, which is to prevent or strongly discourage leaning. The scope should appropriately be focused on EIM RSE failure consequences. However, Bonneville reiterates that appropriate failure consequences can only be effective if the EIM RSE produces accurate results in the first place.

As stated in previous comments, our support for the EIM RSE Enhancements Draft Final Proposal continues to be contingent upon the CAISO expediting the areas listed above still needing to be addressed in a Phase 1b starting in February 2022. We ask that the CAISO provide a clear plan for addressing the remaining issues from Phase 1 before the February 9, 2022 EIM Governing Body and ISO Board of Governors meeting.

[1] Bonneville is a federal power marketing administration within the U.S. Department of Energy that markets electric power from 31 federal hydroelectric projects and some non-federal projects in the Pacific Northwest with a nameplate capacity of 22,500 MW. Bonneville currently supplies around 30 percent of the power consumed in the Northwest. Bonneville also operates 15,000 miles of high voltage transmission that interconnects most of the other transmission systems in the Northwest with Canada and California. Bonneville is obligated by statute to serve Northwest municipalities, public utility districts, cooperatives and then other regional entities prior to selling power out of the region.

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

EDF-Renewables renewables CAISO's transparency in the policy initiatives roadmap and the complexity of the challenge the CAISO faces in priotizing policy development items in the upcoming year. As mentioned on the call, EDF-Renewables requests that CAISO re-classify the Interconnection Process Enhancements (IPE) initiaive as a Major initiaive.

The changes being considered in IPE 2021 are an order of magnitide more impactful than previous IPE iterations. In particular the CAISO's proposal to eliminate Transmission Plan Deliverability Allocation Group 3 is likely to have signifigant ripple effects across the Resource Adequacy contracting market, including: shifting interconnection request analysis burden and commercial viability risk burden to LSEs, changing the criteria that LSEs use to evaluate offers, and signifigantly changing valuation considerations for projects Cluster 13 and prior. For these reasons and many others EDF-Renewables believes IPE should be considered a major intitive, and that when technical implementation is required in the form of changes to the Resource Interconnection Management System (RIMS) application, those changes be treated with equivilant priority to market changes for other Major intiatives. 

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

We would like to see tariff changes discussed to permit PDRs technically capable of meeting the current requirements for providing AGC based regulation services to be able to sell reg up and down into CAISO.  

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

PG&E appreciates the CAISO’s efforts in the development of this roadmap and its integration of stakeholder feedback throughout the process.

In California, large quantities of energy storage procurement are expected to be underway to support the policy goals of the state and better integrate variable renewable energy resources.  Moreover, energy storage procurement may serve as a viable, feasible, and cost-effective alternative solution to transmission system upgrades that adequately address reliability issues identified by the CAISO. For example, the Board Approved 2021-2022 Transmission Plan includes the recommendation of the Mesa substation 115 kV 50 MW BESS and Kern-Lamont 115 kV system 95 MW BESS as transmission system upgrade alternatives.

PG&E believes that there may be more effective ways to identify, evaluate, and prioritize such alternatives through a collaborative process, such as the Storage as a Transmission (SATA) initiative, involving both the CPUC and CAISO.  Accordingly, PG&E requests that the SATA initiative be reintegrated to the policy initiatives roadmap.

PG&E agrees that the management and preservation of state of charge tools are foundational elements to energy storage resources participating in the market and serving as alternatives to transmission-based reliability issues, and as such, requests that the SATA initiative be reintegrated to the roadmap plan following the completion of the Energy Storage Enhancements and RA Enhancements initiatives sometime in 2023.

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

Please see Powerex’s comments available at CAISO 2022 Draft Final Policy Initiatives Roadmap Comments.pdf (powerex.com)

1. Please provide your organization's comments on the 2022 draft final policy initiatives roadmap.

Salt River Project Agricultural Improvement and Power District’s (SRP) comments on the CAISO’s 2022 Draft Final Policy Initiative Roadmap

SRP appreciates the opportunity to comment on the California Independent System Operator (CAISO) 2022 Draft Final Policy Initiative Roadmap. SRP understands that the CAISO’s policy focus for the next three years will be high profile initiatives, such as the Extended Day-Ahead Market (EDAM) and EIM Resource Sufficiency Evaluation (RSE) Enhancements. SRP recognizes these initiatives will require significant time from CAISO staff and interested stakeholders. However, as we have expressed in previous comments, we are concerned that Phase 1 of the EIM RSE Enhancements does not resolve resource sufficiency inaccuracies for summer 2022. Further, an accurate and properly functioning RSE is critical to EIM and should not be postponed until after the EDAM RSE framework is determined. SRP encourages the CAISO to initiate a Phase 1B of this initiative immediately following the completion of the current phase. SRP requests that Phase 1B include:

• Further analysis of the impact of CAISO operator-induced load conformance
• Resolution of interactions between the Hour-Ahead Scheduling Process and EIM RSE resulting in the CAISO Balancing Authority Area becoming over-extended with exports it cannot support without relying on EIM import supply
• Developing and implementing an accurate measure of net load uncertainty
• Further evaluation of the Short-term Unit Commitment horizon proposal
• Detailed review of solar performance relative to forecasts used in the RSE

SRP appreciates the CAISO’s consideration of these comments.