Comments on Tariff Amendments Posted on Jan 5

1. Please provide your organization’s feedback regarding the Resource Adequacy and Modeling Program (RAMPD) Track 1 and 3a Tariff Amendments that was posted on Jan 5

Overall, the proposed tariff amendments reflect the final proposal on Tracks 1 and 3a. CDWR appreciates CAISO maintaining individual Local Regulatory Authority (LRA’s) jurisdiction on planning reserve margin (PRM) and the counting rules and allowing LRAs to adopt default rules voluntarily, if desired.

2. Please provide any additional questions or comments you may have

CDWR seeks clarification on the default rule sections (emphasis added):

40.8.3.8           Participating Loads

“The CAISO calculates the Qualifying Capacity of Participating Loads using the reduction in demand per Dispatch methodology described in Section 40.8.2.5.  Loads of Participating Loads must be available at least 48 hours, and if the Loads can only be dispatched for a maximum of two hours per event, then only 0.89 percent of a Scheduling Coordinator’s portfolio may be made up of such Loads”.

40.8.2.5           Reduction in Demand Per Dispatch

“The reduction in demand per Dispatch methodology calculates a resource’s Qualifying Capacity, which is static for each month of a year, based on the resource’s average reduction in demand on a per-Dispatch basis over the 36-month default Qualifying Capacity evaluation period defined in the BPM.”

CDWR has the following clarification questions:

1. Section 40.8.3.8 indicates loads of a participating load must be available at least 48 hours. What is meant by load must be available? Does this mean that 48 hours in a month to be ready to be dropped or some other interpretation? A numerical example would be helpful for a better understanding.
2. Section 40.8.2.5 indicates qualifying capacity is calculated based on resource’s average reduction in demand on a per dispatch basis over the 36 months period. An illustrative numerical example would be helpful on how this method is applied. If the dispatch did not take place during that period, how will the values be reflected?
3. The Track 1 Final Proposal (Page #23- “Performance-based UCAP for Demand Response”) indicated that supply side DR resources (without mentioning a participating load) with NQC values will be subject to the performance based in lieu of UCAP adjustment. It would be helpful to have a numerical example on how performance to dispatch calculation under proposed section “40.8.2.4 Performance to Dispatch” differs from section 40.8.2.5.

1. Please provide your organization’s feedback regarding the Resource Adequacy and Modeling Program (RAMPD) Track 1 and 3a Tariff Amendments that was posted on Jan 5

Overall, CAISO legal staff has done an excellent job capturing the Board approved policy and policy intent in this draft tariff language.  CESA's redlines (attached) focus on further aligning the draft tariff language with the board approved policy in the October 2025 Board Memo as well as the discussions held throughout the policy initiative.

• The process to determine the PRM and QC values is an annual process.
• Clarify that the resource-specific adjustments made to energy storage ELCC values are to be based on a unit's forced outage rate, rather than some other metric, to be further clarified in the BPM.
• The UCAP methodology should not evaluate Forced Outages that are outside of the control of the resource owner. The recommended language removes the explicit tariff requirement that a specific nature-of-work category must be specified in the BPM. CAISO staff may still choose to implement the policy by selecting specific nature-of-work fields, but the recommended language makes absolutely clear that outages outside the control of the resource owner shall not be evaluated, regardless of their nature-of-work classification.

2. Please provide any additional questions or comments you may have

CESA respectfully requests at least one more iteration of draft tariff language be provided from CAISO with one more comment round and stakeholder meeting before CAISO files the draft tariff language with FERC.

1. Please provide your organization’s feedback regarding the Resource Adequacy and Modeling Program (RAMPD) Track 1 and 3a Tariff Amendments that was posted on Jan 5

Attached are MRP's comments and proposed edits.  Thanks for the opportunity to submit them.  

2. Please provide any additional questions or comments you may have

1. Please provide your organization’s feedback regarding the Resource Adequacy and Modeling Program (RAMPD) Track 1 and 3a Tariff Amendments that was posted on Jan 5

Please see the Attachment to these comments for Six Cities’ recommended revisions and comments on indicated sections of the draft tariff amendments.

2. Please provide any additional questions or comments you may have

The Six Cities do not have any additional comments or questions at this time.