Comments on 2027 Default Resource Adequacy Values Stakeholder Meeting: 9/9/2026

1. Please provide your organization's overall feedback regarding the 2027 Default Resource Adequacy Values Stakeholder Meeting discussions held on September 9, 2026.

CDWR appreciates the CAISO effort and the outcome as the product of default net qualifying capacity (NQC) values and the default planning reserve margin (PRMs) while recognizing the product is applicable only when a LRA does not have its own QC counting rules and set PRM values. CDWR also requests CAISO to provide a SC (upon request) for a resource on details of calculation of default NQC values including calculation method and data points picked to arrive at the default NQC values.

2. Please provide any additional feedback not already captured.

1. Did CAISO come up with actual dispatch of participating load (PL) MWs for Default NQC values? Can CAISO share how the values were calculated? CDWR would like to request the calculation method and the actual data used to derive the numbers (preferred option: CAISO could provide response via a CIDI ticket to the scheduling coordinator).
2. San Luis generator is not allowed to be used for RA today; the default values show significant MWs as NQC. CDWR would like to request the calculation method and the actual data used to derive the numbers (preferred option: CAISO could provide response via a CIDI ticket to the scheduling coordinator).
3. Can an entity (adopting default NQC values) request an increase in NQC values in a monthly process (for let’s say a hydro resource) with an increase in forecasted generation? Will the increase request increase the default values as well? Can an entity (not adopting default NQC) request increase in QC values anytime within a year?

1. Please provide your organization's overall feedback regarding the 2027 Default Resource Adequacy Values Stakeholder Meeting discussions held on September 9, 2026.

 The following comments are regarding the published Draft Default QC list:

1. Pasadena recommends the CAISO begin using the Default RA QC values in 2028 or later as opposed to 2027 given that final values have yet to be published, and even the draft data that is available was published so close to the annual RA filing deadline.  Many entities have already assessed their portfolios and finished procuring their needs.  These changes have noticeably constrained the market further.  Procuring additional capacity after this list was published has been extremely difficult.

2. Pasadena disputes applying the UCAP methodology for resources that were on extended forced outage for major repair work during the inaugural UCAP assessment period.  Including these resources in the UCAP assessment period and applying derates does not seem appropriate if the SC stopped including such a resource in monthly RA supply plans.  It was our understanding that leaving a resource out of a supply plan told the ISO that the resource was not available to the market as a reliable unit and would therefore avoid these types of penalties.  Additionally, we don’t agree that this methodology should be retroactively applied, as SCs did not have an opportunity to adjust their approach to managing outages.

3. Finally, Pasadena also recommends the creation of a formal dispute process for the published Default QC list.  Currently, the process for requesting revisions to the Draft NQC list involves submitting a CIDI ticket.  What is the process for disputing the Default QC list moving forward?

2. Please provide any additional feedback not already captured.

1. Please provide your organization's overall feedback regarding the 2027 Default Resource Adequacy Values Stakeholder Meeting discussions held on September 9, 2026.

MRP appreciates the discussion for the 2027 Default RA values and PRM.  MRP recommends CAISO staff to issue a report with detailed inputs and assumptions for the LOLE study so stakeholders can better understand how the study was performed.  While MRP understands that all planned outages were excluded because planned outages are generally replaced with substitute capacity, certain planned outages that do not require outage substitution should be included.  Transmission induced outages is such an outage.

MRP requests CAISO to provide outage data details so that market participants can validate the UCAP calculations.

2. Please provide any additional feedback not already captured.

It would be helpful for CAISO to provide details of next steps for this initiative.