Comments on issue paper

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

ACP-California does not have any specific comments on the stakeholder call itself but offers comments on the issues and scope in response to the following questions. 

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

ACP-California appreciates CAISO’s effort to review suggested changes to the on-peak deliverability methodology that have been suggested by a variety of stakeholders.

ACP-California appreciates CAISO’s efforts to evaluate whether the on-peak deliverability methodology is too conservative or identifies more transmission than is necessary. We understand CAISO’s finding that the current study methodology is, generally, achieving the desired outcome and is reasonably aligned with that of other ISO/RTOs.  However, it is prudent to keep exploring issues related to the methodology into 2024 and continue to evaluate possible improvements to the deliverability methodology as the standards for reliability planning, Resource Adequacy, and the types of technologies on the system are evolving. Deliverability allocation is a core aspect of Resource Adequacy compliance, and the success of new projects.  It is important to ensure that prudent standards for reliability planning do not unnecessarily stand in the way of project development or opportunities to reduce ratepayer costs through an overly conservative valuation of deliverability. 

CAISO has also evaluated potential mitigations to the concern related to n-2 contingencies that stakeholders have raised related to the On-Peak Deliverability Methodology. ACP-California supports further exploration of these potential options. And, in particular, is interested in a broad discussion on the option to use a form of Interim Deliverability Service (IDS) in instances where planned mitigation is under development and interconnection of the resource, in the interim as those mitigations are finalized, would provide overall system benefits. This type of a solution is critical given the delays in developing mitigation and upgrades that are being observed and experienced in the CAISO region, which may be preventing resources from interconnecting and providing critical support to the grid. We look forward to exploring options for a risk-based assessment to provide IDS as this initiative moves forward.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

ACP-California does not offer any specific comments on the Off-Peak Deliverability Methodology at this time, except to highlight that the use and structure of this methodology should be considered in the context of the new Slice of Day RA paradigm that will be implemented over the coming years, including discussing how OPDS resources contribute to RA under Slice of Day and whether that warrants changes to the approach used for the Off-Peak Deliverability Methodology employed by CAISO. There may be ways to align the Off-Peak Methodology with Slice of Day in a productive way and exploration of this topic should be part of the scope of this initiative (even if it is separated out of a later “track” of work).

We also encourage the CAISO to evaluate how deliverability needs and study methodologies could evolve under the Slice of Day framework to reduce total system cost associated with new procurement.  The CAISO should consider how deliverability in off-peak periods could be better forecasted and explicitly valued through the Energy-Only Off-Peak Deliverability Status (EO-OPDS) option.  ACP-California presented concepts for valuing Energy-Only Off-Peak Deliverability Status in the Slice of Day reforms.  We understand the need to continue to have a single FCDS value, but we believe there are ways to reduce ratepayer costs by valuing capacity across off-peak periods.  We encourage the CAISO to evaluate improvements to EO-OPDS study process and understand how it may provide value to Slice of Day reform and IRP procurement.  During the test periods for Slice of Day in 2024, the CAISO should evaluate how representative wind and solar resources with EO-OPDS (and not FCDS) could be valued in the Slice of Day framework.   

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

We commend CAISO for opening this initiative and exploring issues that should be addressed given changes across the system, including as the CPUC’s RA approach transitions to Slice of Day.

On issue #1, related to the use of multiple tests under the deliverability methodology (high and secondary system need), ACP-California generally agrees with CAISO that the transition to Slice of Day by the CPUC suggests that more, not fewer tests, may be warranted or utilized. Though it will be important to consider how resources are contributing to Slice of Day and whether all tests are necessary for all resources. We look forward to exploring this issue in more depth (and potentially in conjunction with the Off-Peak Deliverability Methodology assumptions and use) as this initiative progresses.

As stated earlier in these comments, on issue #2 (n-2 contingencies) and issue #3 (delays of deliverability network upgrades), ACP-California is particularly supportive of exploring the use of a form of ISD to address the schedule delays that are being experienced in securing deliverability status. And we agree that a “risk-based” approach is appropriate to use and will need to balance operational complexity, modest increases in system risk, and the value of having new resources come online earlier than they otherwise would. We support a strong focus on this particular issue within this initiative, as it appears well positioned to offer the most substantive benefits to increasing the amount of interconnected resources in the near-term while maintaining or improving reliability.

On item #4 (Diablo Canyon inclusion in deliverability studies post-2025), we support additional industry discussion on this topic. As CAISO has highlighted, there are a myriad of factors at play, including PG&E ability to retain its LGIA-based rights for up to three years after actual retirement of the Diablo Canyon Power Plant. Identifying a solution that allows for new resources to utilize the deliverability currently used by Diablo Canyon will be highly beneficial and can support development of new, diverse resources like Offshore Wind. However, it requires coordination with multiple parties and cannot be resolved by the CAISO alone. If CAISO is willing to use this venue to explore potential solutions, that would be welcomed.

ACP-California generally agrees with CAISO’s response to issue #5 (separating local capacity resources from system capacity resources) that this topic reaches beyond the deliverability study methodology. And we look forward to exploring it more in the upcoming RA initiative.

Finally, ACP-California supports CAISO proposed solutions to issues #6 (simultaneous dispatch) and #7 (dispatch levels). We look forward to further exploring issues related to more transformative changes in IPE and to considering targeted changed to the exceedance level approach for various types of intermittent resources.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

AES Clean Energy appreciates the opportunity to comment on the generation deliverability methodology review. Below, AES Clean Energy elaborates on comments submitted in December 2023 and discussed during the June 8, 2023 stakeholder meeting.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

AES Clean Energy appreciates CAISO’s responses to AES Clean Energy comment on the Update Paper.  AES Clean Energy’s comments focus on two issues including the application of N-2 contingencies in the deliverability studies and identified network upgrades driven predominantly by excess studied generation capacity.

1. The CAISO should study N-2 contingencies in the same manner that N-2 contingencies are monitored in real-time operations. If not, AES Clean Energy supports CAISO’s alternative proposal to provide interim deliverability and relief from N-2 constraints.

AES Clean Energy encourages the CAISO to reconsider studying N-2 contingencies in the deliverability methodology in the same way that they are considered in real-time operations. AES Clean Energy’s prior comments stated that while NERC TPL-001 dictates the study of N-2 contingencies under low-probability events, real-time operations only monitor N-2 contingencies for a few selected paths. In the issue paper, CAISO agreed with AES Clean Energy’s assessment and explained the reason for this difference is to ensure that N-2 contingencies are manageable when they occur in real-time.[1]

AES Clean Energy appreciates the CAISO for considering our comments but believes the deliverability study methodology is beyond NERC requirements.  NERC TPL-001 is a planning standard that requires an analysis to test the ability for generation to serve system load under N-2 critical contingency conditions. However, under N-2 contingencies, the CAISO’s On-Peak Deliverability methodology tests whether a generator can deliver its full net qualifying capacity (NQC) to serve load on selected paths based on identified generation pockets made in the dispatch assumptions.[2] The current methodology does not evaluate whether the system load can be reliably served per NERC TPL-001 standards and goes beyond NERC TPL-001 standards by testing whether generation can serve load in specific paths based on identified generation pockets.

The CAISO agreed that NERC does not generally require the analysis of N-2 contingencies in real-time operations.[3] AES Clean Energy’s understanding is that CAISO observes “always credible” and “conditionally” credible N-2 contingencies in real-time operations.  Therefore, AES Clean Energy suggests the CAISO to study N-2 contingencies in the deliverability studies in the same manner that N-2 contingencies are monitored in real-time operations.  For example, CAISO can focus on N-2 contingencies that are “always credible” and relax the mitigation requirement for “conditionally-credible” N-2s or consider non-wire solutions such as dynamic line rating (DLR) and storage as transmission (SAT) as a solution.  This will allow the CAISO to still meet its NERC requirements and prevent unnecessary mitigations including network upgrades. Adopting this approach will allow for additional deliverability on the existing network and will reduce potential transmission rate increases.

If the CAISO decides to not modify its study of N-2 contingencies in the deliverability studies, AES Clean Energy supports the CAISO’s proposal to provide interim deliverability and relief for customers waiting for transmission upgrades, including RAS, to mitigate N-2 contingencies. 

2. The CAISO should decrease the studied deliverable capacity in local areas or dismiss overload on identified constraints if they are pointed away from the load center.

AES Clean Energy believes the CAISO should either (1) decrease the studied deliverable capacity in local areas to prevent overloads on constraints that are not used to serve local loads or (2) dismiss overloads on the identified constraints if the overloads are in the direction away from the load center.  AES Clean Energy’s prior comments stated a concern that the studied deliverability capacity often exceeds the local load within the study area, resulting in inaccurate network upgrades requirements since not all studied capacity will interconnect and serve load within the study region.  In the Issue Paper, the CAISO responds stating that this issue is resolved under the Area and Local deliverability constraint framework where constraints with large amounts of generation behind them that trigger large, high-cost network upgrades are classified as Area Constraints, and corresponding ADNUs are identified. Then, a $/MW cost indicator is provided to the interconnection customers (ICs), so they can decide to choose either Option (A) or Option (B). ADNU costs are not assigned to ICs that select Option (A).[4]

However, this response does not address AES Clean Energy’s concern. AES Clean Energy is concerned the current study methodology identifies upgrades that aren't specifically needed to serve load within a local area. For example, resources looking to interconnect in the San Diego area were constrained due to the San Luis Rey-San Onofre 230kV constraint as identified in the diagram below:

The identified overload is not caused by constraints between generation within San Diego area load. Instead, the overload is driven by a surplus of studied generation that exceeds the load.

AES Clean Energy understands the need to study upgrades for system reliability, but the identified upgrades in regions like San Diego, where constraints are pointed away from the load center, should be carefully evaluated for its need.  In this specific example above, AES Clean Energy agrees that there is some reliability need for SDG&E area generation to help supply load in SCE’s service territory. However, as more and more generation capacity are added to the CAISO queue, the generation dispatch will deviate more from what is reasonable to observe in real-time operations. Therefore, AES Clean Energy suggests that the CAISO modify the deliverability methodology to limit the dispatch of Cluster units to some ratio of system load (i.e. 120%) or dismiss overloads on the identified constraints if the overloads are in the direction away from the load center.

[1] Issue Paper, p. 18.

[2] CAISO’s On Peak Deliverability Methodology, p. 6. 

CAISO groups new generations into electrical groups to test constraints under N-2 contingencies. The CAISO “[e]lectrically groups the proposed new generation units that are to be tested for deliverability.  These electrical groups will be based on engineering knowledge of the transmission system constraints on existing and new generation dispatch.  Generating units will be grouped by transmission limitations that will be expected to constrain the generation

[3] Issue Paper, p. 18.

[4] Issue Paper, p. 20-21.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

 AES Clean Energy has no comments at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

AES Clean Energy appreciates the CAISO for considering the industry’s concerns regarding its deliverability methodology assessment.  For the proposed scope, AES Clean Energy encourages CAISO to reconsider the application of N-2 contingencies within the on-peak deliverability studies. However, AES Clean Energy would support CAISO’s alternative proposal to provide interim deliverability and relief from N-2 contingencies if CAISO does not modify its study assumption.  In addition, the CAISO should continue to consider the issue of identified constraints that are directed away from the local load center. 

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The call that took place on June 8^th, many relevant issues were brought up but it seemed the CAISO was not in a position to adequately respond to those that were raised.  Because of this Avantus, urges the CAISO to treat these issues as relevant and not to be overlooked as the paper overall does not address them in their entirety.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

CAISO has nearly 28,000 MW of renewables (~54% of CAISO peak load) currently installed in its system. This number will be rapidly increasing at the rate of about 7,000 MW/year as directed by the CPUC. At the same time, the evening and night load will be increasing rapidly in the coming years as we see growing charging load of Electric Vehicles (EVs), charging load of batteries associated with Solar PVs, and increased load of “all electric” homes and businesses to the grid. Coupled with retirements of fossil fuel plants, the electric power deficiency in the evening and night will be higher than what it will be in the daytime in the very near future (~5 years).

The deficiency of electric power in the evening and night hours will grow year after year unless we provide resources to balance it. On the other hand, the daytime generation will also grow and will result in surplus generation that we must find a way to fully utilize.

The current CAISO generation queue shows 188 GW of generation, not counting Cluster 15. If we add Cluster 15 generation, that alone is 354 GW. Although not all generation in the CAISO queue will be built but it shows a glut of generation, mostly solar PV, that could be made available in the daytime.

Keeping the above observations in mind, Avantus is proposing the following study methodology changes:

1. Flow impact:

The current methodology ramps up the output of units with a 5% or greater distribution factor (DFAX) or Flow Impact. We feel a 5% DFAX is reasonable, but a 5% flow impact is way too restrictive. A 1000 MW unit with a 0.5% DFAX on a 100 MVA rated transmission line amounts to a flow impact of 5 MW or a 5% flow impact. In essence, we would have to reduce the output of that unit by 1000MW to get a 5MW flow reduction on this transmission line. This is way too restrictive. That is why generators electrically very far away from the deliverability constraint are being included in the 5% DFAX circle even though they barely have any impact. We request CAISO to reevaluate the 5% flow impact assumption.

2. Dispatch of generators in a study group:

In the current deliverability methodology, CAISO ramps up no more than 20 units to their maximum output within a study group. CAISO arrived at this number based on the cumulative availability of 20 units with a 7.5% forced outage rate would be 21%. This assumption needs further evaluation under the changing resource mix especially if it is leading to identification of excessive transmission constraints in the deliverability study.

3. MIC assumption:

The purpose of the deliverability methodology is that when we have a resource shortage, all FCDS generators in an area should be able to simultaneously export generation without being bottlenecked by the transmission system. Lately, CAISO has seen resource shortage conditions when there is a prolonged heat wave across the western US. During such conditions, imports into CAISO would not be available as other regions in the west would also be facing resource shortage conditions. The current modeling assumption in the deliverability methodology is to model imports at their historical max flows. This needs to be investigated as during a region wide resource shortage condition, these imports would not be available and modeling them at their historical max flows is not justifiable.

8. Load assumption:

CAISO uses a 1-in-10 peak load for reliability study and a 1-in-5 load for the deliverability study. CAISO should use the same 1-in-10 load in the deliverability study as well. This will lead to planning of a more secure system and more FCDS being awarded to resources especially in LCR areas.

1. Identification of constraints even though their loading is less than 100%:

In the 2023 TPD allocation report, CAISO identified several deliverability constraints even though their loading was less than 100%. For example, the Gates 500/230kV transformer bank loading is shown as 93.37% which means the transformer is not overloaded. An overload should be identified if the loading is >100%. Yet only 2053.34 MW was awarded deliverability out of the 3420.38 MW seeking it. We request CAISO to provide clarification on this.

In addition, Avantus is proposing the following generation modeling changes.  These changes are with the assumption that state agencies consider increasing their portfolios to allow for reserves during times when generation resources are insufficient to meet load demands:

1. Thermal generation modeling assumption:

CAISO currently models the output of thermal and intermittent resources based on their QC and exceedance values during the year of study. Currently, new renewable energy projects are not able to get deliverability as a major portion of deliverability is reserved by the existing thermal generation. Under the SB100 scenario, these units would be offline, and a significant amount of freed up deliverability would be available for new renewable energy projects. So the existing thermal generation is preventing the development of new renewable energy projects. Therefore, we request CAISO to consider this as a principal that warrants further discussion. A direction that this could take is that CAISO starts performing the deliverability study with generation modeling assumptions keeping SB100 in mind. CAISO can think about modeling thermal units at a reduced output as under the SB100 scenario, these units would be offline. This would lead to freed up deliverability being assigned to new renewable energy projects, and thereby speeding up their development. This would also prevent an overbuild of the transmission system.     

2. Hydro generation:

Model minimum possible hydro generation during the daytime. Save the Hydro for evening and night load. With this above approach, we can use the surplus solar PV in the generation queue to replace hydro at a 1:1 ratio. Thus, for a 500 MW hydro switched off, we can accommodate 500 MW of PV+BESS project to replace that hydro power. In addition, the hydro becomes available in the night when it is needed the most.

3. Pumped Hydro:

This is a common practice to use pumped hydro in the generation mode during the daytime and in the pump mode during the night-time. The times have changed now. With surplus solar PV in the generation queue, we can reverse the operation of the Pumped hydro by using it as a pump in the daytime and a generator in the night. By doing so, we will be adding load in the system as well as replacing the generation it was providing. Thus, if we have a 1000 MW pumped hydro operating as a 1000 MW generator and we switch it to a 1000 MW pump, we are adding a 1000 MW load to the system for which we need 1000 MW generation (ignoring losses) from the queue, and we need another 1000 MW generation from the queue to replace the original generation pumped hydro was providing. Thus, we can replace pumped hydro with a ratio of 2:1. In addition, the pumped hydro becomes a 1000 MW resource in the night time. In contrast, the PG&E’s HELMS Pumped hydro was modeled as a 1200 MW generator in the 2025 Summer peak base cases for Cluster 14 Phase I study. For illustration purposes, this same pumped hydro if modeled as recommended above would accommodate up to 2400 MW from the generation queue in the daytime and would provide up to 1200 MW of generation in the night.

4. Solar PV + Battery (Hybrid)

Most of the Solar PVs in the CAISO queue have batteries attached to them. If there is no battery, no modeling change is needed.

Again, due to surplus generation in the CAISO queue, it is recommended to use selected PV generation to charge the battery during daytime and save a majority portion of the battery for the night. By doing so, much of the glut can be used to charge batteries during peak hours and at the same time make these charged batteries available to handle a large portion of the load in the night.  With that approach of switching selected PV to charge battery rather than supply power to the grid, a 2:1 ratio can be achieved (twice the number of equivalent hybrids can be accommodated).

5. Standalone Battery System (BESS)

Current practice is to charge the battery from the grid during off-peak hours (night-time) and discharge it during peak hours (daytime). Due to glut of generation during daytime, it is very likely that charging from the grid during daytime may be cheaper (high supply, low demand) versus in the night-time. If not, some financial mechanism must be developed to compensate BESS owner for supplying energy during the night when it is needed the most.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

None currently.  

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

A number of issues have been raised by the Stakeholders such as (1) Should N-2 be evaluated for Deliverability studies and its upgrades be required before the projects come online, (2) Should Diablo be modeled in studies past 2025, (3) Should the local capacity resources be separated from the system resources, and (4) how do you mitigate the negative impacts on the customers for delays in completion of the Deliverability Network Upgrades.    

One major issue that is missing in the above list of issues is the “inaccurate modeling of the generation resources with changing times”. Avantus would like to highlight this issue and in doing so has provided proposed solutions outlined in Question 3.  Additionally, we’d like to state that the CAISO should update the generation modeling to reflect the current significant penetration of the renewables and changing loads.

Though the CAISO has proposed some solutions, we urge the CAISO to listen to its Stakeholders as we collectively are striving to creatively and economically be forward thinking as to how to mitigate the outlined issues being discussed in the paper. 

Given the board of approvals is slated to take place in November, its important that the CAISO is giving this the required attention needed to make informed decisions in such a short time frame.  Similar to the IPE 2023, the CAISO should consider hosting an “in person” workshop before any final mitigations are implemented.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the CAISO's Deliverability Assessment Methodology Issue Paper ("Issue Paper," hereafter) issued on May 31, 2023, and subsequently discussed during the stakeholder meeting on June 8, 2023. BAMx supports the Joint Proposed Framework for Discussion submitted by BAMx, California Energy Storage Alliance (CESA), and California Wind Energy Association (CalWEA).

BAMx believes that changes in the CAISO deliverability assessment methodology (described below) can be implemented that would allow significantly more renewable resources to be interconnected quickly, with fewer required transmission upgrades, without compromising the CAISO's ability to meet reliability requirements.

Table 1 below provides a summary of BAMx’s response to each of the issues.

We look forward to working with the CAISO and other stakeholders to ensure a reliable and economical transmission infrastructure.

[1] BAMx consists of City of Palo Alto Utilities and City of Santa Clara, Silicon Valley Power.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

See BAMx comments in response to Q.4.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

No comments at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

BAMx endorses key issues identified by the CAISO. Below we discuss the BAMx’s response to each of the issues.

1. Study of High and Secondary System Need: is more than one stressed system condition necessary?

The CAISO’s primary test is the “high system need” at the time of net peak (which is now also the time of our gross peak). The secondary test is currently performed for the period when solar is dropping off, but has not bottomed out. BAMx agrees with CAISO that, in many cases, HSN has been found to be more binding than SSN.[1] But then you have cases like South of Mesa corridor deliverability constraints and Lugo–Victor–Kramer Corridor Constraints, where SSN is found to be more binding than HSN.[2] SSN tests the ability of other resources to play their expected role as the solar resource output falls away, managing the transition. And BAMx recognizes that the CPUC RA counting of resources will change soon to look at 24 different “slice-of-day” values, further emphasizing the need to test the resource dispatch under additional conditions. However, the resource dispatch levels modeled should be representative of the expected dispatch consistent with resources’ qualifying capacity, and CAISO should allow for reasonable redispatch to mitigate overloads, particularly for storage resources that can flexibly move from discharging to charging and vice-versa. The examples shown in the “Reform of the CAISO Deliverability Test: Proposed Framework for Discussion” paper emphasize the need to model the resource dispatch at more reasonable levels that would offer the new interconnecting generators the required partial or full FCDS status, especially storage resource that we need for local and system reliability purposes.

2.  The need to consider N-2 (on common tower) contingencies.

The TPL-001 standard is one of NERC’s Transmission System Planning Performance Requirements and does not apply to generation deliverability studies. CAISO referenced FAC-002-3 during the June 8, 2023 stakeholder meeting; that standard mandates adherence to applicable NERC Reliability Standards; regional and Transmission Owner planning criteria; and Facility Interconnection requirements; and studies of system conditions under normal and contingency conditions.  The TPL requirements are not mandated to be met via a generation deliverability assessment process, and CAISO already ensures those are met as part of the TPP and GIP. BAMx believes that the application of N-2 contingencies in the deliverability assessment studies is unneeded and excessive. CAISO has access to a wide array of resources across a broad geographic area, including additional Planning Reserve Margin capacity to address common mode N-2 contingencies. The deliverability studies are focused on a subset of resources and thus do not properly consider CAISO’s ability to meet the TPL-001 standards, which are instead appropriately addressed in the reliability assessment. In generation deliverability studies, operating criteria violations can be mitigated simply by reducing some of the generation whose deliverability is being studied. Such a reduction will not necessarily lead to loss of load since the system is planned to have significantly more generation (at least 15% more generation; 17% for the CPUC-jurisdictional LSEs) than the total system demand across the CAISO balancing area that is required to meet the TPL-001 standards. The “Reform of the CAISO Deliverability Test: Proposed Framework for Discussion” paper includes a discussion on how the other RTOs, like PJM and MISO, do not model the N-2 contingencies for their generation capacity deliverability designation studies, the way CAISO does in its deliverability assessment.

The CAISO has suggested that “If a transmission project is delayed, then the n-2 requirement could be relaxed during the operating horizon, provided that reliability can be maintained.”[3] CAISO also has indicated that “Alternatively some form of Interim Deliverability Service (IDS) could be provided as long as planned mitigation is under development, and operational concerns are addressed.” BAMx supports providing interim deliverability based on the original project schedules, and accepting a higher risk of deliverability constraints in the interim period. After all, we need these resources to be built to meet mid-term reliability goals in the short-run, and with the Extended Day-Ahead Market (EDAM), we will need these resources to meet the Resource Sufficiency test. BAMx believes that not having some of the Area Delivery Network Upgrades (ADNU), especially those triggered by N-2 contingencies, will not threaten the reliable operation of the transmission system in either the near-term or the long-term. Although N-2 constraints have not driven the majority of ADNUs, we know that there are constraints like Lugo–Victor–Kramer Corridor on-peak deliverability constraints identified in the 2022-2023 Transmission Planning Process that was exclusively driven by P7 contingencies. In some cases, the lack of transmission upgrades may cause more congestion and/or renewable curtailments, but in our opinion, that can be handled as part of the economic assessment.

3. Overarching concern with delays of deliverability network upgrades

BAMx appreciates CAISO’s plans to explore providing interim deliverability based on the original schedules. We believe that CAISO can do this without increasing the risk of not being able to serve load due to deliverability constraints. Instead, we believe that by not disrupting the resource procurement cycle, CAISO will have access to a broader array of resources sooner and will increase its ability to reliably serve loads. In addition, BAMx emphasizes that the interim steps should not be a substitute for broader reform of the deliverability methodology.

4. Request to remove Diablo Canyon from deliverability studies post 2025.

No BAMx position on this issue at this time.

5. Consideration of separating local capacity resources from system capacity resources

This issue deals with creating two separate and distinct products (versus local capacity currently being a “premium” service that also meets system needs) and requires new approaches to manage the two sets of procurement requirements. BAMx is open to considering this issue in the CAISO’s upcoming resource adequacy initiative.

6. Simultaneous dispatch of resources inside a generation pocket

See the response to Issue #7 below.

7. Dispatch levels for a generation being studied in generation pockets.

BAMx appreciates the CAISO’s proposed transformative changes in the Interconnection Process Enhancement (IPE) 2023 Track 2 to better align resource planning, transmission planning, generation interconnection, and resource procurement. However, it is critical that in its deliverability assessment, the CAISO models generation dispatch levels in the generation pockets at levels that are consistent with the amount of capacity for which the resources receive RA counting credit. While it is true that during the August 2020 and August and December 2022 stressed system conditions, CAISO needed access to all available resources, and this was due to a lack of generation capacity, not a lack of transmission capacity. Modeling generators at their RA counting levels would enable more resources to be eligible for RA capacity without triggering the need for significant transmission network upgrades, as shown in the examples included in the “Reform of the CAISO Deliverability Test: Proposed Framework for Discussion” paper. If the concern is about congestion and/or renewable curtailments, in our opinion, that can be handled as part of a practical economic assessment to address potentially increasing levels of generation curtailments due to congestion. In response to BAMx’s suggestion on the Update Paper regarding the need for economic assessment to address potentially increasing levels of generation curtailments due to congestion, the CAISO pointed out that leaving the n-2 concerns to the TPP will lead to a burden on transmission ratepayers. To address any concerns that additional curtailment will unduly shift economic upgrade needs to the TPP, the curtailment impacts of a reformed deliverability test (i.e., whether storage enabled by reform will offset additional curtailments) can be tested in a production simulation study in the GIP.

[1] Issue Paper, p.24.

[2] CAISO 2022-2023 Transmission Plan, Appendix F: Detailed Policy Assessment.

[3] June 8^th Stakeholder Meeting Presentation, p.22.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The California Community Choice Association (CalCCA) supports the California Independent System Operator (CAISO) conducting a review of its deliverability study methodology. Timeliness and availability of deliverability is critical in advancing new resource development. The state will need to build and interconnect 175,000 megawatts (MW) between 2027 and 2045 to achieve the California Energy Commission’s (CEC) Senate Bill (SB) 100 Core Scenario. This will necessitate a per year build rate of over 7,000 MW – an increase of 557 percent from historical rates of annual new capacity additions. The CAISO’s primary focus of this effort should be on how to accelerate the availability of deliverability to support these new capacity additions.

Integrated Resource Plan (IRP) procurement orders and the Resource Adequacy (RA) program require load-serving entities (LSEs) to meet their obligations with fully deliverable resources. When the CAISO finds that transmission system upgrades and/or network upgrades must take place to make projects deliverable, Community Choice Aggregators (CCAs) and project developers rely on an investor-owned utility’s (IOU’s) timing and ability to make those upgrades. The upgrades can be costly, take many years, and as a result, often stall projects from moving forward to commercial operations. CCAs have identified delays in online dates due to both interconnection queue delays and IOU interconnection and transmission upgrade delays. Therefore, CalCCA is interested in further exploring the seven modifications presented in the Issue Paper, especially those that can increase the amount of available RA supply by providing interim deliverability status to projects with network upgrades in progress. CalCCA is also interested in exploring how to accelerate the necessary transmission system and network upgrades to more quickly expand the amount of deliverability available. In its review of the deliverability methodology, the CAISO must assess the impacts of any identified changes to the methodology to ensure such changes will accurately provide resources with deliverability without unnecessarily disadvantaging available resources and without compromising the level of reliability planned for through the RA program.

CalCCA looks forward to providing more specific comments on the seven modifications outlined in the Issue Paper after more fully evaluating each one.  

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

CalCCA has no additional comments at this time.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

CalCCA has no additional comments at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

CalCCA has no additional comments at this time.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

CESA supports the Joint Proposed Framework for Discussion submitted by the Joint Framework Proponents. Please refer to the comments submitted by the Joint Framework Proponents.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

CESA supports the Joint Proposed Framework for Discussion submitted by the Joint Framework Proponents. Please refer to the comments submitted by the Joint Framework Proponents.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

CESA supports the Joint Proposed Framework for Discussion submitted by the Joint Framework Proponents. Please refer to the comments submitted by the Joint Framework Proponents.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

CESA supports the Joint Proposed Framework for Discussion submitted by the Joint Framework Proponents. Please refer to the comments submitted by the Joint Framework Proponents.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) is the state-appointed independent consumer advocate at the California Public Utilities Commission (CPUC).  Our goal is to ensure that all Californians have affordable, safe, and reliable utility services while advancing the state’s environmental goals.  Our advocacy efforts to protect California customers span the areas of energy, water, and communications regulation.[1]

Cal Advocates appreciates the California Independent System Operator (CAISO) stakeholder discussion on this important topic prior to the analysis phase of the 2023-2024 transmission planning process.  The following are Cal Advocates’ recommendations for the scope of this initiative.

1. Include a Discussion on the Need to Consider N-2 Contingencies in Deliverability Studies.

The CAISO states that studying N-2[2] contingencies on double-circuit towers in generation interconnection studies is a North American Electric Reliability Corporation (NERC) requirement.  The CAISO also states that Midcontinent Independent System Operator (MISO) and PJM comply with this same requirement.[3] 

Cal Advocates confirmed that PJM considers common mode (N-2) contingencies in its generator interconnection studies.[4]  Cal Advocates requests further discussion during this CAISO stakeholder initiative on the method and assumptions PJM utilizes when it applies the common mode outages.  Further discussion will facilitate a more thorough comparison with the CAISO’s practices.

Cal Advocates also confirmed that MISO does not consider N-2 contingencies in its generation interconnection deliverability studies.  Per the MISO Business Practice Manual referenced, MISO only considers P0 and P1[5] (normal and N-1) contingencies in its deliverability studies.[6]  A current MISO employee explained that “deliverability is performed by creating a stressed dispatch case.  Adding more complex contingencies are deemed not credible and therefore only N-1 is performed for deliverability…Only using N-1 aligns with operation where the market is only looking at N-1.”[7]

Similarly, Southwest Power Pool (SPP) considers a different set of contingencies in its generator interconnection studies.  For its stability analysis, SPP considers P0, P1, P2.1-2.3, P4 and P5 events.[8]  “Higher depth contingencies” such as P6 and P7[9] are evaluated as necessary.[10]  SPP also does not consider P3[11] contingency events for interconnection services because the standard allows generation adjustments before the second event.[12]

Based on Cal Advocates’ research, transmission operators determine which contingencies to consider for generation interconnection studies based on standard allowances, system operations and other documented factors.  For this reason, Cal Advocates recommends further discussion on whether N-2 contingencies should be evaluated in the CAISO’s generation interconnection deliverability studies.  Cal Advocates also makes the distinction that generator interconnection studies include separate reliability and deliverability studies.  The reliability studies should consider the grid's performance under normal and contingency conditions in compliance with the NERC planning standards.[13]  The deliverability studies, in contrast, should determine if generators can operate at their maximum capacity without being constrained by the electrical system.[14]

2. Evaluate whether a resource can meet local resource adequacy needs in the generation interconnection studies.

Cal Advocates requests consideration of local resource adequacy needs in the generation interconnection studies, as well as system resource adequacy needs.  To this end, the studies should determine if new generating resources can meet local resource adequacy needs and/or system resource adequacy needs.

[1] Public Utilities Code Section 309.5.

[2] N-2 also referred to as P7 and stands for multiple contingencies such loss of 1. two adjacent vertically or horizontally) circuits on common structure. Or 2.  Loss of a biopolar DC line.  This is the most extreme steady and stability test category per NERC TPL-005 Transmission System Planning Performance Requirements.

[3] Deliverability Assessment Methodology Issue Paper, CAISO, May 31, 2023 at p. 4.

[4] PJM Manual 14B, PJM Region Transmission Planning Process, Revision 52, April 10, 2023 at pp.45-46.

[5] P1 standards for a single contingency such as loss of one of the following: 1. Generator. 2. Transmission Circuit. 3. Transformer, 4. Shunt Device or 5. Single Pole of a DC line.

[6] MISO Generation Interconnection Business Practice Manual BPM-015 r25 (MISO PBM), March 1, 2023 at p. 121.

[7] Email to Public Advocates Office staff from Ryan Westphal, Senior Manager – Resource Utilization, MISO Energy, June 15, 2023 at 12:37 pm.

[8] Southwest Power Pool Generator Interconnection Manual (DISIS Manual), SPP  Generation Interconnection Department, January 2023 (SPP Manual) at p. 29.

[9] P6 and P7 are multiple contingency events.  P7 is the same as a N-2 event.

[10] SPP Generation Interconnection Manual at p. 29.

[11] P3 stands for a multiple contingency that involves the loss of a generator unit followed by system adjustments.  The loss can be one of the following: 1. Generator. 2. Transmission Circuit. 3. Transformer. 4. Shunt Device and 5. Single Pole of a DC line.

[12] SPP Generation Interconnection Manual at p. 20.

[13] MISO BPM at p. 46.

[14] MISO BPM at p. 119.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

Cal Advocates has no comments on this issue at this time.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

Cal Advocates has no comments on this issue at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

Please refer to our response to question 1.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

CalWEA wishes to confirm its endorsement of the separately submitted document, Reform of the CAISO Deliverability Test: Joint Proposed Framework for Discussion, jointly proposed by the Bay Area Municipal Transmission Group (BAMx), California Energy Storage Alliance (CESA), and the California Wind Energy Association (CalWEA).  We very much hope that this document will help to foster a productive and collaborative discussion toward sound and meaningful reforms of the deliverability test.  

We have no further comment at this time.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

CEERT appreciates the CAISO’s recognition that extensive delays in completing transmission upgrades required by many interconnection customers in order to begin delivering power under power purchase agreements are creating a serious obstacle to achieving California’s climate goals and maintaining system reliability.  We strongly support the CAISO’s efforts, across multiple stakeholder processes, to reduce the impact of these delays.  CEERT strongly supports the proposed change that would award interim deliverability status to projects while they wait for n-2 mitigations measures to be completed. It will be helpful to understanding the process for determining eligibility for interim deliverability status that the CAISO develop and publish clear criteria for determining the level of acceptable operational risk of waiting for n-2 mitigations to be completed.

CEERT also understands the CAISO’s explanation as to how it currently uses high and secondary system needs to evaluate deliverability as well as the acknowledgment that changes to the deliverability assessment methodology will need to be developed to effectively administer the hourly slice-of-day approach to resource adequacy.   The slice-of-day approach to resource adequacy has been developed to assure that load serving entities have sufficient resources to meet load and to charge batteries included in their resource portfolios. As the CAISO has explained, the SSN test is meant to test the ability to deliver energy reliably during the hours when solar generation is dropping off and a transition to other resources is required.  CEERT believes that is critically important that the CAISO carefully study the performance of battery resources hour-by-hour during the evening transition period in order to balance decisions about the need for investments in system upgrades with possible changes to the economic dispatch of resources during transition hours including battery storage.

CEERT is concerned that delays in the completion of deliverability projects could disrupt resource procurement of clean energy resources by load serving entities.  The uncertainty caused by delays in interconnection could potentially result in the procurement of alternative, higher cost resources than those that would have been procured if the assignment of deliverability had not been deferred or delayed.  CEERT appreciates the efforts the CAISO has made in the quarterly transmission development forum to better understand the cause of delays.  However, we believe a higher level of visibility is needed to make policy makers aware of the impact of delays in needed network upgrades to assure energy deliverability.

Finally, CEERT applauds the CAISO’s statement that it is time to consider a clearer separation of decisions about the adequacy of local capacity resources from system resource adequacy decisions.  Much fossil generation in California is being kept online and in reserve because of local capacity requirements.  Local resources such as distributed solar, battery storage and demand response measures could be used to reduce local capacity requirements.  However, the need to obtain export deliverability from constrained local areas has been a major obstacle to the development of clean energy resources in these load pockets.  The expeditious creation of two distinct and separate resource adequacy products can help load serving entities adopt innovative solutions to reduce dependence on fossil fuel generation. We understand that this issue will need to be addressed both by the CPUC in its IRP and RA processes and by the CAISO in its resource adequacy stakeholder proceeding.     

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

It is clear to CEERT that the assessment that is conducted to determine deliverability during high and supplemental system need hours is becoming outdated and will need to be revised in advance of the CPUC’s transition to the 24-hour slice-of-day approach for the resource adequacy program.  One of the considerations the CAISO may want to consider for granting interim deliverability is the recognition that projects that impact the transmission system during the transition (SSN) hours could be re-dispatched through battery charging to overcome specific contingencies that may occur in the near term. 

The use of a 50% exceedance-based output value for wind and solar generation for hours 15 through 18 seems arbitrary and requires better explanation by the CAISO.  It is not clear to CEERT why the wind and solar resources during these hours could not be used to charge batteries or be curtailed during contingencies that may occur during these transition hours.  

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

CEERT understands that the purpose of the off-peak deliverability assessment is to identify what local transmission upgrades will be needed to prevent excessive renewable curtailment caused by constraints in the transmission system during hours when solar generation is high.  We understand that the study design is set up to focus on system conditions when there is not a system-wide oversupply of solar, wind or other resources that requires curtailment.  Instead, the study focuses on specific areas like the Central Valley where there may be significant solar resources that require curtailment because transmission is constrained to export the power to other load centers.

CEERT is concerned that the aging infrastructure in the Central Valley that was built long before the growth in solar power began, creates conditions where significant curtailment is likely to occur in the future.  The 2022-2023 transmission plan’s sensitivity scenario identified numerous 60 kV and 115 kV lines in the Central Valley that would be overloaded during off-peak conditions.  While it is important to identify specific bottlenecks that would occur and to consider reconductoring, it is not clear that reconductoring lower voltage lines is a sufficient solution in itself for enabling the development of solar generation in the Central Valley as well as providing a pathway for the delivery of significant amounts of offshore wind energy from the Central Coast wind area.  It is likely that larger, area-wide deliverability upgrades will be needed and will prove economically efficient and improve system-wide reliability.  CEERT encourages the CAISO to use it zonal focus paradigm for considering transmission projects to meet off-peak deliverability constraints, particularly in regards to Central California.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

Generally, CEERT supports the timeline proposed by the CAISO for the Generation Deliverability Methodology Review initiative and coordination with Phase 2 of the Interconnection Process enhancements initiative.  Interconnection and deliverability assignment reform is urgently needed in California.  Current processes and procedures are not only setting back California’s clean energy agenda but creating higher electricity costs for customers.  Researchers at Lawrence Berkeley National Laboratory have found that interconnection costs have increased by an order of magnitude over the last several years.[1]   CEERT recognizes that the CAISO’s proactive zonally-focused transmission planning process will help overcome this challenge to timely and cost-effective interconnection as it is implemented.  However, in the interim flexible measures are needed in applying the deliverability assessment methodology to assure that projects that are ready to interconnect and delivery energy are able to do so.

[1] Queued Up: Characteristics of Power Plants Seeking Transmission Interconnection As of the End of 2022 Joseph Rand, Rose Strauss, Will Gorman, Joachim Seel, Julie Mulvaney Kemp, Seongeun Jeong, Dana Robson, Ryan Wiser Lawrence Berkeley National Laboratory.  https://emp.lbl.gov/sites/default/files/queued_up_2022_04-06-2023.pdf

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

We are happy to see acknowledgment that leaving mitigation to the planning process is neither timely nor effective and that the CAISO is evaluating interim deliverability options.

Slides 22 and 37 addressed n-2 specific considerations, which are separate from Slide 38, which mentions general concerns with deliverability delays due to network upgrades required, and states that the ISO would like to explore providing interim deliverability based on original schedules: could you please give some examples of how the CAISO is planning to review and assign interim deliverability?

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

Intersect Power has no comments at this time.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

Stakeholder Proposed Reforms (N-2 elimination and QC alignment with CPUC) 

Intersect Power encourages the CAISO to set aside the Issue Paper conclusions, and further consider certain reforms that have been proposed by stakeholders, including: (1) the elimination of N-2 contingency scenarios in the deliverability studies, and (2) the alignment of deliverability study dispatch assumptions with the CPUC’s determined Qualifying Capacity (QC) values for the applicable hours and technologies. Intersect Power believes these represent meaningful reforms that will maximize the use of existing and planned transmission system without jeopardizing reliability. Stakeholders have previously submitted, or will be submitting into this comment period, several technical arguments, references, and examples justifying these reforms, and the reforms warrant careful consideration and discussion prior to conclusions being made.

Maximum Import Capability

Intersect Power requests the CAISO evaluate the adequacy and suitability of the process of Maximum Import Capacity (MIC) allocation for counting deliverability of imported resources. There’s a considerable amount of deliverability reserved for imported resources. It therefore represents a material input (i.e., can largely influence the starting amount of available deliverability in an electrical region) into the deliverability assessment methodology, which is the subject of this stakeholder process. Intersect Power has several questions related to the MIC process that would provide helpful clarity to stakeholders on this topic:
 

1. Is a different process for allocating deliverability for in-CAISO resources vs. imported resources necessary on a go-forward basis?
2. Under the current process, do imported resources provide the same reliability benefit that in-CAISO resources provide, and how subjective is that conclusion?
3. Are imported resources studied to the same extent (i.e., constraints, contingencies, dispatch, etc.) from the point of generation to the point of delivery, as in-CAISO resources?
4. Are the criteria for determining the “dispatch” of imported resources reasonable and consistent with in-CAISO resources?
5. Is there a pathway to eliminate, or gradually phase-out, the MIC allocation process so that a single, consistent approach to deliverability allocation can be utilized for both in-CAISO and imported resources?

Interim Deliverability

Intersect Power strongly applauds and supports CAISO’s proposal to mitigate transmission upgrade delays by increasing the opportunities for interim deliverability status (IDS) and encourages CAISO to maximize transparency around deliverability awards.

CAISO has proposed that once a transmission upgrade project is under development, the RAS guidelines can potentially be relaxed until the upgrade is energized.  This would allow CAISO to allocate IDS to customers while they wait for the upgrades to be constructed, if any reliability concerns are addressed.  Intersect Power strongly supports this concept.  Customers are experiencing significant and often unexpected delays to deliverability upgrades that are preventing them from delivering resources needed to comply with the state’s reliability and climate goals.

Intersect Power also strongly encourages the CAISO to improve the transparency around deliverability designations.  Developers need two key pieces of information as early as possible: (1) exactly which upgrades apply to their projects; and (2) whether IDS is available and will continue to be available. 

First, CAISO must notify customers of which deliverability upgrades impact their projects.  CAISO does not currently identify which upgrades apply to which projects.  Although this information may be gleaned through careful study of multiple technical documents, it is very difficult, if not impossible, for most market participants to determine with confidence.  Transparent information about which upgrades will impact specific projects is critical so that developers can follow the progress of the correct projects and identify whether IDS may be available.

Second, CAISO must notify customers of the potential for IDS as soon as possible.  This assessment should be conducted as part of the main deliverability study and results shared with customers along with their deliverability allocations.  Especially considering the long lead times associated with upgrades recently approved in the 2022-23 Transmission Plan, customers will need to know as soon as possible whether there will be IDS available so that they can begin the development process at the right time. Additionally, customers need to know whether IDS will continue to be available after initial receipt. An annual threat of losing IDS presents the same financing challenges as not having IDS to begin with due to the lack of certainty. Therefore, it is necessary to provide certainty of IDS beyond a one-year period, and preferably until the point at which Full Capacity Deliverability Status (FCDS) or Partial Capacity Deliverability Status (PCDS) has been achieved.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

 Intersect Power has no comments at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

Intersect Power’s comments on key issues are provided in response to question #2. In short, there are potential reforms (N-2 elimination, QC alignment with CPUC counting rules, and an evaluation of the MIC allocation process) that offer a more accurate reflection of the capabilities of the existing and planned transmission system and its resource portfolio without sacrificing reliability. Additionally, Intersect Power fully supports the CAISO’s efforts to provide more clarity and certainty into IDS, and strongly encourages the CAISO to pursue ways to further enhance those outcomes beyond what is described in the Issue Paper.

Intersect Power agrees with the CAISO’s proposed timeline, which would culminate in a final proposal going before the CAISO Board of Governors in the Winter of 2023, allowing for any relevant reforms to be implemented into the next Transmission Planning Deliverability (TPD) allocation window occurring in ~Q2/Q3 2024. However, in the event unanticipated delays are encountered, Intersect Power encourages the CAISO to evaluate and determine an outside date for when a proposal would need to be finalized and approved to be implemented in the ~Q2/Q3 2024 TPD allocation window so that appropriate measures can be taken to ensure that timeline is not exceeded.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The Joint Framework Proponents recommend that CAISO and the parties discuss reform of the CAISO’s deliverability test based on the following proposed framework, which will foster development of a common understanding of each specific issue and various possible reforms that aim to address CAISO’s stated concerns. This framework addresses comment template questions 2-4.

Proposed Tenets for Discussion

1. The purpose of the deliverability test is to qualify resources for the CPUC’s RA Program at a level up to their Qualifying Capacity (QC) levels established by the applicable local regulatory authority.[1] 

1. 1. Each LRA’s Resource Adequacy (RA) Program sets QC counting rules for various resource types and an overall QC procurement requirement, including a Planning Reserve Margin (PRM). The overall requirement is allocated across the LRA’s load-serving entities and is expected to ensure sufficient reliability resources will be procured and made available to the CAISO.  QC resources must be deliverable to load, as determined by the CAISO. Thus, the purpose of the deliverability test is to ensure the availability of sufficient resources to serve the system load under stressed system conditions. 

2. The CAISO has various means of addressing system reliability apart from the  deliverability test.

1. 1. System reliability is currently addressed by LRA RA Programs, as well as the CAISO Transmission Planning Process (TPP), and the Generation Interconnection Process (GIP) reliability studies, and not from the CAISO deliverability test. If additional reliability concerns remain with the generation interconnection process, additional reliability test scenarios could be added to the generation interconnection study process. 

1. 2. Reforming the deliverability test will create widespread additional deliverability capacity that will enable storage resources to obtain deliverability status, qualify for the CPUC’s RA Program, and absorb renewable energy that would otherwise be curtailed, substantially and simultaneously mitigating curtailment concerns.

3. The deliverability test should assume stressed, but not extreme, system conditions.  Otherwise, new capacity will be blocked from helping to address stressed conditions.[2]
   1. There are no NERC standards for deliverability tests.[3] 
   2. Reliability studies, governed by NERC standards, should use generation dispatch similar to the levels used in the CAISO’s TPP reliability studies, including the re-dispatch of resources.[4] 
   3. PJM and MISO effectively use resources’ Effective Load Carrying Capability (ELCC)-based QC levels for generation capacity designation studies (which is equivalent to the CAISO generation deliverability test) of Variable Energy Resources.[5]
   4. For assumed transmission system performance, neither MISO nor PJM uses an N-2 contingency scenario,[6] which is a very rare occurrence, for their generation capacity deliverability designation studies.[7]^,[8]
   5. The HSN test is appropriately focused on the times of highest system reliability risk (e.g., HE 18-21) during summer months, when it is necessary for all RA resources to be deliverable to load (at their QC levels).
   6. The SSN test focuses mainly on the local curtailment of supply resources, which does not translate to a lack of system reliability from an RA capacity standpoint since other system resources are available to meet the demand plus PRM.  In fact, PJM and MISO use only one test, equivalent to HSN, aimed at the high system need period when testing for generation capacity designation for RA.
   7. The stakeholders represented herein support the CAISO’s proposal to allow for the assignment of interim deliverability status to assets awaiting the finalization of upgrades related to meeting N-2 requirements. We believe, however, that this change should apply to CAISO’s standard long-term deliverability eligibility criteria, consistent with the tenets above.
   8. Reform will enable existing transmission and new upgrades that have been approved by CAISO to accommodate more generation and storage capacity that will be needed to meet state reliability and clean energy goals.

Proposed Reform Elements for Discussion

1. Stressed, but not extreme, conditions should be assumed in deliverability test studies.

1. 1. Assumed dispatch levels & QC values

Each proposed new variable energy generator’s dispatch should be set at, rather than above, its LRA-determined QC value (i.e., the value that the LRA’s RA Program is counting on).  (Any production above that level can be curtailed in actual operations.)  All existing Variable Energy Resources (VER) should be dispatched in the studies according to their already-assigned NQC levels.[9] A reasonable way to revise the storage dispatch assumptions within the SSN test, if retained, would be to use the average dispatch value interval being studied.[10]  (Appendix A demonstrates how a new storage generator fails the current deliverability test due to unreasonable dispatch assumptions made under the current CAISO deliverability test.)

For RA Year 2023, the CPUC’s QC values for VERs are statistical expectations for production from VERs achieved over many hours, not necessarily during times of potential resource shortfalls.  However, the CPUC has adopted new QC methodologies in the future for its new 24-hourly RA framework that will reflect expected generation levels during each hour.  The CPUC plans to apply the new 24-hour Slice-of-Day framework in 2024 as a test run.  It would be reasonable for CAISO to adopt the CPUC’s new QC values for CPUC-jurisdictional LSEs at the earliest possible time.  Finally, the deliverability test should only apply to those time slices during which there is a distinct possibility of loss of load. 

1. 2. Assumed transmission system performance

Deliverability studies should assume only normal (N-0) and N-1 contingency conditions. 

1. 3. Study area

We recommend that CAISO consider the same flow impact levels being used by PJM for determining the generation circle behind constrained deliverability flowgates.  PJM uses 5% DFAX for all constrained transmission lines up to 500 kV and 10% DFAX for all constrained transmission lines at 500 kV and above.[11] 

2. Reliability and Curtailment Concerns should be addressed separately 

1. 1. Reliability upgrades that currently come out of GIP are limited as they are based on a very limited set of reliability studies.  To address any concerns about reliability not currently addressed in the Generator Interconnection Process, an additional reliability test with an expanded scope could be added to the GIP.[12]  Such reliability studies should use generation dispatch similar to the one used in TPP reliability studies, including re-dispatch of resources.[13] 

2. 2. To address any concerns that additional curtailment will unduly shift economic upgrade needs to the TPP, the curtailment impacts of a reformed deliverability test (i.e., whether storage enabled by reform will offset additional curtailments) can be tested in a production simulation study in the GIP.                                                                                                                     
3. Local deliverability test

We understand that CAISO intends to deal with the issue of local versus system deliverability designation as part of a separate stakeholder process on RA capacity.  We support that decision.  We, however, believe that many of the technical criteria for determining local deliverability designation should be addressed as part of this initiative due to its highly technical content that is dependent on transmission-related studies.

[1] The California Public Utilities Commission (CPUC) establishes QC rules applicable to approximately 90% of the CAISO load. The remainder is determined by local, state or federal entities. CAISO awards Net QC (NQC) depending on available deliverability capacity. If a resource is fully deliverable, then there is no difference between QC and NQC.

[2] The most common stressed conditions – as experienced during the rolling blackouts in August 2020 and the extended stress conditions in September 2022 – is when there is a shortage of resources available in high-demand hours (i.e., the evening net peak), exacerbated by extreme weather. Had there been more generation resources available during those events, more loads could have been served with the existing transmission system. During the August 2020 event, while some imports were not available due to derates of the California-Oregon Intertie (COI), CAISO’s deliverability assessment methodology does not directly apply the N-2 criteria to CAISO interties, instead relying on historical import levels that actually occurred across a branch group during high load hours. This is much less stringent than testing all N-2 conditions that might materialize. During the other events, transmission limitations were not the key drivers of the stressed conditions. Source: CAISO Root Cause Analysis, Mid-August 2020 Extreme Heat Wave, January 31, 2021, pp. 8, 22 ,48, and 88.

[3] The TPL-001 standard is one of NERC’s Transmission System Planning Performance Requirements and does not apply to generation deliverability studies. CAISO referenced FAC-002-3 during the June 8, 2023 stakeholder meeting; that standard mandates adherence to applicable NERC Reliability Standards; regional and Transmission Owner planning criteria; and Facility Interconnection requirements; and studies of system conditions under normal and contingency conditions.  The TPL requirements are not mandated to be met via a generation deliverability assessment process, and CAISO already ensures those are met as part of the TPP and GIP. Including the N-2 contingencies within the deliverability studies does not itself guarantee that the TPL requirements can be met, merely that an amount of load equal to the modeled generation in a subset of the system could be served if the assumed generation is available; however, the levels of generation included in the deliverability studies may be significantly higher than the amounts of generation that reasonably could be expected from the generation resources during the most stressed system conditions.

[4] CAISO 2023-2024 Transmission Planning Process Draft Study Plan, February 21, 2023, p.11, and APPENDIX B: Reliability Assessment of the CAISO ISO 2022-2023 Transmission Plan May 18, 2023, pp. B-18:B-24.

[5] For the purpose capacity designation studies, both MISO and PJM allow the project to select the desired capacity up to their peak capacity and study the project based on the selected capacity.  However, since Variable Energy Resources cannot claim more than their ELCC for RA capacity, VERs are effectively studied at their ELCC. 

[6] An N-2 condition is the unexpected failure or outage of two major system components, such as a generator, transmission line, circuit breaker, switch or other electrical element. CAISO studies common mode (i.e., two circuits on the same tower) contingencies in its generation deliverability assessment methodology.

[7] MISO’s BPM states:  "Contingency files for deliverability studies should only contain P1 and P0 contingencies.” See MISO Generation Interconnection Business Practices Manual BPM-015-r25, Effective Date: MAR-01-2023, Appendix C MISO Generation Deliverability Study Method, p. 121.    

[8] PJM Manual 14B, Appendix C (on Generation Deliverability) Revision: 52 Effective Date: April 10, 2023, on Page 85 says:  “Deliverability, from the perspective of individual generator resources, ensures that, under normal system conditions, if Capacity Resources are available and called on, their ability to provide energy to the system will not be limited by the dispatch of other certified Capacity Resources. This test does not guarantee that a given resource will be chosen to produce energy at any given system load condition. Rather, its purpose is to demonstrate that the installed capacity in any electrical area can be run simultaneously, and that the excess energy above load in that electrical area can be exported to the remainder of PJM, subject to the same single contingency testing used when examining deliverability from the load perspective.” The text is bolded to emphasize that, although PJM’s deliverability test includes both single and common mode (N-2) contingencies, the capacity designation part of the generator deliverability test only includes the single contingencies.

[9] Currently, CAISO assumes that all existing, previously studied Variable Energy Resources (VERs) in the study area are assumed to operate at levels higher than their NQC levels granted by the CAISO, and all VERs requesting deliverability in the study area are assumed to operate at levels higher than the QC levels set by the LRAs.

[10] The Issue Paper notes that CAISO currently assumes a resource output of 50% for storage resources in the SSN test. The ISO argues that this is reasonable since the assumptions are based on recent historical performance. The ISO’s reasoning, however, conflicts with the data observed during the September 2022 events where storage dispatch levels throughout the SSN window ranged between 10-46%. The CAISO argues that the storage assets are dispatchable and uses that as a justification for using their values in the later hours of the SSN timeframe, given their highest need at that time. (CAISO Issue Paper at p. 24.) 

[11] PJM Manual 14B, Appendix C, Section 3.1 on Generator Deliverability Procedure.

[12] Any resulting reliability upgrades are required to be financed by the developer, with refundability.

[13]  NERC reliability studies typically assume historical production or Security-Constrained Economic Dispatch (SCED) dispatch levels. 

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

LSA has no comments at this time.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

N-2 v. N-1 Contingency: 

CAISO’s use of the N-2 contingency in its deliverability assessment goes further than what is required and can be adjusted without impacting system reliability.  TPL-001 is a NERC planning standard that requires a Balancing Area (BA) to ensure that it has enough resources to serve system load under peak conditions assuming an N-2. contingency.  Under this system wide reliability analysis, the BA can depend on the entire system to deliver resources to load using multiple paths and re-dispatch options.

CAISO’s deliverability study, on the other hand, focuses only on a subset of the system to assess whether the resources within that local area can deliver to load using only the paths available within that area.  Under this local area deliverability analysis, applying an N-2 contingency may be too strict because the CAISO in real time can typically rely on the entire system to deliver to load.  Applying the N-2 standard to an assessment that already limits the ability of resources to access all the pathways that are typically available to them in real time may be too conservative.  It may also go beyond the intent of the NERC requirement, which does require application of an N-2 contingency, but only in a system reliability assessment where the CAISO can rely on all pathways to serve load.

LSA appreciates CAISO’s consideration of whether using the N-1 contingency when appropriate for deliverability assessments could more effectively maximize use of existing infrastructure without jeopardizing system reliability.

Interim Deliverability:

LSA supports CAISO’s proposal to mitigate transmission upgrade delays by increasing the opportunities for Interim Deliverability Status (IDS) and encourages CAISO to maximize transparency around deliverability awards.

CAISO has proposed that once a transmission upgrade project needed for deliverability is under development, the RAS guidelines can potentially be relaxed until the upgrade is energized.  This would allow CAISO to allocate IDS to customers while they wait for the upgrades to be constructed, if any reliability concerns are addressed.  LSA strongly supports this concept.  Customers are experiencing significant and often unexpected delays to DNUs that are preventing them from bringing resources on-line that are needed to comply with the state’s reliability and climate goals.

LSA also strongly encourages the CAISO to improve the transparency around deliverability designations.  Developers need two key pieces of information as early as possible: (1) exactly which upgrades apply to their projects; and (2) whether IDS is available. 

First, CAISO should notify customers of which deliverability upgrades impact their projects when the TPD awards are made, and of any changes later (e.g., upgrades that are no longer needed for the FCDS or PCDS designation).  CAISO does not currently identify which upgrades apply to which projects.  Although this information may be gleaned through careful study of multiple technical documents, it is very difficult, if not impossible, for most market participants to determine with confidence for a specific project.  Transparent information about which upgrades will impact specific projects is critical so that developers can follow the progress of the correct transmission projects and identify whether IDS may be available.

Second, CAISO must notify customers of the potential for IDS as soon as possible.  This assessment should be conducted as part of the main deliverability study and results shared with customers along with their deliverability allocations.  Especially considering the long lead times associated with upgrades recently approved in the 2022-23 Transmission Plan, customers will need to know as soon as possible whether there will be IDS available, so that they can determine the risks of proceeding on their then-current development timelines or delay their CODs to match FCDS/PCDS timing.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

LSA has no comments at this time, other than to say that, since any upgrades identified are entirely voluntary and the value of OPDS does not seem to have been recognized by off-takers, it does not yet make up for upgrades that are not identified in the on-peak analysis (e.g., via the SSN scenario, in the few instances where it is binding).

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

LSA supports the CAISO’s intent to consider the possibility of a local deliverability designation but encourages a stronger commitment to considering this option on a timeframe that would allow it to impact the next round of deliverability allocations in February of 2024.  This issue was not mentioned at all in the CAISO’s recent RA Enhancements Initiative workshop, and the CAISO should address this issue before the next TPD Allocation cycle.

CAISO’s paper acknowledges the potential benefits of a local deliverability designation.  With the addition of significant volumes of storage to the grid, a resource’s ability to deliver to nearby storage, in addition to load, is a valuable asset that does not exist within the current deliverability framework.  CAISO points out two major hurdles to moving forward with implementing such a designation.  First, CAISO identifies potential technical issues, including the fact that adding a local deliverability designation could impact deliverability for existing resources outside the local area.  Second, CAISO points out potential policy issues, including the fact that introducing a new local deliverability designation would result in the creation of a new Resource Adequacy product.

CAISO recommends moving this issue out of the Deliverability Methodology Assessment initiative and into the RA Reform initiative.  LSA is encouraged that CAISO intends to pursue this concept but has two main concerns with CAISO’s approach:

1. A decision on this new designation should be made soon so that, if adopted, it can be incorporated into the next Transmission Plan Deliverability (TPD) allocation process in February 2024.  The latest incarnation of the CAISO’s RA Reform initiative does not appear to have officially started and may continue through the middle of 2025, according to a recent CAISO presentation on RA Reform efforts.[1]  If CAISO pushes the local deliverability conversation into the broader RA Reform conversation, there is little chance that it would be completed in time to impact the next round of TPD allocations, which could mean that the new designation would not be available for Cluster 14, and the potentially significant allocations to those projects based on the 2022-2023 Transmission Plan.  .  Considering the volume of resources the state must add to the grid to meet state goals, CAISO does not have the luxury of waiting multiple years to investigate the potential to bring more resources online faster and more effectively by adjusting its deliverability assessment to meet the needs of the current resource fleet.
2. The technical issues CAISO has identified would be better addressed in the current Deliverability Methodology Assessment forum.  Stakeholders and CAISO have already engaged their technical staff to engage in this discussion and they could efficiently include the local deliverability topic because it would involve the same group of people.  If CAISO moves the discussion to the RA reform initiative, the broader policy related issues may crowd-out the deeper technical discussion that needs to occur on this topic.  It would be more efficient for the current Deliverability Methodology Assessment initiative to retain at least the technical aspects of the proposal to create a local deliverability designation.

LSA believes that CAISO should begin now to move this issue through the stakeholder process.

[1] See slide 7 at Presentation-CAISO-RA-Workshop-Current-Processes-and-Interoperability-Jun6-2023.pdf.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

New Leaf Energy, Inc. (“NLE”) has no comment on the June 8, 2023 stakeholder call.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

NLE, an independent developer of solar and energy storage, appreciates the thoughtful responses that CAISO staff has presented in its May 31, 2023 Deliverability Assessment Methodology Issue Paper (“Issue Paper”) to the ideas put forward by stakeholders. In these comments, NLE makes two proposals: first, that Local Resource Adequacy (“RA”) projects should be prioritized in the transmission planning deliverability (“TPD”) allocation process; and second, that distribution factors (“DFAX”) should be utilized in the TPD allocation process.

NLE acknowledges that the CAISO has directed consideration of TPD allocation process changes to the Interconnection Process Enhancements (“IPE”) initiative.[1] However, because the IPE is considering so many complex and detailed issues that are due to be resolved on an extremely fast timeline, NLE raises them for consideration in this initiative as well. NLE is agnostic as to which initiative addresses the details of TPD allocation process (the IPE may indeed be more appropriate) but wants to ensure that the issues get due consideration in time to be reflected in the next TPD allocation cycle, which will apply to the significant Cluster 14 capacity and reflect 2022-2023 Transmission Plan approvals of significant new capacity. Also, there is a substantial amount of overlap between the topics of the two initiatives.

The Deliverability Assessment Methodology initiative was launched in response to stakeholder feedback that the CAISO’s study processes were too conservative and that it is possible to reliably award more TPD to much-needed RA resources onto the CAISO system within the existing transmission infrastructure by changing only the CAISO’s processes for determining the amount of TPD available.[2] NLE believes that both of the policy recommendations presented here support that goal.

In addition to the two proposals put forth by NLE, we would like to express support for the ideas advanced in the Issue Paper regarding Interim Deliverability Status (“IDS”), namely allowing projects to receive some form of IDS while (1) waiting for n-2 deliverability upgrades to be completed (in cases where no reliability concerns exist) and (2) waiting for Participating Transmission Owners (“PTOs”) to complete Network Upgrades.[3]  These measures would meaningfully increase the pool of projects that could viably compete in LSE solicitations, including in the Mid-Term Reliability (“MTR”) procurements, which would benefit ratepayers and ensure that reliability is maintained.

1. Prioritize Local RA Resources in the TPD Allocation Process

It is critically important that the CAISO explore how its TPD allocation processes may overlook the importance of prioritizing the development of Local RA resources, especially energy storage resources, which are reliable and non-emitting, and whose small footprints are well-suited to development in the largely denser and more developed Local Capacity Areas (“LCAs”).

• Overlap with the CAISO’s Target Zones: There is a strong geographic overlap between the LCAs[4] and the transmission planning zones[5] that the CAISO wants to target for resource development.[6] Resources developed in these areas have the double benefit of serving local load and best using CAISO resources in the interconnection study process, and thus should be prioritized.
• Ratepayer Benefits: Increasing the pool of Local RA resources will benefit ratepayers by enhancing competition, reducing the market power of existing generators, and ultimately bringing down costs for ratepayers.
  • 1. Local RA Generally Commands Higher Prices – Local RA has historically been more expensive than System RA. In 2021, the average price of System RA was about $0.29 per kilowatt (“kW”)-month higher than the average price of Local RA.[7]
  • 2. Local RA Can Reduce Reliance on RMR Contracts – When capacity is tight in LCAs due to insufficient Local RA resources, there is a higher likelihood of the CAISO needing to secure Reliability Must Run (“RMR”) contracts, which are very expensive, to supply that local need. For example, in 2018, due to a resource deficiency, the CAISO assigned the Metcalf gas plant an RMR designation. The FERC-approved contract was for $5.97/kW-month.[8] By contrast, at that time, 85 percent of capacity in Metcalf’s LCA (the Greater Bay Area LCA) was priced at or below $3.00/kW-month[9] – nearly half the cost of the Metcalf RMR contract. Prioritizing Local RA over System RA resources will provide a clear path forward for projects within local pockets and decrease the reliance on RMR contracts.
  • 3. Local RA Can Reduce Reliance on CPM Purchases – The Capacity Procurement Mechanism (“CPM”) Soft Offer Cap is $6.31/kW-month.[10] Resources can get prior FERC permission to offer at a higher price if they can show that their costs are higher. Thus, the cost could be higher (if set by a resource allowed to bid) or lower (if there are competitive bids lower than the cap). However, the Soft Offer cap is often a benchmark (e.g., for PPA RA Deficiency Penalties).
  • 4. Local RA Can Avoid Transmission Costs – Local RA resources are an alternative to transmission upgrades to serve load in LCAs. Therefore, Local RA investments avoid transmission costs.
• Meeting State Goals: Much of the state’s thermal generation fleet is located in LCAs. The retirement of these polluting resources is critical to meeting the state’s greenhouse gas reduction goals.[11] However, their forecasted retirement heightens the need to focus on the procurement of Local RA resources. New Local RA resources are available and in the interconnection queue, but they will need TPD in order to be commercially viable and come online.
• Load Growth is in LCAs: It is likely that much of the state’s anticipated load growth due to electrification of the transportation and building sectors will occur within LCAs, which are generally more densely developed and populated, putting more of a strain on the existing fleet of Local RA resources. New generation should therefore be targeted to those regions.
• Less Fungible than System RA: Under the current construct, all deliverable resources in LCAs could bid into LSE solicitations as either System RA or Local RA, while generators outside of LCAs can only bid as System RA. Local RA is thus less fungible, scarcer, and equally (if not more) necessary for reliability.

In the January 4, 2023 comments on the CAISO’s December 13, 2022 Update Paper, NLE was one of many stakeholders including CESA,[12] LSA,[13] and CalWEA,[14] to advocate for the CAISO to consider creating separate deliverability study processes for Local RA and System RA resources. In the Issue Paper, the CAISO defends the current study construct, which requires that all generation receiving TPD be deliverable to “the aggregate of load.”[15] NLE appreciates the CAISO’s willingness to consider (though in the RA Enhancements initiative) LSA’s suggestion that some portion of the Local RA requirement may be served by resources that are deliverable within the LCA but not to the aggregate of load.[16]

However, the CAISO remains concerned with how changing the deliverability study rules and resource qualification criteria on a going-forward basis could impact existing generators with TPD awards.[17] The CAISO is also concerned about scenarios where Local RA resources must be available to serve load outside their LCA under certain conditions.[18]

In response to these concerns, and in consideration of the complexity of the original proposal that NLE and others advanced to create separate Local and System deliverability study processes, NLE presents a new idea that would be administratively easier to implement, fit well with other reforms being considered in the IPE initiative, and facilitate the speedy development of needed new Local RA resources.

Rather than overhaul the study processes, NLE proposes that the CAISO modify the TPD allocation process in its tariff to prioritize Local RA resources. Currently, in the CAISO’s processes, there is no distinction made between Local and System RA; a resource only qualifies as Local RA based on its location within an LCA and could bid in LSE solicitations as either Local or System resources. NLE proposes that the CAISO should determine whether the resource is located in an LCA and then prioritize allocating TPD to those resources.

If there are more projects in a given TPD allocation group than TPD available to award, the CAISO already uses a scoring system to determine which projects should receive that TPD.[19] Points are awarded based on how advance the project is through permitting, how close it is to a Power Purchase Agreement (“PPA”), and how much site exclusivity it has. NLE proposes that there should also be significant points awarded to projects that are located in an LCA.

2. Prioritize Generators with the Lowest DFAX in the TPD Allocation Process in Order to Maximize the Use of Existing Transmission

NLE proposes a second modification to the TPD allocation process scoring system. DFAX, which the Issue Paper reviews thoroughly,[20] play a critical role in how much TPD the CAISO awards over the same transmission infrastructure. NLE encourages the CAISO to incorporate DFAX into its methodology for assigning points within a given group during the TPD allocation process. Prioritizing generators with lower DFAX will result in larger MW quantities of awarded TPD on the same poles and wires.

Along with these comments, NLE is confidentially submitting Attachment A: Case Study Illustrating the Value of Utilizing DFAX in TPD Allocation, which utilizes data that is subject to the CAISO Market Participant Portal Non-Disclosure Agreement. This case study quantifies the positive impact of applying DFAX to the TPD allocation process, illustrating how deliverability can be maximized by allocating TPD to projects with minimal DFAX impacts on the limiting contingency. Doing so would allow the CAISO to prioritize the projects that do the least harm on the system, from a reliability perspective, increase the amount of resources that can participate in the RA program without transmission system upgrades, and maximize the RA benefit from new approved upgrades.

NLE acknowledges that this idea was floated in the IPE Track 2 Discussion Paper,[21] and NLE made supportive comments.[22] However, given the cross-pollination between these two stakeholder initiatives and the extensive coverage of DFAX in the Issue Paper, NLE wishes to build on this idea here in the Deliverability Assessment Methodology context as well.

[1] Issue Paper, p. 27.

[2] CAISO Deliverability Challenges: An ISO Update (December 12, 2022), p. 3, available at: http://www.caiso.com/InitiativeDocuments/Update-Paper-Generation-Deliverability-Methodology-Review-Dec132022.pdf.

[3] Issue Paper, p. 4.

[4] 2022 Local Capacity Area Technical Study (January 15, 2021), p. 5, available at: http://www.caiso.com/InitiativeDocuments/2022LocalCapacityRequirementsFinalStudyManual.pdf. 

[5] CAISO Board-Approved 2022-2023 Transmission Plan (May 18, 2023), p. 4, available at: http://www.caiso.com/InitiativeDocuments/ISO-Board-Approved-2022-2023-Transmission-Plan.pdf.

[6] 2023 Interconnection Process Enhancements Track 2 Discussion Paper (May 31, 2023), p. 11-15, available at: http://www.caiso.com/InitiativeDocuments/Discussion-Paper-Interconnection-Process-Enhancements-2023-Track%202-May312023.pdf.

[7] CPUC 2021 Resource Adequacy Report (March 2023), p. 26, available at: https://www.publicadvocates.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/resource-adequacy-homepage/2021_ra_report.pdf.

[8] See Metcalf Energy Center, LLC, 162 FERC ¶ 63,028, ¶ 10 (Mar. 27, 2018) (converting to $ per kW-month ($43,000,000/(600 MW * 1,000)/12 months = $5.97/kW-month)), available for download at: https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20180327-3043.

[9] CPUC RA Workshop (February 22, 2018), p. 47, available at: https://www.cpuc.ca.gov/-/media/cpuc-website/files/legacyfiles/c/6442456634-current-trends-ra-ed-staff-working-draft-proposal.pdf.

[10] CAISO Tariff Section 43A.4.1.1

[11] SB 100 (de León, 2018) increases the RPS to 60% by 2030 and requires all the state's electricity to come from carbon-free resources by 2045. Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.

[12] California Energy Storage Alliance (“CESA”) comments (January 4, 2023) (“CESA believes that it would also be a good time to consider whether local-only deliverability studies could be developed, conducted, and implemented.”), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/4c7edbc6-5c17-4c7d-8e9a-fe31a4a557ad#org-1c4586fc-f6fa-435b-ae66-4b153ed24b35.

[13] Large-Scale Solar Association (“LSA”) comments (January 4, 2023) (“LSA believes that the CAISO should consider in the upcoming initiative whether some portion of the LCR requirement could be satisfied by resources passing a test to be deliverable only to their LCAs.”), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/4c7edbc6-5c17-4c7d-8e9a-fe31a4a557ad#org-fb4bbe73-60c5-4370-ada7-d3830b30b191.

[14] California Wind Energy Association (“CalWEA”) comments (January 4, 2023) (“As a result, we propose, CAISO and stakeholders consider, in the upcoming process, whether resources in locally constrained load areas should be qualified to provide RA capacity in the local area (only) but not allowed to provide system RA capacity, hence freeing existing RA resources in the constrained area to provide RA capacity to LSEs all over the system.”), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/4c7edbc6-5c17-4c7d-8e9a-fe31a4a557ad#org-0a308017-827f-48dc-9680-291f35dcd574.

[15] Issue Paper, p. 26.

[16] Deliverability Assessment Methodology Stakeholder Call Slides (June 8, 2023), p. 28.

[17] Issue Paper, p. 26. (“Automatically assuming a resource in a local capacity area should be deliverable ignores that an existing resource immediately outside the LCA may have been awarded deliverability because of its proximity to the LCA, and that the existing resource would lose deliverability.”)

[18] Issue Paper, p. 26. (“[…] LCRs must be available to serve load outside their LCAs under some conditions.”

[19] CAISO Business Practice Manual: Generator Interconnection and Deliverability Allocation Procedures v33 (April 26, 2023), Section 6.2.9.4.2 (p. 107-109), available at: https://bpmcm.caiso.com/Pages/BPMDetails.aspx?BPM=Generator%20Interconnection%20and%20Deliverability%20Allocation%20Procedures.

[20] Issue Paper, p. 11-12.

[21] Interconnection Process Enhancements Track 2 Discussion Paper, p. 12-13. (“The projects with the smallest distribution factor on the binding constraint will be selected sequentially to be given full allocations of TPD, or partial allocation if available capacity is insufficient for the last project selected.”)

[22] NLE comments (June 14, 2023), available at: https://stakeholdercenter.caiso.com/Comments/AllComments/6abf35dc-2f05-4e36-9002-794ded46653a#org-912303ab-5f1d-40a4-a23e-85a0964335d9.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

NLE has no comment on the off-peak deliverability assessment methodology. 

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

NLE appreciates the CAISO’s efforts to coordinate the issues raised in this initiative with related (even overlapping) issues in the concurrent IPE Track 2 initiative and the possible RA Enhancements initiative. Currently, the Deliverability Methodology Assessment and IPE initiatives are slated to conclude by roughly the end of the year, meaning that any changes adopted therein could be applied to the Spring 2024 TPD allocation process.

The Issue Paper suggests that the topic of Local RA deliverability topic may be more suitable for the RA Enhancements initiative.[1] NLE disagrees and urges the CAISO to continue considering it in this initiative. With no straw proposal, issue paper, or timeline yet, the RA Enhancements initiative risks not producing actionable results in time for the Spring 2024 TPD allocation process. Given the uncertainty surrounding the timeline for Cluster 15 and beyond, the Spring 2024 TPD allocation process may be the last one with a significant amount of new generation (Cluster 14 projects that have recently received their Phase II study results) with the potential to help meet interim greenhouse gas reduction and reliability goals. Indeed, with Cluster 14 projects able to enter the Spring 2024 TPD allocation process, it is possible that some of these projects will be able to meet the MTR procurement timelines. It will benefit offtakers – and ultimately ratepayers – to have a larger pool of projects participating in these solicitations.

Additionally, consideration of how Local RA resources qualify as deliverable directly impacts the steps that the CAISO takes to assess deliverability in its studies and assign TPD to generators, and thus belongs in this initiative.

NLE thanks the CAISO for its thoughtful engagement with stakeholders on these complex topics and for its consideration of these comments.

[1] Issue Paper, p. 4.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

NextEra Energy Resources, LLC (NextEra Resources) appreciates the opportunity to provide comments on the CAISO’s Generator Deliverability Methodology Issue Paper. While NextEra Resources understands the complexity that goes into the deliverability assessment methodology, CAISO’s willingness to explore adjustments to dispatch assumptions that reflect the evolving nature of the generation fleet and to identify potential ways of mitigating delayed deliverability upgrades are critical to ensuring that California’s intensifying need for reliable resources can be met.  Additionally, NextEra Resources is highly supportive of the CAISO’s proposal to explore policy changes that could provide some form of interim deliverability to projects that are delayed by n-2 contingency studies and appreciates the CAISO’s recognition of the barrier that mitigations for n-2 contingencies create to timely resource development.  Furthermore, NextEra Resources also recognizes the need to identify solutions that can provide increased flexibility without compromising the North American Electric Reliability Corporation (NERC) standards and CAISO’s continued commitment to system reliability. 

While NextEra Resources is generally supportive of the proposed scope of the Generation Deliverability Methodology Review initiative, we would like to see CAISO make further refinement to the dispatch assumptions used for storage during the Secondary System Need (SSN) time window.  Consistent with NextEra Resources previous comments in the Update Paper, there is a continued need to better align dispatch numbers with how storage is dispatched in real time, and NextEra Resources has made recommendations in both near/short term and mid/long-term deliverability assessments.  The CAISO’s response to these recommendations in the issue paper only seemed to acknowledge that storage is a “controllable” resource and noted that the highest need for resources in the SSN window is in the later hours.  However, this acknowledgement doesn’t offer clear insight into why adjusting the dispatch assumptions of storage wouldn’t be feasible.

As noted by CAISO, storage is a controllable resource.  As such, the reliability of storage dispatch is the opposite of intermittent resource output (where a portion of an intermittent resources’ capacity may not be reliably deliverable).  Given the increased flexibility associated with energy storage resources that CAISO seems to have acknowledged, NextEra Resources highly recommends that CAISO further evaluate the most appropriate dispatch assumptions for energy storage resources during the SSN window (including in later hours). While NextEra Resources agrees with CAISO that some level of capacity shortage risk during SSN hours when solar output is reduced is evident and that this reliability risk should be mitigated in the hours leading to the High System Need (HSN) window, the current dispatch assumptions fail to recognize that storage resources will need to be prepared for full discharge during the HSN window.  In essence, lowering the energy storage dispatch assumptions during SSN will more fully reflect the controllable nature of storage resources and ensure that storage operation is fully optimized. Furthermore, this modest reduction to lower levels (i.e., 30%) will better align with State objectives to enable the deliverability of significantly more resources, including long duration resources, rather than depending upon the current dispatch assumption of 50% (for medium and long-term deliverability studies).

Finally, it should be noted that in a February 2023 decision, the California Public Utilities Commission (CPUC) approved the Preferred System Portfolio for inclusion into CAISO’s Transmission Planning Process (TPP) 2023-2024. The decision adopts a 30 million metric ton (MMT) greenhouse gas (GHG) target in 2030 and a 25 MMT GHG target by 2035.  Moreover, this decision is more stringent than prior MMT targets and incorporates a portfolio of cost-effective preferred resources that includes the build out of over 80 GW of resources by 2035 (includes approximately 30 GW of energy storage resources and 40 GW of solar resources). To reliably and economically enable the deliverability of such a significant amount of qualified clean energy resources, it is critical that CAISO identify dispatch assumptions and criteria in on-peak deliverability studies that will maximize resource deliverability while simultaneously optimize dispatch and adjust the output of resources accordingly. A modest adjustment to 30% in the SSN window could offer a lower reliability risk alternative that will result in a more economic outcome while still enabling the development of more projects.  A similar result seems less likely under existing conditions, which continue to restrict the deliverability and flexibility of energy storage resources.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

NextEra Resources has no additional comment at this time.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

NextEra Resources has no additional comment at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

NextEra Resources has no additional comment at this time.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

PG&E appreciates the opportunity to provide its perspectives on the Generator Deliverability Methodology Review issue paper and presentation.  PG&E's comments are provided in the below sections.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

CAISO is proposing an enhancement to provide Interim Deliverability to generators waiting on deliverability upgrades that are driven by n-2 (TPL P7) contingency or PTO timeline extensions. PG&E supports this effort but the Interim Deliverability assignment process needs to be detailed. PTOs need to review to make sure reliability operation is granted before this implementation.

PG&E recommends CAISO re-evaluate the Area Deliverability Constraints (ADC) criteria in effect (BPM GIDAP 6.1.1.4) since the amount of Area Delivery Network Upgrades (ANDU) identified were restricting generators from Deliverability allocation.  To elaborate, PG&E noticed that the renewable base portfolio mapped to the electric circle is usually underestimated, making it very easy for the total MW amount inside the electric circle to exceed the base portfolio value.  This results in an auto-satisfaction of criteria in ADC-C3 and ADC-C4 and eventually makes a constraint easily qualify for an Area Deliverability Constraint.  Once all ADCs are identified, the generators behind an ADNU are not required to build the network upgrade so there is no pathway for the Interconnection Customers (ICs) who are willing to fund the upgrade and acquire the Deliverability.  On the other hand, the cost threshold re-evaluation is also recommended to accommodate the inflation rate increase after the Deliverability methodology update in 2019.  Overall, PG&E desires a reasonable number of ADC can be converted into Local Deliverability Constraints (LDC) and offer a pathway for ICs to fund the upgrade coming out of this ADC criteria re-evaluation. CAISO mentioned an ADC/LDC framework discussion has happened on this topic, please point us where we can refer for this discussion.

Historical Deliverability cluster studies in the PG&E system have identified Deliverability Upgrades due to the limitation on non-CAISO controlled 3rd party facilities that could limit a great range of generators from achieving their maximum MW capacity.  Such constraints can become the bottleneck to achieving TPD allocation and FCDS status in certain pockets.  PG&E requests that CAISO create timelines for faster coordination with Affected System, methods to implement mitigation solutions that support the in-service date (ISD) for the generator seeking FCDS in PG&E system.

PG&E suggests CAISO explore creating alternative pathways for ADNU to be funded besides converting ADNUs into policy projects, considering the existing limitations on the PTO side.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

Regarding the key issues from the methodology discussion,

Key Issue 1: PG&E supports the evaluation of the two stressed system conditions. Both system conditions represented by the HSN and SSN are valid and should continue to be evaluated. 

Key Issue 2: The need to consider n-2 (on common tower) contingencies is still needed. However, similar to how CAISO treats n-2 (P7) contingencies credibility in real time operation, PG&E suggests CAISO use stochastic analysis to evaluate the possibilities for all active n-2 contingencies, and determine which contingencies are more likely to happen depending on its risk zone. After this assessment, CAISO can assign conditional Deliverability to the resources in the electric circle impacted by the contingencies that are less likely to happen. This consideration can avoid restricting generator Deliverability for n-2 contingencies that are not likely to occur and will allow resources to deliver energy when the extreme conditions involve random lines under threat as a contingency in a vicinity but not assessed in the Deliverability study.

Key Issue 7: CAISO mentioned that the dispatch of generation uses a 20% exceedance level for HSN, which was adopted from PJM RTO.  There is no testing or validation process for the value currently being used.  PG&E recommends CAISO perform its own independent analysis to determine the level of exceedance value for HSN and SSN to better reflect resource behavior in the CAISO balancing area.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

1. Generation Dispatch

This paper does not identify any changes in solar and wind dispatch for the HSN or SSN scenarios compared to the existing methodology. The only variation observed is in the dispatch of energy storage for the SSN scenario, which the ISO acknowledges as a less restrictive scenario with rare constraints. The effectiveness of these suggestions in significantly improving the availability of deliverability for projects is questioned by the IC.

For its Initial Base Case Dispatch, the ISO dispatches all generation within a geographic area to 80% to account for interconnection queue which far exceeds the load. The IC agrees that the approach for Initial Dispatch assume all generation be available due to the shortage condition. However, the IC believes that not all queued generation within a geographic area achieves COD. The CAISO could consider a scaling factor to the generators dispatched (assume queue attrition or other metric) to provide more reliable results.

Key Proposed Changes:

1. Solar Capacity Factor for HSN Scenarios:
   1. Reduce the capacity factor from 10% to 3.33 % between 19:00 and 22:00.
   2. The time-of-day capacity factors are as follows:
      1. 7 PM to 8 PM: 5%
      2. 8 PM to 9 PM: 3%
      3. 9 PM to 10 PM: 2%
   3. The average capacity factor should be 3.33%.
2. Offshore Wind (OSW) Dispatch:
   1. Avoid 100% dispatch of OSW at any given time.
   2. The capacity factor of OSW is estimated to range between 46% and 55% based on the UC Berkeley Labor Center report.
   3. Curtailment risks should be addressed by energy storage projects requesting interconnection at Morro Bay, Diablo Canyon, and Humboldt regions.

2. N-2 Events

Could CAISO provide an explanation of the N-2 events for which generation redispatch cannot be utilized as a mitigation measure? According to NERC TPL Criteria, a P7 Event can be mitigated through generation redispatch. CAISO is primarily studying N-2 events, which predominantly involve P7 events. It would be appreciated if CAISO could share more information regarding the specific events within this N-2 category that they are concerned about, leading to limitations on generator deliverability in the 10-year scenario deliverability studies.

3. Timeline

The IC strongly desires to observe the effects of these efforts in the TPD 2024 study. If this necessitates a specific timeline to make decisions on the proposed changes, the IC kindly requests the ISO to prioritize the timeline discussion in future meetings. It is requested to set a deadline for the final proposal, ensuring sufficient time to obtain necessary approvals for the changes to be implemented starting from the 2024 study onwards.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

Generation Dispatch

This paper does not propose any changes to the solar and wind dispatch for the HSN or SSN scenarios compared to the existing methodology. The only variation identified is in the dispatch of energy storage for the SSN scenario. It should be noted that the ISO acknowledges this scenario as having less binding constraints, with rarely any constraints arising from the results. The IC raises concerns about the effectiveness of these suggestions in significantly improving the availability of deliverability for projects.

Key Proposed Changes:

1. Solar Capacity Factor for HSN Scenarios:

   - Reduce the solar capacity factor from 10% to 3.33 % between 19:00 and 22:00.

   - Time-of-day capacity factors:

     - 7 PM to 8 PM: 5%

     - 8 PM to 9 PM: 3%

     - 9 PM to 10 PM: 2%

   - The average capacity factor should be 3.33%.

2. Offshore Wind (OSW) Dispatch:

   - Avoid 100% dispatch of OSW at any given time.

   - The capacity factor of OSW is estimated to range between 46% and 55% according to the UC Berkeley Labor Center's report on California Offshore Wind: Workforce Impacts and Grid Integration.

   - Energy storage projects could mitigate the risk of curtailment by requesting interconnection at Morro Bay, Diablo Canyon, and Humboldt regions.

Table 1: Maximum resource output tested in the deliverability assessment

 N-2

Could CAISO provide an explanation of the N-2 events for which generation redispatch cannot be utilized as a mitigation measure? According to NERC TPL Criteria, a P7 Event can be mitigated through generation redispatch. CAISO is primarily studying N-2 events, which predominantly involve P7 events. It would be appreciated if CAISO could share more information regarding the specific events within this N-2 category that they are concerned about, leading to limitations on generator deliverability in the 10-year scenario deliverability studies.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

No comments 

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

The IC strongly desires to observe the effects of these efforts in the TPD 2024 study. If this necessitates a specific timeline to make decisions on the proposed changes, the IC kindly requests the ISO to prioritize the timeline discussion in future meetings. It is requested to set a deadline for the final proposal, ensuring sufficient time to obtain necessary approvals for the changes to be implemented starting from the 2024 study onwards.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

REV Renewables (REV) appreciates CAISO investigating potential revisions to the generation deliverability methodology to improve the process and enable resources to come online in a reliable, timely and cost-effective manner. In general, REV supports further discussions around the issues identified in the paper, and offers these preliminary comments:

• REV supports reducing barriers to obtaining deliverability (while still maintaining reliability), and support further discussions around how to study the n-2 contingency and what level of upgrades are required as a result. REV suggests that a deeper dive into MISO/PJM deliverability analysis and how n-2 contingencies are evaluated and assessed for upgrades in the reliability and deliverability studies could be helpful for stakeholders.
• For network upgrades in the interconnection process:
  • REV supports CAISO’s current framework of funding upgrades with Option A (customers not funding area deliverability constraints and will instead compete with other generators for deliverability) and Option B (self-funding Area Deliverability Constraint upgrades). However, REV suggests this could be expanded to include an “Option C” solution, in which a customer chooses Option A, but if the project does not receive deliverability in the competitive process, it could have a one-time opportunity to go back and choose Option B to self-fund the upgrade instead. Based on REV’s understanding, no projects have utilized option B to date. But in the current reality of many customers vying for limited transmission capacity, customers who are not successful in obtaining deliverability through Option A could rethink their choice and decide to self-fund. CAISO could create some type of cost or timeline triggers (e.g. less than a certain amount or timeline that developers may reasonably decide to pursue that option) to allow this Option C.
  • An additional issue is that if multiple projects trigger a small upgrade (e.g. a RAS), then CAISO or the PTO should not wait to build the upgrade until enough projects sign LGIAs. Instead, the first project moving forward should get the opportunity to get this built even if it means the project initially funds 100% of the upgrade cost and then gets reimbursed by other projects as they progress.
  • REV notes that these two solutions may be better suited for the Interconnection Process Enhancements initiative, and defers to CAISO on where best to address it.
• Regarding the issue of excessive transmission upgrades, REV agrees with CAISO that there have not been excessive upgrades, as shown by the limited available transmission capacity on the system. California has aggressive clean energy policy goals that require transmission to connect the resources, and it is likely that more transmission upgrades will be required to ensure clean energy can be delivered to customers reliably.
• For the SSN Study, REV requests CAISO to provide data projects that are constrained due to SSN rather than HSN. Is this an issue for certain types of resources? Certain locations? How many projects and megawatts are being constrained?
• For NQC vs Exceedance Based Study Amounts, REV supports further analysis of this issue and how using QC of NQC values could change the amount of deliverability that is available.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

 REV has no comments at this time.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

 REV has no comments at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

REV supports CAISO’s proposed timeline and coordination with the Interconnection Process Enhancements initiative. REV has no further comments at this time. 

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

SEIA appreciates CAISO staff’s responses to stakeholder comments submitted with the December 2022 Update Paper. Recognizing that this effort was initiated to explore potential adjustments to the deliverability methodology to unlock incremental deliverability to support the much-needed interconnection of RA resources, SEIA is supportive of the proposed enhancements to Interim Deliverability Status (IDS) to extend IDS to projects impacted by delays to n-2 deliverability upgrades. This proposal will benefit developers, ratepayers, and load-serving entities by reducing delays to project development timelines, thereby increasing the number of projects eligible to provide RA without increasing reliability risks. SEIA believes that this proposal strikes an appropriate balance between supporting resource development and maintaining system reliability. SEIA believes there are other solutions, like New Leaf’s proposal to prioritize Local RA in the TPD allocation process, that provide similar system benefits without compromising reliability. SEIA encourages CAISO to consider solutions like these through the instant initiative (as opposed to the RA Enhancements Initiative) to ensure a solution is in place in time for the Spring 2024 TPD allocation process.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

SEIA supports the proposed path forward and the delegation of certain topics to other stakeholder initiatives running in parallel (i.e., IPE) that also expect to conclude later this year. Given the to-be-determined RA Enhancement timeline and lengthier runway through 2025, SEIA encourages CAISO to consider solutions that can be implemented relatively quickly in either this initiative or the IPE to ensure the benefits can be realized as soon as practicable.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

The Six Cities remain highly supportive of the CAISO undertaking this initiative.  As the Six Cities have highlighted in prior comments in this and other, related initiatives, CAISO load-serving entities are facing significant challenges in procuring resource adequacy (“RA”) capacity for peak months.  The Six Cities concur with the CAISO that it should be looking for ways to support expedited development of resources that are eligible to provide RA capacity.  Although the CAISO’s Issue Paper is instructive in terms of outlining and explaining existing CAISO approaches, the Six Cities are concerned that the Issue Paper does not adequately focus on a meaningful evaluation of potential alternatives to current practices that would preserve an acceptable level of reliability while removing unreasonable barriers and costs to timely resource development. 

At this stage of this initiative, the Six Cities support consideration of the following:

• The Six Cities have reviewed the “Joint Proposed Framework for Discussion” submitted by the Bay Area Municipal Transmission Group, California Energy Storage Alliance, and California Wind Energy Association.  The Six Cities encourage the CAISO to undertake a meaningful evaluation of the proposals discussed in the Framework.  In addition to formulation of a set of tenets to guide the discussion in this initiative, the changes to the CAISO’s current deliverability assessments that are proposed for the CAISO’s consideration include: (1) clarification of the conditions under which deliverability should be tested, including conditions that are “stressed,” but not necessarily representative of extreme or outlier conditions, and the use of accurate assumed dispatched levels for RA resources; (2) the separation of deliverability requirements from both reliability studies, which are appropriately the purview of the transmission planning and interconnection procedures, and economic studies, which relate to concerns about curtailment levels; and (3) consideration of technical criteria for local deliverability.  Given the discussion in the Issue Paper regarding the deliverability methodologies used by other planning areas, including PJM and MISO, the Six Cities request that the CAISO consider if approaches used in other planning areas could provide the CAISO with an adequate level of reliability while enabling more resources to receive full capacity deliverability status. 
• The Six Cities do not believe that a discussion of reform for the CAISO’s deliverability assessment methodology would be complete without consideration of changes to the CAISO’s Maximum Import Capability (“MIC”) methodology.  As the Six Cities have stressed in their earlier comments in this initiative and elsewhere, MIC continues to operate as an unreasonable restriction on the ability of load-serving entities to procure and rely upon for RA purposes long-term import supply arrangements with resources outside of California.  At a time when the CAISO is seeking access to additional capacity resources and enhanced regional integration, continuing to cap import RA at historical levels is incompatible with these policy objectives.  Therefore, any resulting initiatives should consider impacts on and possible changes to the MIC methodology alongside improvements to the methodology and allocation for deliverability for internal resources. 
• The CAISO asserts in the Issue Paper that its dispatch related assumptions will not be explored in this initiative, citing recent examples of stressed conditions as evidence.  See, e.g., Issue Paper at 19.  The Six Cities request that the CAISO provide an analysis of these conditions that demonstrate the reasonableness of the CAISO’s dispatch assumptions to substantiate these assertions; the Issue Paper does not actually include any empirical or quantitative discussion of its dispatch assumptions relative to resource needs and performance in the cited circumstances.

The Six Cities are supportive of changes to the CAISO’s interim deliverability rules to enable resources to come online prior to when certain network upgrades are in service, but do not think this should be the only area of possible reform considered in this initiative. 

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

Please refer to the comments provided above.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

Please refer to the comments provided above.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

The CAISO should clarify that the scope of this initiative includes consideration of issues related to the CAISO’s deliverability allocation process as well, including the timing of the allocation process relative to interconnection study and procurement activities.  For example, the Six Cities have encountered a “chicken and egg” dilemma of whether to proceed with procurement efforts for resources that do not have deliverability allocations and without any guarantee that resources, even with executed power purchase agreements, will qualify as full capacity deliverability resources in a timely manner.  This creates substantial procurement risk for the Cities, which could find themselves unable to rely on resources that have been procured for RA purposes if the resources do not receive deliverability for the procured capacity or face significant delays due to the need for network upgrades to ensure deliverability throughout the CAISO system.  The Six Cities therefore request that the CAISO develop more affirmative guarantees at an earlier stage of the deliverability allocation processes for deliverability associated with PPAs that have been executed or are shortlisted. 

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

SCE appreciates the opportunity to comment on the CAISO’s Generation Deliverability Methodology Review Issu Paper to ensure that the deliverability requirements strike the appropriate balance between reliability and cost containment.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

SCE supports the CAISO’s current practice of studying n-2 contingencies in both the reliability and deliverability studies and agrees it makes dealing with these contingencies in the operating horizon more manageable. Designing the system to withstand n-2 contingencies in the planning horizon increases the chances that necessary mitigations would be triggered, approved, and built in a timelier manner.

Section 5.2.2 in the on-peak deliverability assessment methodology states that congestion management may not be a feasible mitigation for n-2 contingencies because there are limits to the ability of the market to manage all n-2 contingencies simultaneously and therefore it is not an acceptable vehicle when the consequences of a n-2 contingency are too severe. Instead, remedial action schemes (RAS) or system upgrades are needed to mitigate n-2 contingencies. Given that CAISO’s recently updated RAS guidelines in their Planning Standards are causing significant generation resources to be removed from existing and future RAS/CRAS, SCE recommends that the impact of the updated RAS guidelines on the on-peak and off-peak deliverability assessment methodology be thoroughly assessed to ensure RAS/CRAS effectiveness is being optimized.

In addition, SCE seeks further clarification on the use of a risk-based approach to provide interim deliverability while waiting for related n-2 deliverability upgrades to be completed and on the enhancements the CAISO is considering in the GIDAP reliability studies to proactively address n-2 operational reliability concerns.  

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

No comment at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

SCE agrees with the suggestion to consider separating the local RA product from the system RA product in the CAISO’s RA initiative. However, this clearly indicates how interconnected the RA Initiative will be with this Deliverability initiative, and also with the 2023 Interconnection Process Enhancements Track 2 initiative. Clearly, any rethinking of what it means to provide RA, possibly by the CAISO considering an updated RA mechanism to address the same issues that drove the CPUC to adopt the 24-hour Slice of Day framework, to accommodate the changes that DAME requires in the market or to separate local RA from system RA, may impact how deliverability studies must be done. Any changes to deliverability studies will also impact the generation interconnection process, which may impact the timing of the studies and the how the number of interconnection requests impacts the process. These three stakeholder initiatives should be considered from a wholistic perspective and not individually, in isolation. The CAISO needs to coordinate the issues discussed in these three stakeholder forums. Ideally, the CAISO will develop a unified, or at least coordinated, approach to these three initiatives and provide stakeholders with a chance to comment on the wholistic approach. 

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

Vistra continues to evaluate the CAISO’s issue paper and will look to provide detailed, comprehensive feedback in the future. Currently, we encourage the CAISO to maintain its current procedures for N-2 contingencies in its studies as well as for its deliverability studies of local capacity resources. See our brief comments below. Further, we believe it is critical that the values in Table 1: “Maximum resource output tested in the deliverability assessment” and its implications on Net Qualifying Capacity (Section 5.2.12) needs to be a focus of this initiative and needs to include detailed discussion on the energy storage assumptions.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

Vistra provides feedback on the two below discussions in the Issue Paper.

Section 5.2.2 – N-2 Contingencies

Vistra believes CAISO is appropriately studying n-2 contingencies in its planning studies per the NERC requirements. It is not clear if the request from select stakeholders is to expand the set of contingencies modeled broader than what NERC requirements require. If that is the request, Vistra does not support the CAISO expanding its concept of what constitutes a N-2 contingency in its studies. To do so would make the system appear tighter than it is and may result in less deliverability being available under N-2 conditions. In the alternate, if the request is to provide more flexibility to support deliverability until N-2 mitigation solutions are in-service, this seems reasonable. Vistra is supportive of the CAISO considering a path for interim deliverability for projects that are affected by the current scope of N-2 studies to facilitate projects coming online earlier than the in service dates of any Remedial Action Scheme (RAS) or system upgrade needed to mitigate any N-2 constraints identified in the reliability and deliverability studies. We request the CAISO clarify the scope of this initiative would be not to change its study methodologies for N-2 contingency, but instead to explore a change to its interim deliverability processes to address projects needs that can achieve commercial operations prior to the in-service dates of any identified mitigation.

Section 5.2.10 – Deliverability for local capacity resources

Vistra opposes the idea of separating and unbundling local and system Resource Adequacy (RA). We continue to support that the CAISO should be evaluating new resources deliverability that are located in local capacity areas both for being deliverable when the load pocket is constrained and separates from the broader system as well as able to deliver to the aggregate of load. This issue should not be within scope of the deliverability discussion as it raises a higher level commercial and regulatory question regarding whether the Local Regulatory Authorities would unbundle local and system attributes from generic RA. This question is outside the scope of CAISO’s deliverability methods because unbundling RA is not allowed under the programs today. It would disrupt foundational principles of what is capacity. Capacity resources need to be deliverable to the system (system attributes) at a minimum and if a local resource is deliverable to a local area when that area’s cut planes bind separating it from the system (local attributes) then it would be deliverable to both system and local. The concept of being a local resource that is not deliverable to the system when the local area is not separated is inconsistent with good RA market design. Finally, this issue is outside the CAISO’s RA authority and should not be included in the RA initiative, but instead raised at the Local Regulatory Agency if parties would like to debate the issue in that venue.

Section 5.2.12 – Net Qualifying Capacity versus Exceedance Based Study Amounts

Vistra requests this discussion include energy storage dispatch assumptions. The need to discuss and more deeply explore the why behind the assumed percentages used in the deliverability assumptions by resource type should be a key focus of this effort. We request an in-depth discussion on the basis for the percentages shown in Table 1. Vistra provided comments in the past raising that we are unclear on why there is any change to discharge assumption for energy storage between the High System Need (HSN) and Secondary System Need (SSN) scenarios.[1] The CAISO responded that it believes storage is not similar to a non-intermittent resource.[2] We continue to believe it is important to explore the SSN case in more detail and explore why there is a less than 100% discharge assumption for SSN for batteries. Given our experience as a developer, owner and operator of energy storage, we would like to understand how the CAISO arrived at the view energy storage would be treated as an intermittent resource with lower than 100% deliverability during SSN. Energy storage is an on-demand resource with a cycle use limitation that can be managed such that 100% could be available if managed appropriately for both HSN and SSN case based on our assumptions of when these hours occur. Further transparency and discussing analysis that led to the CAISO arriving to this view would be helpful to better understand its view.  A deeper discussion on why the deliverability assumptions are treating energy storage more similarly to intermittent resources instead of the non-intermittent resources should be in scope. A discussion on what the appropriate level of these assumptions should be should also be in scope.

[1] Vistra Comments on the CAISO’s On-Peak Generation Deliverability Study Generation Dispatch Assumptions posted on June 3, 2022, June 21, 2022, http://www.caiso.com/Documents/VistraCorpComments-GenerationDeliverabilityStudyDispatchAssumptions-Jun062022.pdf.

[2] ISO Responses to Stakeholder Comments, August 9, 2022, http://www.caiso.com/Documents/ISOResponsestoComments-GenerationDeliverabilityStudyDispatchAssumptions-Jun062022.pdf.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

None currently.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

The key issue of generation deliverability assumptions for energy storage merits a deeper discussion in this effort. We request the CAISO explicitly include energy storage deliverability assumptions in the scope as described above. We look forward to learning and discussing more on this critical topic.

1. Please provide a summary of your organization’s comments on the Generation Deliverability Methodology Review stakeholder call.

Wellhead appreciates this opportunity to provide these brief comments on the CAISO’s Generation Deliverability Methodology Review initiative. Wellhead appreciates CAISO’s willingness to undertake this initiative and consider changes to the deliverability methodology.  The plans for building additional transmission capacity cannot be implemented soon enough to connect RA resources by 2032 to meet the state’s clean energy goals and reliability goals. If California is to meet its mid-term reliability and clean energy goals CAISO’s deliverability methodology must augmented in a way that supports projects coming online with deliverability (FCDS, PCDS or interim deliverability) and explicitly facilitates project financing and development.

2. Provide a summary of your organization’s comments on the on-peak deliverability assessment methodology, as described in the issue paper.

CAISO should modify deliverability procedures such that it supports expeditious development. CAISO created the interim deliverability procedures in 2010, a time when California was also experiencing procurement (solar) that outpaced transmission. Interim deliverability allows temporary use of deliverability capability for a generator to come online and serve RA. The current supply condition is more dramatic than that time and should be addressed proportionally.

At this pivotal point CAISO’s deliverability methodology is too conservative and California risks a supply shortage to meet the state’s clean energy goals and reliability goals. Wellhead acknowledges that CAISO must consider a variety of criteria as it considers on-peak methodology. Some of that criterion is mandated by external agencies, but CAISO is empowered to modify certain procedures to enable the assignment deliverability more expeditiously. Wellhead has mature, viable energy storage projects that are ready to deploy to meet mid-term reliability goals, save for deliverability challenges that are being discussed as a part of this initiative. Wellhead joins its voice with the stakeholders on the June 8 call and requests the CAISO seriously consider the following suggestions:

• CAISO should not allow the Secondary System Need (SSN) test to prohibit energy storage resources from obtaining deliverability. Energy storage is unique in its ability to relieve congestion and reduce the impact of transmission contracts by charging. Actual energy storage dispatches for charge and discharge show that storage’s performance does indeed relieve system stresses. CAISO’s deliverability methodology should reflect this.

CAISO’s recent changes to energy storage rules in the Energy Storage Enhancements initiative, as well as upcoming development of new policies, are sufficient to address the risk that storage will deviate from historical behavior and instead contribute to tight system conditions. However, if CAISO has a true concern that energy storage resources will deviate from this behavior and is unwilling to make the SSN test optional for energy storage resources, Wellhead requests CAISO to allow storage resources otherwise meeting deliverability criteria to be granted an interim deliverability. The interim deliverability for these resources could also application operating procedures for storage to ensure that projects charge and discharge in a manner that improves reliability.

• CAISO should not allow the construction timeline for transmission upgraders needed to address N-2 contingencies to prohibit energy storage resources from deliverability. In NERC procedures, n-2 contingencies are analyzed in the planning horizon, but not in real-time operations. In this case, strict application has not been properly balanced with California's supply needs. In no way does Wellhead suggest CAISO eliminate the N-2 planning review, nor cease identifying and requiring transmission to resolve any identified issues. Rather, like the discussion of the SSN test above, when N-2 contingencies occur in the operating horizon (rarely), they can be managed using operations tools that are not considered in planning analysis, and CAISO should allow generators otherwise meeting deliverability criteria to be granted interim deliverability.

3. Provide a summary of your organization’s comments on the off-peak deliverability assessment methodology, as described in the issue paper.

None at this time.

4. Provide a summary of your organization’s comments on the proposed scope, key issues summarized by the ISO, and timeline of the Generation Deliverability Methodology Review initiative.

In the Transmission Development Forum it is clear that network upgrade timelines are being continuously delayed, sometimes for 8 years or more (given how often dates are pushed out.) This puts the state’s clean energy goals, mid-term procurement, and reliability goals at risk.

With Participating Transmission Owner construction timelines triggering such a profound increase in the amount of development uncertainty, CAISO must modify its deliverability methodology to grant deliverability when the barriers to preventing deliverability assignment are highly unlikely to occur or harm reliability. Wellhead recomends that the CAISO reevaluate the need for energy storage resources to be subject to the SSN test and/or allow energy storage resources subject to the SSN to receive interim deliverability. Wellhead also recomends that the CAISO consider alternative approaches for considering upgrades needed to address N-2 contingencies.