Comments on final proposal

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

?AES Clean Energy supports the final proposal of the generation deliverability methodology stakeholder initiative. Specifically, AES Clean Energy supports the increased DFAX levels for 500kV lines and the risk-based approach for rewarding FCDS for projects requiring n-2 mitigations. AES Clean Energy appreciates the CAISO’s responsiveness to stakeholders through the initiative and looks forward to future collaborations. 

Regarding implementation, AES Clean Energy requests the CAISO to notify customers when the PRR process is initiated for further engagement. 

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

The California Community Choice Association (CalCCA) appreciates the opportunity to provide the following comments in response to the California Independent System Operator’s (CAISO) Deliverability Assessment Methodology Final Proposal (Final Proposal).  CalCCA supports the proposed modifications. However, these measures have not gone far enough to provide the much-needed volumes of Resource Adequacy (RA) required to respond to RA capacity scarcity, California Public Utilities Commission (CPUC) procurement orders, and state climate goals.

Over the next 12 months, the CAISO should closely monitor the results of the next Deliverability Assessment(s) to gauge the effectiveness of the modifications and report back to stakeholders.  Further, pending the results of this monitoring, the CAISO should revisit elements of the proposal that stakeholders have suggested remain too stringent. Specifically, CalCCA encourages the CAISO to review the impacts of (1) the dispatch level assumed in the deliverability assessment, and (2) the risk-based approach to N-2 contingencies as follows:      

• The CAISO’s dispatch of resources above their Net Qualifying Capacity  in the deliverability assessment reduces the availability of deliverability capacity for queued projects and new queue entries.
• An overly conservative application of the CAISO’s “risk-based” approach to awarding deliverability status to resources while N-2 mitigations are under development may unnecessarily constrain deliverability capacity. 

Additionally, CalCCA encourages the CAISO to consider possible impacts to the eventual “slice-of-day” approach for RA counting and if any further modifications to the Deliverability Methodology should be considered in light of the new RA framework.

In summary, CalCCA is hopeful that the modifications outlined in the Final Proposal will provide incremental benefit in terms of increasing the volume of megawatts eligible for RA but has reservations that a measurable benefit will be achieved without additional modifications. As with any change, it is important to monitor and assess the actual impacts against those anticipated. The CAISO must perform this assessment and report back to stakeholders so that there is a collective understanding of the relative benefits and, as warranted, revisit key elements of this effort for future modifications.

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

CalWEA has no further comments on CAISO’s proposal.  CalWEA very much appreciates the time and attention that CAISO staff have devoted to this important initiative, the results of which we believe will significantly contribute to the state’s ability to achieve its reliability and clean energy goals in the coming years by enabling many more projects to access the grid without transmission upgrades, and to bring on thousands of megawatts of capacity prior to the completion of planned upgrades.

While we are disappointed that CAISO has opted not to apply the same cascading N-2 criteria consistently across all generation projects, or to study the outcomes of that approach, we are hopeful that this may be done at some point in the future.

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

REV Renewables (REV) overall supports CAISO’s final proposal on Generation Deliverability Methodology Review.  REV also supports CAISO implementing these changes as soon as possible.

CAISO noted that the ADNU/LDNU guidelines would not be implemented until Cluster 15 studies. REV recommends implementing this change sooner so that additional Cluster 14 projects can find a path to becoming commercial and meet the near-term capacity needs. Once implemented, REV believes this should increase the amount of deliverability available for the projects behind ADC-C4 criteria. REV requests that CAISO publish the list of C14 Phase 1 upgrades that would now qualify as LDNU based on this proposal. In addition, rather than implementing the change in C15, REV suggests CAISO do this as part of 2024 reassessment process itself. CAISO has mentioned in the paper itself that it impacts only 10 out of around 100 ADC in the transmission capability estimate document. This leads us to believe that this will have a very localized impact on a couple of CAISO interconnection areas. CAISO should either perform a quick TPD reassessment for these areas, or at least capture this updated information for projects in the 2024 reassessment reports. The official TPD results in the second scenario could then wait till 2025 TPD assessment.  REV understands that this will result in additional work for CAISO to update the cost allocation for projects that will now need to post additional amount for these LDNUs. However, REV still believes that in this case the benefits of getting a clear indication of the path to deliverability outweigh the uncertainty and risk of waiting for CAISO's policy-driven process to first determine and then approve the ADNU. In REV’s analysis, C14 SCE Northern area is one of the areas that should benefit from this assessment.

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

Terra-Gen, LLC. (Terra-Gen) provides general support for CAISO's Generation Deliverability Methodology final proposal.  CAISO's proposal has not substantively changed from its prior version, therefore, Terra-Gen reiterates it prior stakeholder comments submitted in response to specific topics included in CAISO's draft final proposal, available here: Terra-Gen comments on draft final proposal.

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

Vistra is generally supportive of the CAISO’s final proposal on generation deliverability methodology review. We appreciate the CAISO engaging with stakeholders in this effort to strive towards an outcome that balances interests. Of the proposals, Vistra found the proposal to revise the guidelines for identifying Area Deliverability Constraints (ADC) so that there is a potential for less constraints to be identified as needing Area Deliverability Network Upgrades and instead as needing Local Deliverability Network Upgrades such that projects can collectively share a portion of the cost of the LDNU as potentially important to facilitate new pathway to unlocking needed deliverability. In the Interconnection Process Enhancements 2023 effort, Vistra proposed a network subscription model that would allow developers to collectively fund the network upgrades so that roadblocks to funding upgrades needed to increase deliverability could be removed through developers contributing collectively to its cost. The CAISO’s proposal to revise the ADC guidelines may result in more LDNU and projects collectively funding those upgrades, which struck us a unique way to try to accomplish the overarching policy goal Vistra has been seeking CAISO to address. We appreciate the CAISO creativity in trying to find ways to allow for more collective cost funding of upgrades through this proposal until larger scale transmission planning reform is on the table.