Comments on Issue Paper

1. Provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

On June 24, 2021, the CAISO held a meeting to discuss its Planning Standards Remedial Action Scheme (RAS) Guidelines Update Issue Paper (Issue Paper, hereafter). The Bay Area Municipal Transmission group (BAMx)^[1] appreciates the opportunity to comment on the Issue Paper. In these comments, BAMx seeks the details on the CAISO existing “key” Special Protection Schemes (SPS) and the proposed future RAS. BAMx believes that the currently proposed timeline is too aggressive to achieve all the objectives laid out in the Issue Paper. BAMx recommends addressing only a subset of topics including the RAS guideline review updates as part of the currently proposed schedule - and table the topics that require more time and effort, such as potentially limiting the use of future RAS in certain areas and under certain conditions. This could be accomplished via a separate stakeholder process or part of the next planning cycle.  

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

2. Provide your organization’s comments on the background and issues, as described in section 2:

It appears that the Issue Paper and the CAISO’s June 24^th presentation use SPS and RAS terminology interchangeably.  Does the CAISO distinguish between the two in terms of scope and complexity? Please explain how the CAISO uses these terms and how those definitions might differ from those of NERC, WECC, and others (such as the PTO’s) to the extent the CAISO is aware of other entities use of those terms.

The CAISO Issue Paper indicates that “(T)here are currently 69 NERC-related RAS on the BES system with 23 of those RAS being added in the last 10 years.” Please clearly identify and provide details on how these existing 69 NERC-related RAS on the BES in the CAISO footprint compared to the existing “key” forty-three (43), twenty-two (22), and twenty-three (23) SPSs in the PG&E, SCE, and SDG&E Participating Transmission Operator (PTO) areas, respectively as identified in the 2021-2022 TPP Draft Study Plan.[2] Would the CAISO please also identify which of these are load-dropping versus generation-dropping SPSs/RASs?

Although the Issue Paper does not refer to the 36 future proposed RAS’s, the CAISO’s presentation (page 7) during the June 24^th call refers to them. Would the CAISO please provide details on these RASs, whether they were identified in the prior TPP’s or the generation interconnection “Cluster” studies?

[2] Section A6 Special Protection Schemes, in the 2021-2022 Transmission Planning Process

Unified Planning Assumptions and Study Plan, February 18, 2021, pp.A10-A13.

3. Provide your organization’s comments on the next steps, as described in section 3:

BAMx appreciates the CAISO proposed changes to the current guidelines to clarify RAS development, implementation, and ongoing maintenance. The CAISO, in consultation with the stakeholders, needs to develop specific guidelines in its attempt to explore opportunities to potentially limit the use of future RAS in an area that is saturated with existing RAS. Such guidelines may include criteria such as a load-dropping RAS versus a generation-dropping RAS, a tradeoff between feasibility and complexity of RAS versus the cost of alternatives, whether reliability or economic concerns, etc. drive the decision to limit RAS in some instances. 

4. Provide your organization’s comments on the proposed initiative schedule, as described in section 4.1:

BAMx believes that the current proposed schedule - that envisions presenting the proposal to the CAISO Board of Governors in November 2021 - is highly compressed and not conducive to meaningful stakeholder participation. A subset of topics proposed by the CAISO, such as the alignment of RAS with NERC Reliability Standards and revisiting the maximum amount of generation tripping for single and double element contingency in light of Diablo retirement, could be achieved by the proposed timeline. However, other more complex issues, such as potentially limiting the use of future RAS in certain areas and under certain conditions, would likely require a considerably more significant level of effort and stakeholder involvement, and in turn, more time.

5. Additional comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

No additional comments at this time.

1. Provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

EDF-R appreciates that CAISO has opened this initiative. Like the CAISO, EDF-R is concerned with the proliferation of RASs on the CAISO system, both to date and planned. EDF-R is eager to better understand the current RAS implementation on the system and encourages the CAISO to do more with this initiative than clarify and remove redundancies from RAS planning guidelines. EDF-R is disappointed that the CAISO “is not expecting this initiative to have any material impacts to the RAS guidelines.” And encourages the CAISO to use this initiative as an opportunity to consider the current RAS implementation approach’s long-term outcomes and review other system operators’ best practices.  

2. Provide your organization’s comments on the background and issues, as described in section 2:

EDF-R agrees with CAISO that increased use of RAS has been popular because RAS solutions allow for “faster implementation timeline, lower costs, increased utilization of existing facilities and a more efficient use of scarce transmission resources associated with the RAS” but have the negative impacts of increasing operating and outage complexity. RAS implementations can have the inadvertent effect of masking the need for significant transmission buildout. 

At this stage of the initiative EDF-R requests CAISO prepare and share more background information and analysis on current RAS implementation on its system: 

1. In a 2017 paper on a different RAS topic the CAISO described the then RAS arrangements like this: 

“Total generation-drop-related remedial action scheme installations have the capability to arm up to approximately 19,800 MW of generation. Northern California installations have the capability to arm up to 8,600 MW with a maximum single contingency loss of approximately 1,450 MW. Southern California installations have the capability to arm up to 11,200 MW with a maximum single contingency loss of approximately 2,300 MW.” 

EDF-R requests the CAISO update this analysis with 2021 information. 

2. EDF-R is also interested in better understanding the relationship between the system location of one or more RAS implementation as it compares to curtailment. The CAISO provides a daily look at renewable curtailment here: California ISO - Managing Oversupply (caiso.com) but the information is not at the appropriate granularity for correlating it to specific areas. EDF-R requests the CAISO provide some more data related to the congestion and curtailment for RAS zones, including specific areas where RAS schemes increase congestion and curtailment, how many MWh are curtailed annually, and what the cost to the system is.   

3. Finally, EDF-R requests the CAISO provide a substantive update on the outcomes of the Generator Contingency and RAS Modeling initiative. The CAISO’s statement that it “has turned out to be more of a challenge than was expected and is considered a work in progress” is perplexing and opaque.  

3. Provide your organization’s comments on the next steps, as described in section 3:

On the topic of “explore[ing] opportunities to potentially limit the use of future RAS in an area that is saturated with existing RAS.”  EDF-R encourages the CAISO to heavily weight the negative effects of RAS implementation (operational, outage complexity, and the procrastination of initializing development of clearly needed system upgrades) when analyzing the appropriateness of a RAS solution in its transmission planning and generator interconnection studies.  CAISO’s supply need is growing by leaps now and the upcoming procurement of 11.5 GW by 2026 (as recently directed by the CPUC) is much more likely to be the beginning of a major procurement boom than the end of one.?As an example of a transmission planning approach that appropriately caps RAS usage, EDF-R notes that in SPP RASs are assumed permanent by design. For example, SPP is currently going through the process of defining general guidelines for RASs and the general direction that guideline is headed in is that RASd should be typically approved for 2 years, then re-evaluated (link to download relevant SPP May 3, 2021 meeting materials) 

EDF-R also requests that in straw proposal the CAISO more clearly list the specific changes it is proposing alongside some level of analysis regarding the expected outcome of those changes, including when and how new RAS planning guidelines will be implemented, for example, if the planning standards will spur new upgrades in the next GIDAP cycle and borne by generators, or if they will be considered in the TPP and cost born in those processes. EDF-R believes this is the correct level of scrutiny to apply to proposed changes considering the potential outcomes. EDF-R also requests the CAISO clarify if after the review and change to RAS guidelines is complete, will CAISO look retroactively at the 21 RAS added in the last decade? And reconsider the 36 planned? EDF-R would like to better understand potential exit solutions, ultimately it does not serve generators or the system if RASs are eliminated and then have curtailment previously born by generators under RAS be socialized in the market as congestion.  

4. Provide your organization’s comments on the proposed initiative schedule, as described in section 4.1:

CAISO has not included a timeline for the “final proposal” on its schedule. Final proposals are now common in CAISO’s stakeholder initiatives (rather than stopping at the “draft” stage) and are important policy documents, and EDF-R requests CAISO complete that element for this proposal as well.  

5. Additional comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

?None at this time. 

1. Provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

In general, PG&E supports the CAISO’s initiative to update the Remedial Action Scheme (RAS) guidelines. The CAISO’s Issue Paper mentioned that a review of RAS usage in other ISO/RTOs indicated that the CAISO relies far more on RAS’ use in lieu of transmission upgrades relative to other ISO/RTOs. PG&E agrees with the CAISO’s observation on RAS usage. PG&E also recommends that future RAS guidelines and planning requirements should consider the potential reliability risks and additional costs that RAS may introduce to system operations, equipment maintenance and modifications.  Taking such factors into account will lead to a more comprehensive decision-making process when recommending future RAS. 

Below are PG&E’s comments and recommendations on the RAS guidelines update. 

1. The NERC Special Protection Systems Standard Drafting Team recommended that the term “RAS” be retained as the industry-recognized term and that the term “SPS" ultimately be retired. PG&E recommends the future RAS guidelines to update the term “SPS” with the term “RAS.”

2. PG&E currently has 51 existing RAS installed in its system. Concerns about reliability risks and additional costs from RAS installations exist when considering system operations, system protection and system maintenance.  At times these concerns could go beyond what planning studies reveal, such as: multiple RAS in one area increases the operational complexity and the risk of adverse interactions; complex RAS equipment maintenance, testing, and reporting can be complicated, costly and added risks to mis-operations and/or inadvertent operations; transmission upgrades often triggers RAS modification(s) to accommodate system change which adds complexity and cost to the upgrades; large amount of RAS also adds intense NERC compliance burdens to both PTOs and the CAISO. These concerns should be incorporated in the future RAS guidelines when evaluating RAS as an alternative.

3. Based on the information collected from the CAISO BPM generation modeling effort, there are still substantial amount of solar PV inverters that cannot eliminate momentary cessation and will continue to exhibit such behavior which has the potential to trigger large amounts of temporary loss of generation on the system. PG&E recommends the CAISO to further study this phenomenon when revisiting the maximum amount of generation tripping for a single element contingency and make comprehensive updates on both the CAISO SPS 3 guidelines and planning standards.  In addition, as the 1150 MW criterion has been “built in” the California transmission system design in both operations and planning horizon, if no other firm reliability concern is identified, even after Diablo Canyon Power Plant’s retirement, PG&E recommends to keep the 1150MW criterion for consistency of the design of the system.  

4. PG&E recommends that the CAISO’s and PTO’s Operations, System Protection, and RAS groups collaborate to review past RAS events and root cause analyses.  Together these teams can add critical RAS design guidelines/requirements to improve reliability of RAS, such as commonly accepted design for reliably detecting possible ways of equipment outages.

5. In addition to the maximum number of contingencies and monitored system variables, the CAISO SPS 6 guideline should also consider adding the maximum number of substations involved in the RAS.

6. PG&E recommends the CAISO consider adding guidelines to evaluate the removal of existing RAS when designing a transmission project in the same vicinity.

7. The CAISO mentioned there are 36 proposed future RAS. PG&E recommends the CAISO to review these proposed RAS following new RAS Guidelines as they are updated.

2. Provide your organization’s comments on the background and issues, as described in section 2:

see above

3. Provide your organization’s comments on the next steps, as described in section 3:

see above

4. Provide your organization’s comments on the proposed initiative schedule, as described in section 4.1:

see above

5. Additional comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

none

1. Provide a summary of your organization’s comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper:

2. Provide your organization’s comments on the background and issues, as described in section 2:

3. Provide your organization’s comments on the next steps, as described in section 3:

4. Provide your organization’s comments on the proposed initiative schedule, as described in section 4.1:

5. Additional comments on the Planning Standards – Remedial Action Scheme Guidelines Update issue paper: