Comments on Stakeholder Prioritization Workshop, Apr 8, 2026

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

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2. Organization Name

ACP-California

3. Contact name and email address

Molly Croll mcroll@cleanpower.org

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Highest priority among newly proposed 2026 Market Policy initiatives is the Joint Parties MIC Enhancements submission.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Highest priority among existing Market Policy initiatives is the Resource Adequacy Modeling and Program Design

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

ACP-California supports establishing a formal policy track for Western market seams issues, which directly affect the ability of ACP-California members participating outside the CAISO BAA to deliver into CAISO efficiently. A phased approach starting with EDAM, WEIM, and bilateral seams is a reasonable scoping framework as the workstream is developed.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

ACP-CA supports a targeted fix to the Flex RA phantom obligation issue which may be resolved through eliminating flex RA (as ACP-California supports considering, see response to question #9).

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

ACP-California strongly supports the MIC Enhancements initiative and identifies it as our highest priority among newly proposed 2026 Market Policy initiatives. ACP-CA represents utility-scale wind, solar, geothermal, storage, and transmission developers operating both inside CAISO and selling into CAISO from out-of-state (OOS). For our members, MIC is a structural barrier on project financing, contracting, and the timely delivery of resources California is counting on.

Current MIC mechanics are out of step with how generation projects are developed. Tying MIC eligibility to an RA contract active in the next RA year is incompatible with the multi-year timelines required to finance and construct new wind, solar, geothermal, and storage. The result is deliverability risk placed onto the developer despite minimal ability to influence allocation, slowing new project advancement and procurement of resources needed to meet IRP and reliability needs.

ACP-CA highlights three generator-side priorities for the scope of this initiative:

1. Forward MIC certainty for projects with future CODs, on a 3–5 year horizon aligned with development and financing realities.
2. A defined allocation pathway for entities holding long-term specified PPAs, so that MIC availability is not solely tied to LSE procurement cycles. The IRP/TPP integration process and TPP-based MIC expansion do not provide project-level certainty on a financing-relevant timeline.
3. Transparency into how existing MIC is held, used, and expires, and an effective mechanism to reallocate unused MIC on constrained interties[JC1] .

ACP-CA supports addressing these issues comprehensively and supports the Joint Parties' suggestion that the RA Modeling & Program Design initiative serve as the venue for addressing MIC reforms.

 [JC1]The reallocation piece may be out of scope for ACP-CA’s advocacy - any thoughts? (my understanding of MIC is still evolving)

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

ACP-California supports continued examination of the RA framework, including a comprehensive reassessment of whether the Flexible RA product remains justified given the development of Imbalance Reserve and Reliability Capacity products. ACP-CA encourages CAISO to engage stakeholders thoroughly on the design and revenue implications of any consolidation.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

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11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

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12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

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13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

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14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

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15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

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16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

ACP-CA supports establishing a dedicated stakeholder policy venue for EDAM enhancements, including issues unresolved from the EDAM design process. A formal policy initiative is the appropriate venue for addressing emerging EDAM issues, particularly given ACP-CA members' participation as resources outside the CAISO BAA.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

EDAM intertie bidding rules directly affect how resources outside the CAISO BAA participate in the market, and ACP-CA members developing those resources have a direct stake in how those rules are written. The current treatment of intertie bids relative to internal resources warrants a closer look. 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

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19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

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20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

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21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

EDAM congestion revenue allocation directly affects resources with long-term PPAs delivering into CAISO, including OOS resources developed by ACP-CA members. ACP-CA supports continued work on CRA design to develop a durable framework that supports continued delivery of diverse, clean energy resources to California.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

ACP-California members participate in EDAM both as resources within CAISO and within EDAM Entity areas and support continued market design refinement. That said, ACP-CA reserves views on specific enhancements as they are developed.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

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24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

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25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

ACP-CA supports continued work on outage substitution and availability mechanisms, including a more comprehensive review of whether availability incentives remain necessary with UCAP implementation. And ACP-California supports adding the MIC Enhancements topics to the RAMPD initiative (as proposed by the Joint Parties).

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

ACP-California supports adding MIC Enhancements topics (as proposed by the Joint Parties) to the RAMPD initiative.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Backstop procurement reform and long-term EDAM RSE design have direct implications for generator revenue adequacy and the treatment of resources outside the CAISO BAA. ACP-CA supports the workstream while reserving views on specific design choices. 

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Storage has a central and growing role in our membership. ACP-CA supports continued work across all four topic groups, with a focus on uplift, DEB methodology, and SOC management design that better reflect storage's opportunity cost.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

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30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

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31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

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32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

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33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

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34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

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1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Advanced Energy United

3. Contact name and email address

Brian Turner bturner@advancedenergyunited.org

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

No comment

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Advanced Energy United continues to prioritize the DDEMI initiative, including both Track 1 recognition of export beyond the customer meter within demand response products, and Track 2 issues including large load participation and participation options for WEIM/EDAM entities.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No comment

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No comment

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No comment

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No comment

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No comment

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No comment

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comment

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No comment

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No comment

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No comment

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No comment

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No comment

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No comment

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No comment

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

United places a high priority on the DDEMI initiative. We strongly support the continued progress of the Track 1 effort to recognise end-user export in Demand Response performance measurement. We also actively support Track 2's efforts to facilitate participation of DR and aggregated DERs in WEIM and EDAM BAAs, and to define, enhance, or adopt pathways for large load participation in markets, both inside CAISO and in WEIM/EDAM participant BAs.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No comment

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No comment

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No comment

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No comment

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No comment

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No comment

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No comment

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No comment

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No comment

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No comment

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No comment

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No comment

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

No comment

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

No comment

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

AES welcomes the opportunity to contribute to the 2026 Market Policy and Roadmap process and remains committed to supporting a productive, collaborative outcome. However, significant concerns arise from the repeated prioritization of the same initiatives, which raises serious questions about whether real progress is being made. CAISO must redirect its focus toward completing outstanding stakeholder initiatives and advancing a market design proposal to the WEM Governing Body for formal decision. The decision to break the Storage Design and Modeling initiative into separate topic groups for prioritization is particularly troubling. This approach ignores the fact that several design elements are already sufficiently developed to be finalized and brought to the WEM Governing Body within 2026. Fragmenting the initiative in this way risks unnecessarily delaying outcomes that are well within reach.

2. Organization Name

AES Corporation

3. Contact name and email address

rahul.kalaskar@aes.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

the elimination of the Flexible RA product

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Storage Design and Modeling,

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Discuss in EDAM Enhancements

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Support

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Support

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Support

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Support

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No Position

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No Position

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Support

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Support

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No Position

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No Position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Support

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Support

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No Position

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Support

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Support

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Support

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Support

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Support

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Support

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Support

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No Position

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

AES Corporation operates a diverse portfolio, including solar, wind, storage (battery energy storage systems), and thermal generation, that actively participates in the CAISO markets. Our top priorities reflect the operational realities of managing renewable intermittency through imbalance reserve products and optimizing storage asset performance through improved state-of-charge management. We support initiatives that enhance market efficiency, improve price formation, and provide clear operational signals for both renewable and conventional resources. Given our significant storage investments, we strongly support all Storage Design and Modeling topic groups as these directly impact our ability to optimize asset performance and participate effectively in CAISO markets.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

The current process is comprehensive. We appreciate the opportunity to provide input on both newly-proposed and existing initiatives. It would be beneficial to receive earlier visibility into how stakeholder feedback is weighted and incorporated into the final catalog and roadmap decisions.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Appian Way Energy Partners

3. Contact name and email address

Abram Klein, aklein@appianwayenergy.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Our top priority is Western Energy Market Seams.

As the Western Market Expands, the lack of Seams coordination may result in unfair and unintended congestion revenue allocations among EDAM market prticipants. For instance, non-CAISO entities (whether EDAM or Markets+) use of CAISO’s grid on congested flowgates related to path 15 and Path 26. This can erode CAISO transmission customers/ratepayers’ right to use the transmission network (which they pay for) year after year. We believe this initiative needs to address fair allocation for EDAM and Markets+ entities’ usage of CAISO transmission based on historical usage, good utility practice and common sense. There is no need to reinvent the wheel -- the Eastern Interconnection has a tremendous amount of experience dealing with Market-to-Market coordination and external entities’ entitlements. We believe there should be a “business solution” that allocates the rights to flow on adjacent BAA flowgates. Entities whose usage exceed their allocation should pay for the congestion they cause. This approach, or a similar one, is consistent with recommendations from the MSC in the EDAM proceeding, the WEIM market expert, and FERC’s November white paper on Western Seams coordination. 

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Congestion Revenue Rights Enhancements is our top priority. Well-functioning ISO/LMP markets must not only maintain efficient short-term operations and dispatch, but also facilitate longer-term contracting and efficient entry/exit. The ISO has an obligation to ensure the development and operation of market mechanisms to manage congestion given the liquidity challenges of LMP with over 1500 separate locations each with unique pricing. An efficient market for CRR fullfills this function, but CAISO's CRR market performs this function poorly given the huge level of revenue inadequacy that undermines the financial integrity of CRRs to service their intended congestion hedging role. 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

As the Western Market Expands, the lack of Seams coordination may result in unfair and unintended congestion revenue allocations among EDAM market prticipants. For instance, non-CAISO entities (whether EDAM or Markets+) use of CAISO’s grid on congested flowgates related to path 15 and Path 26. This can erode CAISO transmission customers/ratepayers’ right to use the transmission network (which they pay for) year after year. We believe this initiative needs to address fair allocation for EDAM and Markets+ entities’ usage of CAISO transmission based on historical usage, good utility practice and common sense. There is no need to reinvent the wheel -- the Eastern Interconnection has a tremendous amount of experience dealing with Market-to-Market coordination and external entities’ entitlements. We believe there should be a “business solution” that allocates the rights to flow on adjacent BAA flowgates. Entities whose usage exceed their allocation should pay for the congestion they cause. This approach, or a similar one, is consistent with recommendations from the MSC in the EDAM proceeding, the WEIM market expert, and FERC’s November white paper on Western Seams coordination. 

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

  N/A  

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

N/A  

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

N/A  

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

N/A  

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

We concur with WPTF comments.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

It's possible that these charges are due to discretionary dispatcher decisions or heuristics that cause inconsistency between the DA and RT markets. While virtual bids may profit (or lose) from these inconsistencies, they are not likely to impact the magnitude. However, to the extent that the CAISO grid can be operated better and more efficiently to avoid these inconsistencies, that is a worthy investigation. And the presentation raises basic questions about the transparency of how CAISO operates the grid. 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

N/A  

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

N/A  

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

N/A  

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Concur with WPTF's comments

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

N/A  

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

N/A  

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Well-functioning ISO/LMP markets must not only maintain efficient short-term operations and dispatch, but also facilitate longer-term contracting and efficient entry/exit. The ISO has an obligation to ensure the development and operation of market mechanisms to manage congestion given the liquidity challenges of LMP with over 1500 separate locations each with unique pricing. An efficient market for CRR fullfills this function, but CAISO's CRR market performs this function poorly given the huge level of revenue inadequacy that undermines the financial integrity of CRRs to service their intended congestion hedging role. 

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

N/A  

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

N/A  

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

N/A  

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

N/A  

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

N/A  

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

N/A  

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

N/A  

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

N/A  

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

N/A  n

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

N/A  

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

N/A  

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

N/A  

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

N/A  

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

We concur with WPTF -- CAISO should prioritize Market Seams and EDAM Enhancements efforts. Both of these efforts can include several of the proposed policy topics and can be structured into phases such that more immediate issues can be fixed without being delayed while other longer policy discussions within the same effort are taking place.

Additionally, there are a number of ongoing efforts designed to address improvements in price formation that will impact market efficiency in the short- and long-term. These include scarcity pricing and fast-start pricing among others. Getting the prices right in the spot market is essential for CAISO to ensure resiliency and efficient markets. For instance, all markets should be evolving toward greater and more efficient integration of demand response into the wholesale price setting process. Too often, CAISO sees expensive demand response actions taken during tight supply conditions as missing load with a price-suppressive impact. This has multiple pernicious effects, including incorrect long-term price signals, greater reliance on out-of-market RMR contracts for marginal resources, and the disincentivization of the very efficiency-enhancing demand response activities that are urgently needed to most ensure reliability and efficient markets over time. Getting the market prices right in the spot market is the most essential thing for the long-term health of the CAISO market. 

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

I voted on each, but could not submit comments unless I commented in all 34 places. That was unnecessary and required us to add a lot of N/As.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Arizona Public Service Co.

3. Contact name and email address

Brandon Holmes

brandon.holmes@aps.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Western energy market seams topics.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

EDAM Congestion Revenue Allocation

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Support for working towards solutions that provide clarity and minimize friction.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No position

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support making room on the roadmap for EDAM Enhancements identified in the future.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

APS views enabling economic bidding at EDAM intertie locations as an important piece of ensuring that economic trade continues to exist with minimum friction between entities who are in different organized markets in the future. We understand the EDAM tariff provides the option for EDAM entities to enable economic intertie bidding, but up to this point, no EDAM entity has elected to enable this functionality. It would be helpful to understand where the concerns lie, particularly from a BAA reliability standpoint, and work to address those concerns within the market design so that EDAM entities will be comfortable enabling this functionality in the future.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No position

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No position

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support for design evolution that incentives economic participation over self-schedules providing for a more optimal solution.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support making room on the roadmap for EDAM Enhancements identified in the future.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No position

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Avangrid

3. Contact name and email address

Scott Olson scott.olson@avangrid.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

MIC Enhancements

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

RA Track 2

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Avangrid recommends using this initiative to establish a timeline and work plan for address seams issues, either as a standalone initiative or as part of the existing EDAM Enhancements initiative.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Avangrid strongly supports this proposed initiative as necessary to provide certainty for deliverability of long lead time, out of state projects.  Meeting the goals for out of state development defined in the 2025 TPP Base Portfolio may be challenging without further MIC enhancements. 

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Support

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Support

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No position

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Avangrid recommends as an important first step to define the scope of the issues to be addressed in the first phase of EDAM Enhancements.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Support

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Support

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Support

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

Scope is unclear

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Not at this time

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

Not at this time

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

N/A

2. Organization Name

Bay Area Municipal Transmission Group (BAMx)

3. Contact name and email address

Paulo Apolinario (papolinario@svpower.com), Lena Perkins (lena.perkins@paloalto.gov)

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Maximum Import Capability (MIC) enhancements

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Congestion Revenue Rights Enhancements

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No position

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Support

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Support

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Support

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Support

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No position

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No position

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Support

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Support

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Support

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

N/A

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

N/A

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Bonneville Power Administration

3. Contact name and email address

bpamarketinitiatives@bpa.gov

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Western Energy Market Seams Topics

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Price Formation Enhancements: Scarcity Pricing and Market Power Mitigation

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

This item is Bonneville's highest priority among newly proposed initiatives.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No additional comment.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Bonneville would need more information regarding the potential imposition of requirements for parties to make unused allocations available for trade.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No additional comment.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Bonneville supports this initiative in principle and agrees that refinement is preferable to a fundamental redesign.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No additional comment.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No additional comment.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Bonneville concurs with the broader sentiment of this initiative proposal that the potential for changes to the bilateral market stemming from EDAM and Markets+ implementation merits monitoring bilateral market liquidity, and, with broad stakeholder support, investigating viable replacements for use in determining the maximum import bid price.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Bonneville supports refinements rather than elimination or wholesale changes to new products at this time.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Bonneville supports refinements rather than elimination or wholesale changes to new products at this time.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No additional comment.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Bonneville supports harmonization of bidding rules, to the extent practicable, at all interties with EDAM entities (including CAISO)

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No additional comment.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No additional comment.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No additional comment.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No additional comment.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No additional comment.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No additional comment.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Bonneville notes the relative lack of consensus on this sub-component of the broader PFE initiative and would prioritize other initiatives on this list that have garnered greater consensus (and are therefore likely to be more productive).

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Bonneville is supportive of RA modeling and program design initiatives so long as they do not unnecessarily preclude resource participation in the RA market.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Bonneville is supportive of RA modeling and program design initiatives so long as they do not unnecessarily preclude resource participation in the RA market.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Bonneville is supportive of RA modeling and program design initiatives so long as they do not unnecessarily preclude resource participation in the RA market.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Bonneville generally supports enhancements in the storage design and modeling area since the fleet has undergone rapid expansion and market modeling has not evolved with it.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Bonneville generally supports enhancements in the storage design and modeling area since the fleet has undergone rapid expansion and market modeling has not evolved with it.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Bonneville generally supports enhancements in the storage design and modeling area since the fleet has undergone rapid expansion and market modeling has not evolved with it.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Bonneville generally supports enhancements in the storage design and modeling area since the fleet has undergone rapid expansion and market modeling has not evolved with it.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No additional comment.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

The California Community Choice Association (CalCCA) appreciates the opportunity to provide feedback on the 2026 Market Policy Catalog Stakeholder Prioritization Workshop. CalCCA’s priorities described herein focus on the ability to bring new deliverable capacity online to support reliability and clean energy goals. The California Public Utilities Commission (CPUC) has found a 6,000 megawatts reliability need in 2029-2032 and is planning for 19 gigawatts of out-of-California Independent System Operator (CAISO) resources by 2045.[1] Deliverability of internal and external resources is limited, and the process for securing deliverability for out-of-CAISO resources is uncertain and creates barriers for long-term procurement. Therefore, CalCCA’s highest priority for the 2026 Market Policy Catalog and Roadmap is the Maximum Import Capability (MIC) Enhancements initiative submitted by the Joint Parties.[2]

[1]            Decision 26-02-057, Decision Requiring 2029-2032 Electric Resource Procurement and Transmitting Portfolios for 2026-2027 Transmission Planning Process, Rulemaking 25-06-019 (Feb. 26, 2026), at 60, https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=601777006.

[2]            The Joint Parties MIC Submittal (Mar. 2, 2026), https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef#org-85e61823-658d-40e8-9bfe-16753fbfe6cb.The Joint Parties include: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) CalCCA; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) Regents of the University of California (UC Regents).

2. Organization Name

The California Community Choice Association (CalCCA).[1]

[1]            CalCCA represents the interests of 24 community choice electricity providers in California: Apple Valley Choice Energy, Ava Community Energy, Central Coast Community Energy, Clean Energy Alliance, Clean Power Alliance of Southern California, CleanPowerSF, Desert Community Energy, Energy For Palmdale’s Independent Choice, Lancaster Energy, Marin Clean Energy, Orange County Power Authority, Peninsula Clean Energy, Pico Rivera Innovative Municipal Energy, Pioneer Community Energy, Pomona Choice Energy, Rancho Mirage Energy Authority, Redwood Coast Energy Authority, San Diego Community Power, San Jacinto Power, San José Clean Energy, Santa Barbara Clean Energy, Silicon Valley Clean Energy, Sonoma Clean Power, and Valley Clean Energy. 

3. Contact name and email address

Lauren Carr - lauren@cal-cca.org.

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Maximum Import Capacity (MIC) Enhancements

CalCCA assigns the MIC enhancements catalog submission the highest priority among newly proposed initiatives. Within the Resource Adequacy (RA) Modeling and Program Design (RAMPD) initiative, the CAISO should conduct a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing MIC to support eligibility of import resources to provide RA capacity. The ability to bring new deliverable capacity online is paramount to supporting reliability and clean energy goals. As stated in the Joint Parties’ MIC Submittal, CPUC and non-CPUC jurisdictional load serving entities (LSE) are actively evaluating opportunities to contract with out-of-CAISO resources to support long-term planning efforts, but challenges with obtaining MIC when and where needed create barriers to long-term contracting and RA procurement.[1]

CalCCA strongly urges the CAISO to pursue MIC enhancements as part of the RAMPD initiative, rather than under a separate Infrastructure-related initiative. MIC policy and implementation are inextricably intertwined with RA policy and implementation, and the CAISO balancing authority area (BAA) has historically relied on imports to meet RA requirements. It is critical that consideration of enhancements to MIC determination and application be fully integrated with, informed by, and supportive of RA policy and objectives.  

[1]            Joint Parties’ MIC Submittal.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

RA Modeling and Program Design.

CalCCA has selected RAMPD as its highest priority among existing initiatives, as the RA program has gone through significant evolution in recent years and has the potential to significantly impact reliability and affordability outcomes. It is also the appropriate forum for the MIC enhancements stakeholder process, CalCCA’s highest priority among newly proposed initiatives.

Other existing initiatives are also critically important for market efficiency, distributed energy and storage market integration, affordability, and reliability. CalCCA therefore strongly supports the continued prioritization of the following initiatives (in no particular order): (1) Congestion Revenue Rights (CRR) Enhancements; (2) Demand and Distributed Energy Market Integration (DDEMI); (3) BAA-level market power mitigation (MPM); and (4) Storage Design and Modeling.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

CalCCA supports the CAISO’s plan to engage in discussions with stakeholders around market seams. As the Western grid evolves, new seams are emerging, and it is worthwhile exploring how to address these themes to ensure a reliable grid that is as efficient as possible.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

See response in section 4.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Western Power Trading Forum’ s (WPTF) proposal includes two elements: (1) the exploration of removing the flexible RA requirement; and (2) the CAISO enforcement of a minimum planning reserve margin (PRM). CalCCA does not object to examining the need for the flexible RA requirement. However, WPTF’s RA reliability initiative appears to attempt to supersede the local regulatory authorities’ (LRA) authority set forth in Public Utilities Code section 380[1] to set reliability standards for the RA program. LRAs implement this authority by setting their PRM and the CAISO ensures those PRMs are met through backstop procurement if necessary. The proposed RA reliability initiative appears to seek to change this dynamic by allowing the CAISO to set a minimum PRM for LRAs in its BAA. For these reasons, CalCCA opposes the initiative with caveats. The CAISO should instead focus its efforts on identifying potential reforms necessary to improve its backstop mechanisms under its existing authority, as currently scoped in the RAMPD initiative’s Track 3.

[1]            Cal. Pub. Util. Code § 380, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PUC&sectionNum=380.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

CalCCA supports the CAISO examining the liquidity of bi-lateral indices. This examination is necessary to ensure customers and sellers are not adversely impacted by CAISO market processes tied to bi-lateral indices, given the Federal Energy Regulatory Commission’s recent elimination of the Western Electric Coordinating Council soft-offer cap.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position,

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No position.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

CalCCA supports the CAISO’s continued efforts to enhance its CRR process. Revenue adequacy is the most important topic to be addressed in this CRR enhancement initiative. The CAISO should prioritize evaluating the causes of revenue inadequacy and the effectiveness of potential solutions to enable stakeholder to fully evaluate potential solutions.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

CalCCA supports continued efforts to enhance participation models and market rules facilitating the representation of demand and distributed energy in the CAISO markets. In particular, CalCCA strongly supports the CAISO’s efforts to modify the Performance Evaluation Methodologies and the modified Proxy Demand Response market participation model to enhance Distributed Energy Resources (DER) participation in the CAISO markets. In support of these efforts, the CAISO should work closely with the CPUC to create a pathway for DER to obtain RA qualifying capacity values aligned with this new model.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No position.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

CalCCA supports this initiative with caveats. Specifically, CalCCA supports the CAISO’s proposed reforms to BAA-level market power mitigation to transition to a grouping approach and include the CAISO BAA in its assessment of BAA-level market power. Regarding scarcity pricing, this initiative should be limited to the CAISO’s proposed improvements to the existing scarcity pricing mechanisms, not wholesale redesign for the reasons expressed in CalCCA’s prior comments.[1] The CAISO should move forward with completing the BAA-level MPM proposal, which has been thoroughly developed with stakeholders, and does not need to be tied to changes to scarcity pricing.                  

[1]            https://stakeholdercenter.caiso.com/Comments/AllComments/39475c41-a007-4969-9cbd-fb58bf97630a#org-81b47b55-3c58-46ce-a558-7fac6951cc85.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

CalCCA does not support the CAISO continuing a stakeholder process for fast start pricing. Discussions to date have not demonstrated benefits associated with fast-start pricing to justify the associated cost increases. The CAISO has other mechanisms to ensure fast-start resources recover their costs without the customer cost impacts associated with fast-start pricing. Developing fast-start pricing is not a good use of CAISO and stakeholder time and resources when the CAISO already fully compensates fast-start resources for their start-up costs.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

CalCCA has selected RAMPD as its highest priority among existing initiatives, as the RA program has gone through significant evolution in recent years and has the potential to significantly impact reliability and affordability outcomes. It also is the appropriate forum for the MIC enhancements stakeholder process, CalCCA’s highest priority among newly proposed initiatives.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

CalCCA has selected RAMPD as its highest priority among existing initiatives, as the RA program has gone through significant evolution in recent years and has the potential to significantly impact reliability and affordability outcomes. It also is the appropriate forum for the MIC enhancements stakeholder process, CalCCA’s highest priority among newly proposed initiatives.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

CalCCA has selected RAMPD as its highest priority among existing initiatives, as the RA program has gone through significant evolution in recent years and has the potential to significantly impact reliability and affordability outcomes. It also is the appropriate forum for the MIC enhancements stakeholder process, CalCCA’s highest priority among newly proposed initiatives.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

CalCCA has selected RAMPD as its highest priority among existing initiatives, as the RA program has gone through significant evolution in recent years and has the potential to significantly impact reliability and affordability outcomes. It also is the appropriate forum for the MIC enhancements stakeholder process, CalCCA’s highest priority among newly proposed initiatives.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

CalCCA supports continued efforts to enhance energy storage market design, modeling, and processes.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

CalCCA supports continued efforts to enhance energy storage market design, modeling, and processes.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

CalCCA supports continued efforts to enhance energy storage market design, modeling, and processes.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

33. Please describe your organization’s support for the following newly-proposed proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources *

Choose:

• Support - CALCCA CHOICE
• Support with caveats
• Oppose
• Oppose with caveats
• No position

CalCCA supports continued efforts to enhance energy storage market design, modeling, and processes.

34. Please describe your organization’s support for the following newly-proposed proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements *

Choose:

• Support
• Support with caveats
• Oppose
• Oppose with caveats
• No position - CALCCA CHOICE

35. Do you have any additional prioritization feedback that you’d like the ISO to consider?

CalCCA has no comments at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

36. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

CalCCA has no comments at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

California Department of Water Resources – State Water Project (CDWR-SWP)

3. Contact name and email address

Kyle Grousis-Henderson (Kyle.Grousis-Henderson@water.ca.gov)

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Demand and Distributed Energy Market Integration 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

no comments

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

CDWR-SWP strongly supports this initiative and urges CAISO to include it on the 2027–2029 Market Policy Roadmap as a high-priority item. As presented by CDWR-SWP in the stakeholder meeting, the need to address the phantom obligation concern is driven primarily by cost causation. When a resource's commercial operation date is delayed, often due to factors outside the LSE's control, the LSE is left with a phantom flexible RA obligation for a non-operational resource, exposing it to significant backstop costs. CDWR-SWP believes this proposal is easily implementable and should be addressed as soon as possible since it has direct financial impacts on LSEs. The proposed fix is straightforward: prorate the flexible RA allocation reduction to the delayed resource MWs only, with no systemwide true-up required and no reliability impact. Without action, LSEs will continue absorbing unjustified costs for resources that provide zero flexibility benefit to the grid. CDWR-SWP believes this proposal is easily implementable and should be addressed as soon as possible since it has direct financial impacts on LSEs. 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

no comments

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

no comments

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

no comments

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

no comments

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

As presented by CDWR-SWP in the stakeholder meeting, the rising cost of RTCO is significant and reason this is happening remains unclear while LSEs are exposed to significant costs. For CDWR-SWP specifically, RTCO charges have increased over 1694% since 2011 and more than doubled since 2019. CAISO’s DMM confirmed in the 2025 Q3 Market Performance Report that RTCO costs have continued to rise systemwide. The charge is intended to reverse hour-ahead and real-time congestion rents collected from LSEs, but it consistently collects far more than it reverses with no mechanism for LSEs to control or contest the charge. CDWR-SWP recommends the CAISO to open a dedicated stakeholder process to investigate the root causes of RTCO escalation and reform the charge into a true neutrality mechanism. Without action, LSEs will continue absorbing unjustified costs. 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

no comments

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

no comments

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

no comments

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

no comments

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

no comments

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

no comments

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

no comments

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

no comments

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

no comments

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

no comments

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

no comments

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

no comments

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

no comments

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

no comments

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

no comments

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

no comments

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

no comments

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

no comments

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

no comments

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

no comments

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

no comments

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

no comments

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

Thank you for the opportunity to respond to the survey on priority stakeholder initiatives. CEDMC's top priority at CAISO this year is the Demand and Distributed Energy Market Integration (DDEMI) Initiative. 

2. Organization Name

California Energy + Demand Management Council

3. Contact name and email address

Melanie Gillette

policy@cedmc.org

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

No position

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

1. Demand and Distributed Energy Market Integration

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No position

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No position

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No position

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Support

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No position

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

no position

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No position

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the 2026 Market Policy and Roadmap process.  CESA is concerned that current initiatives are being prioritized again.  The CAISO must focus on completing stakeholder initiatives and bringing market design proposal to the WEM Governing Body for decision.  The CAISO’s decision below to separate the Storage Design and Modeling initiative into its separate topic groups for prioritization fails to account for the fact that several design elements should be able to be finalized, with appropriate focus, and brought to the WEM Governing Body in 2026.   

CESA is unclear of the intent of classifying an initiative with support, support with caveats, oppose, oppose with caveats, and no position and how this information will be used by CAISO for prioritization.  CESA is using “support” to identify initiatives that should remain on the roadmap, “no position” for initiatives that could be within the scope of an existing initiative, and “oppose” for initiatives that should be removed from the roadmap or not added at this time.

2. Organization Name

CESA

3. Contact name and email address

Don Tretheway

donald.tretheway@gdsassociates.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

CESA believes classifying the list above as “new” is in most cases inaccurate.  The 2025 Policy Roadmap already included an EDAM Enhancements initiative, but only as needed.  It is obvious that it is needed.  The DAME Configurable Parameters process has already contemplated additional review of the implementation of imbalance reserves.  The current Resource Adequacy Modeling and Program Design initiative is ongoing and should address issues above, including the elimination of the Flexible RA product.  While CESA supports ancillary services real-time optimization, it is clear there is insufficient CAISO bandwidth to take on this issue in the next 18 months since so many existing initiatives seem unlikely to be resolved in this timeframe given the historical completion rate of initiatives. 

For purposes of clarity, CESA’s highest priority from the list of topics above is the elimination of the Flexible RA product.  This topic should be included in the current Resource Adequacy Modeling and Program Design initiative.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Storage Design and Modeling, Topic group 2: Uplift & default energy bids 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Discuss in EDAM Enhancements

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Discuss in RAMPD.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Discuss in RAMPD

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Discuss in RAMPD

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Discuss in DAME Configurable Parameters 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Insufficient CAISO resources to add to roadmap at this time.  CESA looks forward to AS real-time re-optimization as soon as possible. 

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comment.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No comment.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Discuss in EDAM Enhancements 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Discuss in EDAM Enhancements 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Discuss in EDAM Enhancements 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Discuss in EDAM Enhancements 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No comment.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No comment.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No comment.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No comment.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No comment.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No comment.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No comment.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No comment.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No comment.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No comment.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No comment.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No comment.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No comment.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No comment.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No comment.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

See above.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

See above.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates).

3. Contact name and email address

Patrick Cunningham (Patrick.cunningham@cpuc.ca.gov)

Karl Dunkle Werner (karl.dunklewerner@cpuc.ca.gov)

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Cal Advocates identifies the “EDAM and DAME assessment” proposal from the California Public Utilities Commission Energy Division as highest priority.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Cal Advocates identifies the “Storage Design and Modeling, Topic group 2: Uplift & default energy bids” existing initiative as highest priority.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Cal Advocates has no additional feedback at this time.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Cal Advocates has no additional feedback at this time.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Cal Advocates has no additional feedback at this time.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Cal Advocates has no additional feedback at this time.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Cal Advocates has no additional feedback at this time.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Cal Advocates has no additional feedback at this time.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

Cal Advocates has no additional feedback at this time.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Cal Advocates has no additional feedback at this time.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Cal Advocates has no additional feedback at this time.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Cal Advocates has no additional feedback at this time.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Cal Advocates has no additional feedback at this time.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Cal Advocates has no additional feedback at this time.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

Cal Advocates has no additional feedback at this time.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Cal Advocates has no additional feedback at this time.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Cal Advocates has no additional feedback at this time.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Cal Advocates has no additional feedback at this time.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Cal Advocates has no additional feedback at this time.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Cal Advocates has no additional feedback at this time.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Cal Advocates has no additional feedback at this time.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Cal Advocates has no additional feedback at this time.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Cal Advocates has no additional feedback at this time.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Cal Advocates has no additional feedback at this time.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Cal Advocates has no additional feedback at this time.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Cal Advocates has no additional feedback at this time.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Cal Advocates has no additional feedback at this time.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Cal Advocates has no additional feedback at this time.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

Cal Advocates has no additional feedback at this time.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Cal Advocates has no additional feedback at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

 Cal Advocates provides no suggestions at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Calpine

3. Contact name and email address

Chris Devon chris.devon@calpine.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Western Energy Market Seams Topics

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Assessing and improving seams issues should befocused on measures that demonstrably improve price convergence, dispatch efficiency, and open access. CAISO should avoid introducing additional complexity to the extent possible, as well as avoiding bilateral carve-outs or preferential treatment that impacts efficient and transparent market outcomes.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Given the limited impact, this item should not divert resources from higher-priority reliability and market efficiency reforms.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

MIC reforms should remain based upon physical deliverability and transmission capability. Calpine agrees that the CAISO should consider how to further address the misalignment created by annual MIC processes, which constrain long-term contracting and undermine efficient resource development.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

CAISO should consider how to best ensure reliability objectives are achieved through improved modeling, performance incentives, and price signals. Market-based solutions should remain the primary reliability tool. Calpine supports efforts to achieve meeting a 1-in-10 LOLE reliability standard. CAISO should ensure that any efforts to update reliability standards include consideration of backstop reforms and that resulting proposals follow cost causation principles.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Enhancements should strengthen scarcity pricing, deployment accuracy, and operational alignment. Reforms should avoid increased complexity or uplift that obscures efficient price formation and dispatch signals.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Real-time re-optimization can improve dispatch efficiency and price accuracy. Implementation should follow broader price formation reforms to ensure scarcity signals are not inadvertently suppressed.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comment.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Safeguards should not impair competitive bidding behavior or organized market price formation. Overreliance on pricing bilateral indices during periods of potential illiquidity also risks undermining efficient price formation and reducing liquidity and transparency in the CAISO market.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Ongoing evaluation is appropriate, but this effort should remain focused on dispatch efficiency, price convergence, and participant neutrality. This assessment should avoid creating uncertainty or reopening settled design elements unnecessarily.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

A periodic review is appropriate if scoped to objective operational performance metrics. Similar to the other EDAM and DAME assessment items, this effort should not serve as a mechanism to revisit foundational design decisions or reopen settled design elements absent clearly demonstrated issues.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Calpine supports enhancements that increase liquidity, scheduling efficiency, and participation. We oppose changes that introduce administrative burdens or constrain market flexibility. Similar to the other EDAM related items, this effort should not revisit foundational design decisions or reopen settled design elements absent clearly demonstrated issues.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

EDAM and intertie bidding related rules should be delveoped with principles associated with preserving arbitrage opportunities, liquidity, and transparent cross-border price signals. Calpine believes that design changes must remain non-discriminatory and consistent with open access principles.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

Considering additional flexibility in commitment cost bidding may be necessary to reflect true operating costs, reduce uplift, and improve commitment decisions. Reforms should avoid over-mitigation or cost recovery limitations, particularly for frequently mitigated local resources.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Any CRR improvements should strengthen hedging functionality and congestion price signals. Calpine strongly beleives that the CAISO should not introduce any changes that materially reduce liquidity or limit participation in the CRR auction process.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

DER and DR participation should align with consistent telemetry, performance, and accountability standards. Priority effort within this item should be given to addressing large load participation impacts on system reliability and markets.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Any proposed updates to congestion revenue allocation methodologies should preserve locational price signals and congestion economics. CAISO should attempt to preserve efficient market participation incentives to the extent possible. Socialization approaches that weaken investment signals or distort dispatch outcomets should also be avoided.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Priority should be placed on completing and stabilizing existing EDAM design elements before adding other features or introducing additional complexity.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Calpine stringly beleives that strengthening scarcity pricing is foundational to efficient market outcomes and resource adequacy. Scarcity pricing reforms must be coordinated with market power mitigation to ensure credible and actionable price signals and avoid relaibility concerns.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Fast-start pricing policies should seek to correct systematic price suppression. The CAISO should avoid designs that create excess compensation or new uplift pathways.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Reforms should improve outage realism, accountability, and availability incentives. Penalties should be aligned with actual operational capabilities and constraints.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

While transparency has value, the proposed approach appears burdensome and insufficiently justified. Additional reporting requirements should only be adopted where there is a clear, demonstrated reliability benefit.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Backstop mechanisms should remain narrow and apply only as needed. Markets, not administrative processes, should drive long-term outcomes.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Storage outage treatment should reflect physical and operational characteristics, improving alignment with dispatch reality.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Default energy bids must reflect true opportunity costs and preserve scarcity pricing signals. Design considerations should ensure that resource owners are made whole if the reason for uneconomic outcomes or unavailability are due to CAISO market outcomes or actions.  CAISO should avoid muting price formation or unintentionally shifting costs into uplift.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Improved SOC modeling should focus on enhancement to dispatch efficiency and price accuracy. Priority should be given to enhancing existing NGR models before introducing more complex frameworks.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

CAISO should ensure consistent performance obligations and market treatment across all resource types. Designs should avoid preferential rules that distort competition.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

RSE enhancements should complement, not replace, price-based reliability incentives. The mechanism should not evolve into a de facto procurement or administrative reliability tool.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

The CAISO should prioritize completing existing initiatives, particularly Price Formation Enhancements, CRR Enhancements, EDAM and DAME refinements, and RA Modeling and Program Design, before expanding the scope of new work.
Market reforms should be evaluated against a clear efficiency test: Does the proposed changes improve dispatch, pricing, and investment signals under competitive conditions?
Administrative constructs should be minimized in favor of transparent price signals and enforceable performance obligations.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

Clarify how “support with caveats” is weighted in prioritization decisions.
Group closely related initiatives to avoid duplicative stakeholder processes (e.g., EDAM, DAME enhancements have multiple items).
Publish clearer completion expectations and decision timelines to improve stakeholder planning and engagement.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

California Solar and Storage Association

3. Contact name and email address

Jon Hart

jon@calssa.org

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

No comment

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

The Demand and Distributed Energy Market Integration Initiative is CALSSA's highest priority.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

NA

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

NA

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

NA

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

NA

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

NA

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

NA

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

NA

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

NA

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

NA

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

NA

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

NA

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

NA

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

NA

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

NA

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

We strongly support this initiative and plan to engage in it.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

NA

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

NA

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

NA

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

NA

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

NA

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

NA

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

NA

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

NA

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

NA

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

NA

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

NA

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

NA

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

NA

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

NA

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

 California Public Utilities Commission

3. Contact name and email address

Maygol Kabiri, Maygol.kabiri@cpuc.ca.gov

Jordan Miner, jordan.miner@cpuc.ca.gov

Ryan Grieser, Ryan.Grieser@cpuc.ca.gov

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Energy Division staff (ED staff or staff) of the California Public Utilities Commission (CPUC) develop and administer energy policy and programs to serve the public interest, advises the CPUC, and ensures compliance with CPUC decisions and statutory mandates. ED staff provide objective and expert analyses that promote reliable, safe, and environmentally sound energy services at just and reasonable rates for the people of California.

ED staff appreciates CAISO’s consideration of the range of possible new initiatives proposed by stakeholders. ED staff is generally supportive of proposals that would consider/conduct a review of the EDAM design. As a starting point, ED staff views our proposal for an EDAM and DAME assessment as the highest priority for the market policy catalog. ED staff, however, believe PG&E’s 2028 EDAM review proposal and PacifiCorp’s imbalance reserve product enhancements proposal can appropriately be scoped within ED staff’s EDAM and DAME assessment proposal. ED staff is concerned about the scope of WPTF’s EDAM enchantments proposal, which seems too broad. ED staff encourages CAISO to continue to explore the liquidity of bilateral indices in FERC Order 831 implementation, which could be scoped into an EDAM enhancement initiative depending on the final scope of this EDAM initiative.  Finally, ED staff opposes WPTF’s recommendation to change capacity procurement mechanism (CPM) backstop authority as part of Resource Adequacy reform because it would bypass the local regulatory agency’s authority in setting reliability standards of the planning reserve margin.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

ED staff finds that the highest priority existing initiative is EDAM Congestion Revenue Allocation (CRA), especially as it develops a long-term durable design. The flaws in the interim EDAM CRA methodology are well known and have been roundly critiqued by an array of stakeholders. ED staff believes that the development of a long-term solution will be complicated, but critical for ensuring the economic efficiency of EDAM is addressed.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No position. ED staff is generally interested and supportive of these discussions taking place as seams could impact financial and operational aspects of the market, but at this time defers to CAISO on the speed with which these conversations need to take place.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position. 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Support with caveats. Current RA rules require LSEs to obtain a Maximum Import Capability (MIC) allocation to utilize out-of-state resources towards RA obligations. The MIC allocation process occurs annually, and existing frameworks make it difficult to obtain MIC for under construction resources. There is a misalignment between the timeframe of when LSEs enter contracts with out-of-state resources and when they are awarded MIC allocations. This leads to uncertainty in the RA value of the contracted resource. Joint Parties highlight this issue and encourage CAISO to make process enhancements that improve long-term certainty of obtaining MIC for under construction resources. Energy Division supports process enhancements that improve LSEs ability to secure MIC necessary to use out-of-state resources for RA obligations.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Support with caveats. ED staff is supportive of PacifiCorp’s proposal, but find that this proposal could be reasonably scoped within ED staff’s EDAM assessment proposal.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position. ED staff encourages CAISO to consult with DMM, because it is ED staff’s understanding that this proposal could potentially be complicated to implement.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

Support.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Support. ED staff has raised this issue in the last two policy catalog submissions, and note that this issue has become more pressing with FERC’s removal of the Western Electricity Coordinating Council price cap in 2025. In addition, FERC Order 831 is applicable to all RTOs/ISOs so consideration of this topic is within the scope of EDAM enhancements.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Support.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Support. ED staff notes that ED staff’s proposal for an EDAM/DAME assessment scope would be broad enough to include PG&E’s 2028 EDAM review proposal.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support with caveats. ED staff is supportive of EDAM enhancements, but is concerned that WPTF’s proposal is overly broad. The intent of an EDAM enhancement initiative should be to consider enhancements, not conduct a full-scale review and redesign of the EDAM.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position. 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position. 

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Support with caveats – see CPUC comments submitted April 6, 2026, to the Track 1 Straw Proposal and Track 2 Issue Paper.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support. 

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support. Please see answers to questions (4, 10, 13, 14, 15, and 16) for further details.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Oppose with caveats. ED staff is supportive of market power mitigation, but does not support consideration of scarcity pricing at this time.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Oppose. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Support. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position. ED staff is unclear how this question interacts with Track 3B, as this was addressed in Track 3A.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position. ED staff notes that EDAM RSE solutions could be in the scope of an EDAM enhancements initiative.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Support. 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Support. 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Support. 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Support. 

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

Support. 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Not at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

Not at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

See responses below.

2. Organization Name

DC Energy California, LLC

3. Contact name and email address

Justin Cockrell - cockrell@dc-energy.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Western market seams coordination – Appian Way Energy Partners 

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

 EDAM Congestion Revenue Allocation

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

DC Energy particularly supports Appian Way’s call to proactively address market seams issues, including unscheduled parallel flows.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No position

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Support

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

DC Energy particularly supports addressing increased uplift to convergence bids under the new DAME market design.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No postion

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

This initiative should focus on practical, incremental enhancements to the CAISO’s existing CRR market design that make CRRs a more reliable and useful hedging instrument while preserving open access.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No position

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

This initiative should be the top priority for the CAISO.  The existing congestion revenue allocation in EDAM is inequitable for CAISO CRR holders and perpetuates inefficient incentives to self-schedule in EDAM BAAs outside of the CAISO.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Support

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Support

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No postion

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No postion

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No postion

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No postion

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No postion

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No postion 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

N/A

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

N/A

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

ENGIE NA

3. Contact name and email address

Margaret Miller

Margaret.Miller@engie.com 

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

ENGIE is most supportive of WPTF’s RA reliability initiative. In particular, eliminating the Flex RA product. ENGIE agrees that the product has not produced intended benefits and creates unnecessary complexity.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Storage Design and Modeling is ENGIE’s highest priority ongoing initiative.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

ENGIE supports establishing a formal policy track for Western market seams issues.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

no comment

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

ENGIE supports the MIC Enhancements initiative and agrees that MIC is a structural barrier to project financing, contracting, and the timely delivery of resources to CA.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

ENGIE supports the continued examination of the RA framework as our highest priority, especially including a comprehensive reassessment of whether the Flexible RA product is still needed in light of the new DA market products the CAISO recently implemented.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

no comment

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

no comment

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

no comment

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

no comment

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

no comment

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

no comment

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

ENGIE supports establishing a dedicated stakeholder policy venue for EDAM enhancements. 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

ENGIE supports further evaluating EDAM bidding rules

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

no comment

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

no comment

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

no comment

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

ENGIE supports continuing to refine EDAM congestion revenue allocation

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

no comment

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

no comment

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

no comment

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

ENGIE supports with caveats continued work on outage substitution and availability mechanisms, including a more comprehensive review of whether RAAIM remains necessary with UCAP implementation. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

no comment

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

no comment

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

ENGIE supports continuing this discusssion. It is unclear why the CAISO broke out all of these sub dicussions from the total initiative. 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

ENGIE supports continuing Storage Design and Modeling in its entirety. Again, unclear why these topics were broken out separately. 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

ENGIE supports this initiative. This continues to be an important discussion. 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

no comment

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

no comment

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

no comment

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

no comment

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Leapfrog Energy (Leap)

3. Contact name and email address

Collin Smith, collin@leap.energy

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

No comment

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Demand and Distributed Energy Market Integration

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No comment

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No comment

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No comment

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No comment

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No comment

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No comment

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comment

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No comment

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No comment

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No comment

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No comment

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No comment

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No comment

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No comment

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

This initiative is an important venue to discuss existing policy issues connected to DER market integration and should be retained. 

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No comment

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No comment

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No comment

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No comment

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No comment

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No comment

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No comment

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No comment

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No comment

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No comment

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No comment

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No comment

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

Middle River Power LLC (MRP) appreciates the opportunity to provide feedback on prioritization of the newly-proposed and existing Market Policy initiatives.          

2. Organization Name

Middle River Power LLC 

3. Contact name and email address

Tina Chase

tchase@mrpgenco.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Resource adequacy reliability (Western Power Trading Forum)

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No additional comments at this time.               

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No additional comments at this time.                    

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No additional comments at this time.                    

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No additional comments at this time.                   

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Please see MRP’s response to Question 33. 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No additional comments at this time.                    

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No additional comments at this time.                   

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No additional comments at this time.                 

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Please see MRP’s response to Question 33. 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Please see MRP’s response to Question 33. 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Please see MRP’s response to Question 33. 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No additional comments at this time.           

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No additional comments at this time.           

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No additional comments at this time.           

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No additional comments at this time.           

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No additional comments at this time.           

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Please see MRP’s response to Question 33. 

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No additional comments at this time.           

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

MRP continues to appreciate CAISO’s willingness to consider fast start pricing in this initiative and urges CAISO to evaluate the benefits of fast start pricing relative to the benefits provided by the flexible ramping product as it considers this issue. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No additional comments at this time.           

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No additional comments at this time.           

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No additional comments at this time.           

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No additional comments at this time.           

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No additional comments at this time.           

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No additional comments at this time.           

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No additional comments at this time.           

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No additional comments at this time.           

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

There are several proposals related to post-implementation review of EDAM and DAME. MRP recommends that CAISO consolidate these efforts under a single initiative and implement a working group process to review and prioritize the proposals.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

 No additional comments at this time.           

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

Among the newly proposed initiatives in the Market Policy Catalog, PG&E assigns highest priority to the Maximum Import Capability (MIC) enhancements initiative proposed by the Joint Parties.

2. Organization Name

Pacific Gas and Electric Company 

3. Contact name and email address

Adeline Lassource; Adeline.Lassource@pge.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Among the newly proposed initiatives in the Market Policy Catalog, PG&E assigns highest priority to the Maximum Import Capability (MIC) enhancements initiative proposed by the Joint Parties.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Among the existing market policy initiatives, PG&E continues to assign high priority to the following initiatives: 

• EDAM Enhancements 

• Resource Adequacy Modeling and Program Design 

• Congestion Revenue Rights Enhancements 

• EDAM Congestion Revenue Allocation 

• Storage Design and Modeling 

• Demand and Distributed Energy Market Integration 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

PG&E supports discussions on market-to-market seams but is under the impression that workshops are already scheduled and therefore not needed as a new initiative at this time.  

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No comments.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

PG&E supports establishing a standalone initiative or incorporating MIC into the existing Resource Adequacy Modeling and Program Design (RAMPD) initiative, provided it does not delay ongoing RAMPD Tracks—particularly Track 2 (RAAIM reform and planned outage substitution enhancements). 

The Joint Parties have identified several key issues related to the calculation and allocation of Maximum Import Capability (MIC) that warrant further evaluation within this initiative. These include: limitations in the long-term MIC framework to support power purchase agreements with commercial operation dates beyond the immediate year; insufficient MIC to meet LSE demand on popular interties; and inefficiencies that result in unused MIC because of either: (1) a cumbersome trading mechanism; (2) parties not making their unused allocations available for trade, and/or (3) parties making unused MIC available at unusable locations.

PG&E supports these identified issues and recommends that CAISO assess the implementation and utilization of the 2022 MIC enhancements—specifically New Use Import Commitments and MIC expansion—to better understand their effectiveness and inform potential improvements. 

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

WPTF put forward two proposals: 1) removing the Flexible RA product to simplify the framework and reduce costs and 2) Update the CPM mechanism to restore CAISO’s ability to backstop reliability. 

• PG&E supports the proposal to remove the Flex RA requirement, with the caveat that implementation should not delay ongoing RAMPD tracks. CAISO’s analysis presented in the RAMPD working group indicates that Flex RA requirements may be significantly higher than actual system needs (link to the analysis: https://stakeholdercenter.caiso.com/InitiativeDocuments/Presentation-ResourceAdequacyModeling-ProgramDesignWorkingGroup-Jan162024.pdf). 

• No position on the CPM enhancement proposal – PG&E notes that CPM enhancement is currently scoped within the RAMPD initiative (Track 3B). 

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

In the current Policy Roadmap, the CAISO has budgeted time for urgent EDAM / DAME Enhancements initiative.  PG&E recommends keeping this initiative going by selecting our version of this EDAM / DAME Enhancements and including PacifiCorp as a part of it. PG&E’s proposal recommends establishing metrics for EDAM success and using operational data to identify what areas are not hitting the metrics and define the initiative scope. This should provide a transparent basis for prioritizing multiple stakeholder proposals that fall under EDAM / DAME enhancements. 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

The PG&E-proposed initiative is intended to increase the efficiency of real-time procurement and dispatch.  It may also facilitate a uniform market for ancillary services across balancing areas.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comments.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

PG&E supports evaluating where bilateral indices are used in our market mechanisms and evaluating whether, on a case-by-case basis, it is still appropriate to use a bilateral index given the reduction in bilateral liquidity and the removal of the WECC soft offer cap.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

In the current Policy Roadmap, the CAISO has budgeted time for urgent EDAM / DAME Enhancements initiative.  PG&E recommends keeping this initiative going by selecting our version of this EDAME / DAME Enhancements and including the CPUC’s as a part of it. PG&E’s proposal recommends establishing metrics for EDAM success and using operational data to identify what areas are not hitting the metrics and define the initiative scope. This should provide a transparent basis for prioritizing multiple stakeholder proposals that fall under EDAM / DAME enhancements. 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

In the current Policy Roadmap, the CAISO has budgeted time for urgent EDAM / DAME Enhancements initiative.  PG&E recommends keeping this initiative going by selecting our version of this EDAME / DAME Enhancements. PG&E’s proposal recommends establishing metrics for EDAM success and using operational data to identify what areas are not hitting the metrics and define the initiative scope. This should provide a transparent basis for prioritizing multiple stakeholder proposals that fall under EDAM / DAME enhancements. 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

In the current Policy Roadmap, the CAISO has budgeted time for urgent EDAM / DAME Enhancements initiative.  PG&E recommends keeping this initiative going by selecting our version of this EDAME / DAME Enhancements and including WPTF’s as a part of it. PG&E’s proposal recommends establishing metrics for EDAM success and using operational data to identify what areas are not hitting the metrics and define the initiative scope. This should provide a transparent basis for prioritizing multiple stakeholder proposals that fall under EDAM / DAME enhancements.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Intertie bidding is an optional part of a voluntary market. PG&E does not believe it is appropriate to change this at this time.

Western Resource Advocates' proposal is about market-to-market seams.  See question 6 – market-to-market seams discussions are already scheduled for this year.  

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No comments.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Addressing the revenue inadequacy of CRRs is a top priority for PG&E.  

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No comments.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No additional comments.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

PG&E supports and recommends the development of objective metrics to more clearly define its scope and to inform prioritization among the various EDAM enhancements topics proposed by stakeholders.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

PG&E continues to support the limited incremental improvements and enhancements outlined in the straw proposal on Scarcity Pricing & Market Power Mitigation published in September 2025. However, PG&E does not support further policy development on comprehensive scarcity pricing at this time.    

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

PG&E does not support Fast-Start Pricing. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

PG&E supports prioritizing further enhancements to the outage substitution, availability, and incentive mechanisms within Resource Adequacy Modeling and Program Design Initiative Track 2. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No additional comments.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No additional comments.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No additional comments.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No additional comments.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No additional comments.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No additional comments.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No additional comments.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Not at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

Not at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

PacifiCorp

3. Contact name and email address

Connor Kennedy; connor.kennedy@pacificorp.com 

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

EDAM and DAME assessment. PacifiCorp supports evaluating the products and market mechanisms introduced under EDAM and DAME to determine whether they deliver the intended efficiency and reliability.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

EDAM Enhancements. PacifiCorp supports the continued inclusion of TBD EDAM enhancements in the Market Policy Catalog, with the understanding that explicit enhancement needs will become clearer following early market results.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

PacifiCorp supports ongoing dialogue on western energy market seams and plans to participate in the CAISO Market Seams workshop series beginning in July 2026. PacifiCorp is open to addressing seams-related topics within existing initiatives where appropriate.

However, PacifiCorp believes the near-term priority should remain ensuring a well-functioning EDAM rather than creating a new standalone initiative focused on seams. Seams issues often differ depending on the specific markets or participants involved and are better addressed through targeted, issue-specific efforts between the relevant entities directly.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

N/A

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

N/A

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

N/A

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

PacifiCorp submitted this initiative for consideration for the 2027-2029 roadmap. Pending stakeholder prioritization and early EDAM market results, PacifiCorp would support incorporating this into one of the other proposed EDAM enhancements or EDAM assessment initiatives.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

N/A

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

N/A

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

N/A

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

PacifiCorp supports continuous assessment of EDAM and DAME to ensure all new market products are functioning and providing the efficiency and reliability that was intended.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

PacifiCorp supports continuous assessment of EDAM to ensure new market mechanisms are functioning as intended. PacifiCorp would be open to the development of success metrics to support an evaluation of EDAM performance and to enable a more systematic review of the market.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

PacifiCorp supports the continued inclusion of TBD EDAM enhancements in the Market Policy Catalog, with the understanding that explicit enhancement needs will become clearer following early market results.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

PacifiCorp supports continued stakeholder discussion and exploration of economic intertie bidding, including efforts to better understand implementation considerations. At the same time, consistent with the approved EDAM framework, the decision to enable intertie bidding must remain at the discretion of each EDAM Entity at its borders. Maintaining this flexibility ensures entities can evaluate readiness and does not shift decision-making authority away from individual BAAs.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

PacifiCorp supports the ongoing public dialogue on the commitment cost bidding flexibility initiative. Given the initial policy was approved several years ago, PacifiCorp would appreciate CAISO’s continued review of the background and underlying assumptions of the initiative to ensure they remain appropriate under current market conditions, including EDAM. PacifiCorp also notes potential stakeholder bandwidth considerations as EDAM implementation and early operations continue.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

PacifiCorp supports the ongoing congestion revenue rights (CRR) initiative, particularly where it intersects with the concurrent congestion revenue allocation (CRA) initiative. PacifiCorp would appreciate if CAISO could share any analysis, context, and information developed in the CRR initiative to the extent it informs or impacts the CRA initiative.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

PacifiCorp continues to support policy that allows for less stringent requirements for demand response participation in the day-ahead and real-time markets. PacifiCorp appreciates the CAISO’s proposal for changes to registration and load modeling as discussed in the Straw Proposal and Issue Paper Demand and Distributed Energy Market Integration posted in March 2026; however, PacifiCorp believes Track 1 should include a holistic update to the performance evaluation methodology (PEM) in the CAISO’s tariff to enable meaningful progress in the near-term.

PacifiCorp has actively engaged alongside other Western Energy Imbalance Market participants and entities preparing to join the Extended Day-Ahead Market. Through this engagement, there is broad alignment that there are material challenges regarding registration, PEMs, operational characteristics such as metering and telemetry requirements, and modeling. While the proposed multi-year structure of the Demand and Distributed Energy Market Integration seems prudent, steps to register proxy demand resources remain unchanged until tariff and business practice manual revisions can be made for demand response. PacifiCorp looks forward to continued engagement in this initiative.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

PacifiCorp supports the ongoing EDAM congestion revenue allocation initiative and remains actively engaged in the stakeholder process. As an early EDAM participant, PacifiCorp supports development of a durable long-term CRA design that aligns with EDAM and respects existing OATT rights.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

PacifiCorp supports initiating EDAM enhancements for policy development on an as-needed basis, as reflected in the roadmap. PacifiCorp views EDAM enhancements as “EDAM day-two” refinements and recommends that CAISO consider and coordinate them with stakeholders based on early market data and observed outcomes.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

PacifiCorp does not support linking BAA-level market power mitigation to a comprehensive scarcity pricing design at this time. PacifiCorp recommends prioritizing BAA-level MPM, which has clearer support and a more defined path forward. PacifiCorp believes the need for a broader scarcity pricing framework should be evaluated after sufficient EDAM market data and operational experience is available.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

PacifiCorp does not support the inclusion of fast start pricing in the 2027-2029 Roadmap, as the Company believes there are higher priority initiatives that should take precedence such as EDAM enhancements and BAA-level market power mitigation.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

N/A

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

N/A

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

N/A

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

PacifiCorp supports the continuation of all topics under the Storage Design and Modeling initiative. As certain topics under the initiative are a higher priority for PacifiCorp than others, it would be helpful to have a clear and updated timeline and delineation regarding key milestones for each topic, including a status update outlining where in the policy process each topic is currently.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

See previous storage comment.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

See previous storage comment.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

See previous storage comment.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

PacifiCorp supports the continued postponement of the WEIM RSE enhancements initiative. While PacifiCorp supports this initiative as a concept, PacifiCorp believes that stakeholder bandwidth is limited and that there are higher priority initiatives that should take precedence.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Many proposed and existing market policy initiatives relate to the newly implemented EDAM and a broad set of potential future enhancements. Given the scope of EDAM and that the market is still in its early stages, PacifiCorp recommends that CAISO clarify how it will prioritize among specific EDAM enhancement topics as they emerge, particularly when multiple aspects of the market may warrant attention simultaneously.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

PacifiCorp recommends that CAISO improve clarity and consistency in the Market Policy Catalog and Roadmap timelines. The current framing can create confusion, as the “2026” process informs a 2027–2029 roadmap, while stakeholders are asked to provide input on both newly proposed and existing initiatives. Some newly proposed initiatives may warrant near-term attention, while several existing initiatives appear likely to conclude by the end of 2026, potentially falling outside the effective scope of the roadmap period. PacifiCorp recommends that CAISO consider a more streamlined approach that allows stakeholders to provide a comprehensive, cumulative review of both ongoing and forward-looking initiatives on an annual basis, rather than anchoring feedback to specific multi-year timeframes.

PacifiCorp also recommends that CAISO hold a standalone meeting to provide a consolidated status update on all existing initiatives at a defined point in the Roadmap process, including progress to date and any material changes from the original scope. While high level status updates are provided at WEM meetings, deeper context and framing are not provided. Holding a standalone meeting once a year to provide background and context as to why initiatives were originally started, how and if the scope has changed, information on progress to date, and on current initiative status would support more informed stakeholder prioritization and improve overall transparency in the roadmap development process.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

Peninsula Clean Energy (or Westlight Energy, starting in July) prioritizes MIC enhancements as our top initiative.  Our goal of serving our load with 100% renewable energy in all hours, and recent procurement orders from the CPUC both require clean firm resources, such as advanced geothermal, and wind resources capable of generating reliably in winter and nightttime hours.  These resources are almost certainly are going to be either primarily or exclusively available outside of California.  Thus, being able to secure import rights in full in the online year, with certainty, is fundamentally critical to the procurement needed for a clean reliable system.  Since the existing system is complex and difficult to work with, PCE prioritizes adjustments to meet the procurement needs of the early 2030s and beyond. 

2. Organization Name

Peninsula Clean Energy

3. Contact name and email address

Doug Karpa, Managing Counsel of Regulatory Policy

dkarpa@peninsulacleanenergy.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Maximum Import Capability (MIC) enhancements

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Congestion Revenue Rights Enhancements

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

no position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position. 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Peninsula Clean Energy places the highest priority to including within the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing Maximum Import Capability (“MIC”) to support eligibility of import resources to provide Resource Adequacy (“RA”) capacity.  Multiple stakeholders have expressed the view that limitations on availability of MIC impose significant barriers to use of import resources for RA purposes.  Consideration of MIC Enhancements should include analysis of the causes for limitations on MIC availability and comprehensive exploration of both short-term and long-term measures that could mitigate the adverse impacts of MIC limitations, including consideration of relaxing MIC requirements for import RA eligibility under defined circumstances.  

Peninsula Clean Energy strongly urges the CAISO to pursue MIC Enhancements as part of the RAMPD initiative, rather than under a separate Infrastructure related initiative.  MIC policy and implementation are inextricably intertwined with RA policy and implementation.  Indeed, MIC has no role in the CAISO markets other than to establish eligibility for import resources to supply RA capacity.  It is critical that consideration of enhancements to MIC determination and application be fully integrated with, informed by, and supportive of RA policy and objectives.  Although many enhancements can be executed without any change to the simultaneous deliverability study that falls within the scope of the infrastrcture group, no reforms can be conducted without a strong consideration of the market and policy impacts.  Thus, the Policy group is the appropriate forum for this discussion. 

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Improving Congestion Revenue Rights has significant potential to save ratepayer costs and to have CRRs fulfill their primary purpose for LSEs. 

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Market integrated DER are going to be increasingly important for solving both reliability and environmental justice goals, since many local reliability areas cannot be supported with clean resources without either DER or transmission upgrades. 

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

As currently constituted, the uncertainty and challenges of substitution appear to be driving both shorter supply in the RA market and also issues with import rights.  Creating a more rational approach that works for generators should save costs, help California meet reliability goals, and reduce forced outage rates as resoruces are better able to take planned outages. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

We are generally engaged on RA progam design and support examining these issues. 

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position.  We are emphasizing MIC enhancements, but would participate in these issues if CAISO takes them up. 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Just that MIC enhancements needs to be in the RA MPD Working Group.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

The bifurcation is potentially helpful, provided the teams managing the two processes are communicating to ensure that priority issues are taken up in the most appropriate forum. 

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Salt River Project

3. Contact name and email address

Amber Clinkcales  (amber.clinkscales@srpnet.com)

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

The Salt River Project Agricultural Improvement and Power District (SRP) would like to prioritize the following:  

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

No selection at this time.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

SRP supports combining and prioritizing Seams topics.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No position at this time.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No position at this time.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position at this time.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position at this time.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position at this time.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No position at this time.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position at this time.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

SRP supports this initiative.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position at this time.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position at this time.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

SRP supports this initiative.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position at this time.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No position at this time.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No position at this time.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No position at this time.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No position at this time.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position at this time.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position at this time.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No position at this time.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No position at this time.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position at this time.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position at this time.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position at this time.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position at this time.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position at this time.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position at this time.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

None at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

None at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4efAll other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

San Diego Gas and Electric (SDG&E)

3. Contact name and email address

Nikki Emam, nemam@sdge.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

SDG&E appreciates CAISO’s continued efforts to refine and prioritize its stakeholder initiative roadmap. Of the new initiatives suggested by stakeholders, we support the Extended Day Ahead Market (EDAM) and Day-Ahead Market Enhancements (DAME) assessment as our top priority for the 2026 market policy catalog.

While we offer general support for the proposed initiative as outlined by the PUC, we note that several of the proposed initiatives appear to address this topic area. As CAISO moves forward with scoping the EDAM/DAME assessment in the coming year, it will be critical to discuss how broadly this initiative should be defined. This includes working with stakeholders to clearly identify which topics are most appropriately included within the scope of the initiative and which may be better addressed through complementary or subsequent phased efforts. Establishing clear boundaries early in the process will ensure more focused and effective stakeholder engagement given the number of ongoing initiatives.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

EDAM Congestion Revenue Allocation.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Support

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Oppose with caveats

SDG&E does not support this proposal as a stand-alone initiative; however, it may be more effectively considered within the scope of an existing effort, such as RAMPD.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Support

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position

SDG&E takes no position on the proposed Imbalance Reserve Product enhancement initiative at this time. While this may become an appropriate initiative to consider in the future, we recommend gaining additional operational experience with the product over the next year or more before considering changes to this product. In the interim, analysis and discussion of market efficiency impacts will occur within the EDAM/DAME evaluation, which SDG&E has supported as the top priority for the 2026 catalog.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Oppose with caveats

SDG&E supports the concept of Ancillary Services Real-Time Re-optimization and thanks PG&E for bringing this proposal forward. That said, given the current workload of ongoing initiatives and the substantial effort required for implementation, SDG&E recommends postponing this initiative until the 2027 market policy catalog.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

Oppose with caveats

SDG&E does not support this proposal as a stand-alone initiative; however, it may be more effectively considered within the scope of an existing effort, such as RAMPD.  

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Oppose with caveats.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Support.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Support

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Support

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No position

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Support

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Oppose

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Oppose

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Support

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Support

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Support

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Support

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Support

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Support

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Support

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

SDG&E appreciates CAISO’s continued efforts and engagement with stakeholders. We urge CAISO to remain mindful of stakeholder workload when prioritizing and sequencing initiatives, especially in the first year of EDAM/DAME. In particular, efforts should be made to avoid overlapping topic areas and multiple concurrent phases within a single initiative, as this can create unnecessary complexity and strain stakeholder resources when providing feedback on issue papers or proposals. We appreciate the opportunity to provide these comments and look forward to continued engagement with CAISO and the stakeholder community on these important initiatives over the coming year.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

No comment.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

A successful outcome of the Interconnection Customer Working group was the Intra-Cluster prioritization process. However no project in PG&E or SDG&E was able to get selected (https://www.caiso.com/documents/2025-intra-cluster-reliability-network-upgrade-prioritization.pdf) as the corresponding network upgrades did not qualify the "2-year" acceleration threshold being required between the longest and second longest duration network upgrades. There are many projects in the PG&E regioin (and perhaps SDG&E and VEA), that would have qualified for acceleration if a lower threshold was utilized (For example 1 year). The threshold needs to be made dynamic based on the nature of projects that apply for acceleration. Using a fixed threshold has serious implications on the timelines of projects that can achieve commercial viability with an in-earlier in-service date, but are not able to accelerate because their respective potential acceleration from the longest to the second longest duration network upgrades is short of two years by a few months only to find out that at the next Transmission Development Forum one of the upgrades has moved to create a 2-year difference between the longest and second longest duration network upgrades. So the threshold needs to be either lowered to a 1 year difference or perhaps made dynamic based on the specific scenarios applicable to the projects that are applying for acceleration. The in-service dates of the required Transmission upgrades are dynamic and updated at every Transmission Development forum, as such the CAISO Intra-Cluster prioritization process needs to be adaptive and the 2-year old threshold should be removed from the Tariff and perhaps handled in the BPM. Additionally given the dynamic nature of the upgrades, the intra-cluster prioritization process needs to be conducted every year.

CAISO is requested to evaluate and implement the following:

1. Conducting the Intra-Cluster prioritization process on an annual basis

2. Reduce the acceleration threshold to 1 year from the current 2 year threshold

3. Move the threhsold to a BPM instead of keeping it fixed in the Tariff to allow more flexibility for CAISO and the Stakeholders.

2. Organization Name

SB Energy

3. Contact name and email address

Aftab Alam

aftab@sbenergy.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

No comments on this section.

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Congestion Revenue Rights Enhancements

Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design,

Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No comments on this section.

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No comments on this section.

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No comments on this section.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No comments on this section.

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No comments on this section.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No comments on this section.

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

No comments on this section.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No comments on this section.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No comments on this section.

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No comments on this section.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No comments on this section.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No comments on this section.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No comments on this section.

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

No comments on this section.

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

No comments on this section.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No comments on this section.

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No comments on this section.

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No comments on this section.

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No comments on this section.

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

No comments on this section.

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

No comments on this section.

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No comments on this section.

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No comments on this section.

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No comments on this section.

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No comments on this section.

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No comments on this section.

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No comments on this section.

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Provided in 1 above a:nd repeated here

A successful outcome of the Interconnection Customer Working group was the Intra-Cluster prioritization process. However no project in PG&E or SDG&E was able to get selected (https://www.caiso.com/documents/2025-intra-cluster-reliability-network-upgrade-prioritization.pdf) as the corresponding network upgrades did not qualify the "2-year" acceleration threshold being required between the longest and second longest duration network upgrades. There are many projects in the PG&E regioin (and perhaps SDG&E and VEA), that would have qualified for acceleration if a lower threshold was utilized (For example 1 year). The threshold needs to be made dynamic based on the nature of projects that apply for acceleration. Using a fixed threshold has serious implications on the timelines of projects that can achieve commercial viability with an in-earlier in-service date, but are not able to accelerate because their respective potential acceleration from the longest to the second longest duration network upgrades is short of two years by a few months only to find out that at the next Transmission Development Forum one of the upgrades has moved to create a 2-year difference between the longest and second longest duration network upgrades. So the threshold needs to be either lowered to a 1 year difference or perhaps made dynamic based on the specific scenarios applicable to the projects that are applying for acceleration. The in-service dates of the required Transmission upgrades are dynamic and updated at every Transmission Development forum, as such the CAISO Intra-Cluster prioritization process needs to be adaptive and the 2-year old threshold should be removed from the Tariff and perhaps handled in the BPM. Additionally given the dynamic nature of the upgrades, the intra-cluster prioritization process needs to be conducted every year.

CAISO is requested to evaluate and implement the following:

1. Conducting the Intra-Cluster prioritization process on an annual basis

2. Reduce the acceleration threshold to 1 year from the current 2 year threshold

3. Move the threhsold to a BPM instead of keeping it fixed in the Tariff to allow more flexibility for CAISO and the Stakeholders.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

No comments on this section.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

See below

2. Organization Name

Southern California Edison

3. Contact name and email address

Jonathan Rumble

jonathan.rumble@sce.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

• Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

• EDAM Congestion Revenue Allocation

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No position

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

No Position

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Support

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No Position

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Support

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No Position

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

Support

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Support

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Support

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Support

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No Position

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Support

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

Support

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Support

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

This Initiative is already underway and SCE supports its continuation

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

This Initiative is already underway and SCE supports its continuation

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Support

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

This Initiative is underway and SCE supports moving forward with the proposed MPM proposal but does not support moving further forward with additional work focused on Scarcity Pricing

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

SCE does not support moving further forward with additional work focused on Fast Start Pricing

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

This Initiative is underway and SCE supports its continuation 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Support

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Support

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Support

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

This Initiative is underway and SCE supports its continuation 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

This Initiative is underway and SCE supports its continuation 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

This Initiative is underway and SCE supports its continuation  

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

There is a FERC filing related to this Initiative and SCE supports a positive outcome at FERC

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

Not at this time.

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

Not at this time.

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

Please refer to the comments below regarding the Six Cities' priorities among the newly proposed and ongoing stakeholder initiatives.  

2. Organization Name

Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California (the “Six Cities”)

3. Contact name and email address

 Meg McNaul, counsel for Six Cities – mmcnaul@thompsoncoburn.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

The Six Cities’ highest new initiative priority is the Maximum Import Capability (“MIC”) Enhancements initiative.  Please also refer to the Six Cities' comments below in response to question no. 8.  

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

The Six Cities’ highest priority ongoing initiative is the Congestion Revenue Rights Enhancements initiative. 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

The Six Cities note that these initiatives likely fall within the seams-related workshops the CAISO is scheduled to host in the coming months.  Depending on the outcome of those workshops, the Six Cities may support further policy development on certain topics that are relevant to Western energy market seams. 

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

The Six Cities take no position on this topic at this time, but observe that this topic could potentially be considered in the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative, which is already underway.  Consolidating this topic with an ongoing effort may be efficient, particularly if this topic may lend itself to a narrowly focused solution that could be adopted without a substantial implementation burden. 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

The Six Cities attach highest priority to including within the RAMPD initiative a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing MIC to support eligibility of import resources to provide Resource Adequacy (“RA”) capacity.  Multiple stakeholders have expressed the view that limitations on availability of MIC impose significant barriers to use of import resources for RA purposes.  Consideration of MIC Enhancements should include analysis of the causes for limitations on MIC availability and comprehensive exploration of both short-term and long-term measures that could mitigate the adverse impacts of MIC limitations, including consideration of relaxing MIC requirements for import RA eligibility under defined circumstances.  The Six Cities strongly urge the CAISO to pursue MIC Enhancements as part of the RAMPD initiative, rather than under a separate Infrastructure related initiative.  MIC policy and implementation are inextricably intertwined with RA policy and implementation.  Indeed, MIC has no role in the CAISO markets other than to establish eligibility for import resources to supply RA capacity.  Enhancements to MIC determination and application must be fully integrated with, informed by, and supportive of RA policy and objectives.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

As an initial matter, the position statement framework provided above does not capture the Six Cities’ position.  As stated below, the Six Cities oppose one element of this initiative proposal and support a second element. 

The Six Cities oppose the proposal for an initiative to expand the CAISO’s backstop procurement authority to the extent that the suggestion is for the CAISO to engage in Capacity Procurement Mechanism (“CPM”) procurement based on a 1-in-10 loss of load expectation standard.  Moreover, there is already an RA-related initiative underway to consider changes in the CAISO’s backstop procurement authority.

The Six Cities support consideration of WPTF’s second proposal, which is to consider the need to remove flexible Resource Adequacy requirements. 

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

The Six Cities support consideration of enhancements to the Imbalance Reserve (“IR”) product, if and to the extent that market results post-implementation of the Day Ahead Market Enhancements (“DAME”) on May 1^st indicate that changes to the IR product are needed.

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

The Six Cities do not oppose consideration of this topic in a stakeholder initiative, provided that there is CAISO and stakeholder bandwidth to undertake this effort.  The Six Cities agree with PG&E’s observation of potential benefits associated with real-time reoptimization of ancillary services but are concerned with the potential complexity of this effort.  Nevertheless, if real-time ancillary services reoptimization represents a goal for the CAISO’s real-time market, then it may be reasonable to begin consideration of this policy sooner rather than later, especially if the implementation lift will be significant. 

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

The Six Cities support considering the reasons for the increase in these costs.  It may be that before opening a stakeholder initiative to address policy changes, the CAISO could undertake an analysis of these costs and why they are increasing so that stakeholders could assess if a stakeholder initiative is needed or these cost increases can be addressed through some other means. 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

The Six Cities concur with the stated concerns regarding the potential illiquidity of other market indices used as reference points for elements of the CAISO’s markets.  Provided there is sufficient CAISO and stakeholder bandwidth to consider this topic, the Six Cities would support an initiative that evaluates whether alternative metrics to these indices should be adopted.

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

The Six Cities understand that the CAISO is already planning a potential initiative to consider enhancements to EDAM this summer.  Will the scope of this initiative include elements of DAME?

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

The Six Cities support this initiative in 2028.

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

The Six Cities understand that the CAISO is already planning a potential initiative to consider enhancements to EDAM this summer.

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

The Six Cities understand that topics related to intertie bidding are already under consideration in the EDAM initiative.

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

The Six Cities take no position on the advancement of this initiative at this time. 

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

The Six Cities strongly support continued consideration of the issues that are pending in this initiative. 

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

The Six Cities do not oppose continuation of this initiative.  To the extent that the scope of this initiative is broadened to include expanded consideration of topics that are intertwined with scarcity pricing issues under consideration in the Price Formation Enhancements initiative, the Six Cities encourage the CAISO to closely coordinate policy development in these two initiatives.

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

The Six Cities strongly support continued consideration of efforts to provide equitable treatment for the CAISO Balancing Authority Area in terms of eligibility for allocation of congestion revenue associated with parallel flows. 

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

The Six Cities support a stakeholder effort to identify and address consideration of near-term improvements to the EDAM market design.  Will this effort also include consideration of enhancements related to DAME elements?

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

The Six Cities have previously stated that they support limited, incremental revisions to the elements of the CAISO’s current market design related to scarcity pricing, and they continue to support expansion of the CAISO’s market power mitigation tools.  See, e.g., WEM Governing Body Initiative Spotlight on Price Formation Enhancements – Scarcity Pricing, presented on behalf of the Bay Area Municipal Transmission Group, California Community Choice Association, Northern California Power Agency, Pacific Gas and Electric Co., San Diego Gas & Electric Co., Six Cities, and Southern California Edison Co. (Mar. 3, 2026), available at six-cities-perspective-spotlight-briefing-on-price-formation-enhancements-mar-2026.pdf.  The Six Cities do not support additional comprehensive scarcity pricing measures at this time, and request that the CAISO postpone consideration of further implementation of scarcity pricing until market participants have experience with the EDAM and DAME market reforms. 

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

The Six Cities oppose further consideration of fast start pricing within the CAISO markets and request that this topic be removed from the scope of the Price Formation Enhancements initiative. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

The Six Cities support continued consideration of reform to the CAISO’s outage substitution rules and RA availability and incentive mechanisms. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

The Six Cities understand that the reference here to Track 3b may be in error, and this initiative may instead refer to Track 3a.  The Six Cities understand that changes related to Track 3a of the RAMPD initiative have been filed with and accepted by FERC.  See Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,105 (2026).  At this time, there are no further changes that the Six Cities have identified as necessary as a part of the Track 3a topics. 

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

The Six Cities do not oppose consideration of the issues that are included in this track of the RAMPD initiative, although the Six Cities continue to encourage consideration of issues related to the CAISO’s participation in the Resource Sufficiency Evaluation as a stand-alone initiative, rather than as part of the RAMPD process. 

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

The Six Cities take no position on this topic group at this time. 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

The Six Cities take no position on this topic group at this time. 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

The Six Cities take no position on this topic group at this time. 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

The Six Cities take no position on this topic group at this time. 

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

The Six Cities take no position on this initiative at this time. 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

The Six Cities have no additional feedback at this time. 

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

The Six Cities encourage the CAISO to provide additional information and transparency around the bifurcation of the market policy and infrastructure-related Catalog and Roadmap processes.  Does the functional separation of initiatives into these categories also have implications for CAISO staffing and management oversight of initiative topics?  Further, how does the CAISO intend to categorize initiatives that have both market policy and infrastructure related implications?  Further clarification of how the CAISO’s proposes to classify initiatives will aid stakeholders in their understanding of the CAISO’s processes. 

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

State Water Contractors

3. Contact name and email address

Jonathan Young / jyoung@swc.org

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges submitted by the California Department of Water Resources. 

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Demand and Distributed Energy Market Integration. 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

No position. 

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Projects may fail to come online as scheduled for reasons outside a load serving entities control, and entities that engage in good faith to bring resources to market should not bear penalties for those delays. Reducing penalty exposure in such circumstances would lower costs and risk for LSEs, developers, and ratepayers/customers improving overall market conditions and performance. 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

No position. 

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

No position. 

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

No position. 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

No position. 

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

As customers of the State Water Project (SWP), SWC supports this initiative. Real-Time Congestion Offset charges have risen dramatically in recent years — increasing more than 1,500% — imposing significant additional costs on water ratepayers and load serving entities. SWC urges CAISO to open an initiative to investigate the drivers of these increases and evaluate available solutions.

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

No position. 

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

No position. 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

No position. 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

No position. 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

No position. 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

No position. 

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

SWC supportives this initiative. 

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

SWC have been an active participant in the DDEMI working group activities and support its direction and continued development. SWC looks forward to participating in the working group that will be formed later this year to explore and evaluate potential market and operational changes for real-time bidding constructs for flexible load and pumped storage resources. Given the changing climate conditions such as more severe droughts, heat and loss of snowpack, coupled growing demand in the CAISO system and the West, we believe expediting this effort will produce a more reliable and flexible grid. 

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

No position. 

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

No position. 

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

No position. 

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

No position. 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

SWC is supportive of the proposed initiative. 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Support. 

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

No position. 

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

No position. 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

No position. 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

No position. 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

No position. 

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

No position. 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

Sunrun Inc.

3. Contact name and email address

Yang Yu

yang.yu@sunrun.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

Sunrun doesn't have a position on these initiatives 

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

Sunrun’s highest priority is Demand and Distributed Energy Market Integration. As a leading distributed energy resource aggregator, Sunrun supports market reforms that enable residential batteries, virtual power plants, and other distributed energy resources to participate more effectively in wholesale markets. Improving DER integration will enhance grid reliability, increase customer value, support decarbonization goals, and unlock flexible capacity to meet California’s growing system needs.

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

Sunrun doesn't have a position on these initiatives 

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

Sunrun doesn't have a position on these initiatives 

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

Sunrun doesn't have a position on these initiatives 

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

Sunrun doesn't have a position on these initiatives 

10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

Sunrun doesn't have a position on these initiatives 

11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

Sunrun doesn't have a position on these initiatives 

12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

Sunrun doesn't have a position on these initiatives 

13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

Sunrun doesn't have a position on these initiatives 

14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

Sunrun doesn't have a position on these initiatives 

15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

Sunrun doesn't have a position on these initiatives 

16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

Sunrun doesn't have a position on these initiatives 

17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

Sunrun doesn't have a position on these initiatives 

18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

Sunrun doesn't have a position on these initiatives 

19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

Sunrun doesn't have a position on these initiatives 

20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

Sunrun support this initiative

21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

Sunrun doesn't have a position on these initiatives 

22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

Sunrun doesn't have a position on these initiatives 

23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

Sunrun doesn't have a position on these initiatives 

24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

Sunrun doesn't have a position on these initiatives 

25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

Sunrun doesn't have a position on these initiatives 

26. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Resource visibility

Sunrun doesn't have a position on these initiatives 

27. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions

Sunrun doesn't have a position on these initiatives 

28. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 1: Outage management enhancements

Sunrun doesn't have a position on these initiatives 

29. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 2: Uplift & default energy bids

Sunrun doesn't have a position on these initiatives 

30. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 3: State-of-charge management

Sunrun doesn't have a position on these initiatives 

31. Please describe your organization’s support for the following proposed Market Policy initiative: • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources

Sunrun doesn't have a position on these initiatives 

32. Please describe your organization’s support for the following proposed Market Policy initiative: • WEIM Resource Sufficiency Evaluation Enhancements

Sunrun doesn't have a position on these initiatives 

33. 3. Do you have any additional prioritization feedback that you’d like the ISO to consider?

34. 4. Do you have any suggestions for changes to the Market Policy Catalog & Roadmap process?

1. Introduction

The ISO invites all stakeholders to identify their priorities among both newly-proposed and existing Market Policy initiatives. The purpose of this survey is to solicit feedback on stakeholder priorities and use this information to develop the 2026 Market Policy Catalog (released June 2026) and the 2027-2029 Market Policy Roadmap (released late 2026). In this survey, stakeholders will be asked to (1) identify their top priorities among both newly-proposed and existing Market Policy initiatives, and (2) describe their organization’s level of support for all other initiatives. The full text of all submitted initiatives can be viewed here:https://stakeholdercenter.caiso.com/Comments/AllComments/04c6df24-b13b-4e59-b83b-7dd99085b4ef All other 2026 Market Policy Catalog and Roadmap materials, including meeting recordings and slides, can be found on the webpage here: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process

2. Organization Name

The California Municipal Utilities Association (“CMUA”).

3. Contact name and email address

Jessica Melms, Melms@braunlegal.com

4. Please identify your organization’s highest priority among newly-proposed 2026 Market Policy initiatives (please type in one selection - any additional selections will not be counted):

• Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum. • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project) • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents)) • Resource adequacy reliability (Western Power Trading Forum) • Imbalance reserve product enhancements (PacifiCorp) • Ancillary services real-time re-optimization (Pacific Gas & Electric) • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project) • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division) • EDAM and DAME assessment (California Public Utilities Commission Energy Division) • 2028 EDAM review (Pacific Gas & Electric) • EDAM enhancements (Western Power Trading Forum) • EDAM Intertie Bidding-related topics

4. CMUA's highest priority is Maximum Import Capability Enhancments (within 4). 

5. Please identify your organization’s highest priority among existing Market Policy initiatives please type in one selection - any additional selections will not be counted):

• Commitment Cost Bidding Flexibility • Congestion Revenue Rights Enhancements • Demand and Distributed Energy Market Integration • EDAM Congestion Revenue Allocation • EDAM Enhancements • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation • Price Formation Enhancements: Fast Start Pricing • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms • Resource Adequacy Modeling and Program Design, Track 3a: Resource visibility • Resource Adequacy Modeling and Program Design, Track 3b: Backstop reform and long-term EDAM RSE solutions • Storage Design and Modeling, Topic group 1: Outage management enhancements • Storage Design and Modeling, Topic group 2: Uplift & default energy bids • Storage Design and Modeling, Topic group 3: State-of-charge management • Storage Design and Modeling, Topic group 4: Mixed-fuel & distribution-level resources • WEIM Resource Sufficiency Evaluation Enhancements

No position. 

6. Please describe your organization’s support for the following proposed Market Policy initiative: • Western energy market seams topics. This item combines four submissions that share similar themes: (1) Western market seams coordination – Appian Way Energy Partners, (2) Market-to-market seams – Bonneville Power Administration, (3) EDAM BAA transactional market seams enhancements - The Energy Authority, and (4) Internal and external market seams - Western Power Trading Forum.

N/A

7. Please describe your organization’s support for the following proposed Market Policy initiative: • Flex RA phantom obligations due to delayed commercial operation date (California Department of Water Resources – State Water Project)

N/A

8. Please describe your organization’s support for the following proposed Market Policy initiative: • Maximum Import Capability (MIC) enhancements (The Joint Parties: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) the California Community Choice Association; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents))

The California Municipal Utilities Association (“CMUA”) urges the CAISO to undertake a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing Maximum Import Capability (“MIC”) to support eligibility of import resources to provide Resource Adequacy (“RA”) capacity within the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative. In making this recommendation, CMUA joins a broad coalition of stakeholders who have found that limitations on MIC availability impose barriers to the use of import resources for RA purposes.

MIC policy and implementation are tightly coupled with RA policy and implementation, and MIC serves no purpose in CAISO markets other than establishing eligibility for import resources to provide RA capacity. In turn, this review should take place under the RAMPD initiative, rather than under a separate infrastructure related initiative.

California LSEs and local publicly owned electric utilities have been directed to or are independently seeking resources that require import into the CAISO to contribute to system reliability. These amounts are growing and include firm clean resources that are vital to reliable grid operations and achievement of decarbonization goals. MIC, as it is current implemented, is impeding procurement of these resources. Possible changes to the MIC design need to be considered expeditiously.

9. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource adequacy reliability (Western Power Trading Forum)

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10. Please describe your organization’s support for the following proposed Market Policy initiative: • Imbalance reserve product enhancements (PacifiCorp)

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11. Please describe your organization’s support for the following proposed Market Policy initiative: • Ancillary services real-time re-optimization (Pacific Gas & Electric)

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12. Please describe your organization’s support for the following proposed Market Policy initiative: • Rising costs to LSEs with Real-Time Congestion Offset (RTCO) charges (California Department of Water Resources – State Water Project)

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13. Please describe your organization’s support for the following proposed Market Policy initiative: • Liquidity of bilateral indices in FERC Order 831 implementation (California Public Utilities Commission Energy Division)

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14. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM and DAME assessment (California Public Utilities Commission Energy Division)

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15. Please describe your organization’s support for the following proposed Market Policy initiative: • 2028 EDAM review (Pacific Gas & Electric)

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16. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM enhancements (Western Power Trading Forum)

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17. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Intertie Bidding-related topics (Vitol and Western Resource Advocates'' proposal)

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18. Please describe your organization’s support for the following proposed Market Policy initiative: • Commitment Cost Bidding Flexibility

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19. Please describe your organization’s support for the following proposed Market Policy initiative: • Congestion Revenue Rights Enhancements

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20. Please describe your organization’s support for the following proposed Market Policy initiative: • Demand and Distributed Energy Market Integration

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21. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Congestion Revenue Allocation

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22. Please describe your organization’s support for the following proposed Market Policy initiative: • EDAM Enhancements

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23. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Scarcity Pricing & Market Power Mitigation

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24. Please describe your organization’s support for the following proposed Market Policy initiative: • Price Formation Enhancements: Fast Start Pricing

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25. Please describe your organization’s support for the following proposed Market Policy initiative: • Resource Adequacy Modeling and Program Design, Track 2: Outage substitution and availability & incentive mechanisms

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