1.
Please provide your organization’s comments on the July 21 stakeholder call discussion for the 2026 Budget and Grid Management Charge Process.
The City of Santa Clara, California, doing business as Silicon Valley Power (“SVP”) and the Modesto Irrigation District (“MID”) thanks the CAISO for the opportunity to submit comments and questions regarding the CAISO’s 2026 Grid Management Charge (“GMC”) and Budget. SVP and MID submit the following questions and comments for which they request a response from the CAISO:
1) On the July 21, 2025 stakeholder call, CAISO representatives indicated that it may defer conducting a cost-of-service study in calendar year 2026 due to the resources needed to launch major product releases, such as the Extended Day-Ahead Market (“EDAM”), as well to gather a year’s worth of data operating under EDAM before making decisions concerning changes to GMC billing determinants. If the CAISO elects to defer a cost-of-service study in 2026, will it submit a Tariff amendment to the Federal Energy Regulatory Commission (“FERC” or “Commission”) to seek a waiver of its Tariff? See Appendix F, Schedule 1 of the CAISO Tariff, which states that “Every three (3) years, the CAISO will conduct an updated cost-of-service study, in consultation with stakeholders and using costs from the previous year.”
2) During the July 21, 2025 stakeholder call, CAISO representatives referred to projected decreases in cash-funded capital levels in 2026. Please confirm or correct this statement and explain the reasons for projected decreases in cash-funded capital levels in calendar year 2026, including whether such changes have any relation to increases in cash-funded capital between 2024 and 2025.
3) During the July 21, 2025 stakeholder call, CAISO representatives noted that the CAISO observed higher GMC volumes than expected in calendar year 2024. Has the CAISO identified the driver for those higher volumes? Does the CAISO expect this elevated level of GMC volumes to continue in: a) calendar year 2025; and b) calendar year 2026 (for 2026 irrespective of the launch of EDAM)?
