2.
Please provide your organization's feedback in response to the ISO’s GHG Metrics Requests & EDAM GHG Go Live Monitoring Presentation.
We are primarily concerned with data reporting and transparency that could be useful to states with load-based GHG programs and consumers making retail claims, and preventing double counting of generation and associated GHG emissions at the retail level. Current GHG metrics published by CAISO and planned updates, as presented, do not provide this data and transparency.
As we have commented previously (on 9/27/2023), there are three general types of ISO market data that we would like to be reported.
1. Generation data. Resource mix and average emissions from participating generators for the whole market and potentially narrower geographies.
2. Attributed generation data. Generation attributed to GHG compliance zones on a resource-specific basis, by GHG zone, and both for generation that is tracked in WREGIS and generation that is not tracked in WREGIS.
3. Unallocated generation data (residual mix). Generation that is not attributed on a resource-specific basis in the market, including a version that also does not include generation tracked in WREGIS (unallocated non-WREGIS generation).
The first type of data is either currently provided or will be provided through planned updates to current GHG metrics published by CAISO. The second and third types are not provided or planned but are needed by states, market participants, and consumers to characterize market purchases for retail claims or in load-based programs. However, we believe these data requests can largely be satisfied using a GHG Accounting and Reporting approach (also referred to as a “non-priced GHG approach” or WPTF’s proposed framework), which would allocate generation and emissions to LSEs and produce a market residual mix (including hopefully a null power-adjusted residual mix). We generally support moving this approach to a policy initiative. Our preliminary general comments on this framework/approach based on discussions to date are provided under question 4 below.
4.
Please provide your organization's feedback or questions in response to the ISO’s non-priced GHG approach presentation. Does your organization have suggestions on what workshop topics should be addressed or any proposals related to how the Accounting and Tracking approach should work?
CRS generally agrees with CAISO’s presentation of the problem statement and the near-term next step of moving the GHG Accounting and Reporting approach to policy/implementation.
CRS generally supports the out-of-market GHG accounting framework that WPTF has proposed (also variously referred to as a non-priced GHG approach, Accounting and Reporting Approach, Tracking and Reporting Framework, etc.). At this initial stage, we have the a few comments and suggestions to avoid double counting and provide maximum transparency and flexibility to states and compliance entities.
1. Null power adjustments to residual mix
As we understand it, residual mix would include excess generation that is owned or contracted to LSEs and non-contracted generation from IPPs. We strongly support removing reported null power generation (for which the associated RECs or attributes have been sold off) from the residual mix to produce a null power-adjusted residual mix metric.
We and many other stakeholders, including certain states and large energy consumers that will need to report their emissions from purchased electricity, will need a null power-adjusted residual mix because we need to account for REC transactions outside the market. That is a part of accurate load-based accounting of emissions. The purpose of residual mix is to recognize specified transactions in load-based accounting frameworks and not double count generation that has been transacted. All transactions should be accounted for, not only in-market attributions. While some states may choose not to use certificates for their particular accounting and reporting programs, CAISO cannot ignore them due to states with load-based GHG reporting that recognize REC transactions and that will need the null power-adjusted numbers.
In providing both adjusted and non-adjusted residual mix figures, CAISO would not be espousing any one number over any other. Rather, it should simply explain what goes into each. CAISO can also provide the input data (e.g. reported null power MWh) if the market would find that useful.
At one point during the call (while expressing opposition to CAISO staff’s proposal to limit the applicability of the Accounting and Reporting Approach to only entities in states without an established GHG reporting programs on slide 46), WPTF said that the T&R framework is voluntary and does not supersede or impose on any state program. We agree and therefore it should accurately account for RECs and null power.
In terms of methodology, we support removing null power generation (MWh) from the residual mix (for a null power-adjusted metric) rather than assigning a positive emissions value to that generation because doing so would over count emissions. Removing the null power generation from the residual mix, on the other hand, would undercount MWh in the residual mix, but we do not see that as a significant issue.
2. Attribute ownership for allocation to LSEs
Ownership of the associated attributes or RECs should be required for allocation of a renewable generation resource to LSEs post market run under a T&R Framework. First, this is accurate load-based accounting and avoids double counting of this generation. A T&R framework should not allocate specified source to an LSE if the attributes are not owned by the LSE. Second, this is the best default position for such a framework to take and would provide the most flexibility to states and market participants to set their own compliance or reporting requirements regarding RECs.
Requiring attribute ownership for allocation of specified generation to LSEs would not deny entities in states that do not require REC ownership any information they require from CAISO to calculate emissions. However, not requiring ownership of attributes would deny to stakeholders in states that do require REC ownership vital data required to accurately calculate emissions. Where attribute ownership is not required, LSEs can still report specified procurement without attributes/RECs and they can use the null power-adjusted residual mix for everything else. In this case, the T&R Framework’s LSE-specific allocation simply would not be used for state reporting. Meanwhile, the Framework would not double count for states that do require the RECs/attributes. On the other hand, if the T&R Framework allocates to an LSE regardless of whether the REC has been sold off, while excess of that generation could be removed as null power from the residual mix, the non-excess generation would be allocated to the LSE without the RECs. That would cause a problem for states and programs that do require RECs for GHG accounting—there could be double counting of non-excess generation that is allocated to LSEs as specified without the RECs. In other words, having the allocation Framework reflect REC ownership would not affect states and programs that do not require RECs but would affect states that do. This is the most flexible approach and avoids the most double counting. Again, we agree with WPTF that this voluntary accounting and reporting framework is independent can be different from state requirements, and in that case, it should accurately account for RECs and null power.
3. Coordination with WREGIS
Finally, any attribution in the market or post-dispatch allocation of WREGIS registered generation under a non-priced GHG Accounting and Reporting Approach should be coordinated with WREGIS to avoid double counting. The West simply cannot have multiple separate allocation mechanisms operating simultaneously. Please see our 5/1/2024 comments for examples of how double counting can occur, and see our 9/26/22 comments on the EDAM Revised Straw Proposal for a more specific proposal for coordination: https://stakeholdercenter.caiso.com/Common/DownloadFile/b4f1bd16-b72b-4b42-8c32-2fc40ecbc7ef.
