Comments on 2026 Draft Infrastructure Policy Roadmap and 10/15 Stakeholder Meeting

1. Describe your organization’s support for the draft 2027-2029 infrastructure policy roadmap.

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Support.

SDG&E largely agrees with the selection of policy initiative topics. However, we offer the following specific feedback on the selection and timing given CAISO’s ambitious scope:

• SDG&E urges CAISO to adhere to its commitments and proposed timeline for the CRRE initiative. Given the continued delays, SDG&E is frustrated that the initiative has yet to provide a meaningful opportunity to discuss and evaluate solutions to longstanding concerns with the CRR auction design.
• SDG&E also supports a timely decision and implementation of an EDAM CRA solution by Q3 2027 in order to fully support integration of EDAM and pre-EDAM entities congestion revenue policies. Both CRRE and CRA are high priority initiatives for SDG&E.
• SDG&E supports the update to PFE in the roadmap to reflect that there will be no October 2026 decision. However, the topics within this initiative are complex, and many stakeholders, including SDG&E, do not believe comprehensive scarcity pricing is needed at this moment, nor should be a priority in the near term. Accordingly, SDG&E does not support a Q4 2027 decision timeline for a PFE proposal that includes comprehensive scarcity pricing, especially given the volume of issues CAISO plans to undertake. SDG&E’s participation in other initiatives could be hindered by the current schedule if major reforms for scarcity pricing remains a focus. SDG&E continues to have tentative support for more targeted areas of the draft proposal pending additional analysis and does not oppose these being included in the catalog, but if resources are limited supports prioritizing other initiatives.  
• SDG&E generally supports the SDM initiative and timeline but notes that there has been limited discussion of uplift in Track 2 thus far, and it is unlikely that this aspect of the initiative will be ready for a decision by Q1 2027. SDG&E suggests that CAISO update the roadmap accordingly. SDG&E also asks that CAISO explicitly include the non-linearity solution in the Topic Group 1 description to clearly indicate that implementation of this completed policy discussion is expected in Q3 2027.
• SDG&E believes the CAISO should extend the timeline for Track 2 of the RAMPD initiative, moving a Board decision to at least Q2 2027. SDG&E believes the proposed timeline is too ambitious, as significant questions remain and stakeholders have yet to reach agreement on several elements of the proposal, given the complexity of the issues. SDG&E also strongly supports inclusion of Track 5, MIC enhancements, on the roadmap.
• SDG&E supports the inclusion of EDAM enhancements on an “as-needed” basis in the roadmap, which provides CAISO flexibility to address emerging or immediate needs as they arise.
• SDG&E notes that DDEMI now includes a Large Loads focus and is concerned that the various tracks of this initiative could grow into significant overlapping workloads and cautions against expanding scope beyond what can reasonably be completed on this timeline.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 infrastructure policy roadmap.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Oppose.

SDG&E notes several concerns with overlapping initiative phases and their impact on stakeholder workload and the ability to meaningfully engage in policy development. With fifteen initiatives on the roadmap, many involving multiple phases and complex subject areas, the overall volume of work may limit SDG&E’s (and other stakeholders’) ability to provide the level of engagement necessary to fully inform policy development. SDG&E therefore offers the following specific suggestions and urges CAISO to remain flexible and responsive to stakeholder feedback on initiative timing and sequencing throughout the year.

• CAISO should sequence the start of RAMPD Track 5 (MIC Enhancements) so that it does not run concurrently with RAMPD Track 2. Staggering these efforts would help ensure sufficient stakeholder capacity to meaningfully engage in both initiatives.
• Delay the RAMPD Track 2 expected decision date by at least one quarter
• Remove Flex RA from the scope of RAMPD. SDG&E does not view Flex RA as an immediate priority, particularly given the already ambitious scope of the initiative.
• Given that PFE is a lower priority item for SDG&E, we believe the policy development and decision for this initiative (specifically Comprehensive Scarcity Pricing Reform) can be postponed such that stakeholders can focus on higher priority items.

3. Please provide process feedback where applicable, including on the proposed 2027 roadmap process.

SDG&E appreciates the schedule adjustments CAISO has made to provide additional time for stakeholder engagement and analysis. However, SDG&E is concerned with the use of “no sooner than” terminology during the October 1 stakeholder meeting, as it does not provide a clear implementation timeline or expectation. Greater certainty around anticipated implementation dates is important for stakeholders to effectively plan staffing and workload, as well as prepare for necessary process and system updates associated with policy and BRS changes. SDG&E encourages CAISO to provide more defined implementation expectations.