Please provide a summary of your organization’s comments on the CPM Enhancements Track 1 revised draft final proposal
Vistra supports the CAISO’s proposals to enhance its Capacity Procurement Mechanism (CPM) processes included in Track 1.
Vistra is concerned that there is an increased risk of an annual CPM being triggered as result of a collective local or collective system deficiency as result of Central Procurement Entity solicitation failing to meet its local procurement obligations in the Pacific Gas & Electric area. We support the CAISO proposal to clarify that significant event CPMs, similar to existing authority for exceptional dispatch CPMs, can have its CPM capacity reduced in future months if the CPM resource is shown for RA. We believe the same flexibility needs to be afforded to annual CPM designations for collective deficiencies if the resource can be contracted for Resource Adequacy during the year. Vistra does not find it compelling or appropriate that the CAISO should prohibit this practice for RA showing deficiencies. Vistra requests the CAISO remove the prohibition to apply this to RA showing deficiencies from its proposal, and allow it be applied to annual CPM designations cured intra-year.
Vistra again reiterates its request for CAISO to pair its proposal to extend the market notice deadline for CPM designations with a revision to its Operating Procedure 2330 to include a step that the CAISO Generation Desk issues a market notice prior to issue a significant event exceptional dispatch. This is different than the proposed market notice with a CPM designation but consistent with the OP 2330 step that has the CAISO Gen Desk, “Sends Market Notices prior to dispatching Legacy RMR units for reasons other than local area mitigation through an ED.”
Looking forward, we are excited to move to Track 2 of this effort to begin to look more holistically at CPM enhancements. We strongly support Track 2 scope considering enhancements to the CPM soft offer cap and CPM FERC cost recovery review eligibility for offers above the soft offer cap. In addition, we also request the CAISO include in Track 2 scope additional flexibility to reduce CPM volume or the CPM term after a CPM designation has been accepted even for collective deficiencies if it declines to adopt this change in Track 1.
 See Operating Procedure 2330, Real-Time Exceptional Dispatch, http://www.caiso.com/Documents/2330.pdf.
 Id at Page 2.