Comments on dfp track 3

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

The Alliance for Retail Energy Markets (AReM) supports CAISO’s objectives to enhance RA resource visibility and offers the following comments on the Track 3A Draft Final Proposal.

Resource Visibility

Resource visibility is required for CAISO to better anticipate the obligations of generation resources in its balancing area, particularly with the adoption of new capacity requirements in surrounding balancing areas.  The availability classifications CAISO is requesting in the Track 3A Final Proposal appear to be for the purpose of greater CAISO understanding of the availability of capacity in its balancing area.

AReM supports publication of aggregated results of this data collection since it would provide information to the wider market about the supply and demand balance in the market.  Generally, the supply side of the market has greater knowledge of load-serving entities’ (LSE) total requirements than LSEs have of the availability of resources to meet those requirements.  Publishing the aggregated values for the different classifications will allow for more focused efforts in finding resources to meet requirements. At the stakeholder meeting, CAISO expressed concerns regarding data confidentiality. Although AReM supports the need to keep market-sensitive information confidential, AReM encourages CAISO to find a level of data aggregation that can be shared publicly without compromising confidentiality.

Elimination of Section 43A.6.3 Report of Non-Resource Adequacy (RA) Capacity

AReM disagrees with CAISO’s proposal for the elimination of the monthly non-RA capacity report.   The CAISO did not provide any justification either in the Draft Final Proposal or the workshop for the elimination of the report.  As stated in the stakeholder meeting, there is important information in the report, including after-the-fact information about how much the CAISO market is relying on RA-eligible capacity that was not contracted as well as non-RA capacity the CAISO uses.  It is unclear how CAISO’s elimination of this report furthers greater visibility into capacity markets. AReM would be willing to support a well-designed proposal to consolidate this information into another report for administrative efficiency, if that is CAISO’s intent. However, CAISO only proposed elimination of this report, which AReM opposes.   

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the Resource Adequacy Modeling and Program Design (RAMPD) Track 3A Draft Final Proposal (DFP). CalCCA supports the California Independent System Operator’s (CAISO) goal of enhanced visibility into resources potentially available for backstop procurement. Understanding if and how resource adequacy (RA) capacity is dedicated for other purposes will provide valuable insight into the CAISO’s ability to procure backstop capacity should RA requirements not be met or if reliability issues arise intra-month. This situational awareness is especially relevant when the RA market is tight, as it has been for the last several years.

The definitions of the five categories outlined in the Straw Proposal and on slide 11 adequately reflect how RA that is not shown could be used. While there are instances in which capacity could fall into multiple categories or change statuses between reporting and CAISO backstop, it is reasonable to request that scheduling coordinators categorize the capacity to the best of their knowledge at the time of reporting, as the CAISO proposes.

The CAISO should modify its proposal to commit to publishing aggregate information. In the DFP, the CAISO states that it will consider where transparency could provide value to market participants in the future.[1] In the final proposal, the CAISO should commit to providing aggregate net qualifying capacity in each category by month using the information collected as part of this effort. Just as it is imperative for the CAISO to understand why RA resources are not shown on a supply plan, it is imperative that load-serving entities have as much information as possible to aid in their procurement processes. In addition, CalCCA and other stakeholders use publicly available RA market data[2] to analyze the state of the RA market, and this information could be beneficial in informing the reliability of the RA program, the RA market’s competitiveness, and the RA fleet’s interactions with the broader West. CalCCA is not aware of any confidentiality issues that would arise with posting aggregate data, and the CAISO should take advantage of opportunities to increase transparency in the often-opaque bilateral RA market when possible.

[1]            DFP, at 10.

[2]            For example, in recent years, the CAISO began posting aggregate RA showing data following the RA year. This information has been useful in assessing RA showing trends during the recent tight market conditions and informing the impacts of RA-related regulatory and policy decisions. See: https://www.caiso.com/documents/historicalresourceadequacyaggregatedata.xlsx.

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

Track 3A of the Resource Adequacy Modeling and Program Design (RAMPD) initiative is to provide ISO personnel with enhanced visibility into the amount of capacity potentially available for Capacity Procurement Mechanism (CPM) designations. CDWR supports the CAISO effort in this regard and believes the information acquired through this will improve reliability and efficiency. As noted in previous round of comment, there should be no obligation associated with the information provided.

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

Microsoft supports CAISO’s Track 3A proposal to improve visibility into RA-eligible resources not shown as RA. Transparency into how capacity is being used, like being contracted outside the BAA or being reserved for substitution, is essential for ensuring that the RA program and CPM backstop can function effectively. We also encourage CAISO to make aggregated versions of the data public wherever possible. While we recognize confidentiality concerns, additional transparency into trends in RA contracting and availability would provide valuable insights for regulators, market participants, and consumers. 

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

MRP does not support the Track 3A DFP because of the additional administrative burden that will be placed on Scheduling Coordinators to prepare and submit the non-RA capacity data on a year-ahead and month-ahead basis.  Further, the CAISO has not provided any details with regards to the data that it collected during summer of 2025 other than saying that it was useful. The lack of transparency for this request, coupled with the additional burden it places on market participants, does not justify proceeding with the proposal.

While MRP understands the desire to know how much capacity is available in the market, CAISO’s proposal is not a good method of achieving this goal. Instead, MRP recommends implementing the tracking system MRP proposed to track the various sales of the capacity which would give CAISO a near real time account of the capacity. The benefits of MRP’s proposed tracking system exceed the benefits of CAISO’s proposed collection of monthly data. MRP’s proposed tracking system also benefits Scheduling Coordinators who must track and communicate all downstream resales of capacity. MRP has spoken with several LSEs who also support the tracking system because it reduces the administrative burden of tracking capacity. Which may be resold multiple times, to report on RA and Supply plans. In fact, the tracking system can eliminate the upstream and downstream communications of multiple resales.

The tracking system can also include an option for LSEs to highlight surplus capacity that can be made available for outage substitution pool so LSEs can recover some of the cost of RA capacity procurement, thereby lowering rates for ratepayers.

Finally, MRP does not support the proposed elimination of the monthly non-RA report.  The information in the report is useful and provides market transparency.  

MRP requests the CAISO reconsider its Track 3A proposal and consider RA program design more holistically.

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

The Draft Final Proposal has remained largely unchanged since the Straw Proposal was issued in May. The CAISO proposal includes monthly and annual reporting requirements for RA-capacity not shown as RA on the same timeline as RA supply plan reporting (i.e., T-45) following five categories: 1) Sold outside the CAISO BAA; 2) Not Shown Due to Potential Unavailability; 3) Not Shown Due to Being Reserved for Substitution; 4) Contracted to a CAISO BAA LSE But Not Shown; 5) Not Contracted. 

PG&E, along with other stakeholders, previously noted (link to previous PG&E’s comments California ISO - All comments) that most of the information on non-shown RA the CAISO proposes to collect at T-45 will be outdated by T-30.  

PG&E understands the desire for more information about capacity not used for RA and believe a filing at T-45 would give the CAISO additional information to work with should it be necessary. The administrative burden for a one-time filing without change from T-45 is a starting point that will enable to further develop and refine how CAISO sees RA and Non-RA Resources. 

PG&E remains concerned that the information collected at T-45 will not have added value to help CAISO make better decisions and avoid unnecessary costs from backstop procurement or EDAM RSE failure, but is willing to add a one-time filing with change from T-45 to the RA process in order to enable additional information for CAISO availability without materially impacting the administrative burden associated with Resource Adequacy for SCs. 

Retirement of the Non-Resource Adequacy Capacity Report: 

In the Draft Final Proposal, CAISO indicates that in conjunction to the start of these new reporting requirements, the ISO proposes to eliminate the monthly Section 43A.6.3 Report of Non-Resource Adequacy Capacity.  

PG&E encourages the CAISO to reconsider this step and think transparently about the value of the existing information and the added value it is gathering per its request. Adding a request for additional information and eliminating information at the same time is counterproductive and discounts the value of the request. 

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

SDG&E’s June 17 comments noted the administrative burden of the Resource Visibility proposal and recommended adjusting the requirement to focus on those months during which the Competitive Solicitation Process (CSP) is needed. Participants at the workshop on August 28 also discussed the additional administrative burden of providing further granularity beyond the categories included in the initial summer 2025 data request, specifically, the addition of the “Not shown due to potential unavailability” and “Not shown due to being reserved for substitution” categories. SDG&E appreciates CAISO’s assertion that it finds value in both the frequency of the requests, as well as the additional granularity. However, CAISO’s presentations for Tracks 1 and 2 discussed data that CAISO could also use to identify the months in which the report would likely be needed (currently anticipated to be summer months). Additionally, based on the Track 3A discussion, the two additional categories are captured within the “Not contracted” category, and the incremental value of further breaking down this category is unclear. SDG&E encourages CAISO to reconsider its approach and instead utilize the three categories from the initial summer 2025 data request and only require the report for the months in which it is likely to be used and useful.

1. Please provide your organization's overall feedback regarding the Resource Adequacy Modeling and Program Design Track 3 Draft Final Proposal, which was posted on August 27, 2025.

As SCE indicated in its comments on the straw proposal, SCE believes that the Draft Final Proposal will be helpful to the CAISO in providing information on the status of generators, while minimizing the administrative burden on market participants. Some commenters worried that the information provided may not be the most up to date with the requirement to file when the RA plans are initially due, but SCE agrees with the CAISO that the current proposal strikes the correct balance between providing useful information and keeping the administrative burden as low as possible.