Comments on Flexible capacity Feb 07 stakeholder call discussion

1. Please provide your organization's comments on the 2024 Flexible Capacity Needs Assessment Methodology Feb 7, 2023 stakeholder call discussion.

For the 2024 Flexible Capacity Needs Assessment Methodology, CDWR has concerns on the allocation calculation methodology  with treatment of negative load ramps in determining flexible capacity allocations to the LSE. This concern has been raised by CDWR for the past few years and CDWR is interested in working with CAISO to explore solutions that address this issue.

Additionally, CDWR would also like to raise an issue where an LSE is subject to flexible RA obligations associated with renewable resources included in the flexible capacity needs study that fail to reach their target commercial operation date (COD). As it exists today the reporting LSE is required to procure flexible RA to meet obligations allocated to the resource irrespective of the resource reaching its commercial operation in the reported target date (month, and year). Ideally, an LSE should not be subject to financial consequences attributed to an obligation based on a resource that has yet to reach COD.