Comments on Revised Straw Proposal and discussion on June 18, 2026

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

2. Please submit your organization’s overall comments on Track 1

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

4. What key change(s) would your organization recommend to improve the proposal?

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

The California Community Choice Association (CalCCA) appreciates the opportunity to provide comments on the Demand and Distributed Energy Market Integration (DDEMI) Track 1 Revised Straw Proposal (RSP). The CAISO proposes to enable Demand Response (DR) exports, capped at the resource level. The RSP makes an important near-term incremental step to better leverage existing demand flexibility on the California Independent System Operator (CAISO) system. The CAISO should advance the proposal for implementation in 2027, as proposed.

To further advance demand flexibility opportunities, the CAISO should facilitate discussions in future initiative tracks to remove barriers to exports beyond the resource level. While DR exports are supported through the Distributed Energy Resource Aggregation (DERA) model, there is currently no RA pathway for DERA resources, limiting its use. Future discussions in coordination with the California Public Utilities Commission (CPUC) should seek to remove barriers to exporting at the resource aggregation level, whether through future enhancements to the modified Proxy Demand Resource model or through the existing DERA model.

CalCCA is concerned about the deliverability discussions that occurred during the stakeholder meeting. The CAISO’s suggestion that, if DR participation grows, DR may require a transmission plan deliverability (TPD) allocation demonstrates potential flaws with the deliverability methodology overall that must be addressed. First, as discussed in CalCCA’s comments on the On-Peak Deliverability Assessment Methodology Refinements, while CalCCA agrees that DR should be modeled in deliverability studies, the CAISO has not demonstrated that its proposed DR modeling is necessary or appropriate.[1] Second, it raises cost causation questions around equitable funding of the network upgrades necessitated by this potential change. Deliverability issues caused by changes in demand may not be attributable to individual generators (or DR resources). In addition, DR aggregations are fluid, and the customers within an aggregation can change over time. The impacts of demand flexibility and load composition on available deliverability should be carefully explored to determine whether and when network upgrades are required, and how the upgrades should be funded.

CalCCA therefore recommends that the CAISO hold a stakeholder process to gather meaningful input on the proposed refinements to the deliverability assessment methodology and allow stakeholders to propose additional refinements on the overall methodology, with the goal of establishing a methodology that clearly and transparently considers DR impacts on deliverability. As an alternative, the CAISO could maintain the current deliverability process while conducting a sensitivity analysis to evaluate DR impacts. This sensitivity would help to inform the CAISO and stakeholders regarding any necessary further actions. 

[1]              Specifically, the CAISO’s method appears to stem from a concern that increased DR in local areas could strand deliverable resources. It is CalCCA’s understanding that the inclusion of DR is not necessarily to limit or reduce deliverability, but to examine the manner in which increased amounts of behind-the-meter storage used as DR are impacting the ability to export local area resources to loads outside of the local area.  While CalCCA agrees that this gathering of information is necessary to inform the CAISO of grid reliability and deliverability, it is not clear how the inclusion in the test used to assess deliverability will impact currently interconnecting resources.  If the effort is simply to gain an understanding, then it seems the CAISO could obtain that understanding by running a sensitivity analysis in addition to the deliverability assessment. By doing so, entities could be assured that the sensitivity will not affect outcomes at this time.

2. Please submit your organization’s overall comments on Track 1

See response in Section 1 above. 

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

CalCCA supports the proposal for the reasons described in Section 1 above.  

4. What key change(s) would your organization recommend to improve the proposal?

CalCCA has no comments at this time.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

CalCCA has no comments at this time. 

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

See response in Section 1 above.  

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

CalCCA understands the concerns raised by the CPUC about preventing double compensation between wholesale and retail DR programs and agrees it is appropriate to limit participation to customers with an approved interconnection for export to the distribution system at this time. However, preventing Net Billing Tariff (NBT) customers, who are Rule 21 approved and currently export, from participating in wholesale markets strands capacity that could otherwise deliver significant value to the system when it is most needed. CalCCA therefore recommends that the CAISO, in coordination with the CPUC, explore future pathways that would allow customers under the NBT to participate in R.25-09-004.^[1]

[1]              OIR to Enhance Demand Response in California, R.25-09-004, (Sep. 18, 2025).

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

CalCCA understands the CAISO’s proposal to limit participation to the resource level, but, as described in Section 1 above, recommends having future discussions on how to remove barriers to exporting beyond the resource level, whether through enhancements to the modified Proxy Demand Resource model or through the DERA model.

CalCCA supports the proposal to allow SCs to determine how to zero out exports at the resource level. CCAs are best positioned to develop equitable methods to zero out resource-level exports in their programs and should be allowed to do so.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

CalCCA supports the CAISO expanding this proposal to apply to all PEMs. The previous proposal to limit export capability to resources using Meter-Generator-Output (MGO) baseline could have significantly limited export ability, given the limited use of the MGO baseline.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

CalCCA has no comments at this time.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

CalCCA has no additional comments at this time. 

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

Comments on Demand and Distributed Energy Market Integration

Track 1 Revised Straw Proposal

Department of Market Monitoring

July 1, 2026

Summary

The Department of Market Monitoring (DMM) appreciates the opportunity to comment on the Demand and Distributed Energy Market Integration - Track 1 Revised Straw Proposal: End-User Customer Exports in Demand Response Performance Measurement dated June 11, 2026.[1]

For Track 1, DMM continues to support removing the lower limit for individual customers in demand response (DR) aggregations so that individual customers can better reflect their physical capability, while maintaining the aggregate lower-limit of zero to maintain reliability.[2] The non-negative aggregation constraint for DR resources may create an incentive to add non-responsive load to an aggregation, which could further exacerbate the issue of DR underperformance if the non-responsive load exceeds the net export capability of other resources in the aggregation.

DMM continues to recommend the ISO work with partner agencies such as local regulatory authorities and the California Energy Commission to collect additional resource meta data to improve DR monitoring, and consider improving the estimation methodologies of baselines as the stakeholder process continues.

Comments

DMM supports the proposal to remove the lower limit of zero for individual customers in a demand response aggregation to better reflect load flexibility, while maintaining an aggregate resource limit of zero for reliability

DMM continues to support the ISO’s proposal to improve modeling of DR resources by recognizing that some customers are currently approved to export onto the distribution system from their utility distribution company (UDC).[3] However, DMM continues to recommend the ISO ensure the rules and agreements for exporting resources do not allow customers to circumvent the interconnection queue process for generating technologies.

The straw proposal would remove the minimum demand reduction limit of zero for all performance evaluation methodologies and customer load baseline calculations. The removal of the zero bound is for individual customers, while the proposal limits the aggregated DR resource from exporting (or having negative energy market awards) to preserve local and system reliability. DMM supports this element of the proposal to ensure system reliability is preserved, while facilitating customers and resources to best reflect their capabilities to the market.

The non-negative aggregate constraint may incentivize customer aggregations that exceed the performance capability of the resource

Some stakeholders have expressed concern that the non-negative aggregate constraint may incentivize demand response providers to include customers in their resources that may have little or no demand flexibility to facilitate exporting customers’ ability to maximally export without being zeroed out.

DMM has long raised concerns with baseline manipulation, such as a resource inflating their baseline to improve measured dispatch performance when compared against their counterfactual. The incentive to include poor or non-performing resources into the aggregate resource will not influence the baseline of the resource and allow for improved performance. The general concern is that resources backed by customers that have little or no expectation to be responsive to market signals will allow the aggregated resource to export in excess of a status quo. This concern should be scrutinized by the UDC and the ISO for local and system reliability, but does not appear to impact the measurement of performance by the aggregate resource.

While the inclusion of additional non-flexible load does not appear to impact the measurement of performance of an aggregate resource, DMM notes the proposal may lead to greater amounts of demand response resource adequacy that is unable to perform when called upon. The qualifying capacity (QC) of the resource historically provides the majority of revenue for DR resources and therefore, when the proposed ability for some portion of a demand response aggregation to net export is introduced, resources may be incentivized to add non-flexible load to be offset by the net export of another part of the aggregation. If the amount of added non-flexible load is not able to be fully offset by the net export, this may result in a QC level that exceeds the performance capability of the aggregate demand response resource. The determination of a resource’s QC is out of the purview of ISO. However, DMM continues to recommend the ISO work with local regulatory authorities to ensure the QC valuation of the demand response resources is a true reflection of the capability of the resources to provide load flexibility.

DMM recommends the ISO work with the local regulatory authorities to collect additional data to improve the monitoring capabilities of demand response aggregations and the supporting portfolio

DMM continues to recommend the ISO work with partner agencies to provide information on each customer’s expected load flexibility and additional meta data for continued monitoring.[4] As noted in previous comments, insight into the customer’s type, end-use equipment, and control strategy would be valuable for DMM monitoring. For this proposal, information on whether the customers are capable of export to the distribution system would additionally assist monitoring.

DMM continues to recommend the ISO improve the counterfactual estimates in baseline calculations to improve performance accuracy

DMM has previously recommended the ISO consider enhancements to the counterfactual of existing baselines, and will continue to monitor resource behavior if the straw proposal in Track 1 is implemented. There are additional improvements to the calculation of DR baselines that would improve the accuracy of estimating the demand response to an ISO energy schedule. DMM’s leading recommendation is the use of control group methodologies.[5] DMM hopes the ISO will consider improving the baseline calculation methodologies as this stakeholder process continues.

[1] Demand and Distributed Energy Market Integration Track 1 Revised Straw Proposal: End-User Customer Exports in Demand Response Performance Measurement, California ISO, June 11, 2026: https://stakeholdercenter.caiso.com/InitiativeDocuments/Revised-Straw-Proposal-Demand-and-Distributed-Energy-Market-Integration-2026-06-11.pdf

[2] Comments on Demand and Distributed Energy Market Integration Straw Proposal and Issue Paper, Department of Market Monitoring, March 27, 2026: https://www.caiso.com/documents/dmm-comments-on-demand-and-distributed-energy-market-integration-mar-13-2026-straw-proposal-and-issue-paper-mar-27-2026.pdf

[3] The interconnection agreements would be analogous to a Rule 21 export agreement for California Public Utilities Commission jurisdictional utilities.

[4] Comments on Demand and Distributed Energy Market Integration Straw Proposal and Issue Paper, Department of Market Monitoring, March 27, 2026: https://www.caiso.com/documents/dmm-comments-on-demand-and-distributed-energy-market-integration-mar-13-2026-straw-proposal-and-issue-paper-mar-27-2026.pdf

[5] Comments on Demand and Distributed Energy Market Integration Working Group, Department of Market Monitoring, November 6, 2025: https://www.caiso.com/documents/dmm-comments-on-demand-and-distributed-energy-market-integration-working-group-nov-06-2025.pdf

2. Please submit your organization’s overall comments on Track 1

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

4. What key change(s) would your organization recommend to improve the proposal?

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

Energy Division staff (ED staff or staff) of the California Public Utilities Commission (CPUC) develop and administer energy policy and programs to serve the public interest, advise CPUC decision makers, and ensure compliance with CPUC decisions and statutory mandates. ED staff provide objective and expert analyses that promote reliable, safe, and environmentally sound energy services at just and reasonable rates for the people of California. 

ED staff appreciates the productive discussion with stakeholders on June 18^th and the continued dialogue in this and other venues on how to efficiently and cost-effectively utilize clean distributed energy resource capabilities to support affordability and reliability. In these comments ED staff reiterates its concerns on how the straw proposal would provide double compensation for retail Net Energy Metering (NEM)/Net Billing Tariff (NBT) credits and wholesale market energy revenues for the same energy exports from behind-the-meter (BTM) resources.

NEM and NBT are retail tariffs that compensate exporting BTM solar and solar+storage resources in investor-owned utility (IOU) territory for every kWh of energy exported to the distribution grid by a NEM/NBT customer.

The existence of retail compensation for exported energy from BTM solar and solar+storage resources (on a per kWh basis) raises significant concerns about wholesale compensation for exported energy (also on a per kWh basis) simply being double compensation for the same energy. NEM and NBT export compensation function as feed-in tariffs for behind-the-meter solar and solar+storage resources, with distribution utilities in a must-take position for all energy exported to the distribution grid with compensation levels administratively set in advance.

The NBT retail tariffs of the three large IOUs calculate customer export credits using the avoided cost of energy for all 8,760 hours of the year, as well as hourly values for avoided capacity, avoided greenhouse gas emissions, and other attributes. In other words, NBT customers already receive energy payments for their exports based on the value of each kWh of energy they export to the grid. Similarly, NEM tariffs compensate customers one-to-one for exports with retail energy credits. The value of those energy credits is the retail rate the customer would otherwise pay, and those retail rates are designed to recover all utility cost components, including specific cost components based on marginal energy and marginal capacity costs that recover generation costs. In other words, existing NBT and NEM tariffs compensate customers for the energy value of their exports to the grid.

Under the straw proposal, a market award and resulting dispatch of an aggregated resource would incentivize customers in that resource to export additional energy to the distribution grid. However, it is important to state clearly that every kwh of export of an end-user with a NEM/NBT tariff under the proposed modification for PDR/RDRR would inherently be paid twice: 1) for energy value as exports to the grid under the administratively paid framework under NEM/NBT; and 2) as wholesale energy payments.

The avoided energy and generation capacity are also accounted for in the California Energy Commission’s (CEC) Integrated Energy Policy Report (IEPR) demand forecast, which are used to determine resource adequacy requirements for Load Serving Entities (LSEs).

Particularly in light of the affordability crisis facing Californians and particularly California ratepayers, ED staff urges CAISO to incorporate appropriate guardrails into the revised proposal to ensure that ratepayers of the large IOUs do not pay twice (once through retail tariffs and again through wholesale market payments) for the same energy. In order to mitigate potential ratepayer impacts, ED staff suggests that the initial approval of the export proposal exclude NEM/NBT customers while potential solutions to double compensation concerns can be more fully considered. Similarly, ED staff suggests further delaying approval of the export proposal for Reliability Demand Response Resources (RDRR) until the implications on cost and reliability for these resources can be more fully assessed.

2. Please submit your organization’s overall comments on Track 1

ED staff does not object in principle to permitting end-user exports to be counted in the market settlement of DR resources as outlined in the proposal. However, there remains the critical issue of appropriate guardrails to ensure no double compensation, which must be addressed before implementation of this proposal at scale.  

In addition, ED staff requests that CAISO cap the day of adjustments for all PEMs at 100% maximum value (or maximum adjustment factor of 1.0), when resources/resource aggregations include end-user exports. In doing so, ED staff seeks to mitigate any risk of strategic manipulation of load adjustment factors by aggregators of export-capable end-users.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Support with caveats. Please see responses to Questions 2 and 4.

4. What key change(s) would your organization recommend to improve the proposal?

ED staff propose the following recommendations for CAISO’s consideration: 

• Limit the initial roll-out of the proposal to non-NEM/NBT end-users only (exclude NEM/NBT end-users until the double compensation concerns are resolved);
• Implement the proposal for 2028 (the CAISO board adoption may be earlier);
• Defer the inclusion of RDRR resources to a later stage;
• Cap day of adjustments for all PEMs at 100% maximum value (or maximum adjustment factor of 1.0); and
• Clarify that these end-user exports must conform to the CPUC’s prohibited resource policy.

The above recommendations would allow time for CAISO, CPUC, CEC, and IOUs to continue coordinating on outstanding issues and address areas requiring alignment between CAISO and CPUC proceedings.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

ED staff have no comments on issue 5.1 at this time.

On item 5.2, in addition to the changes requested in response to Question 4, ED staff also share the concern raised by PG&E and SDG&E from their initial round of comments that the proposal may create an inadvertent incentive to recruit high load customers into aggregations that provide “limited or no load reduction capabilities”, just so that those customers can absorb the others’ exports and avoid reaching exports caps for the overall aggregation.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

ED staff have no further comments on issue 6 at this time.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

ED staff supports this aspect of the proposal.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

ED staff have no comments on issue 8 at this time.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

ED staff have no comments on issue 9 at this time.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

ED staff requests CAISO cap day of adjustments for all PEMs at 100% maximum value (or maximum adjustment factor of 1.0), when resources include end-user exports. The day-ahead notice in scheduling of DR resources and the ability of exporting customers or their aggregators to adjust day-of consumption allows for potential baseline gaming. Day of adjustments higher than 100% create a perverse incentive for the aggregator and should be disallowed for exporting resources and/or resource aggregations.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

ED staff notes that FERC Order 2222 addresses retail and wholesale double counting and compensation concerns for Distributed Energy Resources, inclusive of demand response.[1] CAISO’s tariff amendment in compliance of FERC Order 2222 explicitly notes its DERA market model is compliant with FERC 2222 because resources NEM/NBT resources are excluded from participation in the DERA market model that compensates resources for exports in the wholesale market.[2]

ED Staff appreciates CAISO’s diligence in ensuring that resources in the DERA market model are not getting compensated for the same services through the wholesale and retail markets and request that the same diligence be applied to PDR/RDRR market models as CAISO considers allowing end-user export compensation in PDR/RDRR market models.

[1] FERC Order 2222, section IV.C.3, paragraphs 147-164.

[2] “A Distributed Energy Resource Aggregation may not receive compensation for capacity, energy, or other services it provides in CAISO’s markets if it provides the same services in retail programs.” CAISO Open Access Transmission Tariff at 4.17.3(g)

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

CALSSA appreciates the CAISO staff's revised straw proposal and the discussion held on June 18. We strongly support the proposal to credit exports and the site level. CALSSA also understands the concerns and challenges raised concerning exports at the aggregation level, and CALSSA looks forward to continuing to engage with the CAISO on these topics in the future. The CAISO's proposal in the revised straw proposal is an important step in correctly valuing behind-the-meter resources and allowing them to provide greater benefits to CA's electric grid.

2. Please submit your organization’s overall comments on Track 1

CALSSA strongly supports the CAISO's proposal to credit exports at the site level within an aggregation. Challenges that must be addressed to credit exports at the aggregation level can be further expolored in future tracks, and CALSSA plans to engage with the CAISO on these topics further. 

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

CALSSA supports the proposal. CALSSA views this proposal as a very important change in the CAISO's valuation methodologies that can inform potential future changes based on experience gained, by both the CAISO and industry, on valuing exports at the site level. 

4. What key change(s) would your organization recommend to improve the proposal?

Revisions to metering to allow for existing meters, as CALSSA has proposed in the past, would facilitate the proposal to allow exports at the site level and would give the CAISO greater insight into how behind-the-meter resources are operating. The notice for the July 9 workshop says that the CAISO will discuss metering options to facilitate site-level exports, so CALSSA pleased to see that will be discussed at the workshop.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

Valuing exports at the site level would be very applicable to PDR as it would change its performance evaluation methodologies. 

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

No comment 

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

CALSSA supports crediting exports for only those sites that have an approved exporting interconnection agreement. Sites that are not approved by the utility distribution company to export should not do so and should not be credited for doing so. Implementation of this rule should be as straightforward and administratively simple as possible; it should not create additional administrative barriers that then prohibit sites from exporting.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

CALSSA supports this proposal at this time. This is not what CALSSA views as the end goal of behind-the-meter participation in CAISO markets, but CALSSA understands that this is a necessary first step at this time. CALSSA asks that the CAISO staff remain open in future tracks and initiatives to revise this rule based on experience with site-level exports within an aggregation.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Crediting exports should apply to all PEMs as that will allow scheduling coordinators flexibility in managing their aggregations. There is no reason to limit it to certain PEMs and prohibit it from others.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

No concerns at this time.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

CALSSA again is very appreciative of the CAISO staff's work and the progress made already in this initiative. We look forward to keeping the conversation and progress going!

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

The meeting was well-run, with the presentation providing helpful context and time for stakeholder feedback.

2. Please submit your organization’s overall comments on Track 1

While limited in scope, Leap appreciates that CAISO used Track 1 to tackle one of the primary issues identified by a majority of stakeholders. Ultimately, focusing track 1 on a single issue rather than trying to address multiple different issues likely allowed CAISO to move faster than would otherwise have been possible. Leap agrees that this was the right approach, but it hopes that CAISO will continue to take up additional problem statements in future tracks, such as allowing DR customers to participate in market-integrated programs using data from their device rather than from their utility meter.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Leap supports this proposal as-is. The straw proposal is well-reasoned and demonstrates one of the rare circumstances in which a simple change can unlock significant benefits, allowing demand-side resources to offer more capacity to the grid while providing CAISO with visibility into resources that are exporting past the meter.

4. What key change(s) would your organization recommend to improve the proposal?

Leap would not recommend any changes at this time.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

Leap supports applying this change to all BAAs as well as both PDR and RDRR resources.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

Leap agrees that there are no immediate deliverability concerns or operational/market implications from the proposal. However, Leap concurs with other stakeholders in the meeting that suggested CAISO revisit its deliverability processes at some point in the future. If future DR resources need to complete a full deliverability study just to reduce load at the Resource level, it will likely wipe out any additional DR participation in CAISO’s market. A simpler, streamlined approach to deliverability studies should be designed for these resources in recognition of their smaller size and unique characteristics.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Leap supports both of these elements of the proposal.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

Leap supports implementing this design and agrees with other stakeholders that SC’s are capable of allocating payments fairly across their end use customers in events where exports are zeroed out. It should be stated that these situations should be rare or non-existent. Because SC’s will not be compensated for Resource-level exports, they will be diligent in ensuring that their Resource exports are minimal if they export at all. If their Resources do export, they will either have to pay customers for performance that the SC did not receive compensation for (leading to a net loss for the SC) or withhold customer payments for load reductions that they provided (leading to dissatisfied customers and potentially customer churn). Both situations are undesirable for an SC, providing a clear incentive for the SC to manage their Resource aggregations to prevent net exports. 

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Leap supports applying this proposal to all PEMs. Doing so would maximize its beneficial impact, and Leap is not aware of any barriers or additional complications to applying it to PEMs outside of MGO.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

There’s always some complexity in calculating performance at the disaggregated level, but Leap and other DR providers are capable of doing so. Leap already calculates DR performance at the meter level before aggregating up to the resource level, so Leap will have a clear picture of how much each customer is exporting and can easily allocate payment reductions to customers appropriately if any of the resource-level exports are zeroed out.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

Leap agrees that, in the long term, there are opportunities to expand this approach to compensating exports so that Resource-level exports are also compensated. For example, an aggregator could be required to ensure that the load across all of its Resources at a sub-LAP is positive, allowing individual Resources to export while still maintaining DR’s status as a load reduction that doesn’t send power back to the transmission system. This could be further expanded by allowing DR Resources to export as long as overall load within the sub-LAP remains positive, maximizing the value that Resource exports could provide while still maintaining DR as a grid resource that reduces load at the distribution level. However, all of these changes would likely require more sophisticated counting methodologies to be developed, and Leap recommends passing the existing straw-proposal as-is and then addressing these additional options as part of a future phase.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

MCE appreciates the opportunity to submit these comments on the meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper. MCE supports the Track 1: Revised Straw Proposal.

2. Please submit your organization’s overall comments on Track 1

MCE supports Track 1 as the most immediate near-term solution in demand response participation model reforms. MCE commends and supports the CAISO’s goal of bringing the Track 1 proposal to the WEM Governing Body Primary Authority in August 2026.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

MCE supports the Track 1 proposal. The Track 1 proposal addresses a critical limitation of the current demand response participation models by allowing demand response providers and the CAISO to capture the additional export capacity that already exists, while maintaining wholesale demand response as a load curtailment product at the resource level.

4. What key change(s) would your organization recommend to improve the proposal?

MCE has no comments at this time.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

MCE supports applying the Track 1 proposal to all Balancing Authority Areas, and both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

MCE has no comments at this time.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

MCE supports the Track 1 proposal requirement that exporting customers must have an approved interconnection agreement for export onto the distribution system.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

MCE supports the proposed design to zero out at the resource-level, rather than the individual customer level. MCE also supports allowing the Scheduling Coordinator (SC) to determine which end-use customers would be zeroed out.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

MCE supports the application of the Track 1 proposal across all Performance Evaluation Methodologies (PEMs).

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

MCE has no comments at this time.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

As the DDEMI effort explores longer-term reforms, MCE encourages the CAISO to consider how current aggregation and registration rules can limit the full potential of the Track 1 proposal. Currently, when the composition of an aggregation changes, DRPs must effectively recreate and reregister the aggregation, which significantly limits overall scalability. Future enhancements to PDR should enable more dynamic portfolios and reduce associated administrative burdens, such as by allowing for more flexible or “like-for-like" substitution of end-users within an aggregation.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

PG&E appreciates the opportunity to comment on the June 18, 2026, Demand and Distributed Energy Market Integration (DDEMI) stakeholder meeting and the Revised Straw Proposal.  PG&E’s comments can be summarized as follows:

• PG&E supports with caveats the Revised Straw Proposal.
• Double Compensation with NEM/NBT should be addressed. 
• The Track 1 proposal should apply across all Balancing Authority Areas and to both PDR and RDRR.
• CAISO’s BAA deliverability discussion is reasonable.
• Interconnection Agreement verification through DRRS should be required for exporting customer locations.
• Scheduling Coordinators should have the responsibility to zero out exporting intervals. CAISO should provide guidelines for SQMD modifications necessary to prevent resource level exports.
• The straw proposal should apply to all PEMs.
• The baseline adjustment methodology should be modified to account for exporting intervals.

2. Please submit your organization’s overall comments on Track 1

PG&E appreciates CAISO’s ongoing efforts to advance additional market integration for distributed energy resources (DERs) through the inclusion of customer level exports within demand response products and views the DDEMI Track 1 Straw Proposal as a constructive mechanism to further target DER dispatch. 

Modifications Are Needed to Avoid Double Compensation for NEM and NBT Customer Exports

However, one significant issue still remains unresolved: double compensation. Distributed generation (DG) tariff customers, such as Net Energy Metering (NEM) and Net Billing Tariff (NBT) customers, are already compensated for exports through their retail rates. Allowing these customers to participate without an approach to remove the double compensation would result in customers paying for the same service twice. Additional compensation for the exact energy (setting aside any additional value that is above the NEM/NBT value due to grid constraints) that is already being compensated is counter to California’s stated goals[1] and the interest of ratepayers. Although the CPUC has jurisdiction over Resource Adequacy rules and double compensation therein, CAISO’s jurisdiction over the energy market requires a CAISO-level solution prior to implementation that would prevent double compensation of energy value.

PG&E is Supportive of Draft Proposal Changes to DRRS and Export Baselining

PG&E supports CAISO’s proposal to enhance the DRRS with the addition of an attribute to identify customer locations that are authorized to export, so that UDCs can verify the interconnection status of those locations prior to inclusion in resources.

PG&E agrees that considering typical export behavior in baseline calculations is necessary to ensure incrementality and supports further development of associated Performance Evaluation Methodologies.

PG&E appreciates CAISO’s discussion in the June 18, 2026, working group meeting of the role of non-performing customers in resource aggregations and encourages CAISO to monitor for any unintended consequences.

[1] California Public Utilities Commission, Decision 09-08-027, Decision Adopting Net Energy Metering Cost-Effectiveness Evaluation (Aug. 20, 2009).

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

PG&E position on the Revised Straw Proposal is support with caveats.

PG&E position on the track 1 Revised Straw Proposal is support with caveats. PG&E believes that the issue of double compensation should be addressed prior to implementation.

4. What key change(s) would your organization recommend to improve the proposal?

Double Compensation with NEM/NBT should be addressed.  Guidelines should be established for Scheduling Coordinators to modify meter data to prevent resource level net exports.

Double Compensation: To improve the proposal, a solution to ensure no double compensation of NEM and NBT customers (and variations therein) should be created, while recognizing that during grid events, there is additional value for that energy above the NEM/NBT compensation.  

SQMD modifications: PG&E recommends that CAISO provide guidelines for Scheduling Coordinators to report Demand Response Energy Measurements when adjustments to Settlement Quality Meter Data are necessary to maintain the resource-level export prohibition. PG&E provides further details in the response to question number 8.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

The Track 1 proposal should apply across all Balancing Authority Areas and to both PDR and RDRR.

1. PG&E supports the availability of the Track 1 proposal across all Balancing Authority Areas, provided that other BAAs can use the PDR/RDRR models and have the appropriate controls and mitigations to ensure no market or reliability impacts. Expanding applicability across the EDAM footprint would increase the value of these models, while allowing each BAA to determine whether implementation is appropriate for its circumstances.
2. PG&E also supports applying this proposal to both the PDR and RDRR models, as doing so would promote consistent treatment of demand response resources across CAISO market participation models and the benefits of the proposal would be available more broadly.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

CAISO’s BAA deliverability discussion is reasonable.

CAISO’s BAA deliverability discussion is reasonable. Deliverability is a key component of the RA program. Since the CAISO does not have visibility into individual customer load, a solution that allows for aggregations within a sublap to include some exporting customers, as long as the overall aggregation does not go negative is reasonable from a deliverability perspective. 

Because PDR and RDRR would remain load-curtailment products, this proposal does not reduce deliverability available to existing resources. In addition, as cited in the Revised Straw proposal, the overall level of demand response resources remains consistent with 2005 levels, when demand response was granted deliverability.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Interconnection Agreement verification through DRRS should be required for exporting customer locations.

PG&E supports the requirement for customer locations that wish to export in a PDR/RDRR aggregation to have an approved interconnection agreement, as this requirement helps preserve the safety and integrity of the distribution system.

PG&E also supports the proposed DRRS attribute because it would allow UDCs to perform a review to verify that a customer location proposed for export treatment has the necessary export interconnection approvals.

PG&E’s Rule 24 program is responsible for performing PG&E’s UDC review of customer locations entered into the DRRS by DRPs.  In addition to enhancing the DRRS to include a new attribute to identify which customers are authorized for the export treatment, the DRRS system will need to be updated to enable UDCs to provide their findings on a per CAISO Location ID basis of the outcome of the UDC review via API service.  

PG&E notes that the addition of the new attribute to DRRS will require the IOUs to implement IT enhancements to facilitate the UDC review process.  IOUs will need to assess the feasibility of the needed enhancements, develop cost and timeline estimates and identify cost recovery.

PG&E also notes that DMM would be able to verify the DRRS status of exporting service accounts to ensure they have a valid interconnection agreement.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

PG&E supports the proposal for Scheduling Coordinators to zero out exporting intervals; CAISO should provide guidelines for SQMD modifications.

PG&E supports the design to replace intervals where aggregated customer meter data during a DR dispatch period is negative (exporting) with zero values, in order to shift the prohibition on exports from the end-use customer to the resource level. The Scheduling Coordinator (SC) should perform this function since they have the responsibility for submitting Settlement Quality Meter Data (SQMD). The SC should also determine which specific end-use customers are zeroed out, which has significance for compensation of customers for wholesale market and/or DR retail program participation.

PG&E suggests that CAISO provide guidelines for adjusting SQMD to maintain the resource level export prohibition, perhaps in the BPM for Demand Response, to ensure SCs have the necessary information to submit accurate SQMD. 

SCs are required to submit three types of data for the Day Matching PEMs: GEN, CBL, BASE[2], To prevent the GEN from reflective a negative value (i.e., an export), the SC is required to adjust CBL and/or BASE, depending on the specific scenario.  For example, CBL needs to be zeroed if BTM DERs result in an export compared to a non-zero BASE value.  BASE and CBL need to be zeroed out when both baseline and event load reflect exports.  Revisions to the PEM guidelines or an additional Appendix will provide clarity for SCs to make the necessary SQMD modifications consistent with this proposal.

[2] BPM for Demand Response, Appendix B:  Baseline/Performance Evaluation Methodology MRI-S Data Submittal Requirements for Demand Response

• GEN: This represents the resources DREM
• CBL: This represents the Load data during the event
• BASE:  This represents the customer load baseline (CLB) used to calculate the DREM attributed to the pure load reduction only.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

The straw proposal should apply to all PEMs.

PG&E continues to support applying this proposal to all PEMs. While the Day Matching methodology is likely to provide the greatest benefit, extending the proposal to other PEMs promotes equitable treatment and may support broader use over time.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

The baseline adjustment methodology should be modified to account for exporting intervals.

PG&E agrees that an approach is needed for calculating the baseline adjustment factor when exporting intervals during adjustment hours may affect the existing methodology and looks forward to reviewing CAISO’s methodology in the Draft Final Proposal. Baseline calculations should account for regular export behavior during non-event intervals to ensure compensation reflects only incremental demand response service above typical operations, rather than routine export behavior. PG&E does not have further concerns with baseline methodology at this time.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

n/a

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) is the independent ratepayer advocate at the California Public Utilities Commission (CPUC).  Cal Advocates’ goal is to ensure that California ratepayers have affordable, safe, and reliable utility services while advancing the state’s environmental goals.

In the comments below, Cal Advocates provides the following recommendations:

• The CAISO should exclude customers who receive export compensation through their retail tariff from participation in Demand Response products that allow exports to offset usage within an aggregation to avoid double compensation.
• The CAISO should establish safeguards and rules to prevent recruiting customers that have no intention of reducing their onsite load into Demand Response aggregations.

2. Please submit your organization’s overall comments on Track 1

The CAISO should exclude customers who receive export compensation through their retail tariff from participation in Demand Response products that allow exports to offset usage within an aggregation to avoid double compensation.  This includes utility tariffs like Net Energy Metering (NEM) which provides export compensation based on the retail rate[1] and the Net Billing Tarriff (NBT) which provides compensation based on values calculated with the CPUC’s Avoided Cost Calculator.[2]  As other stakeholders have pointed out, adding additional wholesale market compensation on top of existing retail tariff export compensation would result in double payments.[3]  Demand Response products provide compensation in order to incentivize a change in participants typical energy consumption. NEM/NBT participants already export and receive compensation for those exports based on the terms of their applicable tariff.  That is, ratepayers already pay those participants for the energy they export.  Therefore, the CAISO should adopt rules to exclude customers who receive export compensation through a retail tariff from being included in Proxy Demand Resource (PDR), Reliability Demand Response Resource (RDRR), or any similar market models.

The CAISO should establish safeguards to prevent Aggregators from including sites that have no ability or intention of reducing onsite load into Demand Response aggregations.  The current proposal allows for exports from one participant within an aggregation to offset the load of another participant within the same aggregation.[4]  However, once all load is offset by exports any additional exports cannot receive compensation as the aggregation’s total load reduction still cannot go lower than zero.  Without clear rules, this creates an adverse incentive to recruit high-load customers into aggregations to act only as a load battery only to absorb other customers’ exports.  This leaves room for market participants to use Demand Response to circumvent the interconnection queue and other generation resource requirements as the CAISO Department of Market Monitoring described.[5]  Therefore, the CAISO should adopt rules to ensure that Demand Response aggregations remain a load reduction product.  

[1] CPUC Decision (D.)22-12-056 at 5-8.

[2] CPUC D.22-12-056 Ordering Paragraph (OP) 1 at 237.

[3] See March 27, 2026, comments of the CPUC, Pacific Gas and Electric, Southern California Edison, and San Diego Gas & Electric.

[4] Revised Straw Proposal at 8.

[5] See March 27, 2026 Comments of the CAISO Department of Market Monitoring, “However, DMM recommends the ISO ensure the rules and agreements for exporting resources do not allow customers to circumvent the interconnection queue process for generating technologies. The concern arises where generation technologies could potentially use the demand response participation pathway to avoid interconnection queue review, system impact studies, and cost responsibility applicable to generation resources.”

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Cal Advocates provides no additional comments at this time.

4. What key change(s) would your organization recommend to improve the proposal?

Cal Advocates provides no additional comments at this time.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

Cal Advocates provides no additional comments at this time.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

Cal Advocates provides no additional comments at this time.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Cal Advocates provides no additional comments at this time.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

Cal Advocates provides no additional comments at this time.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Cal Advocates provides no additional comments at this time.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

Cal Advocates provides no additional comments at this time.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

Cal Advocates provides no additional comments at this time.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

No comment.

2. Please submit your organization’s overall comments on Track 1

See responses to individual questions below.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

SDG&E supports with caveats as explained in more detail below. SDG&E supports cost-effective deployment of resources and supports the proposal to the extent it can deliver least-cost resources that are accurately accounted for. SDG&E remains concerned about the potential for double compensation and would like to see more detail on how NEM or NBT customers would be compensated for DR under the proposed structure.

4. What key change(s) would your organization recommend to improve the proposal?

SDG&E would like to reiterate the importance of considering how to correctly estimate day-of adjustment factors under the Straw Proposal. Improperly estimated adjustment factors could exaggerate the difference between event and non-event days. The Straw Proposal is likely to overstate the demand response for programs with habitual exporters when evaluated under 10-in-10 and similar baseline methodologies.

All performance evaluation methodologies with adjustment factors should address the risk of inflating the adjusted baseline load before allowing exports to determine the baseline. Narrowing the bounds of adjustment factors (which are already "capped" above and below) is one way to mitigate this bias.

SDG&E also recommends that the inclusion of exported energy for individual customers be optional rather than mandatory. Accounting for exported energy would require scheduling coordinators to obtain information on export permits and implement system modifications, which may not be justified. For example, a Demand Response Provider (DRP) operating a residential thermostat program is likely to have both non-NEM and solar customers participating. Given that awards typically occur between 5:00 p.m. and 9:00 p.m., incorporating exported energy is unlikely to materially impact program results. However, it would introduce additional administrative complexity and costs for the scheduling coordinator.

SDG&E also notes that if implementation of the new proposal requires modifications to the CAISO Demand Response Registration System (DRRS) that affect Utility Distribution Companies (UDCs), the UDCs will need sufficient time to implement those changes, as well as time to seek cost recovery from the CPUC to implement the changes.

Finally, each IOU territory has a sufficient number of non-exporting customers to offset exports from customers with distributed generation, ensuring that a PDR or RDRR resource does not result in net exports on an aggregate basis. Consequently, the CAISO proposal is conceptually similar to allowing exported energy from individual customers to count toward Resource Adequacy (RA). While demand response providers that primarily serve customers with energy storage may encounter practical challenges in enrolling enough non-exporting participants, doing so remains feasible. Therefore, from a conceptual perspective, ensuring that a PDR or RDRR resource does not produce net aggregate exports is achievable.

Therefore, this proposal would need to address any issues that result from the CAISO explicitly permitting exported energy from individual customers to count toward Resource Adequacy (RA). For example, CAISO should coordinate with the California Energy Commission (CEC) to confirm that incorporating exported energy from individual customers into demand response resources does not necessitate modifications to the CEC’s RA forecasting methodology.

Additionally, SDG&E would like to see high-level calculation examples of how various resources would participate in addition to resulting compensation changes under the proposals compared to status quo. In particular, SDG&E is interested in seeing new baseline load estimates for exporting resources enrolled in NEM and NBT and how the proposal impacts compensation for these resources.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

No comment.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

No comment.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

No comment.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

No comment.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

SDG&E describes concerns with the Straw Proposal's handling of PEMs that incorporate adjustment factors for baseline calculations in our response to Q10.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

From a measurement and verification standpoint, SDG&E is concerned that excluding end-use exports could make it more challenging to accurately isolate true load reductions from changes driven by customer exports, battery charging and discharging patterns, or other behind-the-meter resources and activities. Performance Evaluation Methodologies that include an adjustment factor may be distorted by the presence of exports in the baseline window. The adjustment factor is used to account for differences in load shape between event and non-event days. If habitual exporters drive the aggregate baseline non-event day load during the adjustment window close to zero then even small increases in the event day load during the adjustment window would result in a higher adjustment factor. This would inflate the counterfactual event-day baseline causing an upwards bias for all event results calculated under the 10-in-10 baseline and similar PEMs.

From a settlement accuracy standpoint, SDG&E believes that any baseline adjustments should be transparent, applied consistently, and based on reliable interval-meter data. In the absence of clearly defined methodologies for accounting for exports and adjusting baselines, settlement outcomes could become less accurate, potentially leading to customer disputes and inconsistent treatment across programs and participant groups.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

No comment. 

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

Southern California Edison (SCE) appreciates the opportunity to comment on the Demand and Distributed Energy Market Integration (DDEMI) Track 1 Revised Straw Proposal.  SCE’s feedback can be seen under the subsequent sections below.

2. Please submit your organization’s overall comments on Track 1

SCE appreciates CAISO’s efforts to improve the modeling of demand response (DR) performance by recognizing utility-authorized end-use customer exports. SCE understands that the proposal is intended as a near-term enhancement to better reflect the capabilities of distributed energy resources and storage, while maintaining the safety and reliability of the distribution and transmission systems and planning processes. 

SCE does not oppose the proposal; however, SCE believes that further refinement is necessary to ensure the proposal achieves its intended objectives without creating unintended market outcomes. In particular, SCE has identified several areas of concern that warrant additional clarification and safeguards, including potential double compensation, limited transparency in settlement and performance calculations, unintended interactions with existing retail rate structures and programs, and aggregation designs that may not reflect true demand response behavior. 

SCE supports the direction of the proposal, but this support is contingent upon CAISO addressing these concerns through clearly defined guardrails, enhanced validation and oversight mechanisms, and alignment with existing regulatory frameworks. These issues and corresponding recommendations are described below.

Double Compensation Risk
There are ongoing concerns that customers could receive compensation through both retail programs (e.g., NEM/NBT) and wholesale DR participation for the same underlying export activity.  It is not clear under CPUC jurisdiction whether these exports are eligible for additional compensation in wholesale markets or how such payments would align with existing retail tariff structures.

SCE recommends that CAISO coordinate with the CPUC and other relevant regulatory authorities to ensure that export treatment is consistent with existing retail compensation mechanisms, net energy metering tariff guiding principles, and requirements of the Public Utilities Code.¹  In the absence of such alignment, CAISO should establish explicit guardrails to prevent duplicate compensation.   

Specifically, CAISO should require explicit attestations and enforceable audit provisions to ensure that any end-use customer export counted towards wholesale DR performance is not also compensated as an incremental export under another wholesale or retail program for the same interval and same MWh.  At minimum, CAISO should require coordination with the UDC and/or LSE to identify applicable retail export compensation regimes prior to allowing export-inclusive performance measurements.

Insufficient details for Settlement, Baseline, and Measurement
SCE is concerned that there is insufficient clarity regarding how exports will be incorporated into baseline calculations and performance measurement, particularly for customers with utility-authorized net export conditions. Without clear and standardized methodologies, there is a risk of inconsistent application across SCs and potential overstatement of performance. At minimum, SCE encourages CAISO to include a draft redline version of the proposed language and methodology changes to section 5. Performance Evaluation Methodology Approval Process of the Demand Response BPM.  

Additionally, because SCs are responsible for calculating and submitting performance data, CAISO may have limited monitoring and auditing visibility into the underlying customer-level data and assumptions used in settlement calculations to ensure compliance with CAISO’s settlement quality and meter data (SQMD) plan. This lack of transparency increases the risk of inconsistent or inaccurate settlement outcomes. In particular, variations in SC methodologies could lead to inconsistent performance results across similarly situated resources. 

SCE recommends that CAISO: 

• Provide detailed guidance and standardized methodologies for baseline and performance calculations involving exports; 
• Establish data transparency and reporting requirements to enable validation of SC-submitted data; and 
• Consider implementing routine audits to verify actual performance calculations (directly or through the Department of Market Monitoring) to ensure the accuracy and integrity of settlement outcomes.
   

Potential Use of Static Load for Export Payment 
SCE is concerned that the proposal may allow demand response aggregations to satisfy performance requirements through accounting constructs rather than actual demand response behavior. Specifically, demand response providers may enroll large, inflexible (static) load within an aggregation to offset exports from DERs, thereby enabling greater wholesale payments without demonstrating incremental load reduction or flexibility. 

If a large static load does not actively curtail or shift consumption during dispatch intervals, it may allow the aggregation to satisfy non-export requirements without contributing meaningful system benefits. In such cases, the market may not be procuring actual demand response but rather an accounting construct where DER exports are netted against passive load. While this may reduce net load in a metered sense, it raises concerns regarding incrementality, fairness, and proper attribution of performance. 

SCE recommends that CAISO establish requirements to ensure that performance reflects incremental and dispatch-responsive behavior. This may include: 

• Requiring minimum performance contributions or responsiveness criteria at the customer level; 
• Establishing rules to prevent the use of static load solely to offset exports; and 
• Providing additional guidance on how aggregations should be structured to demonstrate true demand response capability.
   

Unintended Interactions with Existing Retail Programs and Rate Structures
SCE is concerned that the proposal may unintentionally “cannibalize” existing retail programs and rate structures by changing how a customer’s DER is used to respond or participate in DR programs.  For instance, BTM batteries that were once used to mitigate a customer’s on-peak TOU bill management, is now only being used to respond to market signals which could cause an increase to a customer’s electric bills for the benefit of the third-party DRP’s market revenues. 

Furthermore, given the restriction that enrolled service accounts may only participate in one Resource ID, customers with exporting capabilities and interconnection agreements are likely to be cannibalized from retail DR programs with other DERs that are not considered to be DG (distributed generation), such as solar and BTM battery energy storage system (BESS) (e.g. customers with a BTM BESS and smart thermostat would be removed from the customer’s existing smart thermostat program in order to participate in another resource for BTM BESS).  SCE recommends that CAISO coordinate with the CPUC and relevant regulatory authorities to align wholesale market products with retail program structures.

Conclusion
SCE supports the direction of the proposal as a near-term enhancement but believes that implementation should be contingent on addressing the concerns outlined above. Establishing clear guardrails, ensuring alignment with retail regulatory frameworks, and enhancing validation and settlement transparency are critical to achieving accurate performance measurement and avoiding unintended market outcomes.

¹ D.22-12-056, Decision Revising Net Energy Metering Tariff and Subtariffs

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

See question #2.

4. What key change(s) would your organization recommend to improve the proposal?

See question #2.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

SCE does not have any comments on this topic.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

SCE believes that any consideration of export treatment should be limited to the scope of the Track 1 proposal, which maintains the fundamental load curtailment construct of demand response resources. 

SCE understands that some stakeholders are urging CAISO to expand this framework by allowing Proxy Demand Resources (PDRs) to export energy beyond the aggregate load of the underlying customers. SCE does not support this approach. 

PDR was originally designed as a load curtailment construct, where aggregated retail customers reduce load and bid that reduction into the CAISO market as supply. While PDR participates in the market similarly to a generating resource, its underlying operational premise remains based on reducing consumption rather than producing net new generation.  Allowing PDR aggregations to export beyond aggregate load would fundamentally shift the resource from a load-modifying product to a de facto generating resource, without requiring the same interconnection, deliverability, and regulatory review processes that apply to traditional generation. 

SCE is concerned that this creates a pathway for certain resources to bypass established interconnection frameworks, including the Wholesale Distribution Access Tariff (WDAT) and CAISO interconnection processes.  These frameworks require generating resources to undergo rigorous review processes that ensure resources can reliably and safely be integrated into the grid. 

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

In addition to identifying the approved export interconnection agreement, the DRRS should capture the associated export quantity limits. Some interconnection agreements impose export limits that must be observed under the terms of the agreement, and access to this information is necessary to support accurate settlement.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

SCE does not have any additional comments at this time.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

For non-Meter Generating Output (MGO) PEMs, CAISO should consider the impacts to its monitoring and auditing process if both Net and Gen meter data values are not required by the SC to submit under Control Group, Day Matching, and Weather Matching. Today, CAISO only requires non-MGO PEMs to submit Net meter data values, because any meter data intervals in which there is a net export must be set to a zero value. Under this proposal, will the non-MGO PEMs maintain the current requirement to submit only the Net meter data, or will CAISO require both Net and Gen meter data values to ensure only incremental load curtailment is compensated?

As mentioned above, SCE encourages CAISO to include a draft redline version of the Demand Response BPM with proposed language and methodology changes, so it’s clear to stakeholders the changes to the PEM approval process, meter data requirements, and UDC, SC, or DRP compliance responsibilities under this proposal.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

See question #2.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

SCE does not have any additional comments.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

Sunrun appreciates the opportunity to comment on the DDEMI Track1 Revised Straw Proposal. We believe the proposal is an important first step toward enabling behind-the-meter (BTM) resources to more fully participate in the wholesale market. In particular, Sunrun strongly supports modifying the Proxy Demand Resource (PDR) model to recognize end-use customer exports in performance measurement. This change addresses a longstanding limitation in the PDR construct and more accurately reflects the capabilities of customer-sited battery storage resources.

However, while the current proposal represents meaningful progress, it does not fully resolve the underlying issue through the DDEMI stakeholder process. The requirement that each PDR aggregation remain a net load continues to limit the amount of flexible capacity that can participate in the wholesale market. Although the proposal recognizes exports at the end-use customer level, aggregations comprised primarily of battery storage resources will still have their dispatch constrained by customer load rather than the physical capability of the underlying storage systems.

Sunrun understands CAISO's concerns regarding deliverability and transmission planning assumptions. However, because this initiative explicitly excludes changes to the deliverability framework, Sunrun encourages CAISO to identify an appropriate venue to address these issues as soon as possible. Resolving deliverability questions will ultimately be necessary to unlock the full value of customer-sited storage resources for California.

2. Please submit your organization’s overall comments on Track 1

As discussed above, Sunrun generally supports Track 1 and the incremental progress in unlocking wholesale market participation from BTM DERs. At the same time, Track 1 should be viewed as an important first step rather than the final solution. 

Sunrun recommends that CAISO establish clear next steps in DDEMI and other CAISO processes to enable net exports at the aggregation level and facilitate customer enrollment /asset registration and participation in PDR generally. We discuss our recommendations for specific next steps below.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Sunrun supports the proposal with the caveat that additional improvements are needed to fully enable distributed energy resources to contribute to the CAISO wholesale market. Overall, the Straw Proposal to enable exports within a demand response aggregation does represent an incremental improvement to the existing Proxy Demand Response (PDR) structure. 

However, additional improvements are needed to fully unlock the value of BTM DERs. Most importantly, the proposal continues to prohibit PDR aggregations from becoming net exporters, limiting the amount of flexible capacity that can ultimately be dispatched into the wholesale market. While Sunrun understands CAISO's concerns regarding deliverability and transmission planning assumptions, these issues should be addressed through a dedicated stakeholder effort so that the full capability of customer-sited storage can ultimately be utilized. 

Additionally Sunrun recommends that the CAISO create a scope for a new Track 3 in this initiative focused on developing  proposals for incremental improvements on the following topics:

• Metering requirements: Currently, CAISO does allow for device-level measurement via the Meter Generation Output (MGO) methodology, but the use of this pathway requires meeting ANSI C.12 accuracy and certifications. For smaller, residential-scale battery devices, this type of submetering is not common nor needed. For PDR aggregations, it is most important that settlement is accurate at the aggregation level. CAISO should therefore open a new track in DDEMI to revisit device-level metering requirements for PDR.

• Device-level enrollment into CAISO: One of the biggest barriers to participating in PDR is the customer-level enrollment process, particularly the ShareMyData / Green Button process that is required to allow scheduling coordinators to access utility meter data for settlement purposes. Even for current device-level metering via MGO performance evaluation, it is Sunrun’s understanding that customers are still required to share their utility meter data. Since exports at the customer level have historically been prohibited, customer data was needed to limit device response to customer load. However, by allowing exports in PDR, there is no longer a need to measure customer utility data. Accordingly, Sunrun recommends that the CAISO  take up device-level enrollment issues as soon as possible in a subsequent track of this initiative.

4. What key change(s) would your organization recommend to improve the proposal?

The single most important improvement CAISO could make to the proposal is to establish a pathway to allow  PDR aggregations to become net exporters. While the Revised Straw Proposal recognizes exports at the end-use customer level, preventing the aggregation itself from becoming a net exporter continues to limit dispatch based on customer load rather than the physical capability of the underlying storage resources. As a result, a significant portion of available battery capacity remains unavailable to the wholesale market during periods when CAISO most needs flexible resources.

The aggregation-level export restriction may also create unintended market incentives. Rather than maximizing participation from responsive battery resources, aggregators may be incentivized to enroll customers with little or no load flexibility simply to absorb exports and maintain a net-load aggregation. This increases program complexity without increasing the amount of flexible capacity available to the market.

Sunrun recognizes that resolving this issue requires further consideration of deliverability and transmission planning assumptions. Accordingly, if CAISO is not prepared to modify the proposal in this proceeding, the Final Proposal should include a clear commitment to initiate a follow-on stakeholder process that evaluates how PDR aggregations can provide net exports while preserving reliability and existing deliverability frameworks. 

California has invested heavily in customer-sited battery storage to provide flexible capacity during periods of grid need. The wholesale market should ultimately be structured to capture the full value of these resources.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

Sunrun supports applying the Track 1 proposal to all BAAs. Sunrun also supports the specification that the limits on PDR exports at the aggregation level will apply to the ISO BAA specifically, and that “The ISO defers to other BAAs if they choose to take a different approach.” Since the concern around allowing exports beyond the market-resource level is due to deliverability, BAAs that do not have the same deliverability concerns should be able to allow for exports beyond the market ID level.

Sunrun also supports applying the Track 1 proposal to both PDR and RDRR models, but applying the proposal to PDR is particularly important. As the non-emergency demand response market model, applying the proposal to PDR will ensure that exporting resources can be available to dispatch more economically across a variety of grid conditions.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

Sunrun appreciates the CAISO’s concerns around maintaining deliverability for those generators that have been allocated full or partial capacity deliverability status. However, Sunrun recommends that CAISO further evaluate how deliverability is considered for distribution level resources.

To that end, Sunrun suggests that the CAISO identify a venue and open a procedural pathway to discuss deliverability issues as soon as possible. While addressing deliverability concerns to allow PDR resources to export past their resource ID is a novel issue, Sunrun believes there are reasonable paths forward. Given the import of this discussion, a dedicated CAISO initiative or track within a separate process discussing deliverability-related issues is warranted. Sunrun encourages CAISO to begin this conversation expeditiously.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Sunrun supports the proposal to require approved export interconnection agreements for systems that will be exporting onto the distribution system. Sunrun also believes that identifying the exporting customers via a checkbox or other simple method in the DRRS makes sense to fulfill this requirement.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

Sunrun supports the proposal to zero out exports at the resource level and allow the SC to zero out individual customers. This will ensure that each SC can optimally manage their own portfolio and will streamline performance evaluation for CAISO.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Sunrun supports applying this proposal to all PEMs. By capturing normal export behavior in baselines, whether day-matching, control groups or meter-generation output, all PEMs should reflect incremental load reduction that is provided through exports specifically from CAISO market dispatch. Sunrun sees no reason to exclude a particular PEM from the proposal.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

Overall, including exports in the baseline and then not allowing for all exports to be counted in performance means that CAISO is limiting the performance potential of these assets. This means that not all incremental performance is being accurately measured.

However, due to the policy implications for deliverability discussed above, Sunrun understands the need to have the CAISO’s position to not include net exports out of the market resource at this time. We encourage the CAISO to undertake discussions on deliverability issues as quickly as possible in an appropriate venue so as to further evaluate a more nuanced solution that is tailored to the concern. 

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

Tesla appreciates CAISO's continued engagement and the discussion at the June 18, 2026 meeting. Tesla supports the direction of the Revised Straw Proposal and views it as a meaningful, substantive step forward. The core reforms - removing the requirement that Scheduling Coordinators (SCs) "zero out" authorized exports occurring at the end-use customer level, and recognizing that behavior across all performance evaluation methodologies (PEMs) - will help enable a pathway for behind-the-meter (BTM) storage to contribute its real capability to the wholesale market.

Tesla particularly supports: (i) applying the reform to both the Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) models; (ii) extending it to all PEMs rather than limiting it to the metering generator output (MGO) methodology; and (iii) recognizing authorized exports at the end-use customer (site) level. We encourage CAISO to move expeditiously to advance the adoption and implementation of this policy.

At the same time, Tesla continues to believe the wholesale market should ultimately recognize exports beyond the aggregation resource's own load. We acknowledge that CAISO has concerns about deliverability studies and  that site-level export recognition represents substantive progress, and we do not propose to delay near-term implementation in order to resolve these questions. Instead, we ask CAISO to formally scope exports beyond the aggregation resource for ongoing discussion in Track 2.

2. Please submit your organization’s overall comments on Track 1

Tesla supports Track 1 reforms as an incremental step in the broader DDEMI and PDR reform process. The Revised Straw Proposal's site-level export recognition is a pragmatic, near-term change that can and should be implemented quickly.

Our overall comments emphasize three points:

A. Expedited implementation. Because the change is an accounting refinement rather than a redefinition of demand response, it should proceed on an expedited timeline.

B. Confirm NEM/NBT customer eligibility. The Final Proposal should eliminate any ambiguity around whether customers taking service under Net Energy Metering (NEM) or the Net Billing Tariff (NBT) may have their authorized exports recognized. CAISO should affirm that NEM and NBT customers will continue to be eligible for participation in the PDR program.

C. Preserve a path to broader export recognition. CAISO should commit to scoping exports beyond the aggregation resource in Track 2.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

Tesla supports the proposal with caveats.

Our caveats are clarifications rather than objections:

- Eligibility confirmation (NEM/NBT): The proposal should expressly confirm that NEM/NBT customers with an approved export interconnection remain eligible for PDR/RDRR and that their authorized exports are eligible for recognition in performance measurement.

- Resource-level export floor: We accept the resource-level zero-export limit as a reasonable near-term boundary, but ask that exports beyond the aggregation resource be scoped in Track 2.

4. What key change(s) would your organization recommend to improve the proposal?

We have no other recommendations beyond what we proposed in Question 3.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

We have no comment at this time.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

We do not object to CAISO maintaining, for near-term implementation, that PDR resources may rely only on the resources own load to support curtailment capability.

However, Tesla does not agree that the question of exports beyond the aggregation resource should be foreclosed. We therefore ask CAISO to scope, in Track 2, a discussion to explore a deliverability pathway for exports beyond the aggregation resource rather than treating the current framework as a permanent limit.

This approach preserves the near-term reform while keeping the longer-term opportunity open for study and structured discussion.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

Tesla supports limiting export recognition to end-use customers that hold an approved distribution export interconnection (e.g., a Rule 21 export interconnection), and supports a new DRRS attribute to identify those accounts.

We offer two implementation caveats:

- Timeliness and non-duplication: The enhanced UDC review should leverage existing interconnection records and occur within defined timelines so that it does not become a new barrier to participation or a source of delay. UDC review should simply confirm the existence of an approved export interconnection.

- Clarity on qualifying agreements: CAISO should confirm that any approved distribution export interconnection qualifies - Rule 21 export interconnection for CPUC-jurisdictional utilities, and the analogous agreements for publicly owned utilities and other non-CPUC-jurisdictional entities - so that participation is available consistently across BAAs.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

Tesla supports zeroing out at the resource level (rather than at the individual customer level) and supports allowing the SC to determine which end-use customers' intervals are zeroed out. Resource-level treatment is less restrictive and more accurately reflects aggregate capability than customer-by-customer zeroing, and the SC is already responsible for calculating and submitting settlement-quality meter data, so this allocation of responsibility is consistent with current roles. We recommend revisiting the issue of exporting beyond the resource level in Track 2 discussions.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Tesla strongly supports applying the reform to all PEMs, not solely the MGO methodology. Most DR resources rely on non-MGO PEMs (day matching, weather matching, and control group), so limiting the reform to MGO would deny the benefit to the majority of resources. We agree that baselines should reflect typical export behavior during non-event intervals so that only incremental service above typical behavior is compensated.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

Tesla agrees with the principle that baselines should reflect a customer's typical behavior, including typical export behavior during non-event intervals, so that compensation reflects only incremental curtailment above that baseline. This is an appropriate safeguard against over-compensation and is consistent with how performance is already measured.

CAISO should ensure that changes to baseline methodologies remain transparent as export behavior is incorporated, and that any methodology changes are vetted with stakeholders.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

Track 2 scoping. Tesla requests that CAISO expressly add to the Track 2 scope: (a) exports beyond the aggregation resource and the associated deliverability pathway; (b) device-level metering and telemetry. We have raised the importance of these broader issues previously and continue to view Track 1 as an important incremental step and we look forward to continued engagement in Track 1 and Track 2.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

VGIC appreciates CAISO’s efforts in hosting the June 18, 2026 discussion and advancing the Revised Straw Proposal. VGIC strongly supports the Revised Straw Proposal, as it supports the integration of end-user exports into Demand Response (DR). To meet reliability goals and optimize price formation, CAISO must establish pathways that fully value the capability of distributed energy resources (DERs), including bidirectional electric vehicle charging systems, sometimes referred to as vehicle-to-grid or V2G resources. California utilities and the California Public Utilities Commission have long permitted the safe and reliable distribution system interconnection of these V2G sytems, for example under Rule 21. Notably, V2G systems have no durable retail tariff or program in which to participate and support the California market. Unlike other DERs, V2G systems are not eligible for legacy Net Energy Metering or the Net Billing Tariff compensation schemes, nor are they eligible for any full-scale utility-administered demand response programs. The Revise Straw Proposal may meaningfully unlock the use of V2G resources as a safe, reliable supply-side DR asset. The California Energy Commission recently estimated that the state's existing EV energy storage capacity (18.5 GW at EOY 2025) exceeds all installed energy storage capacity, making it an immensely under-utilized resource to bolster reliability and support accurate price formation.

2. Please submit your organization’s overall comments on Track 1

Track 1 is a critical first step in unleashing the full potential of DERs. VGIC's core position is that market rules should be enhanced to allow for exports as much as possible, including from V2G resources. Track 1 should focus on eliminating barriers and limitations that prevent DERs from fully participating and providing their maximum potential capacity to the grid during critical windows.

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

VGIC strongly supports the revised straw proposal. As detailed above, end-user exports can reliably provide value to CAISO's system, offering more from each DR aggregation by welcoming new resources that have been technically available but underutilized under current rules. This includes V2G solutions.

4. What key change(s) would your organization recommend to improve the proposal?

VGIC believes the proposal could be improved, either now or in a future iteration, by recognizing and compensating exports at the sub-LAP level (i.e., removing zero-ing out altogether, and studying DR aggregatoins for deliverability). In practice, this would allow a homogenous aggregation of assets, such as EVs, to all provide exports rather than requiring these assets be mixed into an aggregation with other resources that may have a positive baseline. Enhancing the revised straw proposal to unlock even greater capabilities by reflecting aggregator-level exports in demand response market models can further the goals detailed by CAISO in the June 18 stakeholder workshop.

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

VGIC supports the applicability of the revised straw proposal to all BAAs. We also support the applicability of the revised straw proposal to both PDR and RDRR market models. Broadly applying this treatment would constitute a fair and reasonable approach to implementing this reform, and, in practice, would maximize the benefit available to the CAISO system by expanding the potential pool of new exporting DR resources that could participate in the market.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

As detailed above, VGIC supports the revised straw proposal at this time, which does not change deliverability treatment. However, we also encourage CAISO to consider modifications to the proposal to allow for exports even at the sub-LAP level (i.e., remove all "zero-ing out" requirements), including any necessary changes to the deliverability framework that would enable that.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

VGIC strongly supports limiting participation to customers with an approved distribution system interconnection agreement. The safety and reliability of California's electricity system is critical, and the emergence of new exporting technologies requires interconnection standards and processes that sufficiently meet all relevant safety standards. Notably, all commercially-available bidirectional charging systems across both residential and non-residential applications (and including both V2G-DC and V2G-AC configurations) currently meet IEEE 1547-2018 requirements via UL 1741 certification. All of these systems are specifically permitted to interconnect under existing utility rules, as they meet the relevant requirements. Any customers whose export would be counted in a DR aggregation should be required to interconnect with the distribution utility. However, customers who are not exporting but who are included in the DR aggregation should not necessarily need to be interconnected with the distribution utility. These customers would be "load-only" customers without any export mode that's been enabled by a manufacturer or an manufacturer-authorized third-party.

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

VGIC supports the revised straw proposal's design to allow SCs to determine which end-use customers are zeroed out. This flexibility empowers SCs to optimize their portfolios, yielding the greatest mutual benefit for both CAISO and the participating end-use customers. Moreover, this ensures that resources capable of robust, reliable exports are not penalized or diluted by non-exporting or underperforming assets within the same resource aggregation.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

Similar to VGIC's position on the revised straw proposal's applicability to all BAAs and to both PDR and RDRR market models, we support applicability across all PEMs. Segmenting rules or prohibiting exports based on the baseline methodology would likely create market distortions. All methodologies should be updated to accurately capture, verify, and reward exported energy to maintain a level playing field.

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

No, VGIC does not have concerns on this matter, as the revised straw proposal adequately addresses the issue.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.

VGIC reiterates that EV assets represent a massive, almost entirely untapped reservoir of flexible export capability for CAISO's system. Ensuring that these resources can export energy and receive fair market compensation is essential for a reliable, cost-efficient grid. The revised straw proposal is a critical first step to making it happen, and VGIC looks forward to further collaboration with stakeholders to enhance the proposal toward one that ultimately removes zeroing-out altogether, such that exports are enabled not only at the end-user level, but at the aggregation level.

1. Please provide your organization’s feedback on the DDEMI meeting discussion on June 18, 2026 and the “Demand and Distributed Energy Market Integration Track 1: Revised Straw Proposal: Reflecting End-User Exports in Demand Response” paper

See attached

2. Please submit your organization’s overall comments on Track 1

3. Does your organization support, support with caveats, oppose, or oppose with caveats the proposal? Please explain the rationale for your position.

4. What key change(s) would your organization recommend to improve the proposal?

5. Please provide your organization’s feedback on the applicability of the Track 1 proposal to: 1.) All Balancing Authority Areas (BAAs) 2.) Both Proxy Demand Resource (PDR) and Reliability Demand Response Resource (RDRR) market models.

6. Please provide your organization’s feedback on the ISO BAA deliverability discussion, including any operational or market implications.

7. Please provide your organization’s feedback on the proposal to limit participation to customers with an approved interconnection for export onto the distribution system, including the implementation of this requirement as an attribute in CAISO’s Demand Response Registration System (DRRS).

8. Please provide your organization’s feedback on the proposed design to zero out at the resource-level and allow the Scheduling Coordinator (SC) to determine which end-use customers are zeroed out.

9. Please provide your organization’s feedback on the applicability of this proposal to all Performance Evaluation Methodologies (PEMs).

10. Does your organization have concerns with how baselines will be calculated or adjusted when end-use exports are netted out? Please describe any implications for measurement, verification, or settlement accuracy.

11. Please provide any additional comments, feedback, or examples. You may upload examples or data using the Attachments field below.