Comments on Comments on Stakeholder Meeting on 3/28

1. Please Provide your Organization's Comments on the Tariff Clarifications Spring 2025 Draft Tariff Language Changes

NCPA does not support the changes to Sections 30.5.1 (v) or 30.5.1 (y) regarding the restriction of economic bidding by Variable Energy Resources until development of a state of the art forecast. CAISO states that the reason for the changes are supported in Appendix Q and Section 34.1.6 of the CAISO Tariff. Appendix Q states that CAISO requires certain data for a certain period in order to produce a state of the art forecast. It does not speak to EIRs that have elected to produce their own forecasts. Tariff Section 34.1.6.1 refers EIRs that have elected to produce their own forecasts to Section 4.8.2.1.1. 4.8.2.1.1 states “Eligible Intermittent Resource may opt to use their own forecast of their resource’s output, and not use the forecast of their output provided by the CAISO, only to the extent the CAISO has certified that the Eligible Intermittent Resource has completed the certification requirements specified in the Business Practice Manuals.” NCPA has found no mention in the BPMs of the steps required for CAISO certification of “state of the art” forecasts.

EIRs must be able to economically bid at COD in order to mitigate exposure to negative pricing and resultant extensive financial losses. While NCPA understands CAISO has concerns with economic bidding of stage two generators, NCPA cannot support this solution for reasons including, but not limited to. those submitted in comments to PRR 1610. NCPA requests for CAISO to initiate a stakeholder initiative that starts with an issue paper from CAISO and a series of workshops in order to ensure CAISO and stakeholders understand the challenges the other is facing. During this initiative, stakeholders and CAISO can develop the process and requirements for state of the art forecast certification. Parties may also discuss adding state of the art forecast development to the NRI process. NCPA looks forward to working with CAISO and stakeholders to develop a win-win solution for all parties.