Comments on Draft 2027-2029 market policy roadmap meeting on Oct.01, 2026

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Bonneville Power Administration appreciates the CAISO’s efforts to expand stakeholder discussion periods and establish more realistic, extended working group timelines in the Draft 2027–2029 Policy Roadmap. Given the breadth and complexity of upcoming market design topics, this intentional pacing allows regional entities adequate time to conduct technical review, coordinate internally, and provide thoughtful input. Bonneville values this collaborative approach, which significantly strengthens regional alignment and produces more durable market policies. Bonneville offers specific comments on several high-priority initiatives below.

Resource Adequacy

Bonneville acknowledges the limited scope of the Resource Adequacy initiative. As regional coordination deepens across the West, Bonneville recommends that CAISO also explicitly consider future alignment with Regional Organization for Western Energy (ROWE) Resource Adequacy policy as the initiative re-orients toward California Public Utilities Commission’s Unforced Capacity framework.

As regional market integration and resource adequacy coordination develop, emerging resource adequacy frameworks should appropriately recognize the diverse characteristics of the variety of resources used to meet load in the West, rather than rely exclusively on methodologies developed around thermal generation portfolios. Bonneville encourages CAISO to support ROWE’s development of a binding Resource Adequacy program as a pre-requisite to join EDAM. This program should incentivize investment in new generation while maintaining a set of minimum standards for a wide variety of concepts such as peak loads, resource accreditation, risk tolerance, and must offer requirements.

Congestion Revenue Allocation

Bonneville appreciates the proposed extension of the working group phase of Congestion Revenue Allocation Phase 2 and CAISO's commitment to additional analysis of the simultaneous feasibility test simulations. The novel complexity of integrating OATT transmission rights with Congestion Revenue Rights (CRRs) warrants careful evaluation, particularly because the underlying transmission constructs reflect different approaches to transmission service and congestion management. Further, the extended timeline offers an opportunity to standardize the congestion rent allocation methodology across the EDAM footprint. 

Bonneville recommends that the working group also consider the interests of Point-to-Point (PTP) versus Network Integration Transmission Service (NT) customers. Bonneville receives a significant portion of transmission revenue from PTP sales. The development and implementation of an organized market in the west must not penalize or disincentivize equitable cost allocation for use of the transmission system.  NT and PTP products have different service characteristics and contractual structures, and any congestion revenue allocation framework must account for those distinctions. 

Bonneville supports additional analytical work to evaluate whether proposed allocation methodologies appropriately preserve the value associated with firm transmission service, maintain equitable treatment across transmission customer classes, and provide predictable outcomes under varying system conditions.

The extended working group schedule provides a valuable opportunity to evaluate these issues thoroughly before advancing a final design.

Price Formation Enhancements

Bonneville strongly supports CAISO’s decision to broaden the Price Formation Enhancements (PFE) initiative to develop a comprehensive scarcity pricing framework alongside balancing authority area-level market power mitigation. Establishing clear, graduated price signals that accurately reflect tightening operating margins and the true value of reserves is essential for operational reliability, efficient regional resource commitment, and long-term investment across the Western footprint. At the same time, Bonneville encourages the ISO to maintain clear momentum and focus as this expanded scope takes shape. While Bonneville appreciates that addressing scarcity pricing comprehensively requires careful technical coordination among diverse regional perspectives, the stakeholder community should mindfully avoid rehashing problem statements. Well-functioning scarcity pricing is not novel; it is a foundational, FERC-approved component of the standard organized market structure.

Bonneville also understands that the PFE reframing will allow for resumed discussions on fast-start pricing, so that all three components—market power mitigation, scarcity pricing, and fast-start pricing—will be reunited in a single track. Given the brevity of the discussion previously devoted to fast-start pricing, stakeholders may benefit from early working group discussions focused on this topic, along with how it is expected to interact with the market power mitigation and scarcity pricing components.

Bonneville emphasizes that the resulting framework should appropriately recognize the operational characteristics of flexible resources and avoid pricing or mitigation outcomes that undervalue legitimate opportunity costs and the provision of flexibility. The objective should be a transparent and durable price formation framework that supports efficient market outcomes while preserving appropriate reliability incentives.

Greenhouse Gas (GHG) Coordination

Bonneville generally supports the areas identified in the roadmap. Additionally, Bonneville requests that CAISO appropriately account for the implementation of the Washington GHG regulation zone within the final roadmap. Bonneville anticipates that additional stakeholder discussion and implementation resources will be necessary in 2027 to implement this new GHG regulation zone, particularly for balancing authority areas spanning across one or more GHG regulatory jurisdiction(s) and non-GHG regulatory areas. Bonneville also requests that the public dialogue on the net export constraint be expanded to include a broader review of the updates made to the GHG design for EDAM, including treatment of committed capacity.

Intertie Bidding

Bonneville would like Intertie Bidding included in the Draft Roadmap. CAISO noted that stakeholders have submitted proposals on this topic have been submitted in prior years, demonstrating sustained regional stakeholder interest.  Efficient intertie bidding and scheduling arrangements play a critical role in facilitating regional power transfers. Market design should enable efficient use of existing transmission capability and avoid unnecessary barriers to transactions across market boundaries.

Recognizing the need to manage initiative workload, Bonneville suggests that CAISO incorporate Intertie Bidding into the EDAM Enhancements or Seams workstreams rather than treating it as an isolated standalone initiative.  Intertie mechanics, including scheduling coordination across seams, market liquidity at boundary points, and alignment with bilateral OATT frameworks, fit naturally within the scope of either workstream.

Integrating this topic would provide a resource-efficient means of addressing seam dynamics, harmonizing intertie bidding capabilities across the entire EDAM footprint, and supporting robust, transparent market access on key regional transmission paths.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Bonneville anticipates having the necessary resources to participate meaningfully in relevant stakeholder initiatives within CAISO's proposed timeline. Bonneville views Resource Adequacy, Congestion Revenue Allocation, Price Formation, GHG Coordination, and Intertie Bidding enhancements as high-priority focus areas in 2027. Bonneville appreciates CAISO's efforts to establish realistic initiative schedules and extended working group periods needed to support effective stakeholder engagement and technical evaluation

3. Does your organization have any feedback about the market policy catalog and roadmap process?

Bonneville seeks clarification on the process by which items are identified and prioritized for inclusion in the EDAM Enhancements initiative, including whether candidate topics will be identified solely by CAISO or whether stakeholders will have an opportunity to nominate additional items. Bonneville believes it is important that the roadmap process provide sufficient opportunities to address market design issues affecting transmission rights, resource flexibility, and regional market access.

If CAISO has already been identified specific items as candidates for EDAM Enhancements or if work is already in flight- it should explicitly list them in the final roadmap.  For example, CAISO has had to address EDAM settlement issues through several emergency Proposed Revision Requests (PRRs) since the day-ahead market launch.  Such efforts to address ongoing and future stabilization and refinement of settlement functionality warrant inclusion on the roadmap as a dedicated workstream (or 'swim lane') under the EDAM Enhancements initiative. 

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

SUPPORT.

The California Community Choice Association (CalCCA) supports the draft 2027-2029 Market Policy Roadmap (Draft Roadmap). The Draft Roadmap is representative of stakeholder priorities, including the Joint Parties’ proposed Maximum Import Capability (MIC) enhancements initiative. CalCCA appreciates the CAISO’s responsiveness to stakeholders’ priorities and revised Resource Adequacy Modeling and Program Design initiative schedule to initiate the MIC enhancements scope item in late 2026. The CAISO should adopt the Draft Roadmap for 2027-2029 as proposed. 

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

SUPPORT.

CalCCA has the resources and capacity to support policy initiatives outlined in the Draft Roadmap.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

CalCCA has no comments at this time.  

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

The California Department of Water Resources – State Water Project (CDWR SWP) appreciates the opportunity to comment on the 2026 CAISO Market Policy Roadmap and Catalog Process, specifically for the draft 2027-2029 CAISO Market Policy Roadmap. Overall, CDWR-SWP supports CAISO’s draft 2027-2029 market policy roadmap. CDWR-SWP has the following positions, comments, and suggestions; broken down based on topic:

Demand and Distributed Energy Market Integration (DDEMI)

Before the Stakeholder meeting, CDWR-SWP had several concerns with the status of the DDEMI initiative described on the Draft 2027-2029 Market Policy Roadmap. The statement found on the 2027-2029 CAISO Market Policy Roadmap Presentation Slide (Page) 7 posted on September 29th, 2026 stated that timings are “being assessed for the real-time demand and pumped-load bidding working group”. Then, the DDEMI Initiative Timeline outlined in the Draft CAISO 2027-2029 Market Policy Roadmap Timeline Excel spreadsheet posted on September 24th, 2026, had a noticeable absence of the working group from DDEMI as a whole. In the 2026 Market Policy Catalog and Roadmap meeting held on October 1st, 2026, CDWR-SWP asked multiple questions inquiring about the status of the DDEMI Working Group. First, CDWR-SWP asked a question about the potential parallels between Track 3 (Large Loads) and that of the working group. Anja Gilbert from the CAISO responded by stating that “by participating in the track 3 efforts, there may be some parallels and as we think about what may need to change about the market models to accommodate large load and large load flexibility, the conversation may arise.” Next, CDWR-SWP asked whether the DDEMI working groups are currently paused or will be tabled. In response to this question, Anja responded by stating that “at this time, we’re looking at it as a pause in terms of managing the sequencing of the work”. CDWR-SWP is encouraged with this response but has some suggestions for the CAISO. Currently, there is ambiguity regarding the status of the Working Group due to its omission from the Roadmap and unclear status description as stated in the Presentation (Slideshow). Due to this issue, CDWR-SWP suggests the CAISO add the planned pausing of the working group on the roadmap timeline for the Draft Final 2027-2029 Market Policy Roadmap. This would indicate to other Stakeholders and the CAISO Board of Governors (BOG) that the working group will continue to progress in the future even if they are currently paused to “Sequence the Work”. CDWR-SWP understand that Track 3, Large Loads, is of priority to CAISO currently, but would like clarification that the large amount of work done throughout multiple working group meetings and papers will continue to be relevant with further development on a later date. CDWR-SWP appreciates and thanks Anja Gilbert, Ansel Lundberg, and the CAISO staff for their quick and clear response to the questions that CDWR-SWP posed during the Stakeholder meeting. Overall, CDWR-SWP supports the current direction of the Demand and Distributed Energy Market Integration (DDEMI) initiative.

Resource Adequacy

CDWR-SWP presented in April 2026 highlighting how delays to the projected Commercial Operation Date (COD) outside of Load-Serving Entities’ (LSE) control could lead to costs in the upwards of several million dollars for LSE because of the Phantom Flex RA obligations. In light of the 2026 Market Policy Roadmap meeting on October 1st, 2026, CDWR-SWP is pleased to hear that CAISO has accepted the proposal on Phantom Flex RA Obligations and will look forward to participating in the discussions for Track 4 of the Resource Adequacy Initiative. CDWR-SWP fully supports CAISO’s continued work and commitment to resolving issues related to Resource Adequacy.

Real-Time Congestion Offset Charges

CDWR-SWP presented back in April 2026 to bring attention to the CAISO and Stakeholders that CDWR-SWP has seen an approximate 1700% increase of its RTCO charge from 2011 to 2025 with a substantial 50% increase in 2021 (when compared to 2020) and 2022 (when compared to 2021). The Department of Market Monitoring confirmed in the Q3 Market Performance Report that the increase of the RTCO costs is system wide. The issue concerning the steady increase of the RTCO charge was first raised by CDWR-SWP in 2024 with repeated attempts in 2025 and now 2026. CDWR SWP expects that this issue should be brought up for discussion again in the stakeholder forum. CDWR-SWP also believes that CAISO could do in-house (outside of stakeholder forum) tracking and assessments outlined in the CDWR-SWP's proposal on a continual basis as it is a major cost component for LSEs. Such an approach may help CAISO establish a sense of urgency for resolving this issue.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

CDWR-SWP will have the resources and capacity to support participation in the portfolio of policy initiatives and looks forward to participating in the various initiatives as outlined in the 2027-2029 Draft Roadmap.

CDWR-SWP will actively engage and participate in the Resource Adequacy – Track 4: Flexible RA issue.

CDWR-SWP thanks the CAISO as well as stakeholders for considering and supporting the proposal submitted by CDWR-SWP regarding Flex RA Phantom Obligations. In addition, CDWR-SWP will continue to monitor DDEMI Track 3 to highlight potential parallels between Large Loads and the Working Group.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

CDWR-SWP has a few comments and suggestions for the CAISO, mainly focused on the proposed changes from the 2026 Annual Policy and Roadmap Process to that of the 2027 Annual Policy and Roadmap Process.

In 2026, Stakeholders interested in submitting a new proposal had to decide between submitting proposals to either the Market Policy or the Infrastructure Policy processes, resulting in a bit of confusion for Stakeholders, especially for proposals that fall partly in both processes. As a result, the CAISO would introduce a change to the 2027 Policy Process by only opening one (1) submittal portal for stakeholders to “funnel” all submitted proposals. Afterwards, the CAISO will independently sort them into the specific Roadmap Process (CAISO BA or WEM) that would best fit based on the problem statement of said Proposal. CDWR-SWP supports this decision, noting that this change to the Proposal submittal process will help reduce (or remove altogether) the confusion Stakeholders faced when submitting proposals annually.

In addition, the CAISO asked Stakeholders if the changes seen in the 2026 CAISO Roadmap process in which the (CAISO) Annual Policy Roadmap(s) were split into two (2) separate roadmaps, Market Policy and Infrastructure Policy, are more preferrable than the 2025 CAISO Roadmap process, in which there was only one combined Annual Roadmap. CDWR-SWP recommends the splitting of the Annual Policy Roadmap Process into Market Policy and Infrastructure Policy Roadmaps like that had occurred in the 2026 process as it would keep both the CAISO and Stakeholder focused on key specific topics and issues.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

The California Energy Storage Alliances (CESA) appreciates the opportunity to comment on the Draft 2027-2029 Market Policy Roadmap. CESA recommends that CAISO develop a roadmap that uses planned decision dates rather than “no sooner than” milestones. The “no sooner than” approach does not allow stakeholders to assess what market design accomplishments are anticipated for 2027 and plan accordingly.

The Storage Design and Modeling initiative’s “no sooner than” milestones will easily be met as historical precedent supports market design policy development taking significantly longer.

CESA provides the following observations and recommendations on the timing of the elements of the Storage Design and Modeling initiative:

1. CESA does believe that the updated Storage Default Energy Bid (DEB) should be ready for a WEM Governing Body decision in Q1 2027.
2. Changes to bid cost recovery, on the other hand, will require far more discussion than can be accomplished in the next 5 months. A realistic decision date for changes to storage uplift, assuming focused efforts, could be achieved in December 2027.
3. The State-of-Charge (SOC) Management topic group will not be ready for WEB Governing Body decision in Q2 2027. CESA requests CAISO provide additional details on the proposed scope of this group. CESA believes the scope is to consider allowing end-of-horizon SOC bidding which is a significant change in the storage market participation paradigm. While end-of-horizon SOC bidding does have merit, robust review and discussion of how this bidding change will interact with SOC modeling constraints used in the market is necessary. If CAISO staff focused solely on the SOC Management topic, a realistic WEM Governing Body decision date would be Q2 2028. Given the stated need to address uplift, the CAISO staff should assess the feasibility of addressing both topics simultaneously. If CAISO staff takes a more sequential approach to the two topics, the SOC Management topic decision date would likely push out to Q1 2029.

The Price Formation Enhancements – Comprehensive Scarcity Pricing & Market Power Mitigation initiative languished in 2026 given inconsistent prioritization by CAISO management. The 2027-2029 Market Policy Initiatives Roadmap is the same as the 2026-2028 Market Policy Initiatives Roadmap except for a full year push in the schedule. CESA recommends CAISO consider splitting up the initiative so that items with consensus can be sent to the WEM Governing Body for decision and slated for implementation sooner.  CESA provides the CAISO with the following recommendations:

1. Immediately seek a WEM Governing Body decision on the BAA nesting approach. This addresses EDAM/WEIM over-mitigation and can include CAISO in the nesting approach, with any group including CAISO deemed competitive. 
2. CAISO system market power mitigation requires an updated study to establish if system market power exists in CAISO.
3. In parallel to preparing the system market power mitigation study, CAISO staff should document how default energy bids will be calculated for non-resource specific imports.
4. Short term scarcity pricing mechanisms should be abandoned. The design complexity and limited benefits do not warrant further work.
5. Comprehensive scarcity pricing should develop the energy supply margin proposal for decision in Q4 2027.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

See above.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

See above.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

SUPPORT

Energy Division staff (ED Staff or Staff) of the California Public Utilities Commission (CPUC) develops and administers energy policy and programs to serve the public interest, advises the CPUC, and ensures compliance with CPUC decisions and statutory mandates. ED Staff provides 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 this opportunity to comment on the 2026 Market Policy Roadmap, CAISO’s plan on scope and timing of stakeholder initiatives. Consistent with its proposal and presentation, ED Staff generally supports CAISO’s 2026 Market Policy Roadmap but suggests additional specificity in the scope of the EDAM Enhancements initiative. Staff recommends CAISO consider addressing bilateral market liquidity in order to ensure end-use customers receive the full benefits of EDAM. ED Staff does not support further policy development on comprehensive scarcity pricing or fast-start pricing. Finally, Staff agrees with CAISO’s proposed approach to divide the 2027 Roadmap into two based on which governing body will approve the initiative.

EDAM Enhancements

ED Staff agrees with CAISO that this EDAM initiative should not be a place to relitigate the entire market design of EDAM. However, Energy Division remains concerned that imbalance reserve requirements are too high and duplicative of the Flex RA product, which unnecessarily increases costs for California ratepayers. CAISO should continuously evaluate EDAM performance in order to ensure that end-use customers receive the full benefits of EDAM.

In the 2026 Market Policy Roadmap, CAISO declined to specify what elements of EDAM will be assessed in this initiative and is using it as a placeholder to reserve policy resources. ED staff suggests that CAISO consider scoping into the initiative working groups to assess various EDAM market design elements that are adjustable to reduce, to the extent possible, overall economic costs for end-use customers. These adjustable elements include the demand curve, imbalance reserve requirements and levels that could be set at different times of the day or year, and configurable parameter levels. As discussed below, bilateral market liquidity could be scoped into this initiative as well. ED Staff also recommends CAISO evaluate certain CAISO BAA specific reliability issues that are related to EDAM including the net export constraint and low-priority exports.   

Bilateral Market Liquidity

ED Staff encourages CAISO to include the issue of bilateral market liquidity as a standalone meeting and report out, as part of ongoing EDAM market performance meetings, or as a track within the EDAM Performance Assessment and Enhancements initiative. Consistent with its proposal and presentation, ED Staff recommends CAISO examine the liquidity of the bilateral indices in a public forum because of the potential impact of thinly traded markets including market manipulation, exercise of market power, and cost increases for end-use customers.   

Seams

Based on the September 30, 2026, Joint CAISO/SPP report to FERC, ED Staff’s understanding is that it is too soon to tell if any of the coordination work will require either CAISO or SPP to change their tariff. ED Staff agrees with CAISO that it is prudent to maintain dedicated capacity for this topic in the roadmap, though the scope of the initiative has not yet been defined. 

Resource Adequacy Modeling and Program Design (RAMPD)

ED Staff recommends CAISO specify that the RAMPD tracks apply only to the CAISO BAA:

• Track 2: Outage substitution and RA availability and incentive mechanism (RAAIM) reform
• Track 3b: EDAM Resource Sufficiency Evaluation (RSE) and changes to the Capacity Procurement Mechanism (CPM)
• Track 4: Reevaluation of the Flex RA program
• Track 5: Enhancement to the allocation and transactability of Maximum Import Capability (MIC)

Otherwise, based on these descriptions, stakeholders could imagine the scope of the RAMPD initiative as broader to include the entire EDAM RSE or an expansion of the CAISO’s CPM authority to other BAAs. 

Existing initiatives: CCR, DDEMI, EDAM CRA, GHG Coordination, Gas Resource Management, Storage Design and Modeling

The priority and timelines for these existing initiatives appear to be appropriate. 

Price Formation Enhancements

ED Staff supports continuing with policy development for market power mitigation.  As discussed in previous comments, ED Staff believes existing mechanisms address issues that Comprehensive Scarcity Pricing (CSP) and Fast Start Pricing (FSP) could address and therefore ED Staff does not support further policy development on CSP or FSP. 

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

SUPPORT

3. Does your organization have any feedback about the market policy catalog and roadmap process?

ED Staff agrees that the separation of the two roadmaps based on which Board governs the initiatives makes sense for 2027. CAISO staff will likely continue to manage all stakeholder initiatives into 2028 though many initiatives previously governed by the WEM Governing Body will be governed by the ROWE Board of Directors. It makes sense to separate initiatives that are expected to be governed by the CAISO BAA such as RA and infrastructure issues.

Questions may arise when the decisional classification for an initiative is determined. For example, there is a lot of work still to be done regarding the CAISO versus ROWE tariffs. Therefore, there may need to be some consideration about what to do in case it is not clear whether the initiative falls under CAISO Board of Governors or ROWE Board of Directors authority for the 2027 roadmap because it is expected to cover years 2028-2030.     

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

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

Support: Cal Advocates supports the September 24, 2026 Draft 2027-2029 CAISO Market Policy Initiatives Roadmap (Draft Roadmap).[1]  The selected initiatives and anticipated pace of development are reasonable.

[1] Available as “2027-2029 ISO Draft Market Policy Roadmap – Sep 24, 2026” at: https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/2026-market-policy-catalog-and-roadmap-process.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Support: Cal Advocates expects to fully participate in relevant stakeholder initiatives as listed and planned for in the Draft Roadmap.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

Cal Advocates has no additional feedback on the roadmap process at this time.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

CALSSA votes in support, particularly with regards to the Demand and Distributed Energy Market Integration (DDEMI) initiative. CALSSA supports CAISO’s timeline to begin implementation of Track 1 no later than the first quarter of 2028 and urges CAISO to prioritize Track 1 and accelerate that schedule wherever possible so that market-qualifying products are in place ahead of the June 30, 2028 deadlines established by SB 913 (Becker, 2026). However, several clarifications within the proposed tracks for DDEMI would significantly improve the affordability and reliability benefits that can be obtained.

CALSSA believes that integration of distributed energy resources into wholesale markets will lower the cost of energy while allowing CAISO to stay ahead of the resource adequacy crunch. CALSSA appreciates the progress that CAISO staff have made in drafting a proposal that would allow exports from individual customers to be recognized under the existing PDR model if the aggregation itself is not a net exporter (Load Curtailment Approach). CAISO staff have correctly recognized the value of creating a solution that can be operationalized in the near term because it is designed to fit within existing constructs.

Developing a participation model that allows exports beyond the aggregation (Net Export Approach) has the potential to enable further participation but also has substantial timeline risk. SB 913 directs the California Public Utilities Commission (CPUC), in coordination with the California Energy Commission (CEC) and CAISO, to enhance existing market-integrated pathways for aggregated distributed energy resources to qualify as resource adequacy (RA) capacity by June 30, 2028. Among other things, the CPUC must establish conditions under which energy exported past the utility meter receives RA credit, determine whether device-level telemetry provides sufficiently accurate measurement for settlement, and fully integrate these resources into the current RA construct and counting conventions. By the same date, the CPUC must develop recommendations for changes to CAISO’s proxy demand resource (PDR) and distributed energy resource aggregation (DERA) participation models, including the must-offer obligation for each, and communicate them to CAISO for consideration in a new or existing initiative. The statute also calls for alignment with CAISO’s existing participation models, which is precisely what the Load Curtailment Approach builds on.

The state is in an energy affordability crisis and significant load growth is forecasted. Although CAISO should investigate developing the Net Export Approach as part of a DDEMI Track 2, the state will maximize affordability, reliability, and operational experience by pursuing a phased approach that completes and implements the Load Curtailment Approach in Track 1 as quickly as possible, while beginning work on the Net Export Approach in a separate Track 2 that proceeds in parallel and does not delay Track 1. The Net Export Approach raises additional questions, including deliverability, distribution system hosting capacity, and export arrangements with utility distribution companies, that will take longer to resolve. Trying to resolve those questions ahead of Q1 2028 risks having no export-qualifying CAISO products available under the timeline in which the CPUC will be finalizing telemetry, export, and resource adequacy credit methodologies rules for distributed energy resources (DERs). It is imperative that fully approved CAISO products, particularly PDR but also ideally DERA, be available as participation vehicles for export-capable DERs.

There will be customers and aggregations where the Load Curtailment Approach is already a fit and involvement in a more expansive model would be unnecessary. CAISO has already identified several additional areas of discussion before the Net Export Approach can be approved, and discussing these in parallel with implementation of the Load Curtailment Approach would maximize the speed of iteration and benefits to the state’s energy system.

The Load Curtailment Approach is already a promising solution with significant stakeholder buy-in, and the remaining issues to be resolved are a subset of those issues remaining for the Net Export Approach. There will be shared issues between these approaches, like resolution of double compensation, and this will allow CAISO to already have a head start when it turns its focus to the Net Export Approach in Track 2. CAISO should view the Load Curtailment Approach as a simpler and quicker version of the Net Export Approach that is a better match for the timelines outlined in SB 913. In the case that the rules for the Net Export Approach are more limiting for some customer categories, the Load Curtailment Approach will be important to facilitate participation.

CAISO should also clarify how device-level telemetry, an important improvement to unlock exports, will be accommodated in Track 1. It is unclear from the roadmap where this would fall, but device-level telemetry is ultimately important to fully unlock participation of the full suite of controllable resources behind-the-meter. Under SB 913, the CPUC will determine whether device-level telemetry provides sufficient and accurate measurement and, if so, establish standardized requirements for settling distributed resources using device-level data. CAISO should design Track 1 registration and settlement so that they can accept device-level telemetry once the CPUC’s requirements are in place, avoiding a later redesign. Although CALSSA recommends that device-level telemetry be accommodated in Track 1, its implementation does not need to block the implementation of the Load Curtailment Approach or the Net Export Approach. CALSSA recognizes that device-level telemetry may take time to develop, and that its implementation is not a prerequisite to either of the approaches. Therefore, CALSSA recommends phased implementation within Track 1. Additionally, utility meter data should remain valid for settlement while the CPUC and CAISO are working out the rules associated with device telemetry-based settlement.

CAISO should coordinate closely with the CPUC as SB 913 is implemented, but should not wait for the CPUC to finalize its rules before moving forward. The CPUC’s rules and guidelines on exports, device-level telemetry, and qualifying capacity counting will be developed in its Demand Response (R.25-09-004) and Resource Adequacy (R.25-10-003) proceedings on roughly the same timeline as DDEMI. If CAISO pauses until those determinations are final, market-qualifying PDR and DERA products will not be ready when the CPUC’s rules take effect, and the affordability and reliability benefits the Legislature intended will be delayed. CALSSA therefore recommends that CAISO proceed with Track 1 on its own accelerated schedule, establish a regular staff-level coordination process with the CPUC and CEC, and reserve space in the 2027-2029 roadmap to take up the CPUC’s recommendations on the PDR and DERA participation models, including must-offer obligations, promptly after they are communicated in 2028.

Finally, the roadmap should address RA qualification for the DERA participation model. SB 913 directs the CPUC to enable aggregated distributed energy resources to qualify as local, system, or flexible RA capacity and to align with CAISO’s existing participation models for these resources. To date, DERA has seen limited use, in part because it lacks a practical pathway to count toward RA. CALSSA recommends that CAISO, in coordination with the CPUC, include work to make DERA an RA-qualifying participation model, including defining its must-offer obligation, so that aggregations that inject energy onto the grid have a viable path to provide RA. Track 2 work on the Net Export Approach would be a natural place to address this.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

CALSSA votes in support. CALSSA has the resources and capacity to support participation in CAISO’s DDEMI initiative. CALSSA represents more than 550 companies involved in distributed solar and storage in California, including aggregators, manufacturers, installers, and service providers. Last year, CALSSA members installed 75% of the distribution-connected solar and storage that was installed in California. CALSSA is motivated to build a sustainable market for distributed solar and storage that benefits stakeholders across the stack, from customers to small installer businesses to large-scale aggregators.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

CALSSA recommends that the roadmap explicitly account for statutory deadlines and parallel CPUC processes that affect CAISO initiatives. For DDEMI, the June 30, 2028 deadlines in SB 913 should inform the priority and sequencing of Track 1 and the timing of any follow-on track, so that CAISO is positioned to act on the CPUC’s recommendations without waiting for the next roadmap cycle.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Support with caveats.  DC Energy agrees with the comments of the Western Power Markets Trading Forum (“WPTF”). 

In particular, DC Energy supports the roadmap for the CRR Enhancements Working Group with its current focus on modeling enhancements in Phase 2A.  There are improvements that the CAISO can and should make in this regard without the need for further Tariff amendments along with other related, complementary enhancements such as improvements to outage data transparency and reporting requirements.  After addressing modeling improvements, the CAISO should return its focus to product definition enhancements, namely the adoption of a Peak-Solar Time of Use period for CRRs and the addition of CRR sink locations for storage resources.

Enhancements to CRR modeling and product definition are essential to the ideas being discussed in the EDAM Congestion Revenue Allocation initiative as well. 

DC Energy also supports the inclusion of an initiative to consider the adoption of virtual bidding in EDAM BAAs outside of the CAISO. 

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Support.  DC Energy has the resources and capacity to support participation in the various policy initiatives in the CAISO and the expanding EDAM market because of its participation in the Western Power Markets Trading Forum (“WPTF”).  WPTF is a member led organization that follows initiatives and comments on behalf of and at the direction of its members.  WPTF represents stakeholders from diverse sectors with an interest in fostering markets that are more competitive in the West.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

Not at this time.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Support with caveats. PacifiCorp generally supports the selection of initiatives and proposed sequencing in the draft 2027-2029 Market Policy Roadmap. PacifiCorp appreciates CAISO's efforts to balance policy development, implementation activities, and stakeholder bandwidth while maintaining flexibility to address emerging EDAM-related issues. PacifiCorp views congestion revenue allocation and price formation as particularly important areas for continued policy development. Decisions in these areas have the potential to create long-lasting impacts on market incentives, transmission value, and costs to market participants, and PacifiCorp encourages CAISO to ensure these initiatives receive appropriate priority in the roadmap.

PacifiCorp offers the following comment regarding the proposed sequencing of the Demand and Distributed Energy Market Integration (DDEMI) initiative:

Demand and Distributed Energy Market Integration:

During the October 1, 2026 annual policy roadmap meeting, CAISO walked stakeholders through the resequencing of the DDEMI work to discuss large loads in the near term and the remaining Track 2 items later in 2027. While PacifiCorp understands that large load interconnection on the system is an important topic, PacifiCorp believes the topics initially contemplated under Track 2 should not be deprioritized or deferred such that meaningful changes cannot be implemented until 2028 or beyond. PacifiCorp has a wide range of demand response resources that it is working to integrate into EDAM and encourages CAISO to preserve the work already underway and establish a clear path for addressing these issues alongside the large load effort.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Support. PacifiCorp will continue to participate in the initiatives most relevant to its operations and market participation and has the resources necessary to engage in the proposed portfolio of stakeholder initiatives. PacifiCorp appreciates CAISO's efforts to sequence policy development and implementation activities across the roadmap period while considering stakeholders’ capacity for participation.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

PacifiCorp recommends that CAISO hold a standalone meeting to provide a consolidated status update on all existing initiatives at a defined point in the Roadmap process, including progress to date and any material changes from the original scope. While high level status updates are provided at WEM meetings, deeper context and framing are not provided. Holding a standalone meeting once a year to provide background and context as to why initiatives were originally started, how and if the scope has changed, information on progress to date, and on current initiative status would support more informed stakeholder prioritization and improve overall transparency in the roadmap development process.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Support

Southern California Edison (SCE) appreciates the CAISO's efforts to develop a focused and achievable 2027-2029 Market Policy Roadmap. SCE supports the CAISO's decision to adjust the timing of several initiatives where additional stakeholder engagement, analysis, coordination, and consideration of regional market perspectives are warranted. Realistic sequencing should improve the quality of policy development, support more durable outcomes, and allow both the CAISO and stakeholders to focus limited resources on the initiatives with the greatest implications for reliability, market efficiency, and customer costs.

SCE also supports the CAISO's approach of consolidating related stakeholder proposals into existing initiatives, where appropriate, rather than creating duplicative stakeholder processes. In particular, SCE appreciates the decision to address Flex RA, Maximum Import Capability (MIC) enhancements, and several EDAM-related stakeholder proposals within existing initiatives, including continued work on MIC enhancements through the Resource Adequacy Modeling and Program Design initiative. This approach should improve coordination among related policy topics, reduce process duplication, and allow stakeholders to develop durable solutions in the most appropriate policy forums. SCE likewise supports the roadmap's continued focus on EDAM Congestion Revenue Allocation, Congestion Revenue Rights Enhancements, Resource Adequacy reforms, and Storage Design and Modeling.

SCE's overall support for the roadmap should not be interpreted as agreement with the scope or policy direction of every initiative. Consistent with its prior comments, SCE continues to support targeted market power mitigation enhancements but does not support expanding the Price Formation Enhancements initiative into a comprehensive scarcity pricing redesign at this time. SCE also continues to oppose further development of fast-start pricing.

More generally, initiatives designated as "as needed," including EDAM Enhancements and Seams, should be advanced only where there is a clearly identified problem statement, a demonstrated need, and an appropriately scoped solution. SCE supports maintaining flexibility in the roadmap to address emerging market issues but encourages the CAISO to remain disciplined in launching new initiatives, given the substantial stakeholder workload associated with the existing portfolio.

Finally, SCE encourages the CAISO to continue monitoring issues identified through the Catalog process that were not advanced as standalone initiatives. In some cases, additional operational experience, market monitoring, or targeted analysis may be the most appropriate next step before a formal stakeholder process is initiated.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

SCE expects to participate in the policy initiatives most relevant to its customers and operations within the timelines outlined in the roadmap. SCE's ability to provide meaningful and timely input, however, depends on the CAISO maintaining the roadmap's current sequencing and continuing to avoid unnecessary overlap among related initiatives.

The roadmap includes several substantial and technically complex efforts, including EDAM Congestion Revenue Allocation, Congestion Revenue Rights Enhancements, multiple Resource Adequacy Modeling and Program Design tracks, Storage Design and Modeling, Price Formation Enhancements, and continued EDAM-related policy development. Developing too many of these efforts concurrently could strain stakeholder resources and diminish the quality of participation. SCE therefore appreciates the CAISO's recent schedule adjustments, which better reflect stakeholder resource limitations and the need for meaningful engagement.

SCE encourages the CAISO to continue evaluating cumulative stakeholder workload and to adjust schedules as needed, particularly where initiatives rely on the same subject matter experts or involve overlapping market design issues. SCE's response to this question reflects the roadmap as currently sequenced and should not be interpreted to mean that stakeholders can absorb significant additions, accelerations, or expanded scopes without corresponding reprioritization elsewhere in the portfolio.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

SCE appreciates the CAISO's continued efforts to improve the transparency and responsiveness of the Market Policy Catalog and Roadmap process. SCE supports the proposed move toward a single intake process and recognizes the potential value of treating Western Energy Markets initiatives separately, provided that closely related issues remain coordinated across roadmaps and stakeholder processes.

For future roadmap cycles, SCE recommends that the CAISO:

1. Continue providing transparency regarding how stakeholder prioritization, reliability and market-efficiency benefits, implementation complexity, resource requirements, regulatory commitments, and organizational capacity influence initiative selection and timing.
2. Provide a consolidated annual status update on active initiatives prior to the prioritization process, including progress to date, significant scope changes, key upcoming milestones, and expected implementation effort.
3. Continue consolidating overlapping stakeholder proposals where appropriate, while clearly identifying how stakeholder concerns will be addressed within existing initiatives and workstreams.
4. Distinguish between issues that require immediate policy development and issues that may be better addressed initially through market performance analysis, operational monitoring, workshops, or public dialogue before launching a formal initiative.
5. Continue evaluating the cumulative workload associated with active and proposed initiatives and treat new additions or accelerated timelines as portfolio decisions that may require corresponding reprioritization of existing work.

Overall, SCE believes the draft roadmap reflects meaningful improvements in sequencing and prioritization and appreciates the CAISO's willingness to adjust schedules in response to stakeholder feedback. SCE looks forward to continued engagement as the roadmap is finalized and implemented.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

In general, the Six Cities support the proposed 2027-2029 market policy roadmap, with a specific focus on initiatives scheduled for 2027.  At this time, the Six Cities view the roadmap as ambitious but acceptably balanced in terms of the resource commitments that will be required for policy development work.  The initiatives that are slated for policy development generally appear to include initiatives that are already underway—in some cases, well underway—and it is reasonable to work toward materially advancing and, where possible, finishing these efforts.  The roadmap also acknowledges emerging areas where policy development is needed, such as the large load topics within the Demand and Distributed Energy Market Integration initiative, or initiatives that are necessitated by regulatory structures, such as the Washington-California linkage topic in the Greenhouse Gas Coordination initiative. 

In particular, the Six Cities support the CAISO’s proposal to begin policy work on Track 5 of the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative, which focuses on changes to the CAISO’s Maximum Import Capability (“MIC”) framework, in the fourth quarter of 2026.  Certain stakeholders who have supported this initiative have been actively engaged in working on problem statements and concepts for proposals.  The Six Cities hope that this independent stakeholder work will help the process to move forward expeditiously. 

Regarding the Congestion Revenue Rights (“CRR”) Enhancements initiative, the proposal to complete policy development work for Phase 2a (Modeling Enhancements) in the near term appears reasonable.  Phase 2b, on the other hand, now appears to include revisions to the CRR allocation process (which were also discussed as a “new scoping area” during the CRR Enhancements stakeholder meeting on September 30^th), while discussion of auction-related reforms has been underway within this initiative for some time.  The Six Cities would not want necessary changes to the CRR auction process to be deferred in order to accommodate discussion of changes to the allocation process.  The September 30^th stakeholder meeting in the CRR Enhancements initiative made clear that at least some preliminary analytical work will be required to assess how load-serving entities are using the allocation process and whether it meets their needs, and this work will likely take time.  For this reason, it may be necessary to separate the topics of allocation and auction reform in the CRR Enhancements initiative.  Unless the scoped issues for Phase 2b reveal that the auction and allocation must be considered in tandem, it would be preferable to include discussion of the allocation in a separate phase to allow the auction topic to advance more expeditiously. 

Several initiatives, including Seams and EDAM Enhancements, which are designated as “as needed” efforts, could require a significant commitment of CAISO staff and stakeholder time, depending on how they are scoped.  If the CAISO begins these initiatives, it might become necessary to reprioritize some of the other initiatives in the roadmap or revise the schedule for these initiatives.  If reprioritizing is required, the Six Cities encourage the CAISO to seek input from stakeholders and, where appropriate, from the Regional Issues Forum. 

Regarding Seams in particular, the Six Cities note that the market policy implications of several of the work streams included in the Joint Report of the CAISO and the Southwest Power Pool (“SPP”), filed in FERC Docket No. AD26-10-000, should potentially be considered in a stakeholder process.  In particular, if the development and implementation of the Western Interconnection Unscheduled Flow Mitigation Plan and the Enhanced Curtailment Calculator tool could have an impact on the CAISO energy markets, then how these items will be deployed within, and may affect, the CAISO’s markets (and market participants) should be considered alongside any related policy issues.  Development of the framework for joint constraint management, as discussed in the Joint Report, could also have policy implications, as could the topics that may be addressed in the CAISO-SPP Seams Coordination Agreement that will be under development in 2027.   

Consistent with prior positions, the Six Cities do not support advancement of Fast Start Pricing in the Price Formation Enhancements initiative. 

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

As noted above in response to Question No. 1, the Six Cities believe that the schedule proposed for 2027 efforts is ambitious and will require a significant commitment of CAISO and stakeholder resources, but it appears to be largely geared toward initiatives that either are underway and should be completed or materially advanced, or otherwise generally reflect stakeholder policy priorities.  The proposed initiative slate does not leave significant bandwidth for additional stakeholder efforts should new issues arise.  As in past years, if it becomes necessary to modify or revise the roadmap, the Six Cities request that the CAISO seek stakeholder input on mid-year changes.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

The Six Cities do not have feedback on the process at this time. 

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

The State Water Contractors (SWC) support and thank CAISO staff for incorporating the California Department of Water Resources (CDWR) “Flex RA phantom obligation due to delayed commercial operation date” submission into the Market Policy Roadmap under the existing Resource Adequacy (RA) efforts. SWC would also like to thank the stakeholders who acknowledged the importance of this initiative and recommended that it move forward as part of an existing initiative.

This initiative is important to SWC because its members pay for the energy procurement related to the operations of the State Water Project (SWP), which is managed and maintained by CDWR. As part of SWP operations, CDWR typically procures energy through purchases on the CAISO market, power purchase agreements, and bilateral agreements. If a variable energy project’s commercial operation date is delayed, SWC member agencies would incur costs under the current flexible RA requirements. CDWR’s proposal recognizes that RA obligations should track deliverable capacity, and that delays outside the load-serving entity’s control should not create stranded or duplicative procurement costs.

SWC recognizes that CAISO is managing several resource-intensive initiatives, which has affected the timing of initiatives in the Demand and Distributed Energy Market Integration (DDEMI) work. SWC supports CAISO staff’s suggestion at the October 1 stakeholder meeting to potentially fold elements of the prior large load flexibility discussions into the new DDEMI Track 3. SWC requests that the final roadmap identify which load flexibility elements might be incorporated, how prior stakeholder input will be carried forward, and the resulting timeline.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

SWC has the capacity and resources to support continued development of the DDEMI Initiatives as well as the Resource Adequacy Modeling and Program Design Track 2, Track 4, and wherever CAISO staff believe the Phantom RA obligations should be addressed. 

3. Does your organization have any feedback about the market policy catalog and roadmap process?

SWC appreciates the evolution of the market policy catalog and roadmap process, as well as the creation of the infrastructure policy catalog and roadmap process. Given the ongoing evolution of both, SWC suggests that, in the future, the CAISO consider allowing stakeholders to submit initiatives for both the market policy and infrastructure processes through a single portal. Upon submittal, CAISO staff could review the initiatives and separate them into the appropriate process. After staff have sorted the initiatives, stakeholders could then provide feedback on the merits of each initiative and its placement in the appropriate process.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Sunrun votes in support of the policy initiative topics and the proposed schedules outlined in the Draft Market Policy Roadmap. Sunrun is the nation’s leading home solar and storage provider with over 1.2 million customers and over 266,000 home batteries installed. Sunrun is in partnership with Tesla and Everyday Electric and our companies have more than 4.66 GW of behind-the-meter assets available in California. Sunrun is an active participant in both the CEC’s Demand Side Grid Support program and the CPUC’s Emergency Load Reduction program and our aggregated fleet of batteries has consistently provided scalable virtual power plant solutions when called upon. In fact, on October 5 and 6 Sunrun dispatched a record-breaking 669 MW and 745 MW from our home batteries. 

Sunrun has been an active participant in the Demand and Distributed Energy Market Integration (DDEMI) initiative. We view Track 1 as a crucial step in integrating these resources with the CAISO markets and support the proposal to implement Track 1 in 2028. 

Sunrun highlights that improvements to the current Proxy Demand Response (PDR) have already been drafted in a staff proposal and would allow exports to be recognized under the existing PDR model if the aggregation itself is not a net exporter. These improvements can be made quickly and Sunrun urges CAISO to do so without waiting for resolution to the more complex aspects of DDEMI Track 1 such as transmission deliverability, metering requirements and device-level enrolment. All three of these issues are critical to resolve and Sunrun is committed to working with stakeholders and the CAISO to settle these complex issues. It would be most efficient to implement the already-slated PDR improvements in 2027 while the DDEMI Track 1 issues are being resolved.

Given the size of Sunrun’s resources, integrating them into the market as early as practicable will reduce costs and improve reliability for the entire market. Allowing exports more broadly will be an important step forward and Sunrun is supportive of the effort.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Sunrun votes in support and plans to continue to fully participate in the initiatives discussed above.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Support

Vitol Inc. appreciates the opportunity to comment on the Draft 2027–2029 Market Policy Roadmap and broadly supports its policy direction. The following observations and recommendations focus on the timing and scope of specific initiatives:

Advance comprehensive scarcity pricing

The Price Formation Enhancement – Comprehensive Scarcity Pricing & Market Power Mitigation initiative made limited progress in 2026 amid shifts in CAISO’s priorities, and the proposed 2027–2029 roadmap retains the prior roadmap’s approach while delaying the schedule by a year. To restore momentum, Vitol recommends advancing comprehensive pricing designs that allow energy prices to rise gradually as supply conditions tighten, such as the energy supply margin concept, with a target decision in Q4 2027. To meet this target, Vitol submits that CAISO should identify the remaining design questions and establish clear milestones for resolving them with stakeholders.

Include EDAM intertie bidding within EDAM Enhancements

Vitol recommends that CAISO include EDAM intertie bidding within the scope of the EDAM Enhancements initiative. Although the presentation excludes intertie bidding submissions from the roadmap, the initiative’s flexibility to address emerging issues provides a suitable framework for considering this functionality.

Enabling economic participation at the interties would improve risk management by allowing entities to express their willingness to buy or sell power at specified prices, while expanding the pool of price-sensitive resources available for least-cost dispatch. Unlike self-schedules, which do not convey that price sensitivity, economic bids would provide greater dispatch flexibility and help stabilize markets. Extending this functionality beyond CAISO’s external interties to interties across EDAM would also improve coordination along market seams. Vitol therefore recommends that the final roadmap explicitly include intertie bidding within the EDAM Enhancements initiative and establish a target date for beginning stakeholder discussions.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Support

As in years past, Vitol continues to have the resources, capacity, and expertise to participate in the relevant initiatives identified in the draft roadmap.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Voltus supports continued prioritization of the DDEMI Track 1 and 2 policy initaitives. In particular, the policy development around end-user exports in Track 1 to date present a straigthforward opportunity for stakeholders and ratepayers to benefit from low-cost resources rapidly providing additional capacty to the grid. For this reason it is important that Track 1 remains contained to its original scope. Voltus believes the ability for individual sites to get credit for net export will provide a material new market opportunity for many behind-the-meter resources, even if a Resource (aggregation of sites) cannot receive credit for net export. In short, it would appear Track 1 presents a low-hanging fruit opportunity to achieve meaningful impact. 

If Track 1 scope expands to include the larger topic of net export of Resources (aggregations of DERs), we are concerned that may derail progress that has been made to date. Policy discussion and development along these lines is important, but should be done in parallel so that incremental progress can be made. Refinement and implementation of the existing Track 1 proposal should significantly overlap and complement the policy development required to expand credit for net export to the Resource level, rather than be seen as mutually exclusive/zero-sum. 

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Voltus has resources to support the applicable policy initiatives (primarily DDEMI).

3. Does your organization have any feedback about the market policy catalog and roadmap process?

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

Please see attached comments.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

Please see attached comments.

3. Does your organization have any feedback about the market policy catalog and roadmap process?

Please see attached comments.

1. Please describe your organization’s support for the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional information that may be helpful in finalizing the selection of initiatives and initiative timing

Voting “support” indicates that your organization largely agrees with both the selection of market policy initiative topics and the proposed schedules for these initiatives. Voting “oppose” indicates that your organization largely opposes the selection of market policy initiatives topics and the proposed schedules for these initiatives

WPTF appreciates the opportunity to comment on the draft 2027–2029 market policy roadmap. We recognize that the CAISO must balance a substantial portfolio of initiatives and provide sufficient time for meaningful stakeholder engagement. Generally speaking we support the broader policy roadmap picture given that its mainly existing initiatives continuing to progress while holding space for EDAM enhancements. We also support including the CAISO initiated policy effort of Virtual Bidding in EDAM BAAs. However, WPTF recommends several changes to the proposed timing and scope to ensure that important market design improvements move forward in a timely manner. In particular, the final roadmap should establish realistic target schedules, prioritize implementation of storage default energy bid enhancements before summer 2027, address reevaluation of flexible resource adequacy requirements, advance comprehensive scarcity pricing, and include EDAM intertie bidding within the EDAM Enhancements initiative.

Establish realistic target schedules

WPTF recommends that the CAISO replace “no sooner than” dates with realistic targets for policy decisions and implementation. A date that only establishes the earliest possible action provides little indication of when stakeholders should actually expect an issue to be resolved. The roadmap should identify when the CAISO intends to complete the work, along with the major dependencies that could affect that schedule. WPTF recognizes that schedules may need to change as proposals develop, but believes those adjustments should be explained through regular updates rather than accommodated through open-ended timelines.

Implement storage default energy bid enhancements before summer 2027

WPTF recommends that the CAISO complete and implement the storage default energy bid (DEB) enhancements before summer 2027. The presentation identifies a Q1 2027 decision for uplift and DEBs, with implementation continuing through 2027. That schedule should be refined to provide a clear commitment to implementing the DEB changes before the summer operating period, when appropriate mitigation parameters are especially important to storage participation and market outcomes.

The uplift discussions should not delay this work. Although DEBs and uplift are being considered within the same topic group, WPTF does not believe that resolution of the broader uplift topic is necessary to implement the DEB enhancements. The CAISO should establish separate decision and implementation milestones where needed so that the DEB changes can proceed while stakeholders continue to work through uplift questions. This sequencing would also be consistent with the stakeholder preference identified in the presentation for finalizing storage and hybrid DEB enhancements before advancing uplift and state-of-charge management.

Expedite CRR Product Definition Changes

WPTF encourages the CAISO to expedite the CRR product definition changes – including the TOU definition and allowing storage as an eligible sink location such that they are in place for the 2028 CRR annual processes. While we understand that timing is reflected on the policy roadmap, these dates are now “no sooner than”. This is a prime example of why establishing a “no sooner than” date can be problematic. The CAISO and stakeholders have made meaningful progress on these topics and there is general consensus that these changes will help improve CRRs. We do not want these changes to be tied to and delayed because of the larger more contentious topics that are also included within this phase.

First determine whether Flex RA is still needed

WPTF supports the CAISO evaluating whether the flexible resource adequacy (Flex RA) framework remains necessary and the concern regarding phantom Flex RA within the Resource Adequacy Modeling and Program Design initiative. However, we recommend sequencing those two topics such that stakeholders first answer the threshold question of if Flex RA is still needed. Only if the CAISO determines that Flex RA remains necessary should if then proceed to address the phantom obligation issue raised by CDWR. This sequencing would avoid spending stakeholder and CAISO resources modifying requirements that may no longer be warranted.

Advance comprehensive scarcity pricing

WPTF remains concerned with continued delays in developing comprehensive scarcity pricing. The presentation indicates that the CAISO has removed the October governing body decision for Price Formation Enhancements and has not established a new decision date while it reassesses the sequencing of scarcity pricing and mitigation reforms. WPTF recommends that the final roadmap provide a concrete schedule for advancing scarcity pricing rather than leave this work subject to further deferral.

WPTF has raised the need for effective scarcity pricing over many years, and the need for appropriate price signals has become more pressing as the market expands and the resource mix changes. Prices should reflect the value of energy and reserves when supply is scarce and provide appropriate incentives for resources to be available and respond to market needs. The CAISO should identify the remaining design questions and establish milestones for resolving them with stakeholders.

Include EDAM intertie bidding within EDAM Enhancements

WPTF recommends that the CAISO include EDAM intertie bidding within the scope of the EDAM Enhancements initiative. The presentation lists the intertie bidding submissions as excluded from the roadmap, even as EDAM Enhancements remains available to address issues as needed. WPTF does not believe intertie bidding should remain a separate topic without an identified place or schedule in the policy process.

Allowing economic intertie bidding within EDAM could help address several known design concerns by providing additional opportunities for market participants to express their willingness to buy or sell energy and for the market to optimize those transactions. The appropriate design and any necessary safeguards should be evaluated through the stakeholder process. Including this work within EDAM Enhancements would allow the CAISO and stakeholders to consider those questions alongside related EDAM issues and assess how intertie bidding could contribute to more efficient market outcomes. WPTF recommends that the final roadmap expressly identify this scope and provide a target for beginning the discussion.

2. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2027-2029 market policy roadmap. Use the text box below to provide any additional context as needed.

Voting “support” indicates that your organization has the necessary resources to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap. Voting “oppose” indicates that your organization does not expect to be able to fully participate in relevant stakeholder initiatives within the timeline outlined in the draft market policy roadmap.

WPTF has the resources and capacity to participate in the relevant initiatives identified in the draft roadmap. WPTF represents several entities with a shared interest in competitive, fair, and efficient markets. Our CAISO Committee brings together a broad range of market participants to review proposals and develop feedback. Accordingly, while WPTF submits a single set of comments, those comments reflect a collaborative process that represents our membership.

Clear schedules and adequate time to review proposals are important to that process. WPTF recommends that the CAISO provide sufficient notice of meetings and comment deadlines, particularly when several related initiatives are moving forward concurrently. It would be extremely helpful if the CAISO were to post papers and presentations at least 2 business days in advance of any meeting. 

3. Does your organization have any feedback about the market policy catalog and roadmap process?