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Please Provide your Organization's Comments on the Tariff Clarifications Spring 2025 Draft Tariff Language Changes
Six Cities’ Comments: The Six Cities appreciate the opportunity to provide comments on CAISO’s proposed Tariff Clarifications for Summer 2025 as described in the Tariff Clarifications Matrix posted on July 2 and modified on July 3, 2025. The Six Cities have no comments on sections from the matrix that are not addressed below.
Section 8.3.8 The proposed change appears to be a substantive tariff revision rather than a clarification, and the Six Cities request further explanation and support for deleting the criteria for selecting resources to provide Voltage Support. FERC’s order in Docket No. ER13-1274-000, 143 FERC ¶ 228 (2013),at ¶ 20, directed the CAISO to submit further information on potential development of a market-based process for procuring Voltage Support. The Six Cities are not aware whether or not the CAISO has submitted such an analysis. But without further analysis and support, the Six Cities do not agree with deletion of the least costly criterion for selection of resources to provide Voltage Support (subject to satisfaction locational requirements).
Section 40.2.2.4(c) The proposed revision to this section also appears to be a substantive modification rather than a simple clarification. In addition, the Section as revised seems unnecessarily complex. A more straightforward modification of the language would be:
c) The Scheduling Coordinator for a Load Serving Entity or CPE may submit at any time from 45 days through 30 days in advance of the relevant month, a revision to its monthly Resource Adequacy Plan to correct either: (i) a discrepancy between its monthly Resource Adequacy Plan and the monthly Supply Plan of a Resource Adequacy Resource providing that Load Serving Entity or CPE with Resource Adequacy Capacity, as provided in Section 40.7(b); or (ii) a deficiency in how much Resource Adequacy Capacity was provided on the monthly Resource Adequacy Plan. From 45 days through 30 days in advance of the relevant month, the Scheduling Coordinator for a Load Serving Entity or CPE also may revise its Resource Adequacy Plan voluntarily either to add additional Resource Adequacy Capacity or remove Resource Adequacy Capacity for any reasonregardless of a discrepancy or deficiency that existed as of 45 days in advance of the relevant month. The CAISO will not accept any revisions to a monthly Resource Adequacy Plan from 30 days in advance of the relevant month through the end of the month, unless the Scheduling Coordinator for the Load Serving Entity or CPE demonstrates good cause for the change and explains why it was not possible to submit the change earlier.
Section 40.4.7.1(c) The second sentence of the proposed addition to this section (allowing a Scheduling Coordinator for a Resource Adequacy Resource apparently unfettered discretion to remove Resource Adequacy Capacity from the Supply Plan between 45 and 30 days in advance of a month) raises the potential for discrepancies between Resource Adequacy Plans of LSEs or CPEs and Supply Plans. How and when would such a discrepancy be resolved?
Section 40.7(a) The proposed change to this section raises the same question noted by the Six Cities in the comment above regarding Section 40.4.7.1(c). If a change to an initial Supply Plan by the Scheduling Coordinator for a Resource Adequacy Resource creates a discrepancy between the Supply Plan and Resource Plans of one or more LSEs or CPEs, how and when would such a discrepancy be resolved?
