Comments on Catalog Submissions - 2025 Annual Policy Initiatives Catalog and Roadmap Development Process

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes

2. Submission title

Stakeholders can submit up to three entries.

EDAM Congestion Allocation Enhancements

3. Has this issue previously been submitted? If yes, please provide a reference.

No

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

The EDAM stakeholder process promised a pathway for firm transmission rights holders in EDAM Entities to continue to use their rights (via balanced self-schedules) to protect firm transmission rights (financially and from a priority perspective) and enable existing contracts to not be unduly disrupted. However, as EDAM has moved closer to implementation it has become clear that it will be difficult, or perhaps impossible, for firm transmission rights holders across an EDAM transmission system to obtain a reasonable hedge for congestion costs, which will undermine the value of those rights and the contracts which rely on them. While we recognize there may be limited methods that could address these concerns within the tariff of individual EDAM Entity participants, there are underlying issues with the CAISO EDAM market rules that are preventing the EDAM Entities from providing this intended protection in a more comprehensive way. The concern is that the current CAISO EDAM tariff allocates congestion to the EDAM Entity where the constraint occurred, which could result in some EDAM Entities not having sufficient congestion revenues to protect firm transmission customers that self-schedule across their system (seeking to use their rights in a manner similar to how they do today).   

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

The initiative should address the allocation of congestion rents in EDAM, with an initial focus on the distribution of congestion rents between EDAM Entities in a manner that can ensure EDAM Entities are able to protect firm transmission customers (as EDAM’s market design intended). 

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

There are a variety of negative outcomes that could occur if this issue is not addressed, including impacts to EDAM’s expansion opportunities.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

This issue must be addressed for EDAM to continue to be an attractive market option for participants in the West. Without enhancements to the current approach, current and future EDAM Entities may be dissuaded from EDAM participation and firm transmission customers may seek other methods to address their concerns and/or may cancel firm transmission contracts, leading to increased costs for transmission for the loads within EDAM BAAs. This must be addressed and implemented before EDAM goes-live, so this initiative should be fast tracked both in the stakeholder process and its implementation schedule.

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

Data on congestion revenue allocation between EDAM BAAs, and examples of how firm transmission customers will be protected, when accounting for how congestion revenues are allocated between EDAM BAAs will be critical to addressing this concern.

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Bonneville does not have suggestions for changes to the process at this time.

2. Submission title

Stakeholders can submit up to three entries.

 Settlements enhancements in the EIM.

3. Has this issue previously been submitted? If yes, please provide a reference.

Yes, this issue was submitted in the 2024 Policy roadmap process.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

This initiative is intended to address two settlements-related issues in the EIM:

1. Assess CAISO practices regarding resolving settlements issue or disputes. Consider allowing price adjustments more than 5 days after operating day.
2. Consider redefining the timelines for allowable resettlements due to market engine errors. For example, reconsider allowing 2 years worth of resettlements for a recently identified error when participants had no opportunity to review market participation and consider adjustments in response to settlements outcomes.
3. Review policies and practices regarding resolution of inappropriate outcomes in the market and settlement-related resolution of the financial outcomes. i.e. If an entity submitted an incorrect base ETSR that resulted in a charge and credit, but both entities agree that the ETSR submitted was wrong. CAISO could develop practices to move that money around as a settlement adjustment between the BAs without rerunning the market.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

The proposed initiative would address the three issues described above to improve market practices with regards to settlements.

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

These impacts could improve efficiency of market settlements outcomes for participants.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

There are not regulatory requirements for implementation dates. The consequences to not addressing this issue is continued errors or inefficiencies in the market settlement process.

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

Analysis of settlements outcomes and impacts of resettlements would likely be necessary. Specific data needs would be defined during initiative scoping.

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes

2. Submission title

Stakeholders can submit up to three entries.

 Transmission Access Charge (TAC) Structure Enhancement 

3. Has this issue previously been submitted? If yes, please provide a reference.

The TAC Structure Enhancement proposal was initiated by CAISO in 2016 and following a series of stakeholder meetings, CAISO published its draft final proposal in September 2018 but then the initiative was placed on hold.

The TAC Structure Enhancements initiative was included in the CAISO policy roadmap for the past several years and the California Department of Water Resources - State Water Projet (CDWR-SWP) provided comments in support of the proposal. 

https://stakeholdercenter.caiso.com/StakeholderInitiatives/Transmission-access-charge-structure-enhancements 

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

As CAISO stated in its Draft Final Proposal, the current volumetric-only approach to assess TAC may no longer best reflect the cost causation, utilization, and benefits of the existing transmission system due to significant changes in resource mix and usage patterns that have accompanied the evolution of the electric industry in California. 

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

CAISO proposed to modify the current volumetric-only billing determinant of TAC to better reflect customer usage and the cost causation and benefits of the transmission system. CAISO found that a hybrid approach - utilizing both peak demand and volumetric measurements of customer use to assess TAC charges - is preferable because the transmission system provides both energy and capacity functions, as well as other reliability benefits. A two-part hybrid approach would capture both peak demand and volumetric use and would better account for these functions. 

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

CDWR-SWP agrees that the hybrid billing determinant as proposed by CAISO is a substantial improvement over the current volumetric methodology.  The hybrid billing determinant would increase market efficiency since it’s more in line with cost causation principles.  Allocating part of transmission costs based on coincident peak demand is consistent with system planning and investment in the transmission system. 

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

CDWR-SWP has no comment at this time. 

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

CDWR-SWP has no comment at this time. 

9. Submission title

Real-Time Congestion Offset (RTCO) Enhancements 

10. Has this issue previously been submitted? If yes, please provide a reference.

Yes, the California Department of Water Resources – State Water Project (CDWR-SWP) submitted this issue in the 2024 Annual Policy Initiatives Catalog and Roadmap Process.

California ISO - Annual policy initiatives roadmap process - 2024

In the Appendix B: Final Dispositions, CAISO responded “This submission is specific to real-time congestion and therefore does not fall within the scope of the planned CRR initiative. Interested parties may resubmit this proposal to the 2025 catalog, if interested in additional review or reporting.”

https://stakeholdercenter.caiso.com/InitiativeDocuments/Appendix-B-2024-Final-Dispositions.xlsx

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

The RTCO charges normalized by Load Serving Entities’ (LSE) loads have increased steadily over the years with some years having a significant rate of increase compared to the prior year.  For example, for CDWR, there was a significant increase, that amounted to 36.67%, in the RTCO charges observed in 2021 (compared with the year 2020) and to 45.55% in the year 2022 (compared with the year 2021 values). CDWR-SWP has observed that the magnitude of RTCO charges have been rising significantly irrespective of load growth resulting in a significant cost to CDWR-SWP.

The chart shown below illustrates RTCO charge increasing over time for CAISO load: 

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

While investigating the causes for such increases, CDWR-SWP recommends CAISO initiate a new stakeholder process to discuss what can be done to transform the current RTCO into a true neutrality charge code that reverses to each market participant, the respective market participant’s Hour Ahead (HA) and Real Time (RT) congestion rents. 

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

CDWR-SWP believes that the main objective of the RTCO settlement mechanism is to reverse the HA and RT congestion rents collected from a market participant.  However, the RTCO charge code does not provide the CAISO stated neutrality by including additional and much larger charges than the reverse of the HA and RT congestion rents collected from the market participants.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

CDWR-SWP observes that not addressing this issue has incurred higher RTCO charges over time for impacted LSEs, and believes postponing the issue will continue to increase charges to LSEs.

Further investigations by CAISO will improve discussions on past market impacts and potential severity increases that will further unbalance markets in the future. 

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

Existing data:

•  RTCO data from 2009 – 2024. 

Missing data:

• Reasons for spikes in the RTCO observed in 2021 and 2022 and increasing magnitude of RTCO costs until 2024. 
• Granular breakdown of the Charge Code 6774. 
• Models of future market impacts. 

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes

2. Submission title

Stakeholders can submit up to three entries.

EDAM Congestion Allocation Revisions

3. Has this issue previously been submitted? If yes, please provide a reference.

Not to our knowledge

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Many parties have identified an issue that frustrates the ability of firm transmission users inside a host EDAM Entity BAA to obtain a reasonable hedge for congestion costs.  The fundamental concern rests with an EDAM market rule regarding the allocation of congestion rents.  The current rule allocates the rents the EDAM Entity where the constraint exists – which can be different than the host EDAM Entity.  This can result in CAISO allocations of congestion rents to host EDAM Entity BAAs that are insufficient to reimburse firm transmission holders for the full cost of congestion. 

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

The allocation of congestion rents in EDAM. 

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The inability to fully hedge congestion undermines the value of firm transmission, decreases the incentive to contract for firm transmission, and reduces the interest in funding new transmission. For those EDAM entities that allow an alternative – so called opt-out – provision, less transmission will be made available to the optimization, decreasing the expected benefits of regionalization.    

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

Harm to firm transmission rights holders will begin immediately with implementation of EDAM for those EDAM Entities that do not allow transmission opt-outs. 

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

No comment

9. Submission title

No comment

10. Has this issue previously been submitted? If yes, please provide a reference.

No comment

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

No comment

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

No comment

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

No comment

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No comment

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

No comment

17. Submission title

No comment

18. Has this issue previously been submitted? If yes, please provide a reference.

No comment

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

No comment

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

No comment

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

No comment

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No comment

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

No comment

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

The California Energy Storage Alliance (CESA) appreciates the opportunity to comment on the 2025 discretionary initiative catalog and roadmap process.  CESA stresses that CAISO must maintain its existing prioritization of the Storage Design and Modeling initiative.  The Storage Design and Modeling initiative should remain a focus area of the 2025 roadmap.  In addition, CESA requests the CAISO identify policy intiatives it plans to commence in 2027 and 2028.  The 2024 Roadmap provided an insufficient outlook of planned policy initiatives as it only identified policy initiatives that were ongoing or starting in 2025.  Lastly, CESA has resubmitted Long-Duration Energy Storage as a Transmission Asset to be considered  as a standalone initiative or scope item in an initiative addressing changes to the transmission planning process.

2. Submission title

Stakeholders can submit up to three entries.

Long-Duration Energy Storage as a Transmission Asset  

3. Has this issue previously been submitted? If yes, please provide a reference.

Yes.  This initiative was submitted in 2024.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

CAISO currently has rules for storage resources to address short-term contingencies which would have triggered reliability upgrades in the transmission plan.  This initiative would review the ability of long-duration energy storage to address reliability, economic, and policy driven transmission upgrades.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

Under current storage as a transmission asset rules, the storage resource can recover its costs through the transmission access charge and is prohibited from participating in the CAISO energy market.  Long-duration energy storage could expand the transmission system but may need the ability to recover additional revenues through the wholesale energy market.   

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The lead time for developing transmission projects is significantly greater than storage resource development.  Expanding transmission capability as soon as possible is needed to meet California’s preferred resource portfolio and emissions reduction goals.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

The lead time for developing transmission projects is significantly greater than storage resource development.  Expanding transmission capability as soon as possible is needed to meet California’s preferred resource portfolio and emissions reduction goals.

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

None

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes

2. Submission title

Stakeholders can submit up to three entries.

Revisions to EDAM Congestion Revenue Allocation

3. Has this issue previously been submitted? If yes, please provide a reference.

 Not that we are aware of

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Firm transmission customers on an EDAM Entity BAA are exposed to congestion-related price spreads and the current EDAM tariff allocates congestion revenues to EDAM Entity BAAs based on the location of where constraints exist, even though constraints can have price impacts on other systems than the one in which they occur. This results in the underfunding of the revenues available for sub-allocation from an EDAM Entity BAA to its firm transmission customers. Firm transmission customers of an EDAM Entity BAA have no mechanism to hedge their full exposure to congestion-driven price spreads.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

 Allocation of EDAM Congestion Revenues

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The current absence of an ability to fully hedge against congestion risk reduces the value of contracting for firm transmission which in turn reduces the incentives to fund new transmission. A near-term solution of allowing greater transmission opt-outs (“ETC/TOR treatment”) overcomes the immediate hedging concerns but at the cost of making less transmission available to the EDAM for optimization, which reduces the expected benefits of participating in the market.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No regulatory requirements, implementation dates, or time-sensitive reliability impacts that we are aware of. However, economic consequences will begin immediately with initiation of the EDAM for transmission customers on EDAM Entity BAAs that do not allow generous access to “ETC/TOR treatment”  

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

DMM quarterly reports on EIM performance may provide indicative data, however important differences likely exist between EIM and EDAM performance.

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

No, NextEra Energy Resources, LLC (NEER) appreciates the California ISO’s efforts to create this mechanism that allows stakeholders to submit proposals where no other such mechanism exists.

2. Submission title

Stakeholders can submit up to three entries.

Standalone Uplift Payment for Uneconomic Dispatch of BESS Resources

3. Has this issue previously been submitted? If yes, please provide a reference.

Unknown. There is currently a discussion underway in CAISO’s Storage Modeling and Design Initiative to reconsider Bid Cost Recovery for storage resources, but those discussions seek to modify existing rules, whereas this submission seeks to introduce an entirely new concept to “make whole” storage resources that are dispatched uneconomically.

REV Renewables also introduced a similar concept in CAISO’s Price Formation Enhancements, Track 1 initiative in 2022 but that concept does not appear to have been workshopped further.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

CAISO’s multi-interval optimization (MIO) can dispatch resources uneconomically or out of merit (relative to their submitted energy offer curves) based on advisory prices for future intervals within the MIO’s one-hour lookahead. For example, a storage resource can be dispatched to charge during intervals when the cost to charge is more than the resource is willing to pay.  On the opposite end, a resource might be dispatched to generate during intervals that pay less than the resource is willing to take based on its energy offer curve. To the extent CAISO’s advisory prices for future intervals prove accurate when those intervals become binding, MIO benefits storage resources by better positioning them to capture opportunities to discharge during high advisory prices or to charge during low advisory prices. However, to the extent CAISO’s advisory prices for future intervals do not materialize when those intervals become binding, those opportunities disappear, and the storage resource is left paying unnecessarily more to charge or being paid unnecessarily less for discharging energy (compared to its submitted energy offer curves).

While the resource remains obligated under the Tariff to follow CAISO’s out-of-merit dispatch to meet the needs of the grid, it should be no worse off for responding to these needs to its own financial detriment. NEER would like CAISO to explore a new uplift mechanism for BESS resources that are dispatched uneconomically by MIO. 

NEER believes that CAISO’s existing vehicle for uplift payments, Bid Cost Recovery (BCR), falls short in addressing sub-optimal out-of-market dispatch because it only awards BCR to resources that realize a net loss in a given market for the trade date. This means BCR offers no relief to a storage resource whose profits for the day are positive yet reduced due to sub-optimal dispatches by MIO that have adverse financial consequences for the resource owner.  Put simply, BCR is a blunt tool that does not adequately accommodate the unique opportunity costs of energy storage.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

NEER proposes that CAISO consider offering a separate uplift payment for BESS resources that considers the unique characteristics of these resources and makes them whole for uneconomic/out-of-merit dispatch that result in adverse financial consequences for the resources.

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The current BCR process does not “make whole” BESS resources that follow out-of-merit dispatch to their financial detriment unless the resources experience a net loss over an entire day, which is not a “make whole” payment, it is a “make positive” payment. This creates consequences for BESS resources that must bear the negative financial consequences of uneconomic out-of-merit dispatch which is inefficient. Since MIO uneconomically dispatches storage resources in part based on the anticipated spread in advisory prices compared to the implied spread between the charging and discharging portions of the storage resource’s energy offer curve, the current paradigm may also incent storage resources to alter their bid curves in an attempt to avoid persistently sub-optimal MIO dispatches, which is similarly inefficient.

Notably, NEER’s proposed solution is more efficient than previous proposals to allow resources to opt out of MIO or to eliminate MIO altogether because the full supply stack of storage resources will still be available to the market.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No known regulatory requirements for implementation deadlines or reliability impacts.

See above issue description for consequences to not addressing this issue. Essentially, this request addresses the negative financial impacts of uneconomic dispatch for storage operators.  

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

CAISO may need to develop a counter-factual process to identify the differential between the cumulative revenues a storage resource actually received and those it would have received if it had been dispatched strictly according to its submitted energy offer curves in a given market for a given trade date. NEER suggests that CAISO’s recently-developed process for making storage resources whole to the negative financial impacts of Exceptional Dispatch (Tariff § 11.5.6.1.2) - also via a separate charge code outside of the current BCR framework – could serve as a template.

9. Submission title

Remove VER “must-follow flag” for co-located BESS providing ancillary services

10. Has this issue previously been submitted? If yes, please provide a reference.

Unknown. In CAISO’s Energy Storage Enhancements, Track 2 initiative, the CAISO modified its rules to allow the co-located storage to deviate from dispatch instructions but did not extend that rule change to solar nor did it offer explanation as to why similar treatment is not appropriate for solar. It appears to NEER that deviations in solar output relative to its dispatch operating target are analogous to the deviations on the charging side of a storage resource allowed by CAISO’s Energy Storage Enhancements, Track 2 initiative.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Current rules requiring co-located Variable Energy Resources (VERs) to follow dispatch operating targets strongly and unnecessarily discourage BESS from participating in the ancillary services markets.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

When a VER and a storage resource co-locate behind the same Aggregate Capability Constraint (ACC) and provide only energy, the VER is effectively allowed to freely generate: while the VER is nominally expected to follow dispatch, the dispatch signal it receives from CAISO is simply an echo of its own forecasted output and it is allowed to deviate from this forecast in real-time.  However, Market Operations BPM § 2.1.22 provides that when any resource behind a standalone or sub-ACC receives an ancillary service award, the VER must instead follow a dispatch calculated by CAISO and may no longer freely generate.

When the both co-located resources have the same off-taker, this rule strongly discourages the co-located storage resource from providing ancillary services to the extent that the forgone energy revenues associated with “curtailed” VER generation (i.e., reduced VER generation compared to if the VER was allowed to generate as available) are expected to outweigh the incremental revenues from the storage resource providing ancillary services. When the co-located resources have different off-takers, this can pose an undue coordination burden on resource operators to the extent the storage operator’s decision to provide ancillary services triggers the “must-follow flag” and negatively impacts the VER operator’s energy revenues.

This initiative would explore alternatives that would allow co-located VERs to generate freely when other co-located resources receive ancillary service awards. 

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

This initiative would explore a barrier that currently discourages co-located batteries from participating in the CAISO’s ancillary services market.  Making this change would provide additional ancillary service capacity to CAISO and a market opportunity for resources.  

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No known regulatory requirements or time-sensitive reliability impacts. The consequences of not addressing this issue include an artificial barrier to market participation for co-located resources capable of providing ancillary services.

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

CAISO has previously discussed the potential for frequency interference between VERs and storage resources providing Regulation behind a shared ACC but has not provided enough detail to justify the effective exclusion of these resources from the ancillary services market.  

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes

2. Submission title

Stakeholders can submit up to three entries.

EDAM Congestion Allocation Revisions

3. Has this issue previously been submitted? If yes, please provide a reference.

 Not to our knowledge.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Many parties have identified an issue that frustrates the ability of firm transmission users inside a host EDAM Entity BAA to obtain a reasonable hedge for congestion costs.  The fundamental concern rests with an EDAM market rule regarding the allocation of congestion rents.  The current rule allocates the rents the EDAM Entity where the constraint exists – which can be different than the host EDAM Entity.  This can result in CAISO allocations of congestion rents to host EDAM Entity BAAs that are insufficient to reimburse firm transmission holders for the full cost of congestion.  

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

The allocation of congestion rents in EDAM. 

NIPPC also recommends using this initiative to pilot stakeholder reforms proposed through the West-Wide Governance Pathways Initiative Launch Committee’s Step 2 Final Proposal, in coordination with the Regional Issues Forum. This would signal a welcome further commitment by the ISO to greater stakeholder involvement in generating and shaping market design solutions, as well as an openness to adaptively address challenges in market design and implementation as they arise.

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The inability to fully hedge congestion undermines the value of firm transmission, decreases the incentive to contract for firm transmission, and reduces the interest in funding new transmission. For those EDAM entities that allow an alternative – so called opt-out – provision, less transmission will be made available to the optimization, decreasing the expected benefits of regionalization.    

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

Harm to firm transmission rights holders will begin immediately with implementation of EDAM for those EDAM Entities that do not allow transmission opt-outs.  

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

No Comment

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Yes. PacifiCorp submits a proposal for the CAISO to create an initiative evaluating the Flexible Ramping Product (FRP).

2. Submission title

Stakeholders can submit up to three entries.

Flexible Ramping Product Enhancements. 

3. Has this issue previously been submitted? If yes, please provide a reference.

No.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

As part of this initiative, PacifiCorp asks the following questions to evaluate whether FRP is working as intended. 

1. Is the flex requirement on WEIM entities reasonable?
   1. What is the quantity of flexible capacity procured in real-time actually dispatched?
   2. Is the flex capacity requirement calculation accurately forecasting flexibility needs? 
2. Is FRP ‘deliverable’ when and where it is needed in the WEIM?
   1. Is FRP deliverable between regions? For example, is FRP that is procured in the Northwest able to be dispatched for flexibility needs in the CAISO, Intermountain West, and Southwest? 
   2. Is FRP awarded to resources with high real-time bids? Does this impact the dispatchability of FRP due to economics? 
3. How well does the FRP demand curve perform?
   1. When prices for FRP get too high, the market procures less FRP. Is the demand curve too restrictive where it will thereby cause a shortage of flexible capacity in constrained areas? 
4. How does FRP interact with the Imbalance Reserve Product Up? 

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

Flexible Ramping Product Enhancements 
This initiative will examine how FRP is functioning within the market by analyzing price impacts, the demand curve, and its interaction with the imbalance reserve product which will be live in Spring 2026. 

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

Ideally, the initiative would improve the market efficiency of the Flexible Ramping Product, leaving the system with enough flexible capacity where and when it is needed. The insights gained from this initiative may also improve system reliability due to having the right amount of flexible capacity available in areas needed. 

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

This initiative is non-urgent since there are no regulatory requirements or immediate reliability concerns. 

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

In a previous meeting, data on FRP utilization was presented. PacifiCorp believes a similar analysis could be applied to this initiative. Additionally, PacifiCorp suggests that analyzing FRP performance during stressed system events would help stakeholders better understand if FRP is providing the necessary flexibility when it is most needed.

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Portland General Electric (“PGE”) does not have suggested changes for the 2025 discretionary initiative catalog. PGE is engaging closely in various CAISO working groups, including storage design and modeling, gas management, CRR enhancements, GHG coordination, and DR/DER integration.

2. Submission title

Stakeholders can submit up to three entries.

N/A

3. Has this issue previously been submitted? If yes, please provide a reference.

N/A

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

N/A

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

N/A

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

N/A

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

N/A

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

N/A

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

No.

2. Submission title

Stakeholders can submit up to three entries.

Revisions to EDAM Congestion Revenue Allocation.

3. Has this issue previously been submitted? If yes, please provide a reference.

No.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Firm transmission customers on an EDAM Entity BAA are exposed to congestion-related price spreads, and the current EDAM tariff allocates congestion revenues to EDAM Entity BAAs based on the location of where constraints exist, even though constraints can have price impacts on other systems than the one in which they occur.

This results in the underfunding of the revenues available for sub-allocation from an EDAM Entity BAA to its firm transmission customers. Firm transmission customers of an EDAM Entity BAA have no mechanism to hedge their full exposure to congestion-driven price spreads.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

See previous.

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

The current inability to fully hedge against congestion risk reduces the value of contracting for firm transmission, which in turn reduces the incentives to fund new transmission. A near-term solution of allowing greater transmission opt-outs overcomes the immediate hedging concerns, but at the cost of making less transmission available to the EDAM market for optimization, which reduces the expected benefits of participating in the market.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

To our knowledge, there are no regulatory or reliability impacts. But we expect economic consequences will begin immediately upon the initiation of EDAM.

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

DMM reports on EIM performance, to the extent that this data can be extrapolated to EDAM performance.

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

Not at this time

2. Submission title

Stakeholders can submit up to three entries.

Economic Intertie bidding under the Extended Day-Ahead Market (E-DAM)

3. Has this issue previously been submitted? If yes, please provide a reference.

Yes. WPTF submitted this improvement in the 2024 process as part of the its E-DAM enhancements.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Today, CAISO EDAM tariff grants EDAM Entities with the flexibility, but not the obligation, to permit economic bidding at the interties between EDAM Balancing Area Authorities (BAAs) and a non-EDAM BAAs. We understand E-DAM entities may want to stand up the new market prior to enabling this functionality, however we submit its review should start within the first six months after E-DAM operations commence.

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

The proposal is limited to enabling economic bidding between EDAM BAAs and a non-EDAM BAAs.  CAISO has experience with economic intertie bidding and this would be a matter of extending the same functionality to the other BAAs participating in E-DAM.

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

Price sensitive bidding is stabilizing to markets whereas self-schedules impede risk management by not permitting an entity to reflect its willingness to buy or sell power at a specified price.  Moreover, enabling intertie bidding across the E-DAM would help improve coordination along market seams, as today this market functionality is only operating at the CAISO external interties.

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

 Not at this time

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

Not aware of any

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

N/A

2. Submission title

Stakeholders can submit up to three entries.

WATT Coalition Recommendation for 2025 CAISO Annual Policy Initiatives Roadmap Process

3. Has this issue previously been submitted? If yes, please provide a reference.

No.

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Thank you for the opportunity to recommend policy initiatives for the next three-year initiatives cycle. The WATT Coalition recommends that CAISO establish a framework to integrate Grid-Enhancing Technologies (GETs) into the Transmission Planning Process (TPP) and transmission operations. GETs should be considered to:

1. reduce congestion, low-cost generator curtailment and risk of load shed by cost-effectively increasing transmission capacity;
2. mitigate constraints while traditional upgrades are planned and constructed, including reducing the impacts of outages that are part of some construction stages;
3. enhance traditional transmission upgrades to proactively increase transmission capacity and flexibility for future needs;
4. serve as alternatives to traditional transmission upgrades in transmission planning or interconnection processes.

Incorporating GETs into transmission planning and operations will help CAISO and California’s utilities cost-effectively meet electricity demand, achieve clean energy goals, and improve grid reliability. This may be considered a non-discretionary policy initiative given that FERC Order No. 1920 requires GETs in transmission planning, and FERC Order No. 881 requires the CAISO to accept Dynamic Line Ratings in operations.

About Grid Enhancing Technologies

Grid Enhancing Technologies, or GETs, are hardware and software that increase the capacity, efficiency and/or safety of the transmission system. These technologies are installed on existing transmission infrastructure to give operators more situational awareness and control over the grid.

Power flow control technologies actively balance the flow on transmission lines. The hardware can intelligently raise or lower the impedance, or the opposition to current, in real time to ensure that power is delivered on lines that have the capacity to carry it. Advanced power flow control (APFC) expands on this function with enhancements such as faster and more flexible deployment options, easy scaling to meet the size of the need, and ability to relocate when needed elsewhere on the grid.

Dynamic Line Rating (DLR) monitors ambient conditions which heat or cool transmission lines to calculate the true capacity of transmission lines, based on their thermal limits. In windy regions where transmission capacity is critical for wind power development, DLR often allows significantly more power flow than a static rating over the course of the year but also detects when flows should be reduced to continue safe and reliable operation in extreme heat or other conditions.

Transmission topology optimization (TTO) software models the grid's network and power flow conditions to identify ways to reroute power flow around congested or overloaded transmission elements. These "reconfigurations" are implemented by switching on or off existing high-voltage circuit breakers. By more evenly distributing flow over the network, topology control increases the transfer capacity of the grid.

About the WATT Coalition

The WATT Coalition advocates for policy that supports the wide deployment of GETs to accelerate the clean energy transition, lower energy costs and enable economic growth. Learn more at watt-transmission.org. WATT’s membership includes DLR, APFC and TTO vendors, as well as independent power producers, clean energy investors and utilities.

Issue description

CAISO’s 2024 TPP identified several uses of APFC through utility-proposed reliability projects. It is the WATT Coalition’s view that the enactment of Senate Bill 1006 last year[1] requires utilities to systematically evaluate the deployment of GETs. The law requires GETs to be evaluated to:

(A) Increase transmission capacity.

(B) Reduce transmission system congestion.

(C) Reduce curtailment of renewable and zero-carbon resources.

(D) Increase reliability.

(E) Reduce the risk of igniting wildfire, by means of investments that are consistent with the transmission utility’s approved wildfire mitigation plan.

(F) Increase capacity to connect new renewable energy and zero-carbon resources.

(G) Increase flexibility to reduce risks surrounding technology and permitting uncertainties in statewide electrical system planning and improve optionality for load-serving entities.

Because CAISO leads the evaluation of economic transmission projects for the state, it would be most efficient for CAISO to evaluate GETs on behalf of the utilities for benefits B and C, at least. By establishing a framework for GETs evaluation in CAISO’s economic planning, CAISO could support utilities in their implementation of SB1006 with best practices. CAISO is also required by FERC Order No. 881 to upgrade its transmission operations capabilities to accept DLR, and by Order No. 2023 to consider some GETs in generator interconnection, and by Order No. 1920 to include GETs in transmission planning. By prioritizing these capabilities this year, CAISO can lead the nation in the use of these efficient and cost-saving solutions.

GETs should also be considered by utilities in reliability planning as a complement to planned transmission to get more value out of new investments and to act as a bridge solution, meeting some of an identified grid need until more costly and time-intensive transmission investments are built. WATT believes that as GETs are utilized in these contexts, utilities will build experience with the technologies to the point that they will find deployments that would otherwise have required a traditional upgrade. Once GETs are tools in the toolbox, they will help utilities meet multiple challenges faster and more cost-effectively, including load growth, decarbonization goals and reliability.

GETs have been shown to have a payback period of as little as six months[2] by unlocking grid capacity for new generation. Recognizing that load growth projections in California have grown significantly, GETs can act as least-regrets solutions that can be deployed in the near term to support evolving grid needs.

We commend a report by Electric Power Engineers: Assessment and Evaluation of Grid Enhancing Technologies (GETs), that describes the value of integrating GETs into transmission planning and elements of the integration. We also commend EPRI’s white papers on each technology for additional description of the benefits and applications of GETs, available on their GET SET website[3].

[1] California Senate Bill 1006, An act to add Section 454.58 to the Public Utilities Code, relating to electricity, 2023-2024 Regular Session, signed into law September 25, 2024,  https://legiscan.com/CA/text/SB1006/id/3022638  

[2] The Brattle Group, Unlocking the Queue with Grid-Enhancing Technologies, February 2021, https://watt-transmission.org/wp-content/uploads/2021/02/Brattle__Unlocking-the-Queue-with-Grid-Enhancing-Technologies__Final-Report_Public-Version.pdf90.pdf (“Unlocking the Queue”)

[3] EPRI, “GET SET: Grid Enhancing Technologies for a Smart Energy Transition,” accessed February 24, 2025, https://interactive.epri.com/get-set/p/1

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

We recommend that going forward, DLR, APFC and TTO be modeled within CAISO’s economic planning as a solution to all or part of each identified need, and as complementary solutions to traditional upgrades. For example, GETs have proven effective in mitigating congestion – most notably by utility PPL, saving $66 million in congestion[1] in just one season – so deploying GETs in the interim while larger transmission investments are built can be a cost-effective option. Further, GETs can help integrate new load and generation that otherwise may not be able to interconnect due to transmission constraints. In PJM, for instance, RMI and Quanta found that GETs could enable the interconnection of 6 GW of new renewable generation by 2027, saving over $500 million in interconnection costs as GETs are cheaper than traditional line upgrades.[2] The ISO will also need to update their transmission operations practices to fully utilize GETs once they are installed on the grid.

[1] PPL Electric Utilities Corporation, Motion to Leave for Comment and First Supplemental Comments of PPL Electric Utilities Corporation, Docket No. AD22-5 (filed February, 2024), https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20240209-5161

[2] RMI, GETting Interconnected in PJM, February 2024, https://rmi.org/insight/analyzing-gets-as-a-tool-for-increasing-interconnection-throughput-from-pjms-queue?submitted=1#thank-you

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

GETs can often resolve 40% or more of transmission congestion by unlocking additional grid capacity[1]. With grid congestion exceeding $1 billion in 2023[2], CAISO could likely reduce wholesale power costs by around $600 million by identifying opportunities to deploy GETs. Further, deployment of GETs can add capacity to the grid, allowing load customers and generation projects to interconnect faster than they would otherwise be able, providing economic benefits to the state and allowing it to advance its clean energy goals. At the system level, GETs can double the capacity for new generation on existing infrastructure, per a study of the Kansas and Oklahoma systems and interconnection queues.[3]

[1] The Brattle Group, Building a Better Grid: How Grid-Enhancing Technologies Complement Transmission Buildouts, April 2023, https://watt-transmission.org/wp-content/uploads/2023/04/Building-a-Better-Grid-How-Grid-Enhancing-Technologies-Complement-Transmission-Buildouts.pdf

[2] Grid Strategies LLC, 2023 Transmission Congestion Report, September 2024, https://gridstrategiesllc.com/wp-content/uploads/Grid-Strategies_2023-Transmission-Congestion-Report.pdf

[3] Unlocking the Queue

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

SB 1006, approved in 2024, requires that transmission utilities in California prepare GETs studies by January 1, 2026 and every two years thereafter. We recommend that CAISO prioritize integrating GETs modeling capabilities, given the January 1, 2026 implementation requirement for SB1006 - ideally, in the 2026 TPP.

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

NREL has demonstrated that benefits of DLR can be rapidly estimated with existing datasets. We recommend that CAISO follow this model to identify candidate lines for DLR deployment. AES Corporation has also developed a replicable method, published at the 2024 IEEE Power & Energy Society General Meeting (PESGM): Time Series Power Flow and Contingency Analysis with Weather Adjusted Line Ratings: A Synthetic WECC Case Study.

Smart Wires Inc. offers software packages to evaluate APFC solutions. www.smartwires.com

NewGrid, Inc. provides transmission topology optimization software and services to efficiently identify beneficial transmission reconfiguration. www.newgrid.com

Conclusion

We thank you again for the opportunity to submit this policy initiative and look forward to further engaging in the next steps. Please do not hesitate to reach out to the WATT Coalition with any comments or questions.

Julia Selker

Executive Director

WATT Coalition

jselker@gridstrategiesllc.com

541-908-5792

9. Submission title

10. Has this issue previously been submitted? If yes, please provide a reference.

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

17. Submission title

18. Has this issue previously been submitted? If yes, please provide a reference.

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

1. Do you have any suggestions for changes to the 2025 discretionary initiative catalog and roadmap process?

No comment.

2. Submission title

Stakeholders can submit up to three entries.

On-going Transparency Effort

3. Has this issue previously been submitted? If yes, please provide a reference.

Yes. WPTF submitted the same policy suggestion in the 2024 Roadmap Process but based on CAISO’s response as to why it was not included indicates it was not clear what the purpose of this effort would be. Thus, we are re-submitting. 

4. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

Transparency is key for a well-functioning competitive market. Throughout stakeholder meetings and various market performance forum discussions there are items/topics where market participants ask for more information and data in the spirit of added transparency.   

5. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

This effort would be an on-going/reoccurring effort that would provide a venue for market participants to make formal requests for added transparency. The requests could range from more documentation on specific market elements or rules to data requests. We envision there would be a process for submissions to be made throughout the year, discussed openly with CAISO staff and stakeholders, and ultimately a resolution is determined and made public – very similar to the PRR process.

For example, there have been recent requests for additional data and information regarding the following. All of these could be considered within the proposed policy process as initial asks:

1. Documentation and examples on how the AGC algorithm determines which resources to use for regulation
2. Data on regulation deployment at a more granular level than provided by the attenuation factors
3. Full hourly load distribution factors
4. Shift factors for DA binding constraints
5. Data on outage modeling in the DAM (similar to what is provided in ERCOT)

6. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

Added transparency increases market efficiency.  

7. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

No regulatory requirements but provides a means and centralized venue for participants to make data and market transparency requests. It also helps ensure a response to all requests is provided in an open and public stakeholder process. 

8. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

None.

9. Submission title

Internal and External Market Seams Issues 

10. Has this issue previously been submitted? If yes, please provide a reference.

Yes, WPTF submitted this policy effort in the 2024 Roadmap Process but did not see a direct response to this submission. 

11. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

With the on-going efforts of EDAM and Markets+ we are looking at an environment where there are multiple markets operating in the west and interacting with the bilateral markets. This naturally will create seam issues between the markets and challenges when participants are having to interact with multiple markets.  

12. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

WPTF recommends the CAISO include in the policy catalog an effort that continually identifies and addresses both internal and external market seams issues that exist due to having multiple markets operating in the west and interacting with a bilateral market, rather than being under one RTO construct.

13. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

Having a transparent policy effort to identify and address the seams issues as they arise will result in a more efficient and transparent market not only for the CAISO but all the western markets. 

14. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

There is a sense of urgency as EDAM is only a year away from implementation. The faster this policy effort is set up the more effective it will be in addressing issues in an expedited and transparent manner.

15. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

None.

17. Submission title

Extended Day-ahead Market Enhancements

18. Has this issue previously been submitted? If yes, please provide a reference.

Yes, WPTF submitted this issue in the 2024 Policy Roadmap process but CAISO did not provide a direct response as to why it was not selected.  

19. Issue Description: Briefly provide a description of the market design issue that the proposed initiative is intended to address.

During the CAISO EDAM policy process, and already in the implementation efforts, there have been some policy questions raised about considering enhancements to the EDAM design. We recognize that the EDAM is already into implementation efforts but believe it’s worthwhile to have a policy process on the roadmap that can address any of the issues/questions as they arise.

20. Proposed Initiative Description: Discuss the scope of the proposed initiative. What specific elements of existing ISO market design does your initiative propose to address?

WPTF recommends the CAISO include in the policy catalog and the roadmap an effort to consider enhancements to the Extended Day-ahead Market design. This effort would include items that were identified during the original stakeholder process – such as participation at interties (scheduling and economic bidding rules), pancaking of charges, convergence bidding, and congestion revenue rights.  One of the first items that could be considered immediately is if there are any changes needed to address the congestion revenue allocation issue that has been raised recently. There should also be ample room within the scope to address issues that may not be known until experience is gained with the existing EDAM design or until we are futher along in the implementation and testing phase.

21. Market Impact: To the extent possible, discuss any anticipated impacts to market efficiency or system reliability.

Further the economic efficiencies and reliability of the EDAM market through further enhancements. 

22. Timing and Urgency: Are there regulatory requirements for implementation dates, or time-sensitive reliability impacts? Are there consequences to not addressing this issue?

None.

23. Data: Identify existing data and missing data needed to analyze the issue and develop solutions.

None.