ACP-California
Submitted 05/14/2026, 07:07 pm
Submitted on behalf of
ACP-California
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
ACP-CA's top priorities for the Infrastructure roadmap in 2026 are the EDF Renewables Comprehensive Alignment Post-Order 1920 submission and the NextEra Streamlined Augmentation of Operational Batteries submission.
ACP-CA is a co-submitter of the Joint Parties MIC Enhancements proposal and also made our own presentation on MIC Enhancements at the April 8th stakeholder meeting. Addressing MIC Enhancements is a high priority to ACP-California. We understand that CAISO may ultimately pursue this initiative as part of the RA Modeling & Program Design initiative within the Market Policy roadmap, and would support its prioritization in whichever roadmap advances it most directly.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
1. high
ACP-CA strongly supports this submission. Given the projected volume of augmentation MMAs (each currently subject to processing timelines that can exceed 12 months), there may be a significant backlog that reduces the ability of operating BESS assets to meet their full RA obligations. NextEra's proposed notification-plus-technical-data-package framework, with its proposed guardrails (no POI increase, 100 Amp incremental short-circuit current limit, Appendix H compliance verification, and updated load-flow and dynamic models), appropriately balances administrative efficiency against reliability protection. This is a narrow, technically bounded reform that should advance promptly in 2026.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
2. medium
ACP-California supports refining opportunities for Energy Only Resources to seek deliverability and strongly supports including this topic in an upcoming stakeholder initiative. We also understand that CAISO will likely be opening an IPE 6.0 in the coming months and believe this topic may be well situated to be addressed as part of that broader initiative.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
1. high
ACP-CA is a co-submitter of the Joint Parties MIC Enhancements proposal and made our own presentation on the topic during the April stakeholder meeting. The current requirement that an RA contract used to lock in MIC be active in the next RA year is a direct barrier to the long-dated PPAs needed to support both CPUC PSP procurement and non-CPUC LSE long-term planning, and the combination of insufficient MIC on popular interties and unused MIC elsewhere indicates both methodology and trading mechanism enhancements are warranted.
As noted in our response to Question 1, ACP-CA supports advancing this work in whichever roadmap (Infrastructure or Market Policy) offers the most direct path to resolution.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
4. not a priority
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
3.low
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
3.low
ACP-CA agrees with several of the gaps SCP identifies, including the underutilization of existing grid capability and the opportunity to better recognize value from EO resources.
That said, the initiative as scoped is broader than ACP-CA would support at this time, and likely broader than what a CAISO stakeholder initiative can productively take on. These issues may be better addressed through the CPUC RA proceeding, and we encourage CAISO to consider whether parallel tracks could create timing or coordination challenges.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
2. medium
ACP-CA supports reinitiating policy exploration on storage as a transmission asset (SATA). However, we would advocate for this initiative to include all storage. We would further advocate that storage market participation for SATA resources (also known as “dual-use”) should be scoped into this initiative, rather than delayed to a later phase, as it may not be economically feasible to develop a use-limited storage resource to serve SATA functions exclusively, which may only provide revenue based on the value of a few hours per day. We note that dual-use participation was part of the SATA initiative opened in 2018 but suspended in 2019.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
1. high
ACP-CA supports this submission as a high priority for the 2026 infrastructure roadmap and encourages CAISO to expand the initiative scope to include related TPD transparency and process improvements:
- Publishing expected TPD by zone and POI from upgrades approved in each TPP
- A penalty-free queue withdrawal mechanism when zonal TPD materially changes due to project cancellation or other developments outside the interconnection customer's control
- More systematic evaluation of TPD availability by zone to identify chronically congested areas where interconnection requests are triggering disproportionate upgrade costs;
- Regular evaluation of whether TPPs are advancing upgrades in major corridors identified in the 20-year outlook as necessary to access important clean energy zones
These gaps in the post-IPE zonal and bus-bar mapping framework have become more pressing following the SDM cancellation and fit naturally within the cadence the EDF proposal anticipates.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
No additional feedback at this time.
Bay Area Municipal Transmission Group (BAMx)
Submitted 05/15/2026, 12:11 pm
Submitted on behalf of
City of Santa Clara dba Silicon Valley Power and City of Palo Alto Utilities
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
BAMx[1] thanks the CAISO for the effort spent to develop infrastructure policy priorities for 2026. We respectfully request that the CAISO prioritize the TAC Structure Enhancements draft final proposal that the ISO developed with broad stakeholder support during the 2016-2018 TAC Structure Review initiative. Adopting the ISO’s proposal from that initiative should not result in significant investment of CAISO or stakeholder resources because the proposal has already been developed with broad support.
The current volumetric-only TAC does not reflect cost causation tied to coincident peak demand. A hybrid TAC incorporating both volumetric and peak-demand components would better align transmission cost recovery with actual system usage and encourage demand flexibility. It would also bring the CAISO into alignment with standard practice at other RTOs and ISOs around the USA: ERCOT[2], ISO-NE[3], MISO[4], NYISO[5], PJM[6], and SPP[7] all have demand-based billing determinates as a component of their regional transmission access charges.
[1] BAMx consists of the City of Santa Clara dba Silicon Valley Power and City of Palo Alto Utilities
[2] https://www.ercot.com/mktinfo/data_agg/4cp
[3] https://www.iso-ne.com/static-assets/documents/100026/2025_06_nlcr_final.pdf
[4] https://docs.misoenergy.org/miso12-legalcontent/Schedule_09_-_Network_Integration_Transmission_Service.pdf
[5] https://nyisoviewer.etariff.biz/ViewerDocLibrary/MasterTariffs/9FullTariffNYISOOATT.pdf
[6] https://www.pjm.com/markets-and-operations/billing-settlements-and-credit/guide-to-billing
[7] https://www.spp.org/documents/75033/participant onboarding guide - transmission settlements.pdf
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
3. Low. The CAISO battery fleet is relatively young, with the bulk of capacity added in just the last two years. The proposal identifies a reasonable modification to the Material Modification Assessment (MMA) process for routine augmentations that maintain storage capacity at contracted levels, but the current battery fleet is young enough that augmentations won’t begin in earnest for several years. There is ample time to address this proposal in future years before the volume of augmentation MMAs increases substantially.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
2. Medium. Converting existing energy-only resources to deliverable status would expand the capacity available in the RA market and potentially reduce costs for RA procurement without substantial CAISO or stakeholder investment.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
1. High. LSEs in need of RA capacity credit for imports face significant challenges acquiring Maximum Import Capability for imported RA resources. The ability to secure MIC is essential for LSEs to contract for imported resources, making it difficult for LSEs to meet capacity needs and leading to and higher prices for California LSEs. Uncertainty around future MIC availability is a barrier to executing PPAs for out-of-state RA needs.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
1. High. See response to question 1.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
2. Low. Non-wires solutions, such as strategic placement of storage or flexible loads, can alleviate transmission constraints without the need for new transmission investment. Where feasible, the Transmission Planning Process could test the effectiveness of these non-wires solutions as an alternative to transmission investment. BAMx anticipates that such a formal testing framework would be a substantial undertaking for CAISO staff and could potentially be deferred to a year with fewer active policy initiatives.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
2. Low. It is true that the current deliverability and RA accreditation framework are summer-oriented, and CEC demand forecasts for the 2040s show a gradual shift to winter peaking conditions. However, this transition is far in the future and there is ample time to develop RA accreditation frameworks that better-recognize resource contributions during winter and shoulder seasons during years with fewer active policy initiatives.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
3. Low. This proposal fits within the SCP proposal for Robust Adaptability Testing in the CAISO Transmission planning process.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
4. Not a priority. Order 1920 alignment will proceed regardless of the stakeholder prioritization process.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Not at this time.
California Community Choice Association
Submitted 05/15/2026, 03:46 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
The California Community Choice Association (CalCCA) appreciates the opportunity to assist the California Independent System Operator (CAISO) with prioritizing infrastructure-related initiatives for exploration in 2026. CalCCA’s highest priorities are: (1) the Energy-Only (EO) to deliverability pathway; and (2) Maximum Import Capability (MIC) enhancements.
EO to deliverability - The CAISO should commit to exploring enhancements necessary to make EO resources fully deliverable when upgrades are required, particularly when projects have made commitments with load serving entities (LSE) or when projects are aligned with local regulatory authority policy needs. The California Public Utilities Commission (CPUC) has recently identified a 6,000 megawatt[1] reliability need between 2029-2032 and has ordered CPUC-jurisdictional LSEs to procure new resources to meet this reliability need.[2] Capacity eligible to satisfy the CPUC’s procurement order must be deliverable or paired with a deliverable resource. In addition, Resource Adequacy (RA) capacity has been scarce for the last few years. While recent builds have helped, load growth may account for all the recently built capacity, requiring more RA to be procured.
A viable approach to converting EO resources to deliverable resources could help expand and expedite opportunities for developers to finance and construct projects without a Transmission Plan Deliverability (TPD) allocation. Constructed and operational projects may be more viable than earlier- stage projects under development, may be able to provide deliverable capacity more quickly than earlier stage projects, and should be allowed to compete against other projects in the interconnection intake process and TPD allocation process to contribute to the state’s RA requirements.
Maximum Import Capacity (MIC) Enhancements - Within the RA Modeling and Program Design (RAMPD) initiative, the CAISO should conduct a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing MIC to support eligibility of import resources to provide RA capacity. The ability to bring new deliverable capacity online is paramount to supporting reliability and clean energy goals. As stated in the Joint Parties’ submittal, CPUC- and non-CPUC- jurisdictional LSEs are actively evaluating opportunities to contract with out-of-CAISO resources to support long-term planning efforts, but challenges with obtaining MIC when and where needed create barriers to long-term contracting and RA procurement.
While the Joint Parties[3] submitted this initiative in both the Market Design and Infrastructure catalog processes,[4] CalCCA strongly urges the CAISO to pursue MIC Enhancements as part of the RAMPD initiative, rather than under a separate infrastructure-related initiative. MIC policy and implementation are inextricably intertwined with RA policy and implementation, and the CAISO balancing authority area (BAA) has historically relied on imports to meet RA requirements. It is critical that consideration of enhancements to MIC determination and application be fully integrated with, informed by, and supportive of RA policy and objectives.
[1] The need is denominated in Net Qualifying Capacity and since the resources are likely to come from non-emitting resources, the amount of installed capacity will be significantly greater.
[2] Decision 26-02-057, Decision Requiring 2029-2032 Electric Resource Procurement and Transmitting Portfolios for 2026-2027 Transmission Planning Process, Rulemaking 25-06-019 (Feb. 26, 2026), at 2, https://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=601777006.
[3] The Joint Parties include: (1) ACP – California; (2) the Bay Area Municipal Transmission Group (BAMx), comprised of the City of Palo Alto Utilities and the City of Santa Clara, dba Silicon Valley Power; (3) CalCCA; (4) the California Municipal Utilities Association; (5) the Six Cities, comprised of the cites of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside California; (6) Shell Energy North America (US), L.P.; and (7) the Regents of the University of California (UC Regents).
[4] See the Joint Parties MIC Submittal (Mar. 2, 2026), https://stakeholdercenter.caiso.com/Comments/AllComments/488eeaed-a534-4241-bf4a-64959057ab88#org-b4a7376a-d17a-4ff6-823a-22a440b8eedc.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
Medium Priority – Streamlining the storage “augmentation” process as proposed by NextEra Energy Resources should be explored to ensure that storage resources can sustain capacity above contractual requirements as battery cells degrade over time.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
High priority – See response in section 1.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
High priority – See response in section 1.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
CalCCA has no comments at this time.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
High priority - The CAISO, in coordination with the CPUC, should reform its transmission planning tools and decision-making processes to be more robust under uncertain scenarios. System planning is becoming increasingly challenged by uncertain assumptions, given the emergence of new large loads like data centers, changes in federal policy, and new technology innovation. Proactive development of transmission capacity, and particularly lines that enable a diverse set of resources that satisfy grid needs under a range of scenarios, is the primary opportunity to improve robustness of California’s grid planning. The CAISO should therefore reform transmission planning tools and decision-making processes to account for uncertainty using robust optimization methods that result in a portfolio that is successful across a range of scenarios.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
CalCCA has no comments at this time.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
CalCCA does not oppose the exploration of long-duration energy storage (LDES) as a transmission asset. However, if the CAISO takes up this initiative, the CAISO should include market participation issues – including the treatment of market revenues and RA accreditation rules – in the scope of the initial phase of the initiative. While GreenGen suggests these issues could be considered in a later phase, these issues will have critical impacts on the cost-effectiveness and viability of this pathway for LDES resources.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
CalCCA has no comments at this time.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
CalCCA has no additional comments at this time.
California Department of Water Resources - State Water Project
Submitted 05/08/2026, 10:46 am
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Transmission Access Charge (TAC) Structure Enhancements
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
Level of priority: 1. High
CDWR Comment: CDWR-SWP believes that the TAC Structure Enhancements with a hybrid TAC design, as discussed during the April 8. 2026 stakeholder meeting, provides the following benefits for market participants:
- It is consistent with cost causation. CAISO’s existing TAC structure results in cost shifts among transmission customers
- Other ISOs use peak demand contribution to assess transmission charges
- Adding a temporal element to the TAC structure would send economic signals encouraging market participants to increasingly move load away from peak demand to reduce their transmission costs. Lowering peak demand would reduce the need for new transmission infrastructure development which would reduce cost to all
- System reliability would increase as reduced peak demand reduces the physical strain on current transmission facilities, leading to decreased maintenance and replacement of transmission facilities would reduce costs to all
- CAISO allocates its annual Local Capacity Requirement for each TAC area to LSEs based on their coincident peak load
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
CDWR-SWP does not have any additional feedback or suggestions at this time
Calpine Corporation
Submitted 05/15/2026, 04:38 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Transmission Access Charge Enhancements
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
Priority - 2
Calpine supports improving clarity and efficiency for augmentation of operational storage assets where it enhances reliability and operational performance, provided interconnection integrity and cost causation principles are preserved.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
Priority - 4
Calpine supports transparent and market-based pathways for energy-only resources to obtain deliverability, where grounded in physical capability and system needs. Cost responsibility should reflect incremental impacts and energy-only resources should not be unfailry advantaged compared to other resources for deliverability allocations.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
Priority - 2
MIC provisions should be improved to provide more stability and ensure competitive outcomes. Imports are critical to reliability and price formation, while the MIC framework is key to ensure reliable import simultaneous deliverability. Calpine supports MIC enhancements grounded in operational reality.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
Priority 1
Calpine supports revisiting TAC structure enhancements to improve alignment with cost causation principles, including the role of peak demand in transmission cost allocation. Any TAC reforms should preserve competitive neutrality, avoid distortive cost shifts, and ensure charges reflect actual system use. Care should be taken to prevent changes that influence siting or dispatch decisions through administrative cost reallocation rather than market signals.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
Priority - 2
Calpine supports improved stress-testing and adaptability analysis in transmission planning where it enhances reliability under evolving conditions and complements existing processes.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
Priority - 4
Aligning transmission planning with evolving grid and RA needs is important, but reforms should remain resource agnostic, and rely upon resource capabilities, performance, and market-based approaches, rather than prescriptive infrastructure mandates.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
Priority - 4
While Calpine opposes priortization of this effort at this time, we support future efforts to reform evaluating non-wires alternatives, including long-duration storage, where they demonstrate cost-effectiveness and reliability comparable to traditional transmission.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
Priority - 2
Calpine strongly supports comprehensive alignment of planning, interconnection, and deliverability processes consistent with FERC Order 1920 to improve efficiency, transparency, and competitive access.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Given limited ISO and stakeholder bandwidth, infrastructure initiatives should prioritize near term implementability and clear reliability or efficiency benefits.
Policy work should focus on improving alignment across planning, interconnection, and market frameworks, rather than introducing novel or independent constructs.
Competitive neutrality, market-driven solutions, transparency for cost causation, and cost causation based cost alloacation should remain guiding principles for all infrastructure policy development.
CPUC
Submitted 05/15/2026, 03:19 am
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Energy Division Staff (Staff) of the California Public Utilities Commission (CPUC) develop and administer energy policy and programs to serve the public interest, advise the CPUC, and ensure compliance with CPUC decisions and statutory mandates. Staff provide objective and expert analyses that promote reliable, safe, and environmentally sound energy services at just and reasonable rates for the people of California.[1] Further, Staff advocate on behalf of California ratepayers at the Federal Energy Regulatory Commission (FERC), under whose jurisdiction CAISO’s transmission planning falls.
Staff appreciate the CAISO’s focus on infrastructure initiatives and the opportunity to comment on Stakeholders’ proposals. The CPUC takes no position on prioritizing the proposed initiatives.
[1] More information about the CPUC Energy Division is available at: https://www.cpuc.ca.gov/about-cpuc/divisions/energy-division
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
The CPUC takes no position on this initiative at this time.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
The CPUC takes no position on this initiative at this time.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
The CPUC takes no position on this initiative at this time.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
Priority: 3 - Low
The proposed High Voltage (HV) TAC reforms are intended to make usage of the transmission system more efficient while more accurately reflecting causation in allocation of costs.
From the CPUC’s perspective, in isolation, the reforms will likely not result in the desired increased efficiency and equitable cost allocation. However, because the majority of transmission revenue requirement is borne by retail ratepayers, and those ratepayers’ costs are allocated by retail rate design, the impact of HV TAC reform should be considered in combination with retail rate design changes under consideration in the Commission’s new rulemaking on California Advanced Electric Rate Design.
As High Voltage TAC reform in combination with retail rate design could more effectively achieve the stated goals, the Commission looks forward to continuing to collaborate with the CAISO and other Stakeholders on equitable allocation of transmission costs to ratepayers.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
The CPUC takes no position on this initiative at this time.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
The CPUC takes no position on this initiative at this time.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
The CPUC takes no position on this initiative at this time.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
The CPUC takes no position on this initiative at this time.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
The CPUC looks forward to the opportunity to engage in future infrastructure-related initiatives.
EDFps
Submitted 05/15/2026, 04:20 pm
Submitted on behalf of
EDF power solutions
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Comprehensive Alignment Post Order 1920, battery storage enhancment procedures, and affected systems are EDFps top concerns.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
EDFps supports this item as ahigh priority, and provides the following informational analysis for consieration as CAISO develops the intiiatve topic.
EDFps requests that the CAISO open an initiative to establish tariff and BPM provisions addressing battery storage augmentation and equipment replacement activities that maintain existing operational capability without requiring a full Material Modification Assessment (MMA).
Battery degradation and augmentation are normal and expected aspects of operating battery storage facilities. Depending on chemistry, dispatch profile, and environmental conditions, battery systems may experience approximately 2–3% annual degradation, requiring periodic replacement or augmentation of battery racks and associated equipment to maintain contracted duration, capacity, and Resource Adeacy value.
Example:
|
Operating Year
|
Approximate Remaining Capability
|
|
Year 1
|
100%
|
|
Year 2
|
97.5%
|
|
Year 3
|
95.0%
|
|
Year 4
|
92.5%
|
|
Year 5
|
90.0%
|
|
Year 6
|
87.5%
|
For a 100 MW / 400 MWh resource, this equates to approximately 350 MWh by Year 6 absent augmentation.
Today, however, routine augmentation activities frequently trigger the MMA process even where:
- injection capability is unchanged,
- the project remains within originally studied parameters, and
- the work is intended solely to maintain existing operational capability.
At the same time, MMA reviews are already significantly backlogged, with many reviews taking six months or longer. As the number of operational storage facilities grows, routing routine augmentation activities through the MMA process risks creating unnecessary administrative burden without corresponding reliability or transmission benefits.
The CAISO already recognizes “Permissible Technological Advancements” (PTAs) as a mechanism to accommodate reasonable technology evolution over a project’s life. Operational battery augmentation and replacement activities should be more clearly addressed within that framework.
Accordingly, EDFps requests that the CAISO evaluate:
- clearer criteria for like-for-like substitutions,
- predefined screening thresholds,
- streamlined review timelines,
- notice-based processes for limited augmentation activities, and
- clearer guidance regarding when a PTA is sufficient versus when an MMA is required.
This proposal is not intended to create a pathway for projects to increase injection capability or avoid necessary interconnection studies. Rather, the objective is to ensure that routine maintenance and augmentation activities that do not materially change system impacts can proceed through a more efficient review pathway.
If the CAISO is not prepared to initiate this effort at this time, EDFps requests that the CAISO publish a report summarizing the last five years of PTA requests, including:
- technology type,
- modification category,
- whether the request was accepted or rejected,
- the basis for the determination,
- whether an MMA was ultimately required, and
- recurring technical concerns identified by the ISO.
Such information would improve transparency and help stakeholders better understand how the PTA framework is being applied to operational storage resources.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
EDFps beieves this is a high priority issue.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Although Affected System coordination reform was not specifically raised during earlier stakeholder meetings, EDF believes the need for additional policy consideration has become increasingly clear in the interim based on ongoing interconnection experience and stakeholder discussions. In particular, growing concerns regarding late-stage study uncertainty, inconsistent coordination practices, and post-COD mitigation requests have elevated Affected System process reform into a high-priority interconnection issue that warrants consideration as part of this initiative.
This proposal recommends that CAISO initiate a stakeholder effort focused on improving coordination, transparency, and procedural consistency for Affected System studies across the Western Interconnection. As regionalization continues to mature, the industry is increasingly moving toward collaborative and voluntary coordination frameworks that improve efficiency and reliability while preserving operational autonomy for participating entities. Affected System coordination represents a logical area for further regional collaboration.
Affected System issues routinely create major delays, cost uncertainty, and procedural inefficiencies for projects interconnecting to the CAISO grid. Under the current framework, generators are often required to complete separate bilateral study processes with neighboring systems before CAISO will allow synchronization, even though there is limited standardization regarding study assumptions, timelines, mitigation methodologies, proportionality standards, or dispute resolution processes.
In practice, Affected System processes frequently:
- delay projects for many months or years,
- require repeated studies with changing assumptions,
- produce shifting mitigation scopes and agreements,
- assign costs that may extend beyond a project’s actual incremental impact,
- and in some cases introduce new mitigation requests very late in development or even after commercial operation has already occurred.
Developers, transmission providers, neighboring systems, consultants, and CAISO staff are all required to devote substantial time and resources to overlapping and often duplicative coordination efforts. At the same time, many neighboring systems — particularly smaller or non-FERC-jurisdictional entities — may face resource constraints and limited engineering or regulatory staffing while managing increasingly complex interconnection requests.
CAISO is uniquely positioned to help facilitate a broader regional discussion regarding these challenges. Through RC West and existing interregional coordination activities, CAISO already maintains extensive visibility into neighboring system conditions, transmission constraints, reliability coordination processes, and regional planning efforts across much of the Western Interconnection. The foundation for greater coordination already exists.
Accordingly, CAISO should consider convening a dedicated stakeholder initiative or working group focused on Affected System coordination reform and regional process improvements. The purpose of such a working group would not be to eliminate legitimate Affected System protections or override neighboring system autonomy, but rather to collaboratively evaluate whether more standardized and coordinated approaches could improve efficiency, predictability, and transparency for all parties.
Topics for consideration could include:
- standardized study assumptions and modeling practices,
- clearer timelines for impact identification and study completion,
- improved data-sharing protocols,
- proportionality standards for upgrade responsibility,
- greater transparency into study methodologies and assumptions,
- dispute resolution or technical review pathways,
- expectations regarding study finality and limitations on late-stage or post-COD mitigation requests absent material system changes,
- and opportunities for coordinated regional transmission solutions rather than project-by-project mitigation approaches.
CAISO could also explore whether successful collaboration through such a working group could eventually support development of a voluntary, opt-in regional framework for coordinated Affected System review processes hosted or facilitated by CAISO. Similar voluntary coordination models are increasingly emerging elsewhere as regional transmission coordination evolves and interconnection challenges become more interconnected across balancing authority boundaries.
Importantly, any future framework should remain voluntary, preserve each participating entity’s operational control and reliability responsibilities, and recognize the unique regulatory structures applicable to different systems throughout the West. The goal is not centralization for its own sake, but rather the development of practical regional coordination tools that reduce unnecessary delays, duplicative studies, late-stage uncertainty, and administrative burdens while maintaining reliable system operations.
California and the broader Western Interconnection increasingly depend on timely interconnection of new generation and storage resources. A collaborative stakeholder effort focused on Affected System coordination could represent an important step toward improving regional interconnection efficiency, financing certainty, and transmission planning coordination across the West.
ENGIE NA
Submitted 05/15/2026, 05:01 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
ENGIE NA’s top priorities for the infrastructure roadmap in 2026 are the CALCCA proposal for EO resources seeking deliverability, Sonoma Clean Power’s Proposal for Reliability Modernization and EDF Renewables proposal for Comprehensive Alignment Post-Order 1920.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
ENGIE supports this submission as medium priority. Given the volume of batteries online and coming online in the coming years this could impact many BESS assets meeting full RA requirements
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
ENGIE strongly supports this initiative as high priority. Refining opportunities for Energy Only Resources to seek deliverability should be addressed in the next upcoming IPE stakeholder process
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
ENGIE supports enhancing the MIC process as medium priority.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
This initiative is low priority for ENGIE
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
This initiative is low priority for ENGIE
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
ENGIE supports this proposal as high priority and agrees that CAISO’s deliverability studies need to be updated to align with what the current RA slice of day program requires for RA compliance. EO resources should be recognized for the value they can provide in supporting system reliability which includes energy sufficiency. This should be addressed in a future IPE stakeholder process.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
ENGIE would support consideration of SATA for all storage types not just long-duration as medium priority and believe precedence has been set by CAISO for some of this already in the TPP. If this discussion were to be limited to long duration only though, this would be low priority for ENGIE
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
ENGIE supports this submission as a high priority for the 2026 infrastructure roadmap and encourages CAISO as part of this initiative, to consider additional TPD transparency and process improvements.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
NextEra Energy Resources
Submitted 05/15/2026, 11:57 am
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
NextEra Energy Resources, LLC, “NextEra Energy Resources,” appreciates the opportunity to submit comments into the 2026 Infrastructure policy catalog and roadmap process. Given CAISO’s finite resources, NextEra Energy Resources believes that CAISO should focus on NextEra’s Streamlined Augmentation of Operational Batteries and Sonoma Clean Power’s (SCP’s) Reliability Modernization proposal. NextEra Energy Resources believes its proposal is low-hanging fruit for the CAISO as it relieves administrative burden while ensuring that current and future operational batteries are able to serve their capacity commitments. NextEra Energy Resources also believes SCP’s proposal warrants high priority to evaluate the role of Energy-Only (EO) resources for resource adequacy, especially with the California Public Utilities Commission’s (CPUC) new Slice of Day resource adequacy construct. NextEra Energy Resources encourages CAISO to incorporate the proposal into the final catalog.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
NextEra Energy Resources is appreciative of the opportunity to present its proposal on April 8 and believes that this proposal should be a high priority for the CAISO to improve the reliability of operational battery storage assets. This will also reduce the expected increase in administrative burden as more batteries reach the point of their first augmentation and submit material modification study requests. As noted in NextEra’s presentation, as of March 1, 2026, the total installed battery capacity in the CAISO footprint is nearly 16GW, with more expected to come online per the current interconnection queue. Given that each battery typically requires at least four augmentations over a 20-year period, NextEra Energy Resources urges the CAISO to consider NextEra’s augmentation process improvement proposal that enables increased confidence in deployed capacity while respecting engineering practices and considerations. Furthermore, NextEra Energy Resources believes this proposal can be implemented through the business practice manual change process and will not require tariff changes. As a result, this proposal can be easily implemented by CAISO.
On the April 8 stakeholder call, NextEra Energy Resources appreciated the California Department of Water Resource’s question regarding the rationale for selecting a 100A threshold for the proposed incremental short circuit current limit under the proposed process. NextEra Energy Resources notes that this suggested threshold is designed to ensure that an augmentation action does not present a risk to existing interconnection facilities, limiting the effective maximum size of an augmentation action under the proposed process. It also provides a mechanism for large-scope actions that exceed this threshold to be studied under existing modification processes for material impact. NextEra Energy Resources is open to further discussion with CAISO and the Participating Transmission Owners (PTOs) to determine an appropriate short circuit threshold that balances the operational needs of deployed battery storage assets with reasonable limits on maximum augmentation size eligible for this process. NextEra Energy Resources looks forward to working with CAISO and the PTOs to align on the appropriate short circuit current threshold.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
No comment.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
No comment.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
No comment.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
No comment.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
NextEra Energy Resources appreciates SCPs’ proposal seeking to align the CAISO’s deliverability and resource adequacy practices to better incorporate the role of energy-only (EO) resources. This should be high priority. NextEra Energy Resources continues to support CAISO to consider avenues to allow EO resources to count towards CPUC resource adequacy (RA) requirements, or at minimum, charging sufficiency requirements within the CPUC’s RA program. NextEra Energy Resources submitted comments within the CPUC RA Track 1 proceeding on this matter and understands that further CAISO studies are needed to determine whether EO resources can meet charging sufficiency requirements.[1] As CAISO stated in their CPUC RA Track 1 Opening Comments, they are committed to conducting an off-peak deliverability study.[2] The preliminary results are targeted by November 2026. NextEra Energy Resources agrees with the CAISO’s approach and urges CAISO to complete the off-peak deliverability assessment on schedule for stakeholder review.
[1] COMMENTS OF NEXTERA ENERGY RESOURCESENERGY RESOURCES, LLC ON TRACK 1 PROPOSALS, Rulemaking (R.)25-10-003, Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider Program Reforms and Refinements, and Establish Forward Resource Adequacy Procurement Obligations, March 6, 2026. Available at: https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M602/K766/602766086.PDF
[2] OPENING COMMENTS OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION ON TRACK 1 PROPOSALS, R. 25-10-003, Order Instituting Rulemaking to Oversee the Resource Adequacy Program, Consider Program Reforms and Refinements, and Establish Forward Resource Adequacy Procurement Obligations, March 6, 2026. Available at: https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M601/K896/601896043.PDF
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
No comment.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
NextEra Energy Resources conceptually supports EDF’s proposal to ensure alignment between the generator interconnection process, transmission plan deliverability allocation process, and the transmission planning process. This should be medium priority. NextEra Energy Resources recognizes that CAISO will be transitioning into a biennial transmission planning process starting 2028 for the 2030 comprehensive plan[1], while the interconnection cluster window openings continue on an annual basis. The CAISO should carefully consider how the deliverability assumptions will be made during the “off cycle” year as the new zonal interconnection process primarily relies on the annual transmission plan to determine the transmission plan deliverability (TPD), merchant, and energy-only interconnection zones. NextEra Energy Resources encourages CAISO to open up a stakeholder discussion to discuss how the biennial transmission planning process will feed into the generator interconnection and deliverability allocation processes that operate on an annual basis.
[1] CAISO. Tariff Amendment to Comply with Order 1920, December 9, 2025. https://www.caiso.com/documents/dec-9-2025-tariff-amendment-order-no-1920-compliance-filing-er26-704.pdf
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
No comment.
Pacific Gas & Electric
Submitted 05/15/2026, 08:52 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Pacific Gas and Electric Company (PG&E) appreciates the opportunity to provide these comments on the stakeholder proposals for the 2026 Infrastructure Policy Catalog and Roadmap Process.
PG&E recommends the CAISO prioritize the Maximum Import Capabilities (MIC) Enhancements proposal, however as described in comments below, PG&E suggests the proposal be taken up in the Market Policy Catalog and Roadmap process rather than in the Policy Infrastructure venue
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
While PG&E appreciates NextEra seeking opportunities to further streamline the battery augmentation process, PG&E believes the proposal to bypass the Material Modification Assessment (MMA) when a battery storage resource adds additional battery units and inverters and only require a direct notification and submission of a technical package to CAISO could introduce reliability and protection risks that warrant continued engineering review through the MMA process
In particular, the addition or replacement of inverters directly affects MVA contribution, fault current at the point of interconnection, and protection settings—impacts that are not captured by MW export limits alone and require updated engineering (including protection) studies to ensure system safety. PG&E is also concerned that applying technical thresholds on a per-augmentation basis, rather than cumulatively, could allow repeated incremental inverter additions to unintentionally bypass fault-current review.
It is also worth noting that current MMA process is already relatively streamlined, with recent PG&E examples demonstrating initial review completion within weeks and total timelines closer to a couple of months when high-quality data packages are provided upfront. Given this, PG&E does not believe that a significantly faster process could be implemented without increasing risk to the system, particularly if equipment changes are permitted without prior engineering notification or review.
For these reasons, PG&E recommends that CAISO retain the existing MMA review framework and considers the proposal to not be a priority at this time.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
PG&E has no comments at this time but reserves the right to provide further comments on any concerns in the future.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
PG&E is aware that the Maximum Import Capability (MIC) Enhancements proposal was submitted in both the Market Policy and Infrastructure Policy Catalog and Roadmap processes. PG&E supports this proposal and recommends it be designated as a high priority. However, PG&E believes the topic is better suited – given the market design and operational flexibilities associated with MIC – to be addressed under the Market Policy Catalog and Roadmap process, where PG&E's detailed comments on the proposal are being submitted.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
PG&E has no comments on this proposal at this time but reserves the right to provide additional comments in the future.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
PG&E is generally supportive of the concept of incorporating additional scenarios and sensitivities into transmission planning to better hedge against resource portfolios used for planning diverging from actual development pipelines, and other uncertainties. However, PG&E notes that FERC Order 1920 already requires CAISO to evaluate multiple divergent long-term scenarios as part of its compliance framework, which may substantially address the objectives outlined in Sonoma Clean Power's proposal. For these reasons, PG&E recommends that CAISO fold any enhancements to adaptability testing into the ongoing Order 1920 implementation process to avoid duplicative efforts.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
PG&E has no comments on this proposal at this time but reserves the right to provide additional comments in the future.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
PG&E has no comments on this proposal at this time but reserves the right to provide additional comments in the future.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
PG&E acknowledges the importance of ensuring alignment across interconnection and transmission planning processes following the implementation of FERC Order 1920 requirements, but notes that this topic may not necessitate an initiative. Rather, CAISO could host a workshop to help all stakeholders develop a clear understanding of how the new process will work and how it will align with the existing generator interconnection process and transmission plan deliverability (TPD) allocation timelines. A collaborative forum of this nature would provide an efficient and practical means of addressing stakeholder questions and ensuring process alignment without the need for a separate, formal initiative.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Peninsula Clean Energy
Submitted 05/15/2026, 02:51 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
Peninsula Clean Energy (or Westlight Energy, starting in July) prioritizes MIC enhancements as our top initiative. Our goal of serving our load with 100% renewable energy in all hours, and recent procurement orders from the CPUC both require clean firm resources, such as advanced geothermal, and wind resources capable of generating reliably in winter and nightttime hours. These resources are almost certainly are going to be either primarily or exclusively available outside of California. Thus, being able to secure import rights in full in the online year, with certainty, is fundamentally critical to the procurement needed for a clean reliable system. Since the existing system is complex and difficult to work with, PCE prioritizes adjustments to meet the procurement needs of the early 2030s and beyond.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
1
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
1
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Peninsula Clean Energy places the highest priority to including within the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing Maximum Import Capability (“MIC”) to support eligibility of import resources to provide Resource Adequacy (“RA”) capacity. Multiple stakeholders have expressed the view that limitations on availability of MIC impose significant barriers to use of import resources for RA purposes. Consideration of MIC Enhancements should include analysis of the causes for limitations on MIC availability and comprehensive exploration of both short-term and long-term measures that could mitigate the adverse impacts of MIC limitations, including consideration of relaxing MIC requirements for import RA eligibility under defined circumstances.
Peninsula Clean Energy strongly urges the CAISO to pursue MIC Enhancements as part of the RAMPD initiative, rather than under a separate Infrastructure-related initiative. MIC policy and implementation are inextricably intertwined with RA policy and implementation. Indeed, MIC has no role in the CAISO markets other than to establish eligibility for import resources to supply RA capacity. It is critical that consideration of enhancements to MIC determination and application be fully integrated with, informed by, and supportive of RA policy and objectives. Although many enhancements can be executed without any change to the simultaneous deliverability study that falls within the scope of the infrastrcture group, no reforms can be conducted without a strong consideration of the market and policy impacts. Thus, the Policy group is the appropriate forum for this discussion.
Rev Renewables
Submitted 05/15/2026, 03:46 pm
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
REV Renewables (REV) supports the NextEra BESS augmentation proposal as the highest priority.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
REV supports this as a High Priority policy. Given the growing BESS fleet and the need to maintain committed capacity levels, it is important there is a streamlined process to allow resources to augment their projects. Augmentation involves limited changes to the facility, as it is not changing POI limits or fuel source, but it may include different batteries or inverters. The current MMA process that can take a year or more does not support timely improvements needed to maintain capacity in the storage fleet. REV understands that some level of study, such as short-circuit or stability analyses, may be required to enable augmentation. However, REV requests a more streamlined process to provide more certainty for the project timeline and approval.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
Six Cities
Submitted 05/15/2026, 04:58 pm
Submitted on behalf of
Cities of Anaheim, Azusa, Banning, Colton, Pasadena, and Riverside, California
1.
Recognizing the finite resources of the ISO and stakeholders, which, if any, policy submissions do you think should be prioritized for exploration in 2026? Please list only your top one or two selections.
The Six Cities support prioritization of policy submission no. 3 below, which is the submittal related to the expansion of opportunities for energy only projects to seek additional deliverability allocations.
As discussed in response to submission no. 4 below, the Six Cities place the Maximum Import Capability Enhancements initiative as a high priority, but view this initiative as properly within the scope of the Resource Adequacy Modeling and Program Design initiative.
2.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Streamlined Augmentation of Operational Batteries submission (NextEra)
This initiative is not a priority for the Six Cities, but the Cities do not oppose consideration of options to address the underlying concerns.
3.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Energy Only Resources Seeking Deliverability submission (Cal-CCA)
The Six Cities agree that this initiative is a high priority. Expanding opportunities for in-service energy only resources to obtain deliverability allocations appears to be an efficient way of expanding the pool of resources that are eligible to provide Resource Adequacy (“RA”) capacity.
4.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Maximum Import Capability Enhancements submission (Joint Parties)
This initiative is a high priority for the Six Cities, although the Six Cities support inclusion of this initiative in the Market Policy Catalog and Roadmap, rather than the Infrastructure Catalog and Roadmap.
The Six Cities attach highest priority to including within the Resource Adequacy Modeling and Program Design (“RAMPD”) initiative a comprehensive review of the practices and policies for quantifying, assigning, transferring, and utilizing Maximum Import Capability (“MIC”) to support eligibility of import resources to provide RA capacity. Multiple stakeholders have expressed the view that limitations on availability of MIC impose significant barriers to use of import resources for RA purposes. Consideration of MIC Enhancements should include analysis of the causes for limitations on MIC availability and comprehensive exploration of both short-term and long-term measures that could mitigate the adverse impacts of MIC limitations, including consideration of relaxing MIC requirements for import RA eligibility under defined circumstances. The Six Cities strongly urge the CAISO to pursue MIC Enhancements as part of the RAMPD initiative, rather than under a separate Infrastructure related initiative. MIC policy and implementation are inextricably intertwined with RA policy and implementation. Indeed, MIC has no role in the CAISO markets other than to establish eligibility for import resources to supply RA capacity. Enhancements to MIC determination and application must be fully integrated with, informed by, and supportive of RA policy and objectives.
5.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Transmission Access Charge Structure Enhancements submission (CDWR and others)
This initiative is not a priority for the Six Cities at this time. In the event that the CAISO and stakeholders elect to advance this initiative, the Six Cities request that the CAISO first provide an updated assessment of projected cost impacts resulting from implementation of the previously-discussed (i.e., in the previous TAC Structure Enhancements initiative) rate design. The Six Cities are concerned that, with the large amounts of new transmission projected to be developed to address load growth, the impacts of any cost shifts among CAISO transmission customers resulting a revised rate methodology may be exacerbated. For this reason, if the change in rate design will result in material TAC cost increases to certain CAISO transmission customers, stakeholders should have the opportunity to consider alternatives to the previously discussed design, including retention of the current rate design.
6.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Robust Adaptability Testing in CAISO Transmission submission (Sonoma Clean Power)
This initiative is not a priority for the Six Cities at this time, but the Six Cities do not oppose consideration of measures to assess ways in which transmission projects under consideration in the CAISO’s Transmission Planning Process can be more appropriately scoped or their timing accelerated in response to changing conditions. If stakeholders support advancement of this initiative, then the as-submitted proposal would likely benefit from one or more working group meetings to more fully define the scope, problem statements, and desired outcomes to ensure the most efficient use of CAISO and stakeholder resources.
7.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Reliability Modernization Initiative submission (Sonoma Clean Power)
The Sonoma Clean Power proposal raises a series of interesting questions regarding the potential evolution of the CAISO’s RA program in ways that might entail broad changes to the program’s purposes and design. To some extent, some of these changes, such as whether energy only projects should be considered as RA resources under certain conditions, may be questions that are best addressed by local regulatory authorities, such as the California Public Utilities Commission or public utility boards and city councils for municipal utilities. However, if the CAISO and stakeholders determine that any of these topics should be addressed through RA policy changes, it is not clear that the Infrastructure Catalog/Roadmap provide the correct forum for this initiative to reside. While the CAISO has the RAMPD initiative underway at this time, the issues in this proposal appear to go beyond those being considered in the RAMPD process, and likely would benefit from a discussion paper to properly scope the initiative. Thus, while the Six Cities do not view this initiative as a near-term priority, there may be value in considering these and related reforms to the RA program in future years.
8.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Long Duration Energy Storage Transmission Asset submission (GreenGen)
This initiative is not a priority for the Six Cities at this time.
9.
Please provide your organization’s comments on and level of priority (1.high, 2.medium, 3.low, or 4.not a priority) for the Comprehensive Alignment Post Order 1920 submission (EDF Renewables)
This initiative is not a priority for the Six Cities at this time, but the Six Cities do not oppose consideration of enhancements to the Transmission Planning Process to augment policy changes implemented pursuant to FERC Order No. 1920. It may be preferable to defer this initiative, however, until the CAISO and stakeholders have additional experience with the CAISO’s revised processes.
10.
Do you have any additional feedback or suggestions that you’d like the ISO to consider?
The Six Cities encourage the CAISO to provide additional information and transparency around the bifurcation of the market policy and infrastructure-related Catalog and Roadmap processes. Does the functional separation of initiatives into these categories also have implications for CAISO staffing and management oversight of initiative topics? Further, how does the CAISO intend to categorize initiatives that have both market policy and infrastructure related implications? Further clarification of how the CAISO’s proposes to classify initiatives will aid stakeholders in their understanding of the CAISO’s processes.
