Comments on Straw proposal and stakeholder discussion from July 9, 2026

The California Energy Storage Alliance (CESA) appreciates the opportunity to comment on the 2026 Variable Operations and Mantenance (VOM) Cost Review straw proposal.  CESA is supportive of the proposal to modify the default VOM included in the storage DEB from $0/MWh to $14.74/MWh which is based upon the LTSA median value.  This proposal elimintes the need for all storage resources to negotiate a VOM to be included in its DEB, while still allowing a negotiated option if a resource's VOM costs are different than the default VOM costs.  CESA also supports reviewing the storage VOM in the next VOM cost review cycle to consider if an inflation-based adjustment is needed and/or if empirical data from future negotiate VOMs justifies a change in the default VOM included in storage DEBs.

Vistra supports the CAISO’s straw proposal and seeks clarity regarding future year inflation adjustments on the proposed storage default VOM.

No comment.

Vistra supports the CAISO’s proposed 9.84% inflation adjustment to current default VOM adders based on Consumer Price Index (CPI) data from the US Bureau of Labor Statistics (BLS). We are seeking greater clarity that this inflation adjustment will apply to all default VOM including the newly proposed storage default VOM.

Support.

Vistra supports the CAISO's proposed default for storage using LTSA-based median value (option 1) of $14.74/MWh. Vistra seeks confirmation that the proposed inflation-based update will apply year over year to the $14.74/MWh.