Comments on Draft 2026-2028 Policy Initiatives Roadmap

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

 AES recognizes the importance of CAISO's policy initiatives roadmap and commits to participating in market design processes that support California's energy transition and grid reliability. However, AES has concerns about the breadth and complexity of initiatives outlined, particularly given that several lack robust straw proposals and appear unlikely to reach decisions within proposed timelines. The roadmap's ambitious scope may exceed realistic completion targets and could dilute the quality of stakeholder engagement. AES questions whether meaningful participation across all initiatives is feasible without compromising the depth of technical input required for effective market design.

AES commits to active participation in key initiatives directly impacting storage operations, resource adequacy, and price formation. However, AES requests that CAISO improve stakeholder process timelines, clarify initiative interdependencies, and provide realistic completion targets to enable efficient resource planning. Inadequate lead time for reviewing technical materials undermines feedback quality and meeting productivity, making resource allocation less effective. To support this roadmap, AES needs greater clarity on priorities and dependencies to allocate resources strategically.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

AES supports the Commitment Cost Bidding Flexibility initiative as a follow-on to Gas Management Enhancements, recognizing that improved bidding flexibility can enhance market efficiency and reduce artificial scarcity pricing

4. Congestion Revenue Rights Enhancements

AES supports enhancements to the CRR products and recognizes the value of expanding eligible sink locations to include storage facilities, particularly given AES's diversified portfolio of solar, storage, wind, and gas assets across California. However, AES shares concerns about the coordination between the CRR Enhancements initiative and the EDAM Congestion Revenue Allocation Phase 2 initiative, as these interconnected market design changes require a cohesive stakeholder process that reflects the needs of multi-technology operators. The hedging function of CRR products must be evaluated across the entire EDAM footprint, not limited to individual balancing authority areas, to ensure consistent and equitable treatment of storage and other distributed resources that AES operates.AES recommends that CAISO either combine these initiatives or establish formal mechanisms to ensure tight coupling and coordinated stakeholder engagement. 

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

AES supports the EDAM Congestion Revenue Allocation initiative and recognizes its importance in establishing fair and transparent mechanisms for distributing congestion revenues across the expanded EDAM footprint. As an operator of solar, storage, wind, and gas assets across California and potentially in other EDAM regions, AES has a vested interest in ensuring that congestion revenue allocation reflects the true economic value of resources and supports efficient market outcomes. However, AES emphasizes that this initiative must be tightly coordinated with the Congestion Revenue Rights Enhancements initiative to avoid creating conflicting or inconsistent treatment of congestion revenues across different market products and timeframes.

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

AES strongly supports the Price Formation Enhancements initiative focused on scarcity pricing and market power mitigation, recognizing that accurate price signals are essential for efficient market operations and grid reliability. AES benefits from market designs that reflect actual scarcity conditions and enable resources to provide value during critical periods. Enhanced scarcity pricing mechanisms will improve incentives for storage deployment and discharge during peak demand periods, while also supporting the economic viability of flexible gas resources that provide reliability services. Effective market power mitigation measures will ensure that all resource types, including storage and renewable generators, can participate fairly and compete on equal footing in energy and ancillary services markets.

11. Price Formation Enhancements: Fast start pricing

No additional comments

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

AES supports the Resource Adequacy Track 2 initiative focused on outage and substitution reform, recognizing that more efficient processes are critical to maintaining system reliability while reducing artificial capacity-market tightness. As an operator of solar, storage, wind, and gas assets across California, AES recognizes that the current bilateral substitution market suffers from high transaction costs, limited short-duration capacity availability, artificial withholding, and scheduling coordinator practices that undermine efficient resource utilization. However, AES emphasizes that reforms must significantly improve outage and substitution processes while maintaining clear cost-recovery mechanisms and avoiding barriers to participation, including standardizing contract terms to align with actual outage durations and reducing transaction costs and uncertainty. AES commits to active participation and requests detailed straw proposals demonstrating how proposed reforms will reduce artificial tightness, lower transaction costs, and improve system reliability while enabling storage resources to participate effectively in capacity market transactions. Effective outage and substitution reform will support more reliable operations, reduce unnecessary procurement costs, and enable AES to optimize asset availability across its diversified California portfolio. 

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

No additional comments

14. Storage Design and Modeling

AES strongly supports the Storage Design and Modeling initiative, recognizing that rapid growth in battery energy storage systems across California requires comprehensive market design evolution to optimize storage participation and grid value. As a major operator of storage assets across California, AES acknowledges that current market rules and participation models were designed before large-scale storage deployment and require holistic review similar to the Participating Intermittent Resource Program reforms implemented for wind and solar a decade ago. Market design changes of equivalent magnitude are necessary to ensure that storage resources can efficiently provide energy arbitrage, capacity support, ancillary services, and grid stability services while being appropriately compensated for their contributions. AES requests that CAISO publish a revised draft roadmap outlining the planned implementation timeline and sequencing of market design changes developed through this initiative to provide clarity on long-term storage participation frameworks. AES commits to active engagement in this initiative and looks forward to collaborating with CAISO and stakeholders to develop innovative market design solutions that maximize storage value, support California's clean energy transition, and enhance grid reliability. 

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

AES requests that CAISO establish clear prioritization and sequencing initiatives to prevent scope creep and ensure that foundational market design work is completed before pursuing expansive enhancements. The roadmap would benefit from explicit identification of initiative dependencies and prerequisites, enabling stakeholders like AES to allocate resources strategically and avoid delays in critical storage, price formation, and resource adequacy work. AES strongly recommends that CAISO restore its historical practice of distributing meeting materials at least one week in advance of stakeholder calls and working group meetings to enable meaningful preparation and productive engagement. AES also encourages CAISO to hold in-person meetings instead of virtual meetings and requests senior leadership to attend key meetings.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

No comments at this time.

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

No comments at this time.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

Bay Area Municipal Transmission Group (BAMx[1]) supports addressing the TAC Structure Initiative proposed by CDWR – State Water Project for the reasons described by Joint Commenters in their comments.

[1] BAMx comprises City of Santa Clara dba Silicon Valley Power and City of Palo Alto Utilities.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

We are particularly interested in Internal and external market seams issues. 

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

We strongly support Internal and external market seams issues and transactional seams coordination. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

Bonneville appreciates the considerable effort CAISO has put forth in the Price Formation Enhancement initiative and strongly supports continued work on this particular component of the larger initiative. Bonneville believes the MPM modifications proposed in this initiative can be real improvements to the process that will result in a truer reflection of the potential for exercise of market power in the market footprint. With respect to scarcity pricing, Bonneville believes this initiative is a timely complement to EDAM implementation. With growing interdependence of balancing authorities in the west, price formation – particularly in signaling impending stressed / scarcity conditions – takes on greater significance as the market engine optimizes unit commitment and dispatch of an increasingly diverse set of resources that are meeting load across a growing geographic and temporal footprint.  While undoubtedly complex, Bonneville believes that the pursuit of an improved scarcity pricing mechanism is worthwhile in principle – to more closely align with market constructs in other regions – and in practice – to avoid major consequences due to reliability events.

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

Bonneville supports prioritization of this initiative.  Specifically, Bonneville would like to include in the scope of this initiative a minor change to forecasted movement settlement to align with the flexible ramping sufficiency test.  The Department of Market Monitoring describes the conceptual issue in extensive detail in the Q1 2025 Report on Market Issues and Performance (Section 9.3, pgs 92 – 94). Bonneville believes the adjustment recommended by DMM – that base WEIM transfers be accounted for in forecasted movement settlement – will help align cost-causation principles with the outcomes of the Resource Sufficiency Evaluation. Although the language of the CAISO Tariff already supports this outcome, clarification is needed to prevent misapplication of forecasted movement settlements in the future.

In addition, Bonneville would like to propose a change to the use of T-55 advisory Flex Ramp Sufficiency results in the formation and settlement of Flexible Ramping Product (FRP) Awards. Bonneville has been financially harmed due to the FRP Refinements made in February 2023 (CAISO BPM for Market operations Section 7.1.3.1.1) due to Flexible Ramp Sufficiency test failures occurring at T-55 which were resolved by T-40. The T-55 advisory tests are not suitable for use in financially binding settlements and while market process timing limitations may preclude the binding (T-40) test results from being used in the first hourly binding FMM interval, a mechanism should be provided to recoup any applicable FRP charges due to T-55 failures which are resolved by T-40.

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

The California Community Choice Association (CalCCA) appreciates the ambitious scope of issues the California Independent System Operator (CAISO) plans to address in 2026-2028. CalCCA recommends the CAISO consistently check in with stakeholders and reevaluate its scope of work throughout 2026 to 2028 to confirm the pace of initiative development is workable. CalCCA’s participation in the policy initiatives in the roadmap will depend on the depth of the initiatives, their applicability to community choice aggregators (CCA), and the amount of urgent issues that emerge requiring immediate attention by the CAISO and stakeholders (e.g., new Federal Energy Regulatory Commission proceedings, urgent market issues – especially given extended day-ahead market (EDAM) implementation in 2026).  

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

See responses in sections 3-17, below.  

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

CalCCA supports the CAISO moving forward with the policy development process for congestion revenue rights (CRR) enhancements. The CAISO should simulate the CRR allocation and auction results of a prior year if the Department of Market Monitoring’s willing buyer/willing seller proposal had been in place. LSEs should be able to evaluate proposals in this initiative based on how the proposals will affect their ability to acquire CRRs for hedging. The willing buyer/willing seller proposal will impact the CRRs that LSEs receive through the allocation and the CRRs that market participants, including LSEs, can obtain through the auction. CalCCA’s March 26, 2025, comments describe how the CAISO can perform this analysis to provide LSEs the information they need to evaluate the proposal.[1]

[1]            CalCCA Comments on CRR Enhancements Working Group Meeting (Mar. 26, 2025): https://stakeholdercenter.caiso.com/Comments/AllComments/bbb949f8-adea-47aa-893d-e55bcdf67c9f#org-d7a46234-99b7-4f98-8bba-86d0230ba82e.

5. Demand and Distributed Energy Market Integration

CalCCA supports continued efforts to enhance participation models and market rules facilitating the representation of demand and distributed energy in the CAISO markets. In particular, CalCCA strongly supports the CAISO’s efforts to modify the Performance Evaluation Methodologies and the Proxy Demand Response and Distributed Energy Resources (DER) Aggregation market participation models to enhance DER participation in the CAISO markets. In support of these efforts, the CAISO should work closely with the California Public Utilities Commission to create a pathway for DER to obtain resource adequacy (RA) qualifying capacity values.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

The CAISO has sufficiently developed policy on scarcity pricing and market power mitigation (MPM) in its Straw Proposal,[1] and CalCCA does not anticipate needing an additional three quarters of policy development. CalCCA supports the CAISO’s proposed targeted modifications to scarcity pricing and pausing discussion of a wholesale redesign until issues with flexible ramping product performance and ancillary service procurement are resolved. CalCCA also strongly supports the CAISO’s proposed grouped Balancing Authority Area (BAA) -level MPM design. The CAISO should adopt the proposed changes in the Straw Proposal and move forward with obtaining approval to file tariff changes at Federal Energy Regulatory Commission to implement the proposed changes.

[1]            CAISO Straw Proposal on BAA-level MPM and Scarcity Pricing (Aug. 22, 2025): https://stakeholdercenter.caiso.com/InitiativeDocuments/StrawProposal-Price-Formation-Enhancements-BAA-Level-MPM-Scarcity-Pricing.pdf.

11. Price Formation Enhancements: Fast start pricing

CalCCA supports the CAISO’s plan to postpone the stakeholder process for fast start pricing and reconsider whether to revisit it at a later date. Discussions to date have not demonstrated benefits associated with fast-start pricing to justify the associated cost increases. The CAISO has other mechanisms to ensure fast-start resources recover their costs without the customer cost impacts associated with fast-start pricing. Spending time developing fast-start pricing is not a good use of CAISO and stakeholder time and resources when the CAISO already fully compensates fast-start resources for their start-up costs.  

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

CalCCA supports continued efforts to enhance RA modeling and program design. However, the roadmap’s initiative descriptions need to be updated to include maximum import capability (MIC) enhancements somewhere within scope of the RA Modeling and Program Design (RAMPD) initiative. The CAISO’s 2024 Roadmap included MIC enhancements within the scope of RAMPD,[1] but the RAPMD working groups have yet to discuss the issue. Given the challenges LSEs face with obtaining MIC on popular interties and managing uncertainty around whether MIC will be available for long-term contracting, the CAISO should prioritize MIC enhancements within the RAMPD initiative.

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

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

See response in section 12.

14. Storage Design and Modeling

CalCCA supports continued efforts to enhance energy storage market design, modeling, and processes.

15. WEIM Resource Sufficiency Evaluation Enhancements

CalCCA supports the CAISO’s proposed examination of unresolved policy from the Resource Sufficiency Evaluation Enhancements Phase 2 effort but does not view it as high of a priority as other initiatives on the roadmap.

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

As described in section 12 and 13, the CAISO should modify the 2026-2028 Policy Roadmap to include enhancements to MIC.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

As described in sections 10 and 11, the CAISO should deprioritize scarcity pricing and fast start pricing. The CAISO has sufficiently developed policy on targeted modifications to scarcity pricing, and there is insufficient justification for fast start pricing.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

California Department of Water Resources – State Water Project (CDWR-SWP) supports the CRR Enhancements Initiative with the following caveat: CDWR-SWP believes the CAISO should perform an analysis to determine if split of the On-Peak CRR Time of Use (TOU) is beneficial to the CRR Auction Efficiency.  The analysis should consider the split of the On-Peak TOU in two: Regular On-Peak (HE07 to HE16 or HE17), and Super-Peak (HE16 or HE17 to HE22).

Also, CDWR-SWP suggests that the CAISO potentially explores the alignment of the above proposed TOU to that of the currently in place Availability Assessment Hours (AAH) that typically change yearly (±1 Hr) in the Resource Adequacy (RA) framework. Further on, the analysis should determine the best split of the On-Peak TOU that would bring the most benefits to CRR Auction Efficiency. 

5. Demand and Distributed Energy Market Integration

For the policy development phase, which is to be implemented next year, CDWR-SWP believes that the CAISO’s structured stakeholder process should align with the six guiding principles: Efficiency, Competition, Feasibility, Simplicity, Reliability, Compliance, and Public Policy to ensure fair and balanced outcomes. Expanding real time market access for Participating Load improves flexibility, reliability, and delivers economic and environmental benefits. Continued progress depends on clear priorities, transparent evaluation, and financial impact analysis to support a fair and efficient market for all. 

6. EDAM Congestion Revenue Allocation

In previous CAISO stakeholder processes on this topic, CDWR-SWP supported CAISO’s EDAM CRR Allocation proposal, which extends CRR revenue settlement beyond CAISO interties to include generation nodes located within adjacent Balancing Authorities (BAs).The caveat is that CDWR-SWP is concerned with the process of how the existing annual and Long-Term (LT) CRR sourced at interties would be transitioned to CRR sourced at generation nodes (for BAs that join the EDAM), or generation aggregation points (for BAs that do not join the EDAM).

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

Assuming CDWR-SWP energy resources are within California, (besides Hoover contract) hence should not be affected by GHG Coordination.

GHG Coordination is aimed at increasing transparency of GHG emissions intensity of electricity transfers in the Western Energy Imbalance Market (WEIM) and Extended Day-Ahead Market (EDAM) footprints. Its primary goal is to support state, local, and corporate GHG reduction efforts by providing data that links market dispatch outcomes with resource ownership and contracting arrangements. Western states, like California have adopted a range of GHG policies, some using carbon pricing mechanisms. For states without a carbon pricing mechanism, the CAISO market currently lacks a way to reflect emissions-related compliance. To address this gap, the working group developed the Accounting and Reporting approach, which provides a post-market emissions dataset that reporting entities can use to support their GHG reporting obligations.

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

Depends on the Track 3b proposal and outcome.

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

No comments. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

The CDWR-SWP, Bay Area Municipal Transmission Group, and State Water Contractors (together, the Joint Commenters) respectfully reiterate their request that the CAISO reconsider the Transmission Access Charge (TAC) Structure Enhancements initiative in its 2026–2028 Policy Initiative Roadmap. It was proposed by CDWR-SWP in the 2025 Policy Initiative Catalog but was subsequently moved by the CAISO to the 2025–2026 Transmission Planning Process on the basis that it was infrastructure related. However, it was later dismissed without stakeholder engagement and based on reasoning which mischaracterized the core issue without further stakeholder engagement or meetings to hold additional discussions.

The Joint Commenters respectfully request that this initiative be reconsidered to allow it to undergo a complete and transparent stakeholder process.

Note: Bay Area Municipal Transmission Group comprises the City of Santa Clara (Silicon Valley Power) and City of Palo Alto. 

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

N/A

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

N/A

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

N/A

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

The California Energy Storage Alliance (CESA) appreciates the opportunity to provide comments on the Draft 2026-2028 Policy Initiatives Roadmap.  The breadth of issues listed in the roadmap is onerous, in part due to the CAISO’s continuing practice of leaving market design elements incomplete and deferring unresolved issues to subsequent initiatives.  This approach has resulted in a far wider breadth of issues than necessary, and made it difficult to prioritize initiatives, preventing resources from being redirected and focused on efficiently and effectively addressing the next set of critical issues.

Upon review of 2025 WEM Governing Body decisions, the number and magnitude of issues resolved is minimal.  CESA is skeptical that CAISO can complete Demand and Distributed Energy Market Integration, Congestion Revenue Rights Enhancements, EDAM Congestion Revenue Allocation, Price Formation Enhancements - Scarcity pricing & market power mitigation, and Resource Adequacy Modeling and Program Design - Track 2: Outage & substitution initiatives and bring to the WEM Governing Body for decision.  Many of these initiatives have been underway for most of 3035 and beyond, yet none of these initiatives have a robust straw proposal developed.

Lastly, historically CAISO posted documents a week in advance of a stakeholder call/meeting.  This allowed stakeholders to be prepared to engage in discussions at the meetings and led to more comprehensive and productive stakeholder conversations.  CAISO is no longer providing meeting materials with sufficient lead time to allow stakeholder review prior to a call/meeting which undermines the call/meeting effectiveness. For example, the import scheduling scenarios document was posted on the day of the Intertie Scheduling and Resource Adequacy Imports in Extended Day-Ahead Market Workshop. The document contained significant market design implications regarding intertie pricing, intertie scheduling, congestion revenue right (CRR) mapping, and import resource adequacy (RA) changes.  As of November 9, no materials have been posted for the Price Formation call on November 10 or the Storage Design and Modeling meeting on November 12.  If calls/meetings are not effective, the roadmap is not achievable.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

See below.

3. Commitment Cost Bidding Flexibility

CESA notes that this is a follow-on initiative to the Gas Management Enhancements initiative. 

4. Congestion Revenue Rights Enhancements

CESA supports changes to the CRR products and allowing storage locations to be an eligible sink. At the September 9 working group, the CAISO attempted to differentiate and bifurcate certain issues between the EDAM Congestion Revenue Allocation (CRA) Phase 2 initiative and the CRR Enhancements. CESA believes that the distribution of congestion revenues to transmission customers requires a more coordinated stakeholder process.  While CESA agrees with the CRR Market Function’s assessment of hedging (as shown on slide 40), we emphasize that this function applies across the entire EDAM footprint, not just within the CAISO balancing authority area (BAA).  The Congestion Revenue Rights Enhancements and the EDAM CRA initiatives should be combined or at a minimum tightly coupled.  

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

The Congestion Revenue Rights Enhancements and the EDAM CRA initiatives should be combined or at a minimum tightly coupled. See comments above.

7. EDAM Enhancements

CESA encourages the CAISO to ensure that the significant market design changes needed to enhance EDAM are managed in a way that allows continued progress on other important non-EDAM initiatives. With careful planning and more efficient execution, CAISO can avoid delays similar to those experienced in the first half of 2025 and maintain momentum across all workstreams.

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

CAISO committed to developing a more robust scarcity pricing mechanism in 2020.  The CAISO's current market design does not enable energy prices to gradually rise above the marginal cost resource as the probablity of scaricity materializing increases, similar to other ISO/RTOs.

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

CESA supports pursuing this initiative if the proposals offer significantly more efficient outage and substitution rules and processes, as this would help alleviate artificial capacity market tightness. The current proposal will not achieve these objectives.

The current bilateral substitution capacity market is plagued by several inefficiencies that contribute to artificial capacity tightness and undermine system reliability. These issues include high transaction costs associated with discovery, multi-counterparty arrangements, contracting, and settlement. There is also a notable unavailability of short-duration capacity (e.g., for one-day substitutions) and an unwillingness among suppliers to engage in the bilateral market due to these complicating factors. A critical problem arises when Scheduling Coordinators (SCs) hold back Resource Adequacy (RA) capacity for partial-month outage substitutions, inadvertently creating artificial tightness in the RA bilateral market as more capacity is withheld than necessary. This situation, coupled with outage approval uncertainty and challenges like mismatches between contract terms and outage durations, often leads to potential maintenance delays and an increase in forced outage rates, ultimately impairing system reliability.

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

CESA supports pursuing this initiative. CAISO’s studies indicate a 0.3-0.7 LOLE for 2025 and likely a higher risk of loss of load was incurred in 2024. These are much higher than the industry standard 0.1 LOLE. These results indicate that CAISO must re-examine its backstop triggers and processes to meet its reliability imperative. One tool CAISO has to maintain committed capacity at a 0.1 LOLE level, regardless of the capacity delivered from the myriad local regulatory authority resource adequacy programs, is its backstop capacity procurement process.  CESA encourages the CAISO to focus on improving its backstop capacity procurement process as a more direct approach to improving reliability.

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

CESA requests the CAISO publish another revised draft roadmap showing the planned implementation of market design changes developed through this initiative.

CESA has been advocating, since beginning of 2024, that the rapid increase in storage within the CAISO footprint urgently requires a holistic review of storage participation. This is similar to ten years ago when wind and solar reached production levels that caused the Participating Intermittent Resource Program to negatively impact market efficiency. To address this, CAISO developed a system that automatically updates resource bids within the operating hour. Market design changes of a similar magnitude should be considered for storage resources, yet after many months of Storage Design and Modeling working group meetings, limited progress has been made.

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

No additional comments.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

See opening comments.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

CALSSA supports the Demand and Distributed Energy Market Integration (DDEMI) initiative. We have participated in the initiative since the working group launched in Q1 of 2025. We will have the resources and capacity to support continued participation during the policy development phase in 2026 and beyond, if the initiative shows meaningful progress can be made on changes to policy that we have advocated for in the scoping process so far.

CALSSA members support the initiative both individually and through CALSSA, providing additional resources and capacity to this effort.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

CALSSA strongly supports the Demand and Distributed Energy Market Integration initiative, as noted below, and takes no position on other initiatives.

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

CALSSA strongly supports the Demand and Distributed Energy Market Integration (DDEMI) initiative, and we support it continuing on the timeline in the draft roadmap or more quickly. DDEMI provides an opportunity for the CAISO to increase participation of distributed energy resources (DERs) in its market. The current participation pathways include obstacles that have limited participation of DERs, especially DERs capable of exporting to the grid, such as behind-the-meter (BTM) batteries. The work of the DDEMI initiative is crucial to identify and eliminate obstacles. Doing so will allow the CAISO to gain access to a substantial resource that includes both existing and new assets. For example, if current installation trends continue, California will have over 9,000 MW of BTM storage capacity by 2040.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

Our understanding is that the CAISO’s roadmap includes policy development for the Demand and Distributed Energy Market Integration initiative beginning in Q4 2025 and continuing through Q3 2026, followed by a decision in Q4 2026. CALSSA strongly supports maintaining that current timeline for DDEMI, or accelerating it to allow implementation to begin earlier than Q1 2027.

Within the DDEMI initiative, CALSSA strongly supports addressing issues related to the ability of exporting DERs, including BTM batteries, to participate in the CAISO market. The highest priority issues are reforming the PDR model to include exports and addressing metering requirements. Related problem statements under the Performance Evaluation Methodology topic are also high priorities, including problem statement 2 (existing PEMs are not well suited for emerging DR participation—including exporting DERs like BTM batteries) and problem statement 6 (device-level registration). CALSSA strongly supports having these issues addressed early in the DDEMI policy development process and having a decision and implementation happen as quickly as possible. 

CALSSA also wishes the working group to address issues related to exporting DER market participation through other pathways, including the DER Aggregation participation model, and supports taking up those issues for policy development later in the 2026 policy development timeframe.

The DER Aggregation participation model currently does not have a pathway to access resource adequacy. This is a multi-agency issue that would require each agency to coordinate efforts and work through their respective issues. CALSSA believes that the CAISO should work through the resource adequacy issues that are within its jurisdiction for the DER Aggregation participation model.

The 2026-2028 draft policy initiatives roadmap has a second policy development phase for DDEMI issues in Q1-Q2 2027. CALSSA supports bifurcating the policy development process as a way to move more quickly to decision and implementation for issues addressed during the first policy development period ending in Q2 2026. The 2027 policy development period would be appropriate for long-term issues such as expansion of demand-side bidding discussed during the working group meeting on September 9, 2025.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

DDEMI only.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

ChargeScape is the continuation of over a decade of experience gained through the foundational work of the Open Vehicle-Grid Integration Platform (OVGIP), which was initially launched as a pilot collaboration between Ford, BMW, General Motors, and other EV automakers. The OVGIP served as an industry-first initiative to explore how electric vehicles could support grid stability and energy management through demand response and managed charging. In 2024, following the success of OVGIP’s pilots, ChargeScape was officially established an independent joint venture with BMW, Ford, Honda and Nissan as investors. ChargeScape’s long-term data agreements with these and other OEMs allow us to provide secure, reliable EV telematics data access, advanced EV load control, and direct access to the EV driver for the purposes of customer enrollment and engagement. ChargeScape’s direct OEM integrations, which include Tesla through telematics and EVSE, represent 63% of the EVs in Connecticut. ChargeScape’s areas of expertise include active EV load control via OEM telematics and networked EVSEs, localized load management to deliver asset-level optimization, and bidirectional charging (V2X).

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

ChargeScape supports the DDEMI initiative’s efforts to enhance the Proxy Demand Resource (PDR) model and urges CAISO to consider reforms that would enable energy storage resources to participate more effectively through exports. While electric vehicles currently participate in PDR as curtailment assets, bidirectional EVs functioning as mobile energy storage could provide greater system and market value if permitted to export energy into the wholesale market. ChargeScape encourages CAISO to ensure that export-related issues are explicitly included within the scope of the DDEMI initiative and that concerns related to deliverability are appropriately addressed. Although PDR remains the most compatible CAISO participation model for behind-the-meter (BTM) storage, its current design as a load-curtailment mechanism precludes measurement of exported energy. As a result, resource performance is capped based on conservative site load estimates, leaving significant BTM storage capacity underutilized and unavailable to the CAISO market.

Existing PDR metering requirements also present barriers to broader participation by limiting the use of device-level metering. The requirement for revenue-grade meters on each individual resource within an aggregation imposes substantial administrative and cost burdens. Technologies such as telematics from EVs and EVSEs represent a more cost-effective and widely available means to access data required to verify performance. 

The PDR model was originally designed for traditional demand response resources focused exclusively on load reduction behind the utility meter. However, given the evolution of distributed energy technologies, CAISO should expand the PDR model to reflect the operational capabilities of modern assets, such as bidirectional EVs, which can provide both load reduction and export services. Such an expansion would enable these resources to contribute more fully to system reliability and market efficiency by delivering exports that reduce load across portions of the distribution grid and provide value beyond individual customer premises.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

DC Energy has the resources to support active participation in the policy initiatives that may have an immediate impact on its participation in CAISO markets, but DC Energy would find it difficult to engage actively in the full panoply of possible initiatives outlined in the draft Policy Roadmap.  

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

See below 

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

The CAISO should continue to build on the past year of progress in the Congestion Revenue Rights Enhancements Working Group initiative and pursue practical improvements to improve the utility and reliability of CRRs. 

DC Energy supports the CAISO’s suggestion that the CRR Enhancements Working Group pursue a straw proposal focused on changes to the CRR product definition that will enhance their utility as a hedging instrument as a first practical step.  More specifically, expanding or redefining the times of use available for CRRs so they better match current and emerging congestion patterns, which are increasingly driven by solar and battery resources, should better align CRRs with day-ahead expectations. 

However, straw proposals to reduce the uniquely high risk of CRR underfunding in the CAISO, which ultimately diminishes the reliability of CRRs as a hedging instrument, should be prioritized first.  The CAISO should address the root causes of congestion revenue inadequacy by eliminating the current shift factor cut-off discrepancy, improving unscheduled parallel flow modeling, and improving outage reporting practices.  

These practical improvements would better align CRRs with the day-ahead congestion patterns and improve CRR underfunding, which would reduce risk premiums and thus maximize auction revenue.

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

This policy initiative is essential in order to satisfy the CAISO’s stated commitments to the Federal Energy Regulatory Commission.  The CAISO has acknowledged an asymmetry arising from the disparate treatment of CRRs in the CAISO and long-term firm OATT rights in other EDAM BAAs and has pledged to make a near-term enhancement to congestion revenue allocation under EDAM in order to address this inequality.[1]  When EDAM is first implemented, long-term firm OATT rights holders in EDAM BAAs outside of the CAISO will be eligible to receive congestion revenue from constraints that bind in other EDAM BAAs, including the CAISO, due to unscheduled parallel flows.  Meanwhile, CRR holders in the CAISO will not be eligible to receive congestion revenue on constraints that bind in other EDAM BAAs due to parallel flows.  It appears that unscheduled parallel flows on the CAISO system from power scheduled in other EDAM BAAs will be more significant than unscheduled parallel flows in other EDAM BAAs due to power scheduled in the CAISO, but nonetheless, the CAISO should make this near-term enhancement as soon as practicable to eliminate undue discrimination in the allocation of congestion revenue.

DC Energy agrees with the Draft Roadmap; the CAISO must “[d]evelop a long-term, durable design for allocating congestion revenues among balancing areas participating in [EDAM].”  All EDAM BAAs should move away from physical transmission rights because they have an inherent “use it or lose it” aspect that ties them to bidding and scheduling behavior.  EDAM should move to a system of financial transmission rights where congestion revenue allocation and the ability to hedge congestion costs are not tied to physical bids and schedules.  A combination of firm flow entitlements on seams with non-EDAM BAAs and auctioned, centrally clearing, EDAM-wide CRRs with source and sink locations across and among all EDAM BAAs, similar to interstate RTOs, is the best way to address the self-scheduling and congestion allocation issues now facing EDAM.  DC Energy supports the extension of the day-ahead market to other BAAs in the WECC but is concerned that the need for a durable long-term solution may arise quickly; therefore, the CAISO should begin the process of arriving at a durable long-term solution now.

[1] Final Proposal: Tariff Amendment – EDAM Congestion Allocation, California Independent System Operator, at 27 (Jun. 6, 2025).

7. EDAM Enhancements

DC Energy thinks it is prudent of the CAISO to reserve policy resources for EDAM as necessary.

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

Price formation is fundamental for markets and should be a priority for the CAISO.  Scarcity pricing is essential to incentivizing the efficient dispatch of resources and a necessary prerequisite to useful demand response.  As stated in the Draft Roadmap, scarcity pricing would send efficient price signals to “reduce unnecessary mitigation, better reflect system stress in market prices, strengthen reliability signals, and provide consistent incentives across the Western Energy Imbalance Market and Extended Day Ahead Market.”

11. Price Formation Enhancements: Fast start pricing

Again, price formation is fundamental for markets and should be a priority for the CAISO.  As stated in the Draft Roadmap, “integrating commitment costs of fast start resources into market prices [would] better reflect the incremental cost of serving load.

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

No comment

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

No comment

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

I can support direct participation in the DDEMI initiative and additionaly support through CALSSA, one of Enphase's trade associations.  

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

Enphase supports the Demand and Distributed Energy Market Integration initiative

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

I support this initiative because changes are needed to current CAISO models to enable exporting behind-the-meter DERs such as rooftop solar, paired batteries, and controllable devices like EVSE and Heat Pumps to participate in the CAISO market as RA resources

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

GoodLeap supports the Demand and Distributed Energy Market Integration (DDEMI) initiative. As a financier, owner, and manager of distributed energy resources we are well positioned to meaningfully participate in the DDEMI initiative outlined in the Policy Roadmap. As a member of the California Solar and Storage Association (CALSSA) we have indirectly participated in the initiative since the working group launched in Q1 of 2025 and intend to remain engaged on the policy changes that CALSSA has advocated for in the scoping process to date.  

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

GoodLeap strongly supports the Demand and Distributed Energy Market Integration initiative and takes no position on other initiatives.

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

Within the DDEMI initiative, GoodLeap strongly supports reforming the Proxy Demand Resource (PDR) to better leverage the capabilities of DERs, which may behave differently than pure load curtailment. Reforms to PDR, including allowing behind-the-meter storage-based dispatch rather than only load reduction, are essential for effectively capturing the benefits of DERs in the CAISO market.

In alignment with CALSSA, GoodLeap also wishes the working group to address issues related to exporting DER market participation through other pathways, including the DER Aggregation participation model.

In addition, GoodLeap wishes for the CAISO to work through resource adequacy issues that are within its jurisdiction for the DER Aggregation participation model.

Finally, GoodLeap supports maintaining that current timeline for DDEMI, or even accelerating it to allow implementation to begin earlier than Q1 2027.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

California Department of Water Resources – State Water Project (CDWR), Bay Area Municipal Transmission Group (BAMx[1]), and State Water Contractors (SWC) (together, Joint Commenters) submit these comments on an item that was proposed by CDWR in the 2025 Policy Initiative Catalog Because it was an infrastructure-related submission, it was routed to the 2025-2026 Transmission Planning Process to be addressed in that venue. Joint Commenters are raising it here because we believe it has not been adequately addressed and we request that this initiative be reconsidered in a complete and transparent stakeholder process.

As noted above, earlier this year, the California Department of Water Resources – State Water Project (CDWR) submitted a proposal in the 2025 Policy Initiatives Catalog to revisit/restart the Transmission Access Charge (TAC) Structure initiative that had been developed between 2016 and 2018, resulting in a Draft Final Proposal in 2018.[2] Rather than finalize the Draft Final Proposal and take it to the CAISO Board of Governors, CAISO put the TAC initiative on hold to focus on developing the Extended Day Ahead Market (EDAM). CDWR’s proposed revival of the TAC Structure Initiative was supported by the Consumer Owned Utility Sector in the Regional Issues Forum Round Table Report[3] and was strongly supported by each of the Joint Commenters. Because it was an infrastructure-related submission, CAISO routed it to the 2025-2026 Transmission Planning Process to be addressed in that venue.

Unfortunately, at the September 25, 2025 Transmission Planning Process stakeholder meeting, CAISO dismissed this proposed initiative, stating, “The ISO considered this in 2018 but held the item to enable EDAM development. Since 2018, levels of behind-the-meter solar have stabilized, rendering these changes unnecessary and overly complex in today’s market.” [4]

This statement misunderstands the motivation for the changes to the TAC structure that were summarized in the CAISO’s final presentation in the TAC Structure Initiative as follows:[5]

• Modifications to TAC structure should meet objectives of FERC ratemaking principles & ISO cost allocation principles
• Major objectives that ISO intends to reflect in proposed TAC structure modifications include two main concepts:
  • Reflect cost causation and cost drivers when decisions to invest in transmission infrastructure were made
  • Reflect current customer use and benefits, which may be different than cost causation
• ISO supports a rate structure that fairly links the billing determinants to cost causation and benefits accruing to users of the system

Joint Commenters believe that, while the scope of the Western Energy Market has evolved since 2018, the underlying reasons for modifying the TAC structure to better reflect cost causation and benefits accruing to users of the system have not changed. In particular,

• The current volumetric-only approach fails to reflect cost causation and utilization of the transmission system, resulting in inequitable allocation of costs.  Costs should reflect that transmission networks are built to handle coincident peak demand when the grid is strained the most.
• The initial TAC Structure Initiative effort had broad support and thoughtful engagement from stakeholders including CAISO’s Department of Market Monitoring (DMM), California’s three largest investor-owned utilities, municipal utilities, independent transmission developers, retail marketers and the California Public Utilities Commission.[6]
• The proposal aligns with CAISO’s Resource Adequacy (RA) capacity obligations based on contributions to coincident peak demand, where load shifting is valued under system and local RA requirements.
• The proposal is consistent with approaches CAISO’s DMM has supported for allocation of natural gas transmission infrastructure costs, arguing that recovering fixed gas transport costs through volumetric rates can cause market inefficiencies.[7] Similarly, recovering a larger portion of fixed electric transmission costs through a demand-based rate structure, and less from volumetric rates, will incentivize better load management practices through demand management programs or installation of peak shaving technologies. This behavior would reduce the need for new transmission that is driven by peak demand requirements.
• The current design sends inefficient price signals for operation of Battery Energy Storage System (BESS) resources that are located behind retail meters, since retail rates recover at least a portion of CAISO’s volumetric transmission charges resulting from BESS resource charging, even though this is during periods of abundant transmission - while their discharging during periods of peak demand reduces or delays the need for new transmission.
• The proposal is consistent with California’s climate goals as articulated by Governor Newsom[8] and state agencies[9] regarding expansion of load/demand flexibility and maximizing the existing transmission network to incentivize future users to curtail and shift loads outside of peak hours.
• Other regional transmission organizations and independent system operators factor coincident peak demand in determining and allocating transmission charges, including MISO, SPP, NYISO, ERCOT, ISO-NE and PJM.[10]

In addition to our concerns about CAISO’s misunderstanding of the substance and need for the proposal, Joint Commenters are frustrated by the process used to date. CAISO infrastructure staff have dismissed the need for this initiative, without any stakeholder meetings to discuss the issues that motivated the initiative in 2016-2018, or to consider input from stakeholders on the current need for the TAC structure changes that were fully vetted and proposed to be adopted in 2018. Joint Commenters therefore continue to request that the CAISO begin a stakeholder process in 2026 to evaluate whether there are any adjustments warranted to the recommendations included in the 2018 Draft Final Proposal.

In addition, in the Regional Issues Forum (RIF) Enhancement Project Draft Final Proposal issued on November 7, 2025,[11] the RIF Liaisons proposed to pilot the use of sector sponsors to facilitate an upcoming stakeholder process to gain experience as we transition to the Stakeholder Representative Committee process envisioned by the Pathways Launch Committee. Joint Commenters are willing to make their representatives available to serve as sector sponsors for the new TAC Structure Enhancements initiative proposed by CDWR.

[1] BAMx comprises City of Santa Clara/Silicon Valley Power and City of Palo Alto.

[2] See CDWR February 28, 2025 Comments on Catalog Submissions

[3] Regional Issues Forum Roundtable Report, May 22, 2025, Page 9

[4] September 25, 2025 Transmission Planning Process Stakeholder Meeting, Pg. 61

[5] September 24, 2018 TAC Structure Initiative Stakeholder Meeting Presentation, Pg. 5

[6] See Stakeholder Comments on Transmission Access Charge Draft Final Proposal, September 24, 2018

[7] DMM Comments - PG&E Gas EG LT Rate Design, December 10, 2019

[8] Governor Gavin Newsom – Building the Electricity Grid of the Future: California’s Clean Energy Transition Plan, May 2023.

[9] CPUC Demand Response Program / CEC Load Flexibility Goal Press Release

[10] CAISO Review Transmission Access Charge Structure Issue Paper, June 30, 2017, pp.15-18.

[11] Regional Issues Forum Enhancement Project Draft Final Proposal, November 7, 2025

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

NV Energy will make every effort to participate in every stakeholder initiative that impacts our participation in the WEIM and potential participation in EDAM. However, it would be helpful for CAISO to be mindful of the resource constraints considering the activities that are underway in the West. The stakeholder process may have large impacts to the market design and NV Energy would like to dedicate sufficient time to each initiative in order to provide the most informed and helpful comments to CAISO.

Furthermore, NV Energy implores CAISO to evaluate the frequency, length, and content being discussed in the stakeholder sessions. For example, a pattern has emerged where lengthy infrequent sessions have been scheduled with multiple initiatives with large market implications. Material in these sessions cannot be fully presented without having to shorten or skip much needed in-depth stakeholder discussion due to their complexity and importance. Additionally, the lengthy time between sessions has made it difficult to track and follow issues raised by stakeholders.

NV Energy recommends that CAISO reserve the appropriate amount of time for each meeting and schedule separate stand-alone sessions back-to-back for discussion on more contentious proposals. For instance, it would be better to discuss a complex issue in a 3-day session rather than meeting once per month. This should not be taken to mean that CAISO should speed up the pace in the stakeholder process, but to schedule more calls for complex issues and potentially consider taking on less initiatives at one time.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

NV Energy opposes the current proposed scope for the price formation enhancements.  CAISO should focus on enhancing the market power mitigation framework which NV Energy believes is further along in design. The comprehensive scarcity pricing framework is very important and deserves dedicated stakeholder time. It should not compete for attention with numerous other major initiatives that are currently underway, in implementation, or about to begin.  Scarcity pricing has large implications that impact market dispatch and should be thought out carefully rather than rushed. For perspective, the stakeholder community is preparing for an EDAM congestion revenue initiative, analyzing intertie scheduling changes from EDAM, and working on the implementation for changes from EDAM.  Additionally, the footprint of the market is on the verge of major changes with future implementations and potential participant exits. This is not the appropriate time to discuss additional large-scale market changes when stakeholders lack the data and understanding of the impacts of the new Day Ahead Market design. Decisions and stakeholder comments are better informed by market performance data which none currently exists. NV Energy believes it would be best to get the comprehensive scarcity pricing design right the first time rather than have to continuously improve because we lacked data to inform comments and market design decisions at this time.

11. Price Formation Enhancements: Fast start pricing

NV Energy supports the proposed roadmap schedule for Price Formation Enhancements: Fast Start pricing. 

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

 Price formation, please see comments above in question 10.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

PacifiCorp believes it can support the listed initiatives that are impactful to the Company. PacifiCorp thanks the CAISO and is looking forward to continued collaboration with the stakeholder community on the topics set forth in the roadmap.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

PacifiCorp provides the following comments on individual initiatives. 

3. Commitment Cost Bidding Flexibility

PacifiCorp supports the public dialogue as the initial step to ensure that the tariff filing is still in line with stakeholder needs when considering enhancements to commitment costs bidding flexibility. Based on the limited discussions that have recently resurfaced in the gas resource management working group, PacifiCorp believes this initiative may require a lot of bandwidth from stakeholders to participate, which may not be possible with EDAM go-live getting closer. If the CAISO finds this initiative will require significant stakeholder engagement, the Company recommends evaluation of this initiative later in 2026, to allow for adequate participation gained from the dispatch of resources in EDAM. 

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

PacifiCorp is highly engaged in the demand and distributed energy market integration working group and thanks the CAISO for prioritizing this effort. PacifiCorp supports continuing to develop policy with the goal of implementation by the end of 2026 as outlined in the draft roadmap. The Company continues to believe conversations and future policy development will be highly impactful to combat forecasted load growth in the coming years. Market integration of demand response programs provides another tool for balancing authority areas (BAA) to communicate additional available capacity. It is imperative that the CAISO support a participation model that allows for registration of programs with varying regulatory approval and believes as technologies continue to evolve, the market needs to also evolve with the needs of stakeholders both inside and outside of California. PacifiCorp has found the metering, telemetry, and performance evaluation methodology requirements required for program registration to be very stringent and the available business practice manual to be convoluted with requirements for the CISO BAA and WEIM BAAs. PacifiCorp looks forward to continued discussions with stakeholders and resolutions within the policy development process.  

6. EDAM Congestion Revenue Allocation

PacifiCorp supports further development to identify long-term solutions to the EDAM congestion rent allocation design. The enhanced FERC approved design provided a workable interim solution for transmission customers to receive allocation of congestion revenues, however, it was clear from the first phase of this initiative that more discussions were needed to find a permanent design.  

7. EDAM Enhancements

PacifiCorp supports initiating EDAM enhancements for policy development on an as-needed basis as reflected in the roadmap. PacifiCorp views EDAM enhancements as “EDAM day-two” refinements that should be considered and coordinated with stakeholders based on how EDAM is functioning in the market. 

8. Finance Enhancements

9. Greenhouse Gas Coordination

PacifiCorp supports the implementation schedule as depicted in the roadmap with implementation activities starting mid 2026 into 2027. 

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

PacifiCorp supports the schedule for scarcity pricing and market power mitigation enhancements as in the 2026 – 2028 Draft Policy Initiatives Roadmap. The Company believes policy development is progressing as to have a decision on enhancements by Q4 2026 at the latest.  

11. Price Formation Enhancements: Fast start pricing

PacifiCorp supports postponing discussions about fast start pricing as there are other initiatives that take precedence for PacifiCorp. Postponing the initiative will allow PacifiCorp to provide robust participation in other initiatives. 

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

PacifiCorp supports the policy development of storage design and modeling throughout 2026.The Company believes there may be some designs within this initiative that could go to the Western Energy Markets Governing Body before Q2 2027. Similarly, there may be enhancements that could be implemented on a faster timeline than what is suggested in the roadmap. 

15. WEIM Resource Sufficiency Evaluation Enhancements

PacifiCorp supports the postponement of WEIM RSE enhancements until more stakeholder bandwidth is available. Currently, there have not been substantial impacts to warrant starting another phase of this initiative.  

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

PacifiCorp does not have any additional feedback. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

As part of the 2025 annual policy submission process, PacifiCorp had submitted an initiative to evaluate how the flexible ramping capacity product is functioning within the market by analyzing price impacts, the demand curve, and its interaction with the imbalance reserve product. PacifiCorp believes this will be prudent as there’s more experience gained with EDAM but does not believe it is a primary stakeholder priority until the data is available.  

Lastly, as there was not an area within this comment template to provide feedback on the gas resource manage implementation, PacifiCorp would like to express its appreciation for the CAISO continuing to work with stakeholders on solutions and supports implementation on the timeline as drafted in the roadmap. 

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

SDG&E believes the roadmap outlines a very ambitious spread and scope of initiatives for policy development for the next three years. While we are in support of examining many of the items listed in the spreadsheet and presentation, it is critical to appropriately prioritize high-impact projects that have been consistently identified by stakeholders for enhancements. Given that EDAM/DAME is going live in 2026, SDG&E recommends the CAISO reduce the number of initiatives or extend the timeline so lower priority initiatives commence later in 2026.  The CAISO should expect that new issues will arise in EDAM/DAME akin to the EDAM Congestion Revenue Allocation initiative, which resulted in an extremely expedited initiative and required the CAISO to pause other initiatives so stakeholders could participate.  More contingency bandwidth will ensure that stakeholders are able to participate adequately and issues are resolved in a way that benefits all stakeholders.  As currently proposed, SDG&E may not have the resources to participate in all initiatives and need to prioritize.   

Additionally, SDG&E requests clarification on where the CAISO will be addressing Seams coordination, and whether this is meant to be included in the “EDAM Enhancements” initiative.  SDG&E believes that the CAISO should begin to address Seams coordination issues in the near future, as they will have significant impacts on EDAM and EDAM entities, including the CAISO BA.   

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

See comments below.

3. Commitment Cost Bidding Flexibility

SDG&E does not believe this is a priority at this time. CAISO and stakeholders need to limit the scope of initiatives in 2026 in order to successfully implement EDAM/DAME and make any necessary changes, potentially on expedited timelines. As discussed above, the CAISO should reserve additional resources and delay certain initiatives to ensure it is able to be agile in response to necessary EDAM/DAME issues. 

4. Congestion Revenue Rights Enhancements

SDG&E strongly supports including this initiative in the timeline but would appreciate more information on what the scope of the Policy Development and Decision in Q1-3 of 2026 are versus the Policy Development listed in Q1-2 in 2027. SDG&E urges the CAISO to address underfunding issues sooner rather than later, as this issue directly impacts load.   

5. Demand and Distributed Energy Market Integration

SDG&E believes this initiative could be delayed until 2027 to ensure there is enough bandwidth among stakeholders to appropriately participate. 

6. EDAM Congestion Revenue Allocation

SDG&E supports the CAISO’s inclusion of this initiative in the roadmap and the proposed timeline. We appreciate CAISO’s commitment to addressing this issue to ensure that a more permanent EDAM Congestion Revenue Allocation solution is implemented in a timely manner.  

7. EDAM Enhancements

SDG&E supports CAISO’s carveout for EDAM Enhancements, but as stated earlier, CAISO should consider that EDAM enhancements may take significant effort from stakeholders and plan for contingency if these enhancements need to take priority over other initiatives, similar to how the CAISO prioritized the interim EDAM Congestion Revenue Allocation expedited initiative.   

8. Finance Enhancements

SDG&E has no feedback at this time. If this issue can be delayed until 2027, SDG&E recommends reserving additional resources for EDAM Enhancements.  

9. Greenhouse Gas Coordination

SDG&E has no feedback at this time.  

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

As noted in the Joint LSE presentation at the workshop on 11/10/25, SDG&E supports further development of the incremental improvements identified in the CAISO Straw Proposal. However, SDG&E does not believe that the CAISO should move forward with comprehensive price formation reforms in 2026. These efforts should be delayed and the need for these reforms should be re-evaluated following implementation of and experience with EDAM/DAME. As discussed in the Price Formation Enhancements workshop on 11/10/25, EDAM/DAME will introduce new products into the market, and it is not clear at this time that an additional scarcity pricing product or modification of current products is necessary. Additionally, until Ancillary Services are co-optimized across the EDAM footprint, it would not be appropriate to introduce CAISO-only scarcity pricing.  

11. Price Formation Enhancements: Fast start pricing

SDG&E supports delaying any fast start pricing initiative until 2027. EDAM/DAME should be implemented successfully before revisiting this topic.  

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

SDG&E supports continued development of RAMPD Track 2.

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

SDG&E supports development of RAMPD Track 3B. 

14. Storage Design and Modeling

SDG&E continues to see Storage Design and Modeling as a priority initiative. In regard to the timeline, we reiterate our prior requests that functional enhancements, such as implementation of overlapping outage cards in OMS, be expedited beyond the anticipated 2027 production date.

15. WEIM Resource Sufficiency Evaluation Enhancements

SDG&E has no feedback at this time. 

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

SDG&E has no feedback at this time. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

Please see prior comments.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

SCE believes that it should have sufficient resources to actively participate in all or nearly all of the Working Group Initiatives in 2026 proposed in the Draft Policy Roadmap.  However, SCE also believes that the DAME/EDAM implementation may require more attention and dedicated resources than allocated by the CAISO in the placeholder Initiative for emergent issues for DAME/EDAM implementation.  If it is the case that Implementation requires more resources and attention than currently contemplated, it will be likely that SCE will choose to prioritize its work on policy issues related to implementation and will allocate resources away from other Initiatives. 

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

Generally, SCE supports the identified Initiaitives with exceptions identified below. 

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

SCE does support moving forward with the CAISO’s already discussed and agreed upon Straw Proposal. Additionally, SCE does appreciate that the CAISO’s is listening to parts of its stakeholder community that are pushing for the adoption of broader scarcity pricing modifications beyond that in the CAISO’s Straw Proposal. However, SCE, as indicated in our joint presentation earlier this week, believes that this Initiative is ill-timed and should be re-evaluated following the implementation of DAME/EDAM. If subsequent evaluation of market performance following implementation of EDAM reveals a need for additional scarcity pricing mechanisms, then any mechanisms considered should apply throughout the integrated market footprint and create consistent price signals and incentives for all market participants.

11. Price Formation Enhancements: Fast start pricing

SCE believes that there has not been sufficient evidence to support moving forward, even if delayed, with this Initiative.

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

The suggestion that SCE has regarding the 2026 Catalog is that the CAISO should, at least internally, be prepared to de-prioritize some of the Initiatives so that if and when policy issues surrounding DAME/EDAM implementation arise there is clear understanding of how the CAISO will allocate resources to deal with those potential emergent issues.  Experience has taught us that major changes to the markets often do not go as smoothly as desired and CAISO will need to be able to address policy issues expediently and effectively, and the CAISO may need to reflect these changes in tariff filings. It will be better to set loose expectations of what will be de-prioritized for contingency purposes.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

As mentioned above, SCE believes that the Price Formation Enhancements Scarcity Pricing Initiative be de-prioritized and re-evaluated following DAME/EDAM Implementation. Also, SCE believes that the CAISO should no longer pursue the Price Formation Enhancements Fast Start Pricing Initiative.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

Shell Energy the resources and capacity necessary to support particiaption in the proposed CAISO initiatives outlined. 

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

Shell appreciates the opportunity to provide feedback on supported items in this policy roadmap: 

1. EDAM congestion revenue: Strongly support the development of and a continued focus on a durable design for allocation of congestion revenue and believes that a stable and transparent allocation of congestion is foundational to a well-functioning market. Further, a robust data-driven analytical approach will be necessary to inform the direction of this policy process. 
2. RA modeling: Strongly support the continued focus on this multi-track effort and view this is a critical to ensure that RA accreditation matches actual reliability contribution for various resource types. 
3. CRR enhancements: Strongly support development of policy solutions focused on addressing deficit offsets, revenue inadequacy, and rational price formation. Further, considerations may be given to an EDAM-wide congestion hedging framework. 
4. Price formation: Support pursuing the development of a scarcity operating reserve demand curve that supports accurate price formation during stressed system intervals. The inherent complexity in managing price formation across CAISO/EDAM/EIM footprints with penalty prices added to products not procured by all participants necessitates attention. 
5. GHG coordination: Support the ISO's plan to continue evolving the GHG framework across WEIM/EDAM footprints with the understanding that as more jurisdictions adopt of modify GHG programs, a robust attribution and reporting process becomes increasingly important. 

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

In general, the Six Cities support or do not oppose the Roadmap, subject to the comments provided below regarding the continuation and prioritization of certain initiatives.  The Six Cities encourage the CAISO to remain flexible regarding the proposed timelines for initiatives throughout the year and to continue to communicate with stakeholders and the WEM Regional Issues Forum as projected schedules for initiatives are revised and as new initiatives are added to 2026 Roadmap or, alternatively, removed or rescheduled in favor of changing priorities. 

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

The Six Cities do not oppose reviewing the elements of the Commitment Cost and Default Energy Bid Enhancements initiative that were not implemented, but encourage the CAISO to ensure that this initiative is appropriately scoped and the objectives for the initiative well-defined to support efficient use of CAISO and stakeholder resources. 

4. Congestion Revenue Rights Enhancements

The Six Cities agree that the CRR Enhancements initiative should move forward into the policy development stage.  The Six Cities do not oppose near-term consideration of modifications to the CRR product definitions to improve hedging opportunities for LSEs and resources.  In addition, however, the Six Cities urge the CAISO to move forward promptly with further consideration of DMM’s willing seller/willing buyer proposal for the CRR auction design and also support prompt, parallel consideration of the proposal by BAMx to align eligibility for holding CRRs with demonstration of need to hedge deliveries of energy.  Auction reformation should be delayed no longer and should have high level priority in this initiative. 

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

The Six Cities support continued efforts to assess and implement measures to address asymmetries in the allocation of congestion revenues as between Extended Day Ahead Market (“EDAM”) Balancing Authority Areas (“BAAs”) and the CAISO BAA.  Correcting these asymmetries should be a high priority in 2026.

7. EDAM Enhancements

The Six Cities concur in holding space within the Roadmap to address emerging issues related to the implementation of EDAM. 

8. Finance Enhancements

9. Greenhouse Gas Coordination

The Six Cities support implementation of the Greenhouse Gas accounting and reporting framework developed in the Greenhouse Gas Coordination initiative.  The Six Cities do not see a need for near-term consideration of market design changes relating to Greenhouse Gas Coordination.  In particular, the Six Cities urge the CAISO to defer any consideration of market design changes to reflect non-priced greenhouse gas policies in market processes (e.g., dispatch order) until after implementation of the EDAM and an initial period of experience with the EDAM design.

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

While the Six Cities appreciate the CAISO’s objective of being responsive to one subgroup of stakeholders that would like the CAISO to pursue more comprehensive scarcity pricing reform beyond the changes discussed in the CAISO’s Straw Proposal in this initiative, the Six Cities remain concerned that focusing on comprehensive scarcity pricing measures is an unneeded distraction at this time.  Instead, consideration of more expansive scarcity pricing proposals should be deferred until after the Day Ahead Market Enhancements and EDAM are implemented and there has been an initial period of experience with those very substantial market design changes.  The Six Cities do support advancement of the market power mitigation related elements of the CAISO’s Straw Proposal, which are necessary to provide parallel treatment of BAAs participating in the EDAM, and they likewise support continued consideration of the incremental changes related to scarcity pricing in the Straw Proposal. 

11. Price Formation Enhancements: Fast start pricing

The Six Cities oppose continued consideration of fast start pricing.  The work conducted within the Price Formation Enhancements initiative does not demonstrate a need for fast start pricing in the near term.  The Six Cities recommend removal of this topic from the Roadmap. 

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

The Six Cities also support consideration of comprehensive changes to the CAISO’s Maximum Import Capability rules within this initiative and request confirmation as to the applicable track for this topic, which is not reflected in the Roadmap. 

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

The Six Cities also support consideration of comprehensive changes to the CAISO’s Maximum Import Capability rules within this initiative and request confirmation as to the applicable track for this topic, which is not reflected in the Roadmap. 

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

At this time, the Six Cities recommend deferring this initiative until after the implementation of the EDAM and the Day Ahead Market Enhancements (“DAME”).  Any immediate issues that require attention could likely be handled in the EDAM Enhancements initiative or addressed through a standalone policy effort.

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

The Six Cities have no suggestions for the 2026 process at this time, but look forward to collaborating with the WEM Regional Issues Forum to discuss proposals for new initiatives and prioritization of new and existing initiatives.  The Six Cities request that the CAISO provide a further comment period for proposed new initiatives in January/February 2026, consistent with prior years’ Catalog development process. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

Please refer to the comments provided above.  The Six Cities specifically support deprioritization of comprehensive scarcity pricing measures and removal of fast start pricing from the Roadmap. 

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

SWC  aligns our comments with the California Department of Water Resources on the following initiatives: Congestion Revenue Rights Enhancements, Demand and Distributed Energy Market Integration, and Resource Adequacy Modeling and Program Design Track 2. We also wish to note our joint comments with CDWR and BAMx regarding the Transmission Access Charge Structure initiative.

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

We support the continued work of the DDEMI working group and appreciate CAISO staff’s engagement. We urge CAISO to advance initiatives that have demonstrated quantifiable value to the market.

We echo the California Department of Water Resources' comments recognizing participating load resources that are already integrated into the CAISO system and have quantifiable and reliable performance. We believe a financial analysis is necessary to quantify the benefits and should include reduced curtailment of renewable energy, better utilization of existing capacity, potential for additional participation from PL resources, and the avoided costs of dispatching higher priced generation.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

SWC aligns our comments with the CDWR regarding the creation of a scheduling coordinator outage substitution pool to provide transparency and flexibility for sellers and buyers.

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

SWC recommends further developing the stakeholder processes around Non-Catalog items to allow for greater stakeholder input and discussion with CAISO staff.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

As noted, we along with other stakeholders - BAMx and CDWR support the reconsideration of the Transmission Access Structure initiative proposed by CDWR earlier this year.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

We strongly support CAISO moving forward with policy development for the DDEMI initiative beginning in Q1 2026, as outlined in the draft ISO policy roadmap. With more than 2,500 MW of behind-the-meter storage already deployed in California—and an additional 50 to 80 MW coming online each month—this initiative is essential to removing existing barriers and enabling these resources to actively participate in the CAISO market.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

Tesla supports the Demand and Distributed Energy Market Integration (DDEMI) initiative and confirms that we have the resources and organizational capacity to actively participate throughout the 2026-2028 policy development cycle. Tesla has participated consistently since the initiative launched in early 2025 and will remain actively engaged to advance reforms that meaningfully address the challenges facing distributed energy resources (DERs) participation in the CAISO market, particularly behind-the-meter (BTM) storage.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

Tesla encourages CAISO to identify priority solutions within DDEMI, such as near-term PDR program enhancements, and place those items on an expedited timeline within the broader roadmap to ensure early progress on the most impactful reforms. Otherwise, Tesla generally supports the DDEMI proposed timeline, as the initiative is the key venue for addressing long-standing barriers that limit the participation of behind-the-meter storage and other DERs, including the need to credit exported energy in PDR performance, modernize metering requirements to enable cost-effective device-level measurement, update baseline methodologies, and establish a viable path for exporting DERs to qualify for resource adequacy. With California’s BTM storage fleet rapidly expanding, timely reforms are essential to unlock meaningful system benefits, strengthen reliability, and ensure DERs can fully participate in CAISO markets.

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

The Energy Authority (TEA) finds CAISO's 2026-2028 Policy Roadmap to be an achievable plan that will require strong stakeholder engagement but ultimately provide a good return on that investment of time and effort.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

TEA supports all initiatives included in the Roadmap and sees them as balancing the priorities of stakeholders across multiple areas well. That said, TEA would appreciate a more explicit acknowledgement of the need to assess and develop market seams solutions, specifically in two areas: (1) enhancing bilateral transaction efficiency between the WEIM/EDAM ares and adjacent SPP markets (Markets+ and RTOE); and (2) enhancing intertie transaction efficiency and alignment internal to CAISO's markets (i.e., modeling and effecting transfers between WEIM and EDAM, and transfering different types of products across all areas). TEA believes these efforts could generally be woven into existing identified initiatives but still believes stakeholders would benefit from a direct description being added where appropriate.

3. Commitment Cost Bidding Flexibility

TEA strongly supports this initiative as a path for addressing price-formation issues in the day to day performance of CAISO's markets, vs. the edge-case scenarios generally targeted in the Price Formation Enhancements initiative when looking at scarcity pricing. Further, TEA appreciates that CAISO is following through on a promise made when CCDEBE's initial phase moved forward in the late 2010s and stakeholders compromised on the design on the expectation that a long-term solution that recognized the value of market-based commitment cost bidding. 

4. Congestion Revenue Rights Enhancements

TEA supports additional work on the CRR market but requests that this work be tightly coordinated with the EDAM Congestion Revenue Allocation workstream.

5. Demand and Distributed Energy Market Integration

TEA supports this effort but requests that EDAM Entity BAs/TSPs be brought into the working groups as solutions are developed and encouraged to scope changes to their EDAM Tariffs and Business Practices to ensure any policy developed at the CAISO level that would benefit the non-CAISO EDAM BAAs' market participants are able to provide that value as soon as possible.

6. EDAM Congestion Revenue Allocation

TEA strongly supports this initiative. TEA expects the existing EDAM CRA methodology will severely limit EDAM benefits and harm certain entities, especially smaller LSEs that will be relying on NT transmission in an EDAM BAA. TEA also expects the existing methodology will undermine the efficiency of the CAISO CRR market. TEA therefore is hopeful this initiative will receive sufficient attention and move quickly from ideation to implementation. 

7. EDAM Enhancements

TEA supports CAISO leaving room in its stakeholder process for working on unexpected issues that may arise during EDAM implementation or areas where the market is functional but could be improved. TEA would like to understand better though how CAISO will identify and commit to enhancements, consider requests, etc.

8. Finance Enhancements

9. Greenhouse Gas Coordination

TEA supports this effort but does not find reporting on the market to be as high of a priority as executing the market and therefore to the extent resources become constrained, TEA sees there being higher-value deliverables that should be targeted.

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

TEA at this time does not see value in pressing forward with the current trajectory of the scarcity-pricing and MPM aspect of PFE but does believe that with some revisiting of the purpose of pursuing PFE in general, this work could move in a helpful direction - for example, by looking at broad price formation trends and externalities, including how the presence of adjacent organized markets with different price formation rules will impact price formation in CAISO's markets.

11. Price Formation Enhancements: Fast start pricing

TEA believes that fast-start pricing similarly needs to revisit its purpose in the context of CAISO's markets as they exist today and as they are evolving in the coming years, especially related to transacting at market seams.

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

In concept, continuing to enhance the WEIM RSE is a good target. However, working to perfect that model at this point when the WEIM as a stand-alone market has a limited future (practically speaking) may not be the best use of time. If CAISO is to continue working on WEIM RSE enhancements, they should be done with an eye toward what is most useful within an EDAM context - for example, given EDAM, are there AET enhancements? Is that a program that needs to continue once EDAM's scale outweighs WEIM-only participation?

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

TEA appreciates CAISO's work on its Policy Roadmap and Catalog over the past few years. Each cycle has seen improvements and increased participation and buy-in among stakeholders. It is easy to forget how far this effort has come now that the process is stabilizing and working well year on year. Going forward, TEA would like stakeholders and CAISO to consider how to integrate EDAM Entity-owned stakeholder and change-management processes in over-arching CAISO efforts, and how to integrate that with Board and GB oversight and the role of the RIF.

Thank you for the opportunity to provide comments and all the work that has gone into incorporating stakeholder input in this annual process.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

See "support w caveats" notes above.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

TransAlta Energy Marketing U.S. (TEMUS) will participate, either directly or indirectly, in advancing policy initiatives with the greatest impact to its businesses.

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

It is unclear how this initiative can proceed as a stand-alone initiative given the interdependence with the Extended Day-ahead Market (EDAM) and on-going and emerging issues with its implementation.

5. Demand and Distributed Energy Market Integration

6. EDAM Congestion Revenue Allocation

It is unclear how this initiative can proceed as a stand-alone initiative given the interdependence with the Extended Day-ahead Market (EDAM) and on-going and emerging issues with its implementation.

7. EDAM Enhancements

This initiative appears to be a “catch-all” placeholder for emerging issues with EDAM implementation – it is unclear whether this proposed EDAM Enhancements initiative would replace or supplement the existing EDAM initiative still listed under the CAISO’s policy initiatives.

TEMUS supports flagging this initiative with the highest priority assuming that it is intended to be a collaborative effort with stakeholders, unlike the August 21 and November 5 workshop “downloads” held under the current EDAM policy initiative.

8. Finance Enhancements

9. Greenhouse Gas Coordination

TEMUS strongly recommends that the CAISO prioritize implementation of the EDAM and address ongoing issues before tackling this initiative so as to avoid misleading or incorrect emission reporting, which could have serious unintended financial or regulatory consequences.

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

Given the lack of progress on addressing the need for scarcity pricing in the current policy initiative, TEMUS recommends the CAISO continue the work on this initiative.

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

15. WEIM Resource Sufficiency Evaluation Enhancements

Again, TEMUS notes the potential dependencies between this initiative and EDAM implementation issues, Day-ahead Market Enhancements (DAME) configurable parameters, long-term EDAM Resource Sufficiency Evaluation solutions and interoperability with the Western Resource Adequacy Program (WRAP).

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

CAISO’s decisions regarding the selection of policy initiatives both for consideration and for action remains completely opaque. In addition, there should be a process to revisit initiatives previously identified by stakeholders, especially if they are submitted multiple times.

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?

TEMUS recommends that the CAISO focus on EDAM implementation and collaboratively addressing issues that emerge. In addition, TEMUS recommends that the CAISO immediately create a clear and transparent process for stakeholders to stand up emerging implementation issues to be addressed instead of relying on “back-room” lobbying.

1. Please indicate whether your organization has the resources and capacity to support participation in the portfolio of policy initiatives outlined in the draft 2026-2028 Policy Roadmap?

2. Please describe your organization’s support for each of the individual initiatives listed in the draft 2026-2028 Policy Roadmap:

3. Commitment Cost Bidding Flexibility

4. Congestion Revenue Rights Enhancements

5. Demand and Distributed Energy Market Integration

US Solar is a strong supporter of the DEMI policy effort. 

Distributed Energy Market Integration is a critical policy initiative, and should be expanded to include both Behind the Meter AND Front of the Meter DERs. 

There were many comments on the recent CPUC proposed procurement order that advocate for greater procurement of DERs, and these resources should be better forecasted and modeled and integrated into the CAISO system. 

6. EDAM Congestion Revenue Allocation

7. EDAM Enhancements

8. Finance Enhancements

9. Greenhouse Gas Coordination

10. Price Formation Enhancements: Scarcity pricing and market power mitigation

11. Price Formation Enhancements: Fast start pricing

12. Resource Adequacy Modeling and Program Design: Track 2, outage and substitution

13. Resource Adequacy Modeling and Program Design: Track 3b, backstop reform and long-term EDAM Resource Sufficiency Evaluation solutions

14. Storage Design and Modeling

There should be a greater focus on Distribution System connected BESS systems and the related policies beyond the grid charging or lack of charging topic. 

15. WEIM Resource Sufficiency Evaluation Enhancements

16. Do you have any additional feedback on the draft 2026-2028 Policy Roadmap, or suggestions for changes to the 2026 Catalog and Roadmap process?

Deliverability for Distributed Generation (DDG) is an underutilized mechanism that should be evaluated for potential policy reforms. Given the significant near term need for clean energy, and the multiple commentors advocating for greater DER procurements as part of the CPUC near term procurement order - there should be a near term evaluation of how the DDG process can be improved to enable more procurement and deliverability in advance of the next CAISO transmission cluster study. 

The DDG effort could be included as part of the DER integration topic and/or the Resource Adequacy topic. 

17. Are there any specific initiatives or areas in the Roadmap that your organization believes should be deprioritized or reconsidered?