Comments on 1/21 call

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

The Salt River Project Agricultural Improvement and Power District (SRP), Arizona Public Service (APS) and Tucson Electric Power (TEP), collectively identified as the Arizona Utilities, appreciate the opportunity to comment on the January 21, 2025, GHG Coordination Working Group meeting. The Arizona Utilities continue to evaluate the proposed “No GHG Cost” counterfactual and support further analysis on secondary dispatch, attribution of imports, and policy considerations related to the overcollection of GHG costs. The Arizona Utilities remain engaged in discussions regarding GHG accounting and reporting to ensure an approach that supports state-mandated as well as voluntary corporate GHG reduction goals. The Arizona Utilities request clarification on how the proposed climate region concept would apply to entities with voluntary corporate GHG goals. The Arizona Utilities encourage a reporting framework that provides access to granular emissions data and is open to further discussion on mapping SC IDs to LSEs. Additionally, the Arizona Utilities seek more information on how non-participating entity contracts will be accounted for in emissions calculations.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

The Arizona Utilities appreciate the explanation and detailed example provided for the proposed “No GHG Cost” option. The Arizona Utilities encourage the minimization of secondary dispatch and ensuring fair attribution of emissions. The Arizona Utilities agree with comments made during the working group session supporting additional examples. The following topics could be explored in future meetings/examples:

1.   Comparison of secondary dispatch impacts between the current approved counterfactual and the No GHG Cost option.

2.  Additional details on the impact of attributing only the portion of the imports above the counterfactual to a pricing zone versus all of the imports.

3.  Policy considerations for managing the overcollection of GHG costs.

4.  Implications to generators providing low emission energy and changes in attribution of those resources to the pricing zone.  The example suggests that the result would be less total GHG attributions, and therefore potential revenues, to external resources, which could lower the incentive to participate with GHG bids.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

The Arizona Utilities remain supportive of an after-the-fact approach to accounting for GHG and encourage the CAISO to continue incorporating feedback from entities with state-mandated GHG reduction goals as well as those with voluntary corporate GHG reduction goals. The Arizona Utilities are concerned that the proposed concept of a climate region lacks clear criteria and may exclude entities with voluntary corporate GHG reduction goals. In stakeholder calls, CAISO has stated that it will not determine which entities are in the climate region or not, and the Arizona Utilities are unclear how the accounting for a climate region would be done without involvement from the CAISO. The Arizona Utilities request clarification on the criteria and process for defining a climate region, and if the CAISO will provide any guidance for creating a climate region. The Arizona Utilities are concerned that the inclusion of a climate region will lead to inequitable treatment.

Additionally, the Arizona Utilities appreciate the CAISO stating on the stakeholder call that this report would be optional for entities. The Arizona Utilities agree that this report should be created or utilized at the discretion of each entity, subject to the requirements of their respective regulator. It is also critical that the data that is shared outside of the confidential report be publicly available or, alternatively, aggregated in a manner that it does not implicate one entity.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

The Arizona Utilities prefer access to the report in total at the most granular level but would accept the residual emission rate if it is the only available option. Rather than producing just the “final total” for each entity, the Arizona Utilities would prefer that each line item be available on the report (i.e. Dispatched Owned Resources MW and GHG by resource, Dispatched Contracts for Purchase MW and GHG by resource, etc.). By providing this level of granularity rather than just a total, entities may be able to extract the information needed for their internal reporting requirements.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

The Arizona Utilities are open to mapping SC IDs to an LSE in order to produce a GHG report. It may require participants to create additional SCs to identify any 3^rd party generation in their BA and vice-versa for reporting purposes. However, SC mapping may not resolve challenges in differentiating retail load from BA load. This is important for SRP, as its voluntary corporate GHG reduction goal is based on retail load.

The Arizona Utilities request more information on the expected timeline for implementing the report using each of the possible options: BAA level, LSE level, and SC mapping level.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

The Arizona Utilities are open to further discussions on this topic and requests more information on how non-participating entity contracts would be included in emissions calculations.

7. What additional content would you like to see in future GHG calls?

The Arizona Utilities are supportive of the direction of the GHG Coordination Working Group and are interested in further discussion on both the Accounting and Reporting Approach as well as GHG counterfactual options. The Arizona Utilities support stakeholder request for more information on the impacts of secondary dispatch.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

BPA appreciates the CAISO’s continued effort to develop a GHG accounting and reporting approach.  Overall, BPA does not object to the CAISO’s plan to begin with accounting and reporting on a BAA level, but BPA currently does not see use in that approach for BPA.  BPA does find value in a scheduling coordinator or LSE level approach where the results are tailored to a specific entity.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

BPA appreciates the CAISO’s willingness to explore other options.  To the extent the CAISO is providing analysis on alternative options to the counterfactual or other aspects of the market design for GHG pricing, BPA requests that the CAISO also share information on the other objectives that were considered as part of the original discussion on design for pricing programs.  It is difficult to provide substantive feedback on an option without a more holistic look at how a particular alternative aligns with the totality of objectives.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

No comment.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

To the extent the CAISO is providing reporting and calculating the residual rate on a BAA level, BPA does not see a use for an individual report at this time. 

Given BPA’s position is the BAA level calculation does not meet individual entity reporting needs, when the CAISO moves to an entity-level (whether scheduling coordinator or LSE) approach, at that time an entity level report would provide value.

BPA would also like to understand how the BAA level approach could provide for appropriate identification of null resources.  Additional discussion is needed on this topic.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

BPA requests the CAISO clarify whether the scheduling coordinator approach will provide the flexibility for a Scheduling Coordinator to exclude resources that they may be the Scheduling Coordinator for but are not owned/contracted to the scheduling coordinator (and vice versa).  Assuming this functionality will exist, BPA believes this approach may meet its needs. An example of how this mapping would work would be helpful. 

BPA notes that its support for an LSE approach would treat BPA as the LSE for customer loads in its BAA (NOT its individual customers who are technically the LSEs).  If BPA is correctly understanding what the CAISO intends with the scheduling coordinator approach, it may provide for similar treatment.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

It seems unlikely that the CAISO will be able to identify contractual arrangements between non-participating entities.  This may be an area where it is unrealistic to map such resources anywhere but the residual mix.  Based on the discussion at the workgroup, there is also a related question on how the CAISO could identify owned resources for a non-participating entity.  BPA believes it is important to identify a non-participating entity’s owned resources (at least those over some de minimis threshold) participating in the market.  If this is not information the CAISO requests today from participants, is it a parameter the CAISO could request in the future?  Or is there public data the CAISO or third party could use to identify resource ownership for purposes of the GHG report? 

7. What additional content would you like to see in future GHG calls?

No comment at this time.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

Comments on Greenhouse Gas Coordination  

Working Group Meeting – January 21, 2025

Department of Market Monitoring

February 11, 2025

Summary

The Department of Market Monitoring (DMM) appreciates the opportunity to comment on the California ISO’s Greenhouse Gas Coordination Working Group meeting held on January 21, 2025.[1] The presentation addressed two topics: (1) the further specification of the accounting and reporting approach to allocating greenhouse gas (GHG) emissions to entities not in priced GHG regulation areas and (2) the no GHG cost reference pass counterfactual. DMM offers brief comments on each of these topics below.

DMM continues to support development of the accounting and reporting approach

DMM continues to support the further development of the accounting and reporting approach as a near-term means of incorporating non-priced GHG policies into the extended day-ahead market (EDAM). The accounting and reporting approach is a wholly out-of-market approach that leverages and enhances existing market processes and data to allocate GHG emissions to entities in areas with non-priced GHG policies. The primary benefit of this approach is that it is a non-market process that attributes GHG emissions after the market runs, and as such would likely have minimal direct market impacts.

The counterfactual method with no GHG cost may minimize the likelihood of secondary dispatch, but introduces additional complexities to the overall market design

The discussion of the counterfactual reference pass with no GHG costs focused on examples designed to demonstrate how the no GHG cost reference pass counterfactual would work, and why it could lead to the over-collection of GHG revenues. The ISO also discussed potential approaches to address the over-collection of GHG revenues under the no GHG cost counterfactual method.

The no GHG cost counterfactual method sets the baseline reference by calculating the optimal dispatch for the whole EDAM footprint, excluding GHG costs. The baseline is then used to identify which imports into priced GHG regulation areas would be due to the inclusion of GHG costs into the market optimization. This approach is distinct from the method currently approved for use in EDAM (CAISO method) and the method proposed by Vistra and other stakeholders (Vistra et al method) because it does not limit the optimized counterfactual dispatch to either the non-GHG regulation areas or individual non-GHG regulation balancing areas.

One of the potential advantages of this approach is that this counterfactual takes into account the entire EDAM grid area and all potential transfers and resources, which leads to a more complete accounting of transmission constraints and resulting congestion. Additionally, the use of the whole EDAM area in the reference pass results in a counterfactual with full economic displacement across all EDAM BAAs. This may reduce the likelihood of estimated secondary dispatch because the pool of attributable resources will be smaller due to the allowance for transfers into the priced GHG regulation areas.

In the working group presentation, the ISO further elaborated on the potential for over-collection of GHG revenues in the no GHG cost counterfactual method. The potential for over-collection of GHG revenues arises from the fact that all imports into a GHG regulation area are settled on the marginal price, which includes the GHG marginal cost component, but only attributed imports are paid the GHG marginal cost component. In the case of the CAISO method and Vistra et al methods, this is not an issue because those reference pass counterfactual methods do not include imports into priced GHG regulation areas, and as such all imports into those areas are attributed.

However, in the case of the no GHG cost counterfactual method, there may be a mix of imports that are attributed and unattributed. This is because the no GHG cost method optimizes across the entire EDAM footprint and permits imports into GHG regulation areas in the reference pass. These imports into GHG regulation areas that occur in the reference pass are not attributed, and as such are not paid the GHG marginal cost component. This can lead to over-collection of GHG revenues.

The ISO put forward two possible remedies for over-collection. The first proposed remedy was an uplift payment to load, equivalent to the charged GHG cost for unattributed transfers. The second remedy recognizes that unattributed transfers into a GHG regulation area carry a cost that priced GHG regulation areas wish to capture. To capture that cost, the ISO proposed calculating the average GHG cost of unattributed reference imports into priced GHG regulation areas. That average cost would then be used to calculate the total GHG cost of those unattributed imports, subtracted from the over-collected revenue, and given to the relevant regulatory agencies. The remaining portion of the over-collected revenue would be returned to load.

The second remedy described above requires that the ISO develop a means of calculating the cost of GHG associated with non-attributed imports into priced GHG regulation areas. The introduction of a non-marginal pricing approach to GHG, and an uplift payment into the settlement process for GHG costs, would introduce additional complexities into the overall market design. As such, the ISO should specify in greater detail how the pricing mechanism, settlement, and uplift payments would be determined, in order to allow more complete analysis of this proposed approach.

The no GHG cost counterfactual approach does not account for implicit GHG costs included in energy bids of resources in priced GHG regulation areas

DMM recognizes that the no GHG cost counterfactual is a new possible approach that is still under development. As noted in previous comments, one important element missing from the proposed no cost GHG counterfactual is an approach to extract or control for the GHG costs in priced GHG regulation areas.[2] For resources within priced GHG regulation areas, GHG costs are implicitly included in the energy bids rather than explicitly included as a discrete component of the bids. This is in contrast to resources in non-priced GHG regulation areas, which include an explicit and discrete GHG bid cost adder. 

If the embedded GHG costs are not extracted from the bids of resources in priced GHG regulation areas, the no GHG cost counterfactual method would not provide an accurate measure of what the optimal solution would have been in absence of any GHG costs in the market footprint. DMM requests that the ISO propose one or more methods for how this could be achieved. 

[1]  GHG Coordination Working Group - January 21, 2025, California ISO, January 21, 2025:

   https://stakeholdercenter.caiso.com/StakeholderInitiatives/Greenhouse-gas-coordination-working-group

[2] Comments on Greenhouse Gas Coordination 11-12-2024 Working Group Meeting, Department of Market Monitoring, November 26, 2024: https://stakeholdercenter.caiso.com/Common/DownloadFile/64a1c706-1b28-44fd-88a2-5a46175ec1dc

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

7. What additional content would you like to see in future GHG calls?

Please see the PDF attached below the final question for DMM's fully formatted complete set of comments. For the reader's convenience, the complete text of the comments is pasted in response to #1, but there may be some formatting errors.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

Our comments focus on supporting the A&R approach, with particular interest in future discussions about accounting for null power. We request more details on the smaller working group structure. We articulate some benefits of CAISO producing residual rate data and LSE-level reports, as well as an ideal outcome, while emphasizing the need to coordinate with WREGIS to prevent double counting of renewable energy. We provide some comments on voluntary climate regions. We raise some concerns related to potential inconsistencies between SC-level mapping and LSE reporting. We also suggest that non-participating entities' contractual arrangements should either be determined based on public data and subsequently reviewed or the associated generation should go in the residual mix.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

No comment at this time.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

We continue to support the development of an A&R approach and we agree with the premises laid out in the Issue Paper. We are most interested in discussions related to accounting for null power as a part of the approach.

We’d like some more information on the smaller group breakout sessions being considered for the A&R approach development. What is the desired output, e.g., detailed accounting and reporting rules, an expanded higher-level issue paper laying out the scope and identifing relevant questions and options? What issues and questions would the smaller group focus on? What would fall within the obligations of the smaller group members relative to the larger group, e.g., leading calls, preparing materials, report drafting, etc.? What is the overall timeframe, cadence, meeting length, and number of sessions for the smaller group?  

Further comments on the A&R approach below.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

We recognize the added value of market residual mixes for LSEs in states with GHG reporting and other requirements, particularly the advantages this would provide over the default emissions rates, grid averages, etc. This may support additional market participation. We also recognize that residual rate data alone would not provide LSEs with entity-specific allocation data that could be used for reporting. While LSEs could develop their own full reports using their own data, CAISO-calculated report totals would produce greater consistency among entities participating in the market, which may provide even greater support for market participation. 

Resource-specific allocation to LSE load must be coordinated with REC systems (e.g., WREGIS) in order to avoid double counting of renewable energy generation and associated emissions. Some complications related to avoiding double claims may be at least partially avoided by producing only a market residual rate rather than a full report, though RECs and null power should be considered in that calculation as well. Those complications would remain with the individual entities and states. Ideally, CAISO could produce LSE report totals that properly account for null power, share the allocation data with WREGIS, and WREGIS could incorporate that allocation data into its system. This would meet the most needs of entities with reporting obligations, support the greatest market participation, support market-wide and perhaps even regional consistency of allocation, and avoid harming renewable energy markets and programs (compliance and voluntary) that rely on RECs.

Regarding voluntary “climate regions” and the calculation of climate region residual rates, we are generally agnostic on the idea of voluntary sharing of excess MW and emissions among LSEs within a defined voluntary climate region before allocation to the residual mix. Null power should also be properly accounted for in this allocation of generation, and it should be included in what is shared with WREGIS for WREGIS-registered generation. While we also generally agree with other stakeholders at the meeting that there is nevertheless a distinction between GHG pricing zones (compliance climate region) and voluntary climate regions, we would like to hear more discussion of whether and how this distinction affects the need for the zone or region to be reflected and accounted for before application of the market residual mix, or otherwise how the distinction between compliance and voluntary climate regions would be reflected in the accounting.

We generally agree that netting out what was attributed to GHG zones in the market appropriately recognizes that attribution affects allocation and aligns the A&R approach with how the deeming works. A conversation is needed about the designation of null power in attributed generation, including whether to allow attributed generation to be subsequently called null. Consistency between resource-specific attribution and allocation and properly reflecting resource-specific attribution in a comprehensive load-based accounting framework would appear to require that that not be allowed. 

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

If there can be a consistent methodology for mapping SCs to LSEs and agreement on that method for allocation to LSEs, such that LSE-level reports can be provided, that would have the same implications for other tracking and allocation systems. Again, in this case, null power would need to be properly accounted for and the resulting allocation would need to be coordinated with WREGIS to avoid double counting of renewable energy. However, with SC level mapping of LSEs as the basis for LSE-level data, there might be a discrepancy with reporting that LSEs do (e.g., to states) based on their own load data. That inconsistency may cause confusion and present complications with respect to coordinating allocation and claims with REC systems. For example, we may see a situation where CAISO is producing LSE-level reports based on SC mapping, as well as individual reports by those LSEs based on their own contractual arrangements (resulting in a different allocation), as well as an allocation of renewable energy to LSEs based on RECs that (if not properly coordinated with the previous two) results in yet a third different allocation of generation. This should be avoided.

If allocation terminates at the SC-level, it is unclear how SC-level allocation would affect retail claims. Resource-specific accounting and claims at a broader level may cause confusion or inconsistency with respect to retail claims. As we commented previously (see our 10/2/24 comments), for load-based accounting, this question is about the boundary within which the retail claim/attributes need to remain and between which double counting needs to be prevented. If allocation is to load in a larger boundary rather than a single group of customers (LSEs), then trading, individual claims, and differentiated reporting is still possible within the boundary. The individual retail claims may be unclear, and this may make enforcement of the allocation to load (i.e., preventing attributes from leaving the larger boundary) more difficult.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

It was noted at the meeting that full LSE reports under an A&R approach require entities to notify CAISO about what generation should be associated with their entity. Otherwise, the contractual arrangements of non-participating entities will not be reflected and associated generation will go into the residual rate. That is generally correct and consistent with how other all-generation certificate tracking systems in other regions of the country work: non-participating generation is reported and goes in the residual mix. If entities wish to have their generation kept out of the residual mix and to be allocated on a specified basis, then they must participate in the A&R framework (or register in the case of all-generation certificate tracking systems). However, we generally agree with other stakeholders in the meeting that CAISO should be able to access public information about ownership of generating resources and map resources to LSEs using that public data, while giving non-participating utilities the ability to object/override it.

7. What additional content would you like to see in future GHG calls?

CRS is most interested in questions related to RECs and null power and coordination with WREGIS.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

PG&E thanks the ISO for its continued effort to provide greater transparency into GHG accounting. PG&E supports creating a voluntary emissions accounting system that encourages participation in EDAM and WEIM by helping those participants with non-priced GHG programs or targets. However, PG&E’s support is predicated on the assumption that the voluntary accounting system will not affect California GHG accounting and will be paid for by its participants. In addition, PG&E encourages the ISO to create a separate track within this working group for discussion of the EDAM GHG counterfactual to ensure the right audience is present and the proper resources and time are spent to have further dialogue on the counterfactual's implications in EDAM and WEIM.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

PG&E encourages the ISO to create a separate track within this working group for discussion of the EDAM GHG counterfactual to ensure the right audience is present and the proper resources and time are spent to have further dialogue on the counterfactual's implications in EDAM and WEIM. PG&E believes the correct question is, “How much is each resource expected to serve native load in the day-ahead timeframe?” This is critical to understanding which counterfactual is the right one.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

No comment.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

No comment.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

No comment.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

No comment.

7. What additional content would you like to see in future GHG calls?

No comment.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

PacifiCorp continues to strongly support the direction the CAISO is taking throughout this process. In line with previous comments, PacifiCorp endorses the progressive development of the accounting and reporting framework as it adapts to evolving reporting requirements.  

PacifiCorp’s comments discuss the following:  

• PacifiCorp recommends re-evaluating the counterfactual after EDAM go-live and continued evaluation as the market footprint expands. 
• PacifiCorp supports the adoption of the market residual rate first and recommends the CAISO to continue to participate in rulemaking processes to determine whether the full report is necessary. 
• PacifiCorp does not believe that scheduling coordinator level reporting would equate to the LSE level reporting sought by stakeholders. 
• PacifiCorp supports CAISO’s proposal to reflect long-term contractual arrangements but ideally would want to move to have short-term contracts in the future. 
• For non-participating entities’ resources, the approach discussed during the stakeholder call is appropriate where the CAISO will utilize the Masterfile, eGRID, EIA and lastly a calculation based on fuel type and heat rate done by the CAISO. 

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

PacifiCorp thanks the ISO for walking stakeholders through detailed counterfactual examples. PacifiCorp continues to support moving forward with the FERC-approved counterfactual design, without precluding revisiting the other options presented after operational experience is gained after the launch of EDAM.  At this time, without operational data, it is difficult to gauge what changes to the reference pass should occur. The addition of more EDAM participants in 2026 into 2027 will introduce further complexity into how the overall functionality is performing which will provide valuable insight.  

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

PacifiCorp appreciates the CAISO’s summation of the stakeholder group’s objectives, problem statements, and agreed-upon foundational solution of the “accounting and reporting” paradigm to address non-price based states. The presentation accurately captures the issues and discussion to date. 

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

PacifiCorp has consistently advocated for and continues to support the adoption of a market residual rate. This rate aligns with its existing reporting frameworks and serves as the most appropriate characterization of unspecified market power for clean energy compliance reporting. Ultimately, air regulators have the authority to determine how regulated entities should report unspecified energy. It is anticipated that upcoming rulemakings will address this subject in the context of organized markets expansion.  

PacifiCorp understands the differences between the two reports regarding timelines, costs, and data gaps. Therefore, while generally supporting the full report in the future, PacifiCorp recommends prioritizing the production of the residual rate first due to the reduced administrative burden placed on the CAISO. In either case, PacifiCorp would still be responsible for compiling its final compliance report to all regulators as there are remaining reporting elements that the CAISO cannot produce through the full report option. In the meantime, CAISO should participate in rulemaking processes and continue to collaborate with regulators to determine if the full report option is necessary.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

In PacifiCorp’s case, preparing reports based on Scheduling Coordinator mapping will not add additional value as it will not correlate with PacifiCorp’s LSE-level reporting. This is due to differences in how multi-jurisdictional retail providers divide the system and assign resources to retail customers in individual states. Additionally, in the broader discussion, it is PacifiCorp’s understanding that a single scheduling coordinator could be responsible for scheduling multiple assets, therefore, this granularity may not add value but defer to other stakeholders on the usefulness of this enhancement. PacifiCorp adds that while the working group’s reaction to the BAA-only approach was not broadly supported, PacifiCorp has the ability to produce its own necessary annual LSE-level reporting with a BAA-level report structure with internal data regarding retail and third-party load in its BAA.  

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

PacifiCorp supports CAISO’s proposal to reflect long-term contractual arrangements but ideally would want to move to have short-term contracts in the future as it would add to the market participant's position to effectively lower its need for importing at the market residual rate. As for non-participating entities’ resources, the approach discussed during the stakeholder call is appropriate where the CAISO will utilize the Masterfile, eGRID, EIA and lastly a calculation based on fuel type and heat rate done by the CAISO.

7. What additional content would you like to see in future GHG calls?

No comment.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

PGE thanks CAISO staff and working group participants for their dedication to this stakeholder initiative. PGE remains concerned that the mechanisms under consideration by this group may not offer a clear path to reflecting the value of PGE's non-emitting portfolio buildout, which will benefit the entire market footprint. PGE notes that the existing proposal is not fully interoperable with PGE regulatory requirements under HB2021, because interval specific GHG attributions go to priced GHG regions. PGE understands that Oregon GHG statutes are unique among working group participants and thanks the group for engaging in this topic.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

PGE appreciates the ISO's commitment to educating stakeholders on ISO practices. With regards to the GHG counterfactual design, PGE is in favor of an approach that ensures fair attribution, transparency, minimization of unintended consequences, and regional equity.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

PGE appreciates the opportunity to shape the discussions around the GHG Accounting and Reporting design. PGE's overarching goal is to reach a fair outcome for all participants, including those that do not have a pricing mechanism for emissions but have either declining emissions caps or voluntary GHG reduction goals that do not include a pricing component.

PGE is interested in utilizing remaining workshops to discuss and evaluate the voluntary intra-GHG pricing zone and climate region concepts.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

PGE would like to evaluate the cost implications between a full entity report or only the residual rate. Would publishing only the residual rate preclude future requests for a full report if needed? Last, PGE requests clarification on the CAISO’s information requirements for contracts between PGE and a contracted resource (whether participating or non-participating in a CAISO-operated market). These questions are a part of PGE’s ongoing evaluation of the reporting options.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

PGE believes that a BAA or Scheduling Coordinator-level report is suitable in the interim, and potentially as a long-term solution. PGE can sub-allocate for LSEs and SCs within the PGE BAA, although PGE’s preference would be suballocation by the CAISO prior to data publication. Regardless, PGE would like to discuss the cost implications of this decision more closely.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

Because this is a complicated design question, PGE first seeks clarity on whether the CAISO would need non-participating entity’s contractual arrangements if CAISO only publishes residual rate.

More broadly, PGE does not currently see a need to incorporate non-participating entity contractual arrangement in CAISO’s Accounting & Reporting approach since such contractual arrangements can be reported separately by PGE. However, PGE requests clarification from the CAISO staff should the ISO believe such contractual information necessary.

7. What additional content would you like to see in future GHG calls?

PGE thanks working group participants for their collaboration. PGE believes additional information on best practices across other regional markets might be of utility in identifying existing mechanisms for non-priced, emissions-constrained entities in other wholesale markets.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

The Public Generating Pool (PGP) appreciates the opportunity to comment on the progress made so far in the GHG Coordination Working Group. In these comments, PGP makes several suggestions with respect to the topics discussed at the January 21, 2025, Working Group meeting.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

The Public Generating Pool (PGP) appreciates the opportunity to comment on the progress made so far in the GHG Coordination Working Group. In these comments, PGP makes several suggestions with respect to the topics discussed at the January 21, 2025, Working Group meeting.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

PGP appreciates the summary of the December 20th Issue Paper provided in CAISO’s January 21st Accounting and Reporting Approach presentation.

PGP recommends that CAISO and the Working Group consider reframing some of the orientation and approach to Accounting and Reporting to better reflect the voluntary nature of participation. PGP’s observation is that the paper and discussion around this topic starts from the perspective of a solution that is applied across the footprint e.g., CAISO is able to conduct and provide reporting at the LSE level across the entire EDAM footprint. The CAISO and the Working Group seem to be considering the cost and logistics of the approach in this context. From PGP’s perspective, accomplishing an LSE-level reporting approach across the footprint would result in the most “accurate” residual mix but is an unlikely outcome because CAISO will not have the ability to require participation. PGP recommends a reframe whereby the cost and logistics are considered in the context of collecting data from willing participants and setting default assumption for entities who do not participate. In this way, the conversation becomes about how CAISO can receive and house data willingly provided versus how CAISO can gain access to data that it does not currently routinely collect. By nature, the default assumptions for entities who are not participating will be imperfect and lack granularity; however, PGP’s view is that this is inevitable given the voluntary nature of participation. PGP’s view is also that a less-than-perfect residual mix will still have value for market participants and will provide a starting point to improve accuracy and granularity over time.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

At this time, PGP recommends a sequential approach for development and implementation of the Accounting and Reporting Approach, beginning with prioritization of the publication of a residual rate followed by continued consideration of a “report total.” As noted in previous comments, PGP supports the goal of calculating a residual rate at the LSE level, since this is where individual entity emissions accounting is performed. Regardless of the level at which it is calculated, any calculations of a residual rate will have to be responsive to concerns about the inclusion of null power resources, as articulated in PGP’s October 10, 2024, and November 27, 2024, comments to the Working Group.   

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

PGP’s perspective is that the goal of the Accounting and Reporting framework is to provide entities data associated with resources mapped to them and to create a reasonable estimate of a residual mix. The calculation of any residual mix depends upon the measure of defined energy to defined load to determine a quantity of excess energy that will be contributed to residual energy. PGP believes that the LSE-calculation* of resources as compared to load is the most useful, but theoretically excess energy can be calculated at various granularities as long as the associated loads and resources are defined and only counted once. With respect to the Scheduling Coordinator mapping, it is unclear to PGP how the loads will be defined to compare to energy produced from defined resources to calculate an excess quantity and develop a residual mix. Preparing reports of average emissions rates or other production-based data points based on resources only are likely to be less useful for GHG reporting purposes. It may be useful to introduce new language to the discussion for load serving entities with participating resources to differentiate these participants from nested loads within the BAs who have no direct interaction with the market under the EDAM framework and to explore data sourcing and needs for this subset of LSEs, should they be interested in voluntary participation in the reporting framework.

*With respect to the Bonneville Power Administration, PGP assumes that not all LSEs within Bonneville’s BAA will need or require individual reports. For purposes of producing a more-accurate residual mix, PGP expects it will not be necessary to perform a calculation for each of BPA’s load-following customers. BPA customers who are BAAs or have their own resources may be more interested in an LSE-specific calculation.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

PGP believes the approach outlined on Slide 41 of the ISO’s January 21st Accounting and Reporting Approach is appropriate, whereby the ISO would utilize the Master File, eGRID emissions factors, EIA emissions factors, and lastly a calculation based on fuel type and heat rate performed by the CAISO. PGP recommends establishing a set of default assumptions for non-participating entities. The default presumptions should be based on publicly available data and should not require non-participating entities to submit confidential information. As noted above, PGP believes that the exercise of calculating a residual mix will not be perfect or, in some instances, very granular, due to the lack of granular data collection from all entities. However, some high level default assumptions can be put in place based on publicly available data for non-participating entities. For instance, CAISO and the Working Group could explore a default assumption of assigning large resources (25 MW or greater) to a non-participating LSE-owner if the owner is known to be an LSE. Any contractual arrangements not supplied to CAISO associated with a resource will not be incorporated.

The reason to create the default assumption for owned resources is to avoid large resources who are known to be serving native load from being incorporated into the residual mix. The lack of more granular contractual data will decrease the accuracy of the residual mix, but, as noted above, PGP does not believe that a perfectly accurate residual mix is achievable in this context.

7. What additional content would you like to see in future GHG calls?

PGP would like to see future CAISO GHG Coordination Working Group meetings include more dedicated time for facilitated stakeholder discussion of the various issues and questions for the development of the Accounting and Reporting Approach. In particular, PGP continues to be interested in dedicated discussion on the issue of reporting null power within a residual rate, regardless of the level at which it is calculated. For this discussion, PGP recommends that CAISO invite Washington state regulators—the Utilities & Transportation Commission, Department of Commerce, and Department of Ecology—to provide an overview of their interpretation of CETA’s double-counting provisions for the benefit of the Working Group participants, similar to the presentation on Oregon’s Perspective on Emissions Tracking and Accounting provided at the May 29, 2024, Working Group meeting.

It may also be useful to provide information to the Working Group with respect to how the Southwest Power Pool Markets+ addressed issues of null power. PGP is willing to provide this overview and/or work with SPP or other stakeholders to present perspectives on the topic.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

As an emissions tracking software and data provider for U.S. utilities and grid operators, Singularity Energy appreciates the opportunity to provide feedback on the proposed accounting and reporting approach based on our experience working with grid operator data and implementing similar tracking systems for other entities. Our feedback can be summarized as:

• Various methodological details of the proposed approach will require refinement, including the choice of resource-specific emission rates, the treatment of biogenic emissions, allocating JOUs and multi-offtaker PPAs, alternatives to the “average” approach for releasing to the residual mix, how “attributed” energy should be allocated to LSEs, and accounting for energy storage.
• We provide thoughts on how to address certain challenges including mapping resources to LSEs and obtaining LSE-specific load data.
• We recommend CAISO publish both the residual rate and report total.
• We support reporting data at the LSE level
• We recommend performing a default allocation to non-participating entities.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

No feedback

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

Resource-specific emission rates: To calculate generator-specific emissions, CAISO proposes using static emissions factors, either submitted by the resource owner, published in eGRID, published by EIA, or calculated by CAISO. While the use of static, annual-average, generator-specific emissions factors has been the status quo approach for estimating annual total emissions, our analysis has found that such approaches are not appropriate for accurate, temporally granular allocation of emissions, such as on a 5-minutely basis as proposed. This is due to the fact that generator heat rates (and thus emissions factors) change from interval to interval based on various factors, and that certain generators can fuel switch over time.

Furthermore, the emission factors published by eGRID are only published at the plant level, rather than generator level, meaning that their use may mis-allocate emissions across multiple generators located at the same plant, which may or may not be owned or contracted by the same entity. We compared hourly emissions calculated using eGRID plant-level emissions factors to measured hourly CO2 emissions data reported to EPA CAMPD using CEMS devices, and found that eGRID factors mis-estimated hourly emissions totals by 17% in CAISO, 12% in BANC, and 45% in PGE, for example. Use of generator-specific emissions factors available through public data sources such as the Open Grid Emissions dataset reduced these errors, and use of generator-specific heat rate curve models (which Singularity has calculated based on publicly-available data) proved to most accurately estimate emissions for these regions.

We would recommend using a heat rate curve model approach to most accurately allocate emissions on a 5-minutely basis, or at the very least, generator-specific static emissions factors.

Tracking and allocation of biogenic CO2 emissions: While California and Washington’s GHG pricing programs generally exclude biogenic CO2 emissions (from the combustion of biomass or biogas), consideration should be given to whether such exclusion is universally applicable for all states/LSEs. Even within California, certain biomass generators may or may not qualify for this exclusion.

While the exclusion of biogenic emissions from CAISO’s accounting and reporting approach may be justified in cases by certain state policies, the broader academic literature indicates that a blanket assumption of zero global warming potential for all biomass combustion is not appropriate given the variety of sources. Biomass combustion is one of the most carbon-intensive sources of power generation (from a direct stack emissions perspective), and research by Miller et al (2023) found that the use of biomass-adjusted emissions factors underestimates total direct CO2 emissions from power generation by 12% in CAISO, 40% in IID, 32% in Pacificorp West, and 9% in BPA.

While this may be a policy consideration outside the scope of the design of CAISO’s accounting approach, the choice of default emission factors do affect this accounting. For example, the plant-level emission factors published in eGRID treat all biomass generation as having zero CO2 emissions.

We recommend that CAISO collect more information about the reporting needs of stakeholders concerning the inclusion or exclusion of biogenic CO2 emissions, and ensure that the factors used for calculating resource emissions take into account generator-specific qualification for exclusion under any state GHG pricing policies. One option would be to separately track and report biogenic and non-biogenic CO2 emissions so that these values could be used separately or in combination to meet stakeholders’ needs flexibly.

Mapping of resources to LSEs: CAISO has noted its difficulty identifying how to map generators to LSEs based on ownership since such data is not currently collected by CAISO. However, we understand there to be multiple ways for a default mapping to be determined.

One option would be to first map each generation resource to its unique EIA plant and generator ID, and then utilize publicly available data about generator ownership in EIA Form 860 to perform a default mapping. If EIA identifiers are not already collected by CAISO, we have found through past experience that performing that mapping is straightforward if not somewhat time consuming. However, mapping each resource to its EIA IDs would be a necessary step anyway in order to identify the appropriate emissions factor from emissions databases such as eGRID, the EIA, or the Open Grid Emissions dataset.

Another option would be to utilize CAISO’s own Full Network Model mapping, which identifies the relationship between generation resources and Utility Distribution Companies (UDCs). While UDCs do not represent the full range of LSEs, it could serve as one potential starting point.

While the above approaches could be used for mapping resources based on owner, mapping based on (long-term) contracts is more challenging, as there is no public database that contains that information that we are aware of. However, each LSE’s IRP filing could provide an indication of which resources are contracted for a default mapping.

We also recommend that the system as implemented allows each LSE to check its default mapping, make changes, and have those changes confirmed by the relevant counterparty.

Mapping Jointly Owned Units and multi-offtaker PPAs: When mapping resources to LSEs, there should be an option to be able to reflect not only ownership/contract but the percentage ownership/offtake in the case of JOUS or resources with multiple offtakers. Such arrangements can vary, and be represented as a fixed share of energy, fixed MWh blocks, or other arrangements. CAISO should solicit inputs on the types of arrangements that may need to be accommodated, but a fixed % approach may be a good starting point.

LSE-specific load data: While LSE-specific load data may need to be directly collected from each LSE (or each UDC on behalf of the LSEs in their distribution territory), one potential avenue to explore is whether LSE-specific load data exists as part of CAISO’s state estimator model / full network model. If it is possible to map individual bus IDs or Cnode IDs from the network model to LSEs, then the 5-minutely load data could be pulled from the state estimator data. While this may not match metered, settled load exactly, it may provide a reasonable starting point for the allocation.

It is also possible that this data already exists somewhere in CAISO’s systems. For example, in the data that CAISO reports to the EIA Hourly Electric Grid Monitor (i.e. Survey Form 930), it reports hourly load data for PG&E, SCE, SDG&E, and Valley Electric Association. It is unclear where this data comes from and whether it represents UDC load or LSE load, but somehow CAISO already is reporting this data. See https://www.eia.gov/electricity/gridmonitor/dashboard/electric_overview/balancing_authority/CISO.

While CAISO does not have data at the LSE level, CAISO does have data for individual BAAs, and in many cases, these BAAs may overlap with LSEs (eg PGE, SMUD/BANC, LADWP, IID, etc), so it may be possible in some cases to use BAA load data for certain LSEs.

Alternatives to the “average” approach for allocating generation to the residual mix: In the case that an LSE’s supply exceeds its load in a given interval, CAISO proposes allocating the excess to the residual mix as an average share of the LSE’s total supply position. However, we are concerned about offering this as the only option available for allocating excess generation to the residual mix. This approach would in effect allow for part of an LSE’s renewable energy position used for RPS compliance, or “non-bypassable” nuclear power to be released to the residual mix to then fill other entities short positions, resulting in potential double-counting of this renewable or non-bypassable generation. As an alternative, there should be an option for an LSE’s clean energy portfolio to be allocated to its own load first, and not end up in the residual mix unless the LSE is long in clean energy or otherwise elects to do so.

To facilitate this, LSEs could elect to define a manual stack order for the resources in their portfolio that would be used to determine which resources are released to the residual mix. Such a stack order could be defined on a resource-by-resource basis, or on a fuel-type basis (eg allocate solar to my own load first).

A third alternative allocation approach that could be offered would be based on an economic stack order approach, where the resources with the cheapest offers are allocated to the LSE’s load first, and the most expensive are allocated to the residual mix.

The current formula appears to not allocate “attributed” energy: The current formula used to summarize the accounting approach subtracts attributed generators from an LSE’s supply position if that generation is attributed to a different market. However, the formula does not currently add this attributed energy to the supply mix of LSEs in areas to which it is attributed. For example, if a WA LSE owns generation that is attributed to CA, that generation is subtracted from their (and thus the state of Washington’s) supply, but currently the formula does not reflect that this attributed energy is then added to CA’s supply.

Similarly, while the formula shows contracted generation being added to an LSE’s portfolio, it does not show that contracted generation could also be subtracted (for example if an LSE owns a resource, but another LSE buys the generation from them).

I assume that attributed energy, if part of a bilateral contract, would be reflected in the “dispatched contracts for purchase” adjustment, attributed energy that is not reflected in a bilateral contract should be somehow allocated to LSEs in the area receiving the attributed energy.

There are several options for where attributed energy could show up:

• Attributed energy could be proportionally allocated to all LSEs in the receiving area after accounting for total owned/contracted. It would then be part of the determination of an LSE’s net position relative to its load, and could then potentially in part be released to the residual mix.
• Attributed energy could go directly into the residual mix. In this case, attributed energy would only be allocated to LSEs with a short position in that interval as part of the broader residual mix. (likewise, in figure 2, the attributed energy could first go into the voluntary intra-GHG LSE adjustment first, before getting released to the residual mix).

Accounting for energy storage: The proposed approach does not currently mention how standalone energy storage should be handled in allocation, even though they now serve as a major percentage of CAISO’s supply mix. Here I am referring specifically to standalone, transmission connected storage resources that support the system, not hybrid resources or behind-the-meter resources.

Rather than treating storage as a zero-carbon generator, or as load, standardization efforts around global emissions accounting standards seem to be moving toward treating storage as a transmission-style asset in that they move energy around the grid (although they move energy over time, rather than across space). What this means is that the emissions intensity of the electricity discharged by energy storage would be calculated based on the emissions intensity of the electricity used to charge the storage resource.

There are developing standards on how this would work in practice, but it would mean that CAISO’s accounting approach should include a way to allocate generation to storage charging, which is then re-allocated back out to LSE load when the battery discharges.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

We would recommend that CAISO should publish both residual rates and the report total, as this allows there to be a single, consistent source for these data and calculations. Only publishing the residual rate may result in individual LSEs using the data inconsistently. In addition to the value that this data provides to LSE, the type of data included in the total report would have value to end users and voluntary GHG reporters, and provides greater transparency.

Since in my understanding, calculation of the market residual rate requires information on LSE load to understand which resources should end up in the residual, producing the total report should not substantially impact the timeline or cost of making the data available.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

We support an LSE-level report since the purpose of this approach is to focus on attributing emissions to load, which would be reflected by LSEs.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

For the most accurate allocation of resources to LSEs and the market residual mix, we think that it would be best to utilize a default mapping of resources to all LSEs, and to perform an allocation for all LSEs, whether they participate or not. As noted on the call, it would be inappropriate for generation owned by a non-participating entity to end up in the residual mix to be claimed by other LSEs. However, there should be a way for all LSEs to override the default mapping. These default mappings could be based on ownership data represented in EIA Form 860. Contractual arrangement data could potentially be derived from LSE IRP filings.

7. What additional content would you like to see in future GHG calls?

The issues identified in response to question 3 could be discussed in future GHG calls.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

The Six Cities support further evaluation and consideration of the “No GHG” counterfactual approach, as it appears to have advantages over the CAISO’s current counterfactual methodology and the counter-factual methodology proposed by Vistra, and recommend that further evaluations of the No GHG methodology move forward on a timeline that could allow implementation at the inception of EDAM operation.  The Six Cities request further explanation and evaluation regarding (a) the treatment of resources committed to serving specific loads under the No GHG approach, and (b) the alternative approaches for allocating GHG revenues that may be collected in excess of average GHG cost.

Under any Accounting and Reporting methodology, prior to the adoption of any form of Intra-GHG area or region adjustments or reassignment mechanism as contemplated in Slide 39 of the presentation, the Six Cities request further explanation of the rationale for and evaluation of the potential consequences of any reassignment of surplus designated energy within a GHG zone rather than consideration as residual energy.

If data are tracked at the LSE level or through Scheduling Coordinator ID mapping, such data should be distributed to each LSE on resources used to serve its own load, and each LSE should have responsibility and authority for further publication or distribution of its own resource data based on policies or requirements established by its Local Regulatory Authority or other local, state, or federal regulatory authorities having applicable jurisdiction.

As part of the ongoing evaluation of alternative approaches for accounting and reporting, the Six Cities request that the CAISO provide (a) a high level estimate of the costs of implementing different approaches, and (b) a description of alternative methods for recovering the implementation costs for each approach.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

Based on the January 21, 2025 Working Group discussion and presentation, the Six Cities support further evaluation and consideration of the “No GHG” counterfactual approach.  As summarized on Slide 15 of the presentation, it appears that the No GHG counterfactual approach has advantages over the CAISO’s current counterfactual methodology and the counter-factual methodology proposed by Vistra.  The No GHG methodology contemplates optimized transfers among all BAAs prior to GHG attributions, which appears to address concerns previously expressed by the Six Cities and other stakeholders that the counterfactual methodology currently used by the CAISO provides preferential access to the most economic residual supply resources to non-GHG BAAs.  According to the CAISO’s summary, while optimizing economic transfers among all BAAs, the No GHG approach would reduce overall IFM costs, reduce costs to load in both GHG areas and non-GHG areas, and reduce GHG attributions and secondary dispatch as compared with the current and proposed Vistra counterfactual methodologies.

The Six Cities would appreciate further explanation regarding the treatment of resources committed to serving specific loads under the No GHG approach.  Further discussion also is necessary regarding the alternative approaches for allocating GHG revenues that may be collected in excess of average GHG cost.  Given the potential benefits of the No GHG approach as described above, the Six Cities recommend that further evaluations of the No GHG methodology, including market simulations, move forward on a timeline that could allow implementation of that methodology at the inception of EDAM operation.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

With regard to the potential for Intra-GHG area or region adjustments as contemplated in Slide 39 of the presentation, the Six Cities at this time take no substantive position concerning the appropriateness of any Intra GHG area adjustments.  Prior to the adoption of any form of Intra-GHG area or region adjustments or reassignment mechanism, the Six Cities request further explanation of the rationale for and evaluation of the potential consequences of any reassignment of surplus designated energy within a GHG zone rather than consideration as residual energy.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

As the Six Cities have expressed in previous comments, if data are tracked at the LSE level, such data should be distributed to each LSE on resources used to serve its own load.  Each LSE should have responsibility and authority for further publication or distribution of its own data based on policies or requirements established by its Local Regulatory Authority or other local, state, or federal regulatory authorities having applicable jurisdiction.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

The Six Cities take no position at this time with respect to assembly of data based on mapping of Scheduling Coordinator IDs versus LSE reporting.  However, any SC ID level data should be treated as described in response to Question 4 above, i.e., reported in the first instance only to the LSEs responsible for load served by the resource in question, with such LSEs having responsibility and authority for further publication or distribution of their own data based on policies or requirements established by the applicable Local Regulatory Authority or other local, state, or federal regulatory authorities having applicable jurisdiction.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

The Six Cities have no comments on this topic at this time.

7. What additional content would you like to see in future GHG calls?

As part of the ongoing evaluation of alternative approaches for accounting and reporting, the Six Cities request that the CAISO provide (a) a high level estimate of the costs of implementing different approaches, and (b) a description of alternative methods for recovering the implementation costs for each approach.

1. Please provide a summary of your organization's comments on the January 21, 2025 GHG Coordination Working Group.

The Washington Utilities and Transportation Commission (UTC) pre-emptively raises concerns for future discussions related to the post-market accounting and reporting of EDAM for Washington’s non-priced GHG program. The UTC’s primary concern relates to the use of Renewable Energy Credits (RECs) and other non-power attributes for compliance with Washington’s Clean Energy Transformation Act (CETA), and the potential for double-counting of those non-power attributes in market transactions.

2. Please provide your organization's feedback on the ISO’s “Counterfactual Examples” presentation.

The UTC does not have feedback on the ISO’s “Counterfactual Examples” presentation, and thanks the ISO for their presentation.

3. Please provide your organization’s feedback on the ISO’s “Accounting and Reporting Approach” presentation.

The UTC does not have feedback on the ISO’s “Accounting and Reporting Approach” presentation, and thanks the ISO for their presentation.

4. For the Accounting and Reporting approach, please provide your organization’s feedback on what data the CAISO should publish for entities (i.e., whether the CAISO should produce residual rates or the report total).

The UTC is concerned about the publication of an official market residual rate and how those calculated rates interact with the REC-based accounting that must occur under CETA. Please see the final entry in this form for the UTC’s comments on this issue.

5. For the Accounting and Reporting approach, please provide your organization’s feedback on what entity the report should be produced for and whether mapping Scheduling Coordinator IDs could equate to a LSE report for your organization.

The UTC is still reviewing whether reporting and mapping at the Scheduling Coordinator level would allow for data reporting that would match the reporting that regulated utilities must provide for purposes of CETA, and will provide further information to the ISO.

6. For the Accounting and Reporting approach, please provide your organization’s feedback on how the report can capture some or all of non-participating entity contractual arrangements.

The UTC notes that Markets+ allows energy designation for resources contracted into Washington to be identified under the Type 1A Energy designation, even if they are not participating entities. Having the ISO collect for reporting purposes contracts that participating entities have with nonparticipating entities could be helpful.

The UTC does not have additional feedback on this topic at this time.

7. What additional content would you like to see in future GHG calls?

The UTC provides the following comments for future consideration as the straw proposal develops and the ISO engages in future work regarding the Accounting and Reporting Framework for EDAM:

Under CETA, investor-owned utilities in Washington must procure renewable or non-emitting energy equivalent to 80% of their retail load over a 4-year compliance period during the years 2030 and 2045. To verify their procurement of renewable or non-emitting energy, the utilities must prove ownership of the RECs or other non-power attributes of the energy they have procured.

In the context of the day-ahead markets being developed in the West, there is not currently a system that allows for the facilitation of REC transfers in tandem with market operations or post-market reporting. Two issues arise in the context of compliance for utilities subject to CETA, the attribution and offering of renewable energy in the context of a day-ahead market.

For utilities offering renewable energy into a day-ahead market, under the accounting and reporting framework proposed by WPTF, an issue arises in the instance where a utility generates renewable or non-emitting energy in excess of load but wishes to retain the associated REC or non-power attributes. In this situation, in a bilateral agreement, the utility would “retain” the REC and sell unspecified (null) power to the other party. The UTC understands that the issue of unspecified power in a day-ahead market is significantly more challenging.

For a utility to claim those retained RECs or any other REC associated with energy offered into the market, there must be sufficient safeguards against the double-counting of non-power attributes. If a utility retains a REC associated with non-emitting energy that is offered into the market as null power, but the lack of emissions from that resource is factored into the official residual rate of the market, that will constitute double-counting under CETA as the non-power attributes of the emissions rate have been communicated and claimed by other parties. A utility would not be able to make a claim on that power for CETA compliance.

As the UTC understands it, the solution to this problem in the context of Markets+ was to simply publish all the underlying data without providing an official residual rate of the market, along with only providing a quarterly report of the null power fuel mix and disclaimers surrounding the use of the data. The UTC does not raise this solution as the only acceptable option, only as a reference.

Under CETA, claims for compliance with the statute require a REC or comparable nonpower attribute. The UTC would encourage the ISO to pursue any options for a post-market accounting and reporting framework that would facilitate the transfer of RECs and nonpower attributes, as well of the matching of RECs and nonpower attributes to energy.

The UTC recognizes that Washington is not the only non-priced GHG program that must be accommodated in EDAM. The UTC is raising these topics now in hopes that there will be sufficient runway to address them as the straw proposal is being developed. The UTC thanks CAISO for the attention paid to these critical issues, and looks forward to future engagement opportunities.